The following privacy notice outlines how we collect, use, protect and transfer your personal data.
WHO ARE WE?
Cross Atlantic Properties Ltd trading as Mink Hand and Foot Spa.
HOW CAN YOU CONTACT US?
Address: Mink Hand and Foot Spa | The Oval | Shelbourne Road | Ballsbridge | Dublin 4. Email: firstname.lastname@example.org
WHAT DO WE DO?
At Mink we are ultimately committed to our clients, our team, our growth, our innovation and our excellence. We pride ourselves in indulging our clients with the ultimate luxury hand and foot experience.
Mink takes your privacy seriously, and keeping our clients personal information safe and secure remains our top priority.
HOW DO WE PROCESS DATA?
Mink processes personal data in relation to:
Employees: Staff employed at Mink have provided personal data to our HR department for the purpose of employment. We may hold educational, financial and contact data, in addition to references, employment history and health data, if necessary.
Clients: Clients of Mink have provided personal data to our Front of House Team for the purposes of booking appointments at our salons. It is necessary for us to have up-to-date contact details for each client in the event that any unforeseen circumstance affects your appointment, and we need to get in touch. We also use this information to maintain our standard of excellent customer service and care. Clients can opt-out of communications at any time. We also collect sensitive medical data if it is relevant to a particular treatment you have requested.
PERSONAL DATA COLLECTED
The personal data that we collect are;
- Email Address
- Date of Birth
- Phone Number
- Health Information
SPECIAL CATEGORIES OF PERSONAL DATA COLLECTED
Health questions are asked in many of our consent forms to potentially highlight treatments that may have a negative effect on your health due to medication you are taking or a condition you have. Mink asks for consent prior to gathering and processing this information. At any time after giving consent, you can withdraw your consent, subject to legal, insurance and contractual restrictions (see more on 'your rights as an individual'). Your privacy is very important to us and we only use this information for determining your suitability for the treatment.
Mink does not collect the personal data of children under the age of 16 without parental or guardian consent. If you believe that we hold any information from or about a child under age 16, please contact us, and if we cannot immediately obtain appropriate parental or guardian consent, will remove the personal data from storage.
PURPOSE AND LEGAL BASIS FOR COLLECTING YOUR DATA
Mink takes your privacy very seriously, and we will never sell or rent your personal data to any third-party. Sharing of your data and direct marketing activities are only carried out with your express consent, which you are free to withdraw at any time.
We need to obtain and process your personal data to provide you with our products, services and treatments and to fulfil our business and legal obligations. We will never collect any personal information from you that we do not need or retain any data that is no longer necessary for the purposes specified in this notice.
Where we request sensitive personal data from you (i.e. health or medical data), the reason(s) for the request will be clearly given along with the purposes of the processing. Explicit consent through a signature will always be required for us to obtain and process your health information.
CONSEQUENCES OF NOT PROVIDING YOUR PERSONAL INFORMATION TO MINK
In the event that you want to purchase a product or service from Mink, certain personal information is required to enter into a contract with you. We will not be able to enter into a contract with you to fulfil an attempt to purchase a product or service if you do not provide your personal information. As noted in this privacy statement, we are processing your personal data to comply with legal and statutory obligations and in the performance of a contract. You can always choose not to provide personal information; however, we will be unable to provide certain products, services and treatments in these instances.
WHO IS PROCESSING MY DATA?
Mink Hand and Foot Spa, The Oval, Ballsbridge, Dublin 4 are the Data Controller and processes your personal information for the purposes laid out in this privacy notice. Phorest, Anglesea Mills, 9 Anglesea Row, Smithfield, Dublin 7, D07 W5NE, Ireland, acts as Data Processor on behalf of Mink, and have access to personal information only in cases that customer support or trouble shooting is required by Mink. Further, they must process the personal information in accordance with this privacy notice and as permitted by applicable data protection laws.
WHY DO WE PROCESS YOUR DATA?
Your personal data is processed to;
- Collect specific personal data (name, address, email, contact number, DOB) that is required to enter into a contract to sell a product or service.
- Engage in communication with you including confirmation and reminders of appointments, and requests to cancel or change bookings.
- Collect health information to perform the agreed services appropriately, and potentially highlight areas that products and services mat cause issues to clients because of their health.
- Ensure a safe services and provide industry standard service.
- Select relevant offers, promotions and information for you.
- Estimate the number of clients we have.
- Hold personal data that is required by law or to respond to legal process.
- Hold for insurance purposes.
- Store customer records.
Suppliers: Third party vendors or contractors may have provided personal data to Mink for the purposes of a single or ongoing business transactions. This information will be retained in line with statutory financial obligations.
WHERE DID WE GET YOUR DATA FROM/ WHAT DO WE DO WITH YOUR INFORMATION?
We get data from you when:
You apply for a position or come and work for Mink; when you contact us about availing of our services; or when we complete a business transaction with you as a supplier of products or services.
Your personal data is collected when you provide it to us through Phorest software, our website, over the phone, in our salons, by email, social media, in writing or any other means by which you provide it to us. Information is stored using the Phorest software platform as well as some level of paper record keeping. Mink gives you access to information about your account and bookings through Phorest Software, for the limited purpose of viewing and updating that information ensuring the information we hold is correct and up to date.
Our website logs IP addresses, browser types and length of user sessions for administration purposes. We use your IP address to help diagnose problems with our server, to administer our website and to help improve the quality of service available on the site. Your IP address is used to gather broad demographic information. We do not link IP addresses to anything personally identifiable. This means that a user's session will be tracked, but the user will be anonymous.
