- Agreement to Terms
1.1 These Terms and Conditions constitute a legally binding agreement made between you, whether personally or on behalf of an entity (you), and www.pamperingangels.co.uk, doing business as Pampering Angels , located at unit 3 paddock industrial Estate, Paddock Road, Caversham, Reading, RG4 5BY United Kingdom (we, us), concerning your access to and use of the Pampering Angels World (www.pamperingangelsworld.com) website as well as any related applications (the Site).
The Site provides the following services: Online Beauty and holistic courses as well as beauty products. (Services). You agree that by accessing the Site and/or Services, you have read, understood, and agree to be bound by all of these Terms and Conditions.
If you do not agree with all of these Terms and Conditions, then you are prohibited from using the Site and Services and you must discontinue use immediately. We recommend that you print a copy of these Terms and Conditions for future reference.
1.2 The supplemental policies set out in Section 1.7 below, as well as any supplemental terms and condition or documents that may be posted on the Site from time to time, are expressly incorporated by reference.
1.3 We may make changes to these Terms and Conditions at any time. The updated version of these Terms and Conditions will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. You are responsible for reviewing these Terms and Conditions to stay informed of updates. Your continued use of the Site represents that you have accepted such changes.
1.4 We may update or change the Site from time to time to reflect changes to our products, our users’ needs and/or our business priorities.
1.5 Our site is directed to people residing in United Kingdom. The information provided on the Site is not intended for distribution to or use by any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject us to any registration requirement within such jurisdiction or country.
1.6 The Site is intended for users who are at least 18 years old. If you are under the age of 18, you are not permitted to register for the Site or use the Services without parental permission.
1.7 Additional policies which also apply to your use of the Site include:
- If you purchase digital goods, physical goods, and/or services from the Site, our terms and conditions of supply https://www.pamperingangelsworld.com/terms-and-conditions/ will apply to the sales and use.
- Certain parts of this Site can be used only on payment of a fee.
- Acceptable Use
2.1 You may not access or use the Site for any purpose other than that for which we make the site and our services available. The Site may not be used in connection with any commercial endeavors except those that are specifically endorsed or approved by us.
2.2 As a user of this Site, you agree not to:
- Harass, annoy, intimidate, or threaten any of our employees, agents, or other users
- Delete the copyright or other proprietary rights notice from any of the content
- Upload or transmit (or attempt to upload or to transmit) viruses, Trojan horses, or other material that interferes with any party’s uninterrupted use and enjoyment of the Site, or any material that acts as a passive or active information collection or transmission mechanism
- Threaten users with negative feedback or offering services solely to give positive feedback to users
- Make any unauthorized use of the Site, including collecting usernames and/or email addresses of users to send unsolicited email or creating user accounts under false pretenses
- Falsely imply a relationship with us or another company with whom you do not have a relationship
- Information you provide to us
3.1 You represent and warrant that: (a) all registration information you submit will be true, accurate, current, and complete and relate to you and not a third party; (b) you will maintain the accuracy of such information and promptly update such information as necessary; (c) you will keep your password confidential and will be responsible for all use of your password and account; (d) you have the legal capacity and you agree to comply with these Terms and Conditions; and (e) you are not a minor in the jurisdiction in which you reside, or if a minor, you have received parental permission to use the Site.
If you know or suspect that anyone other than you knows your user information (such as an identification code or user name) and/or password you must promptly notify us at email@example.com.
3.2 If you provide any information that is untrue, inaccurate, not current or incomplete, we may suspend or terminate your account. We may remove or change a user name you select if we determine that such user name is inappropriate.
- Our content
4.1 Unless otherwise indicated, the Site and Services including source code, databases, functionality, software, website designs, audio, video, text, photographs, and graphics on the Site (Our Content) are owned or licensed to us, and are protected by copyright and trade mark laws.
4.2 Except as expressly provided in these Terms and Conditions, no part of the Site, Services or Our Content may be copied, reproduced, aggregated, republished, uploaded, posted, publicly displayed, encoded, translated, transmitted, distributed, sold, licensed, or otherwise exploited for any commercial purpose whatsoever, without our express prior written permission.
