Adonia Privacy Policy 20/08/2021

This Privacy Policy concerns privacy aspects of personal information captured, stored and/or processed by Adonia Boutique Hammam Spa in the course of our business and demonstrates compliance with the UK General Data Protection Regulation (UK GDPR).

Compliance with the UK GDPR shall be evidenced by reference to a data protection compliance folder in the Adonia filing system. This shall include this Privacy Policy to be read in association with the Data Policy. Under the UK GDPR your rights are as follows:


  • the right to be informed

  • the right of access

  • the right to rectification

  • the right to erasure

  • the right to restrict processing

  • the right to data portability

  • the right to object

  • the right not to be subject to automated decision-making including profiling.


Adonia shall ensure that any personal information is:


  • fairly and lawfully processed

  • processed for limited purposes

  • adequate, relevant and not excessive

  • accurate and up to date

  • not kept for longer than is necessary

  • processed in line with your rights

  • not transferred to other countries


Adonia has established the relevant lawful bases as follows:


  • We have reviewed the purposes of our processing activities, and selected the most appropriate lawful basis (or bases) for each activity.


  • We have checked that the processing is necessary for the relevant purpose, and are satisfied that there is no other reasonable way to achieve that purpose.


  • We have documented our decision on which lawful basis applies to help us demonstrate compliance.


  • We have included information about both the purposes of the processing and the lawful basis for the processing in this Privacy Policy.


The lawful bases for processing are set out in Article 6 of the UK GDPR and the relevant data types have been aligned with the relevant bases as follows:


(a) Consent: the individual has given clear consent for you (Adonia) to process their personal data for a specific purpose. Feedback and mailing list, where client has signed an opt-in form. This is to allow the business (Adonia) to provide to, or inform the customer of news and offers from Adonia.


(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract. Client information related to booking or sales transactions, plus employee/contractor and supplier data for engagement or potential engagement or purchasing.


(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations). Right to work in the UK evidence. Data to support HMRC aspects of payroll processing.


(d) Vital interests: the processing is necessary to protect someone’s life. Consultation data relating to health and suitability for treatments.


(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law. Not directly applicable to Adonia.


(f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks). CCTV data to help prevent crime, or as evidence for prosecutions such as for shoplifting, damage to property, and theft. Petty theft is a known factor in retail establishments.


If, as determined by Adonia, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.


CCTV

The premises are under CCTV surveillance with 24 hour recording for the purposes of crime prevention from the exterior shop front to the rear right of way. The use of CCTV has been registered with the Information Commissioner’s Office (ICO) and is under the control of Adonia’s Data Protection Officer. Adonia assures that CCTV is NOT present in the changing area, shower room, WC, and treatment rooms of the premises.


Further Information:


To more fully understand your rights and options relating to data privacy and the UK GDPR please visit the Information Commissioner’s Office website: https://ico.org.uk/