If you fill out a form requesting more information from Mink we ask that you provide your name, an email address and comments etc. We require these details to better understand the needs of visitors to this website and in order to provide any requested information promptly.
In the case of the above, Mink maintains a database of information which may be held and used by us for purposes such as user profiling, administration, marketing research and to inform you about our services generally.
Our website may provide links to other sites. Privacy policies on these sites may differ from that on our site, and we advise that you review the other site's policies before providing personal information. While every care as been taken to ensure the high quality and standards of sites to which we link, Mink can take no responsibility for the content of these sites.
Our website has security measures in place to protect the loss, misuse and alteration of the information under its control. Information held by this site is stored on password protected machines, behind a firewall and not accessible to the general public via the Web.
SAFEGUARDING YOUR PERSONAL DATA
Appropriate measures are taken to protect your personal data from access from unauthorised persons or inappropriate access, internal or external. Your connection to the Phorest system uses a HTTP secure communication protocol and TLS security. This means all information passes to the Phorest system is encrypted during data input and transfer to the cloud. Any paper files recording your personal data are held locked in a filing cabinet or safe which can only be accessed by authorised personnel in the salon. Employees are only assigned specific access rights and can only access the salon software with the PIN number assigned to them by the management of the salon.
Marketing: With your permission, we may send you SMS or Emails about our salons, new products and other Mink news.
How do you get my consent?
If we ask for your personal information for a secondary reason like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you for the continued collection, use or disclosure of your information, by contacting us at email@example.com.
HOW LONG DO WE KEEP YOUR DATA FOR?
Employees: We will retain your personal details as a past, current or future employee in line with employment law.
Clients: Mink retains your personal data for as long as necessary to provide you with our services as our client. Mink are required under tax laws to keep your personal data for a minimum of 7 years. Health and Safety records will be retained for 10 years and where we have your consent for marketing purposes, we will retain the minimum required data until you notify us that you no longer wish to receive such information. The criteria for which we would continue to process your personal information includes;
- Where there is a legal basis, obligation or legitimate interest to continuing processing your personal information
- Where processing is necessary for the establishment, exercise or defence of legal claims
We currently monitor our active database, and archive the details of clients who have not availed of our services for 5 years continuously.
Suppliers: We retain the personal data of any suppliers for as long as deemed relevant and legally necessary.
WHERE DO WE KEEP YOUR DATA/ TRANSFERS OF PERSONAL INFORMATION
When your personal data is processed through Phorest software, all of it is held within the EU. Your information is processed by the Phorest software and stored in the Amazon Web Service cloud. During this process your data is encrypted in transit and at rest.
DO WE SHARE YOUR DATA?
We may be legally obliged to share your data with government agencies, for example for employment or financial compliance. We may also have interfaces with software providers that allow them to access your personal data. These situations are on the basis of a third party data processor agreement which contain clear contractual safeguards for personal data.
Your personal data is shared only with Phorest representatives in cases that customer support and troubleshooting is required for the salon. Mink do not share your personal information with any third party without your prior consent, other than those already disclosed in this privacy notice or as part of our legal obligations under the relevant data protection laws.
USE OF DATA PROCESSORS
Data processors are third parties who provide some elements of our business services for us. Where we use a third-party, we have strict agreements in place governing the processing of your personal data, on which no action can be taken without instruction from us. The third-parties with whom we work will never share or disclose your personal information and will hold it securely at all times.
WHAT ARE YOUR RIGHTS AND WHO SHOULD YOU CONTACT?
Individuals have rights over their personal data under EU Law. These rights are not absolute and some qualifications and restrictions do apply. In summary, your rights are;
- To be informed of how your personal data will be used before it is collected.
- To access your personal data, and information on how your information is used after it has been gathered.
- To have personal data corrected if it is incomplete, inaccurate or out-of-date.
- To request the removal or deletion of personal data where there is no compelling reason for its continued processing.
- To restrict processing, or to 'block' processing of your personal data.
- To data portability, having your data moved, copied or transferred from Mink to another organisation in an easily readable format.
- To object to direct marketing from us.
- To lodge a complaint to the Data Protection Commission (contact details set out below).
In the event that you believe your privacy rights have been infringed, you also have the right to seek compensation through the courts. Mink is committed to helping individuals exercise their rights.
In order to exercise any of the above rights, if you have a query, or if you would simply like more information in relation to our Data Protections, we recommend you contact either a Manager at the relevant salon, Ballsbridge or Donnybrook, the General Management Team at Mink, Mink Hand and Foot Spa, The Oval, Ballsbridge, Dublin 4, or email: firstname.lastname@example.org.
CONTACT DETAILS FOR THE OFFICE OF THE DATA PROTECTION COMMISSIONER
+353 57 8684800
+353 (0) 761 104 800
Lo Call 1890 252 231
Data Protection Commissioner
WHAT OUR COOKIES?
For the full Mink website experience, and to make full use of personalised features, your computer or mobile phone will need to accept cookies.
We use information from cookies to make your browsing experience better. In general, cookies are used to retain user preferences and provide anonymised tracking data to third party applications like Google Analytics. Mink uses Google Analytics to collect anonymous information about how visitors use our website. We use the information to compile reports and to help us improve our website. The information collected includes the number of visitors to the website, the pages they visited and where they have come to the website from. Our cookies don't store sensitive information such as your name, address or payment details.
If you'd prefer to restrict or delete cookies from our website, you can use your browser to do this. All browsers have the ability to block cookies. Simply visit the 'Help' menu of your particular browser to learn how to change your cookie preference.