4.3 Provided that you are eligible to use the Site, you are granted a limited licence to access and use the Site and Our Content and to download or print a copy of any portion of the Content to which you have properly gained access solely for your personal, non-commercial use.
4.4 You shall not (a) try to gain unauthorised access to the Site or any networks, servers or computer systems connected to the Site; and/or (b) make for any purpose including error correction, any modifications, adaptions, additions or enhancements to the Site or Our Content, including the modification of the paper or digital copies you may have downloaded.
4.5 We shall (a) prepare the Site and Our Content with reasonable skill and care; and (b) use industry standard virus detection software to try to block the uploading of content to the Site that contains viruses.
4.6 The content on the Site is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from taking, any action on the basis of the content on the Site.
4.7 Although we make reasonable efforts to update the information on our site, we make no representations, warranties or guarantees, whether express or implied, that Our Content on the Site is accurate, complete or up to date.
- Site Management
5.1 We reserve the right at our sole discretion, to (1) monitor the Site for breaches of these Terms and Conditions; (2) take appropriate legal action against anyone in breach of applicable laws or these Terms and Conditions; (3) remove from the Site or otherwise disable all files and content that are excessive in size or are in any way a burden to our systems; and (4) otherwise manage the Site in a manner designed to protect our rights and property and to facilitate the proper functioning of the Site and Services.
5.2 We do not guarantee that the Site will be secure or free from bugs or viruses.
5.3 You are responsible for configuring your information technology, computer programs and platform to access the Site and you should use your own virus protection software.
- Modifications to and availability of the Site
6.1 We reserve the right to change, modify, or remove the contents of the Site at any time or for any reason at our sole discretion without notice. We also reserve the right to modify or discontinue all or part of the Services without notice at any time.
6.2 We cannot guarantee the Site and Services will be available at all times. We may experience hardware, software, or other problems or need to perform maintenance related to the Site, resulting in interruptions, delays, or errors. You agree that we have no liability whatsoever for any loss, damage, or inconvenience caused by your inability to access or use the Site or Services during any downtime or discontinuance of the Site or Services.We are not obliged to maintain and support the Site or Services or to supply any corrections, updates, or releases.
6.3 There may be information on the Site that contains typographical errors, inaccuracies, or omissions that may relate to the Services, including descriptions, pricing, availability, and various other information. We reserve the right to correct any errors, inaccuracies, or omissions and to change or update the information at any time, without prior notice.
- Disclaimer/Limitation of Liability
7.1 The Site and Services are provided on an as-is and as-available basis. You agree that your use of the Site and/or Services will be at your sole risk except as expressly set out in these Terms and Conditions. All warranties, terms, conditions and undertakings, express or implied (including by statute, custom or usage, a course of dealing, or common law) in connection with the Site and Services and your use thereof including, without limitation, the implied warranties of satisfactory quality, fitness for a particular purpose and non-infringement are excluded to the fullest extent permitted by applicable law.
We make no warranties or representations about the accuracy or completeness of the Site’s content and are not liable for any (1) errors or omissions in content: (2) any unauthorized access to or use of our servers and/or any and all personal information and/or financial information stored on our server; (3) any interruption or cessation of transmission to or from the site or services; and/or (4) any bugs, viruses, trojan horses, or the like which may be transmitted to or through the site by any third party. We will not be responsible for any delay or failure to comply with our obligations under these Terms and Conditions if such delay or failure is caused by an event beyond our reasonable control.
7.2 Our responsibility for loss or damage suffered by you:
Whether you are a consumer or a business user:
- We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.
- If we fail to comply with these Terms and Conditions, we will be responsible for loss or damage you suffer that is a foreseeable result of our breach of these Terms and Conditions, but we would not be responsible for any loss or damage that were not foreseeable at the time you started using the Site/Services.
