Privacy Notice for clients of the botonics Plastic Surgery Group

1. DEFINITION AND SCOPE

botonics representatives (referred to as “botonics”, “us” or “we” throughout this document) Clients/potential clients/business contacts dealing with botonics “you”

2. PURPOSE OF THIS NOTICE

This notice describes how botonics collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 1998 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’). For the purpose of the Data Protection Legislation and this notice, botonics are ‘data controllers’. This means that they are responsible for deciding how they hold and use personal data about you. They are required under the Data Protection Legislation to notify you of the information contained in this privacy notice. The details (including contact details) of the Data Protection Point of Contact for botonics who is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data can be obtained by contacting William Green ([email protected], 0845 680 1964). Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

3. HOW WE MAY COLLECT YOUR PERSONAL DATA

We obtain personal data about you, for example, when:

• you ask us to provide you with a quote in respect of the services we could provide;
•  you engage us to provide our services and also during the provision of those services;
•  you contact us by email, telephone, post (for example when you have a query about our services); or
•  from third parties and/or publicly available resources (for example, from HMRC or from Companies House).

4. THE KIND OF INFORMATION WE HOLD ABOUT YOU

The information we hold about you may include the following:

•  your personal details (such as your name and/or address);
•  details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
•  details of any services you have received from us;
•  our correspondence and communications with you;
•  information about any complaints and enquiries you make to us;
•  information we receive from other sources, such as third parties and/or publicly available resources (for example, from HMRC or from Companies House).

5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU

We may process your personal data for purposes necessary for the performance of our contract with you and to comply with our legal obligations. We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes. We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes. Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Situations in which we will use your personal data

We may use your personal data in order to:

•  carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services);
•  provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes; and
•  notify you about any changes to our services.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you. If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations. We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected. When assessing what retention period is appropriate for your personal data, we take into consideration:

•  the requirements of our business and the services provided;
•  any statutory or legal obligations;
•  the purposes for which we originally collected the personal data;
•  the lawful grounds on which we based our processing;
•  the types of personal data we have collected;
•  the amount and categories of your personal data; and
•  whether the purpose of the processing could reasonably be fulfilled by other means.

Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose. Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

6. DATA SHARING

Why might you share my personal data with third parties?

We will share your personal data with third parties where we are required by law, where it is necessary for the performance of our contract with you, to administer the relationship between us or where we have another legitimate interest in doing so.

Which third-party service providers process my personal data?

“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: database hosting services, professional advisory services, administration services and marketing services. All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

We will not transfer the personal data we collect about you outside of the EEA.

8. DATA SECURITY

We continue to have in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details at section 2.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please use the contact details set out at section 2 above. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

10. RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email the Data Protection Point of Contact for botonics (see section 2 above). Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

11. CHANGES TO THIS NOTICE

Any changes we may make to our privacy notice in the future will be updated on our website at: https://www.botonics.co.uk/private/ This privacy notice was last updated on 24 May 2018.

12. COOKIES AND TRACKING NOTICE

A cookie is a small text file that a website saves on your computer or mobile device in order to facilitate and enhance your interaction with that service. We or our service providers may use cookies and equivalent technologies such as clear gifs, web beacons, pixel tags, Javascript, device fingerprinting, and third-party cookies on our website and, where relevant, in our promotional e-mails. They also help us track users, conduct research, allow you to back click to earlier registration pages viewed by you and improve our content and services. For instance, we may use web beacons on our websites to access and set cookies and otherwise help us to better understand how users are moving through our websites. Information provided by the web beacon includes the computer’s IP address, the type of browser being used and the time that the web beacon was viewed. We may also use web beacons in e-mails and newsletters so that we know when such communications have been opened and to otherwise help us tailor our communications to individual users. Learn more about when and how we use cookies and tracking technologies and some of our service providers:

• When it’s strictly necessary

These cookies and other technologies enable us to recognize you when you return to our service and to maintain your web session so you can more easily navigate the subscription process or your viewing of your call details. They are also essential for you to access secure areas of our sites, for example, to use shopping baskets or make payments. Google Tag Manager is a third-party service provider that allows us to manage website tags via an interface. Tags are small elements of code that are used, for example, to measure traffic and visitor behavior, to understand the effect of online advertising and social channels, to set up remarketing and orientation towards target groups, and to test and optimize websites. Google Tag Manager only implements tags. This means that no cookies are used and, as a result, no personal data is recorded. We list it here for completeness and to be transparent about the tools we use. If deactivation has been performed at a domain, page, event or 3rd party script level, this remains in place for all tracking tags if these are implemented with Google Tag Manager.

