Who are We?
This website is operated by Replace London Limited trading as ‘Re Place’ and in these website terms “we“, “us“, “our“ and “ours“ means Re Place. Our company number is 13514610; our registered office is at 30 City Road, London, United Kingdom, EC1Y 2AB and our main trading address is 196 Westbourne Grove, London W11 2RH. To contact us, please email email@example.com.
What is the Purpose of this Policy?
This policy describes how we collect and process personal information about you when you visit this website [or book services with us], in accordance with the Data Protection Act 2018 as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 which merge the previous requirements of that Act with the requirements of the General Data Protection Regulation ((EU) 2016/679) (“UK GDPR”) and any other data protection and privacy laws and regulations applicable to us or to our processing of your personal information (“Data Protection Legislation”).
For the avoidance of doubt, this website is not intended for children and we do not knowingly collect data relating to children.
Data Protection Officer and UK Representative
We have appointed a Data Protection Officer who is responsible for assisting with enquiries in relation to this privacy notice and our treatment of your personal information. If you wish to contact our Data Protection Officer please use the contact details below (“Questions Regarding this Policy/Data Protection Officer”).
How We Collect Your Personal Information
We obtain information about you when you use our website, for example: (i) when you fill in booking forms on our site, subscribe to any service, or contact us about Re Place services; (ii) if you contact us, we may keep a record of that correspondence; and (iii) we collect details of your visits to our website including traffic data, location data, weblogs and other communication data, and the resources that you access.
We may also obtain your personal information from the following sources (please note that this list is not exhaustive): Google when you have authorised Google to collect such data through the use of Google products; third party online public platforms, social media; and the public domain (“third party sources”). We may combine the information which we obtain about you when you use our website with information which we obtain about you from these third party sources.
Cookies and Log Data
We may obtain information about your general internet use by depositing certain bits of information called “cookies” in your web browser software or the hard drive of your computer. Cookies are sent back only to the website that deposited them when a visitor returns to that site.
Cookies help us to improve our website and to deliver a better and more personalized service. Some of the cookies we use are essential for our website to operate.
When you visit our website, our servers may record information (“log data”), including information that your browser automatically sends whenever you visit our website. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the website), browser type and settings, the date and time of your request.
The Kind of Information We Hold About You
We collect the following personal information about you:
Processing your booking: The personal details you provide when submitting a booking request. This includes personal details such as your name, address, e-mail address, phone number, gender, date of birth and country. We also collect information about your debit/credit card and bank account information provided by you to our payment service providers, that we require for the purpose of recording and processing bookings. For further details please also refer to the section below headed “Payment Information”.
Other Information: Personal details you choose to give when corresponding with us by phone or e-mail, participating in user/customer/member surveys or otherwise visiting and interacting with our website, and personal information that you provide to us when you visit our wellness concept space. We can also combine personal information that you provide to us with other information we collect about you when you make a booking through third-party services, as necessary to process your requests.
The Ways We Use Information
We may process your personal information for purposes necessary for the performance of a contract with you, for example for the processing or fulfilment of bookings for our services, and to comply with our legal obligations.
We may process your personal information 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 information. This includes processing for marketing, business creation, development, management, and statistical and research purposes, which will include analysis and tracking of transactions and the creation of marketing profiles. You have the right to object to this processing where we rely on a legitimate interest and either there is something about the particular situation which makes you wish to object to processing on that ground or the processing is for direct marketing purposes.
We may process your personal information for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal information then we will obtain your separate consent at that time and you will also have the right to withdraw your consent to processing for these specific purposes (see ‘Right to Withdraw Consent’ section below).
Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information.
Situations in which we will use your personal information
We may use your personal information, in order to:
- ensure that content from our website is presented in the most effective manner;
- send you the latest information about our company, events and special offers, where you have consented to be contacted for such purposes;
- seek your opinions on the services we provide;
- carry out our obligations arising from any agreements entered into between you and us (including to process, fulfil and notify you of your product order status);
- obtain additional information about you from third party sources (see ‘How We Collect Your Personal Information’ section); and
- notify you about changes to our services.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Any credit/debit card payments and other payments you make through our website will be processed by our third party payment provider and the payment data you submit will be securely stored and encrypted by our payment service provider using up to date industry standards. Please note that we do not ourselves directly process or store the debit/credit card data that you submit.
[We may arrange that card or payment data you submit in support of a booking is stored for the purpose of processing your booking.
[We store and use this card or payment information for the purpose of processing any future payments that you make as a customer for additional services. We will store this data in accordance with our legal obligations under applicable law and only for so long as legally permitted.
You may choose to opt out of us holding your card or payment data although this means that you will need to re-supply us with card/payment details to for the purpose of making any future purchases.]
We will share your personal information with third parties where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so. We are not in the business of selling your personal information to third parties.
Transferring information outside of the UK
Your personal information will be transferred to and stored in countries other than the UK, including the USA and other destinations outside the European Economic Area (“EEA”), for example, to our third party payment provider and affiliated businesses for the purposes described above. Please note that the countries concerned may not provide the same legal standards for protection of your personal information that you have in the United Kingdom or EEA.
Whenever we transfer your personal information out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information through Adequacy Regulations made under Section 17A of the Data Protection Act 2018.
- Where we use certain service providers, we may use specific contracts approved by the Information Commissioner’s Office (such as the International Data Transfer Agreement) which give personal information the same protection it has in the UK.
[Please contact our Data Protection Officer if you want further information on the specific mechanism used by us when transferring your personal information out of the UK.]
We have appropriate security measures in place to protect against the accidental loss, misuse, access and/or alteration of the information you provide although we cannot 100% guarantee the security of personal information that you provide to us online. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We will only retain your personal information for as long as is necessary to fulfil the purposes for which it is collected which retention period is determined by the nature and duration of your relationship with us. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymise the personal information so that it can no longer be associated with you, in which case it is no longer personal information.
Your Personal Information Rights
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if there are changes to your personal information of which we need to be made aware.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information. This enables you to receive details of the personal information we hold about you and to check that we are processing it lawfully.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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 ground. 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 information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
- In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information 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. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent. You can exercise this option at any time by contacting us using the contact details provided in this policy.
If you want to exercise any of the above rights, please contact us at [firstname.lastname@example.org]. [Alternatively, contact our Data Protection Officer, using the contact details below].
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if any request made by you 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.
Changes to this Policy
Questions Regarding this Policy/[Data Protection Officer]
Should you have any questions regarding this policy, you can contact [us at email@example.com]/[our Data Protection Officer at ]
You also have the right to make a complaint to the Information Commissioner’s Office (ICO: www.ico.org.uk), the UK supervisory authority for data protection issues, at any time. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.