Notwithstanding anything to the contrary contained in the Disclaimer/Limitation of Liability section, our liability to you for any cause whatsoever and regardless of the form of the action, will at all times be limited to a total aggregate amount equal to the greater of (a) the sum of £5000 or (b) the amount paid, if any, by you to us for the Services/Site during the six (6) month period prior to any cause of action arising. Different limitations and exclusions of liability will apply to liability arising as a result of the supply of any products to you, which will be set out in our Terms and conditions of supply https://www.pamperingangelsworld.com/terms-and-conditions/.
If you are a business user:
We will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:
- use of, or inability to use, our Site/Services; or
- use of or reliance on any content displayed on our Site.
In particular, we will not be liable for:
- loss of profits, sales, business, or revenue;
- business interruption;
- loss of anticipated savings;
- loss of business opportunity, goodwill or reputation; or
- any indirect or consequential loss or damage.
If you are a consumer user:
- Please note that we only provide our Site for domestic and private use. You agree not to use our Site for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.
- If defective digital content that we have supplied, damages a device or digital content belonging to you and this is caused by our failure to use reasonable care and skill, we will either repair the damage or pay you compensation.
- You have legal rights in relation to goods that are faulty or not as described. Advice about your legal rights is available from your local Citizens’ Advice Bureau or Trading Standards office. Nothing in these Terms and Conditions will affect these legal rights.
- Term and Termination
8.1 These Terms and Conditions shall remain in full force and effect while you use the Site or Services or are otherwise a user of the Site, as applicable. You may terminate your use or participation at any time, for any reason, by following the instructions for terminating user accounts in your account settings, if available, or by contacting us at firstname.lastname@example.org.
8.2 Without limiting any other provision of these Terms and Conditions, we reserve the right to, in our sole discretion and without notice or liability, deny access to and use of the Site and the Services (including blocking certain IP addresses), to any person for any reason including without limitation for breach of any representation, warranty or covenant contained in these Terms and Conditions or of any applicable law or regulation.
If we determine, in our sole discretion, that your use of the Site/Services is in breach of these Terms and Conditions or of any applicable law or regulation, we may terminate your use or participation in the Site and the Services or delete your profile and any content or information that you posted at any time, without warning, in our sole discretion.
8.3 If we terminate or suspend your account for any reason set out in this Section 9, you are prohibited from registering and creating a new account under your name, a fake or borrowed name, or the name of any third party, even if you may be acting on behalf of the third party. In addition to terminating or suspending your account, we reserve the right to take appropriate legal action, including without limitation pursuing civil, criminal, and injunctive redress.
- Mobile Application
9.1 If you access the Services via a mobile application, then we grant you a revocable, non-exclusive, non-transferable, limited right to install and use the mobile application on wireless electronic devices owned or controlled by you, and to access and use the mobile application on such devices strictly in accordance with the terms and conditions of this license.
9.2 For business users only – You will not:
(a) reverse engineer, decompile or otherwise try to discover the source code of the software/application unless you have first written to us requesting interoperability information and we have failed to provide you with that information or if we have failed to offer to provide you with interoperability information on reasonable conditions”;
(b) make any modification, adaptation, improvement, enhancement, translation or derivative work from the application;
(c) breach any applicable laws, rules or regulations in connection with your access or use of the application;
(d) remove, alter or obscure any proprietary notice (including any notice of copyright or trade mark) posted by us or the licensors of the application;
(e) use the application for any revenue generating endeavor, commercial enterprise, or other purpose for which it is not designed or intended;
(f) make the application available over a network or other environment permitting access or use by multiple devices or users at the same time;
(g) use the application for creating a product, service or software that is, directly or indirectly, competitive with or in any way a substitute for the application;
(h) use the application to send automated queries to any website or to send any unsolicited commercial e-mail; or
(i) use any proprietary information or any of our interfaces or our other intellectual property in the design, development, manufacture, licensing or distribution of any applications, accessories or devices for use with the application.