• For performance and analytics

These cookies and similar technologies collect statistical information about how you use our websites so that we can improve your user experience. We use cookies to identify the number of unique visitors we receive to different parts of the website and identify where leads originate. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.   Google Analytics is one of the third-party analytics providers that we use to help us improve our website. Google Analytics uses cookies to help the website analyze how visitors use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by a Google server in the United States. Google uses this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing website operators with other services relating to website activity and internet usage. You can prevent the storage of data relating to your use of the website and created via the cookie (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available here.

• To enable functionality

These cookies and similar technologies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on our sites more easily. They also enable customization of the layout and/or content of the pages on our sites.

• For targeted advertising

These cookies and other technologies record your visits to our website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our website more relevant to your interests. We may also share this information with third parties for this purpose. These companies may use information about your online activities over time and across our services and other online properties, the region of the country or world where your IP address indicates you are located, as well as other information about you, in order to provide advertisements about goods and services of interest to you. The information practices of these ads networks are governed by their own privacy policies and are not covered by this Privacy Policy. For more information about third-party advertisers and how to prevent them from using your information, visit Aboutads.info and for our EEA users https://www.youronlinechoices.eu. You have to opt out using each of your web browsing applications, computers and mobile devices separately.

• Social media cookies and widgets We use social media platforms to advertise to you online and to monitor the success of our advertising (for instance by receiving reports when you click on our ads on Facebook, LinkedIn and others). We summarize the main advertising and social media partners who drop cookies below:
• LinkedIn Ads: the analysis and conversion tracking technology provided by the social network LinkedIn is integrated into our website. When you visit our website, a connection is established between your browser and the LinkedIn server via the remarketing tags. This informs LinkedIn that you visited our website with your IP address, meaning that LinkedIn can connect your visit to our website with your user account. We can use this information to display LinkedIn ads. Please be aware that we as the website provider do not receive any information about the content of the transferred data or how it is used by LinkedIn. Further information can be found in LinkedIn’s privacy policy.
• Marketo: We use third party marketing software from a company called Marketo to send some of our e-mails. We use cookies as part of tracking so we have information on e-mail open rates and click through rates. We also track activity on the website. For example, visitors can download marketing white papers from the site and we use Marketo cookies to see who does this and if they then visit other parts of our website. For more information on Marketo’s privacy and cookie policy, please visit Marketo’s privacy policy.
• DoubleClick: Google’s Doubleclick re-targeting cookie lets us serve personalized advertising to you when you’re browsing other websites and social media platforms. You can control advertising personalization on Google and partner websites here.
• Facebook Custom Audience: This service from Facebook enables us to display personalized ads to people on our e-mail lists when they visit Facebook. We provide personal information such as your e-mail address and phone number in encrypted form to Facebook (so they cannot be seen by anyone at Facebook) to enable Facebook to determine if you are a registered account holder with Facebook.
• Twitter advertising and remarketing: We advertise on Twitter and our advertising content will be tailored to your interests on the basis of your browsing behavior and the pages you have consulted on this and other websites. In order to improve the relevance of our marketing content, the cookie may therefore transmit such data to Twitter, who will use it to understand your interests better including to benefit their other advertising customers. If you decide that you do not wish your browsing data to be collected, you can find comprehensive information on Twitter’s advertising policy and the steps you can take to protect your privacy here.
• We also use Facebook Connect to allow you to sign up and log in to our websites by using your Facebook account. If you sign up using Facebook Connect, Facebook will ask your permission to share certain information from your Facebook account with us. This may include your first name, last name, and e-mail address in order for us to verify your identity and gender, general location, a link to your Facebook profile, your time zone, birthday, profile picture, your “likes” and your list of friends. This information is collected by Facebook and is provided to us under the terms of Facebook’s data privacy policy. You can control the information that we receive from Facebook using the privacy settings in your Facebook account.

How to control cookies

You can control and/or delete cookies as you wish – for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work. You will not be able to opt-out of any cookies or other technologies that are “strictly necessary” for the services. Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the site.

13. CONTACT US

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email us (see section 2 above). You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow SK9 5AF Telephone – 0303 123 1113 (local rate) or 01625 545 745 Website – https://ico.org.uk/concerns