WEBSITE PRIVACY POLICY

INTRODUCTION
Purpose of this privacy policy
This Privacy Policy describes how Nail Harmony Essex collect and process personal data through your use of this website including any personal data you send to us directly through our website or otherwise including when you purchase a product, register an account with us or enter into any of our competitions.

By using our site http://www.gelishcollection.com you confirm that this policy has been read and understood.

Controller
Nail Harmony Essex Ltd is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy). We are committed to protecting the privacy and security of your personal data.
Contact Details

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Full name: Nail Harmony Essex Ltd, company registration number 08158845.
Postal address: 3 Colesdale, Cuffley, Herts, EN6 4LQ
Email: lhe@gsgroupuk.com

You can also contact us directly via our website contact page.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you.
Marketing and Communications Data includes your preferences in receiving marketing from us.

Profile Data includes usernames and passwords, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.

We do NOT collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
Third-party links
This website may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
    •  Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, through the contact page on our website or otherwise. This includes personal data you provide when you apply for our products or services, create an account on our website, subscribe to our service or publications, request marketing to be sent to you, enter a competition, promotion or survey or give us feedback.
    •    Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
    •    Where we need to perform the contract we are about to enter into or have entered into with you.
    •    Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    •    Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data.
Purposes for which we will use your personal data
Purpose/Activity
Type of data
Lawful basis for processing
To register you as a new client
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver our services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
We have set out below a description of the ways we plan to use your personal data, and which of the legal basis we rely on to do so and what our legitimate interests are where appropriate.
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Disclosures of your personal data
We will only disclose your personal data to third parties where required by law or to our employees, contractors or designated agents or third-party service providers who require such information to assist us with administering the relationship with you, including third-party service providers who provide services to us or on our behalf. Third-party service providers may include, but not be limited to data storage or hosting providers.

We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us. We do not permit our third-party service providers to process your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.

We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:
    •    To other members of our group of companies for the purposes set out in this Privacy Policy and as necessary to perform our contract with you.
    •    To comply with legal obligations or valid legal processes such as search warrants or court orders.
    •    To protect our rights and property.
    •    If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary and we will anonynmise the data where possible.
    •    For additional purposes with your consent where such consent is required by law.
    •    Cross-Border Data Transfers
We do not transfer your personal data outside the European Economic Area (EEA).
    •    Data security
We have put in place 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.
    •    Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
    •    Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a "data subject access request").

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.
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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data.

No fee usually required
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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.