9.3 The following terms apply when you use a mobile application obtained from either the Apple Store or Google Play (each an App Distributor) to access the Services:
(a) The licence granted to you for our mobile application is limited to a non-transferable licence to use the application on a device that utilizes the Apple iOS or Android operating system, as applicable, and in accordance with the usage rules set forth in the applicable App Distributor terms of service;
(b) We are responsible for providing any maintenance and support services with respect to the mobile application as specified in these Terms and Conditions or as otherwise required under applicable law. You acknowledge that each App Distributor has no obligation whatsoever to furnish any maintenance and support services with respect to the mobile application;
(c) In the event of any failure of the mobile application to conform to any applicable warranty, you may notify an App Distributor, and the App Distributor, in accordance with its terms and policies, may refund the purchase price, if any, paid for the mobile application, and to the maximum extent permitted by applicable law, an App Distributor will have no other warranty obligation whatsoever with respect to the mobile application;
(d) You represent and warrant that (i) you are not located in a country that is subject to a U.K. government embargo, or that has been designated by the U.K. government as a “terrorist supporting” country; and (ii) you are not listed on any U.K. government list of prohibited or restricted parties;
(e) You must comply with applicable third party terms of agreement when using the mobile application, e.g., if you have a VoIP application, then you must not be in breach of their wireless data service agreement when using the mobile application; and
(f) You acknowledge and agree that the App Distributors are third party beneficiaries of these Terms and Conditions, and that each App Distributor will have the right (and will be deemed to have accepted the right) to enforce these Terms and Conditions against you as a third party beneficiary thereof.
10.1 Visiting the Site, sending us emails, and completing online forms constitute electronic communications. You consent to receive electronic communications and you agree that all agreements, notices, disclosures, and other communications we provide to you electronically, via email and on the Site, satisfy any legal requirement that such communication be in writing.
You hereby agree to the use of electronic signatures, contracts, orders and other records and to electronic delivery of notices, policies and records of transactions initiated or completed by us or via the Site. You hereby waive any rights or requirements under any statutes, regulations, rules, ordinances or other laws in any jurisdiction which require an original signature or delivery or retention of non-electronic records, or to payments or the granting of credits by other than electronic means.
10.2 These Terms and Conditions and any policies or operating rules posted by us on the Site or in respect to the Services constitute the entire agreement and understanding between you and us.
10.3 Our failure to exercise or enforce any right or provision of these Terms and Conditions shall not operate as a waiver of such right or provision.
10.4 We may assign any or all of our rights and obligations to others at any time.
10.5 We shall not be responsible or liable for any loss, damage, delay or failure to act caused by any cause beyond our reasonable control.
10.6 If any provision or part of a provision of these Terms and Conditions is unlawful, void or unenforceable, that provision or part of the provision is deemed severable from these Terms and Conditions and does not affect the validity and enforceability of any remaining provisions.
10.7 There is no joint venture, partnership, employment or agency relationship created between you and us as a result of these Terms and Conditions or use of the Site or Services.
10.8 For consumers only – Please note that these Terms and Conditions, their subject matter and their formation, are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction expect that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland. If you have any complaint or wish to raise a dispute under these Terms and Conditions or otherwise in relation to the Site please follow this link http://ec.europa.eu/odr
10.9 For business users only – If you are a business user, these Terms and Conditions, their subject matter and their formation (and any non-contractual disputes or claims) are governed by English Law. We both agree to the exclusive jurisdiction of the courts of England and Wales.
10.10 Except as stated under the Mobile Application section, a person who is not a party to these Terms and Conditions shall have no right under the Contracts (Rights of Third Parties) Act 1999 to enforce any term of these Terms and Conditions.
10.11 In order to resolve a complaint regarding the Services or to receive further information regarding use of the Services, please contact us by email at email@example.com.
Data Protection Act 2018 Policy
This Policy sets out the obligations Pampering Angels,(“the Company”) regarding data protection and the rights of customers and business contacts (“data subjects”) in respect of their personal data under Data Protection Act 2018 (Formally EU Regulation 2016/679 General Data Protection Regulation (“GDPR”)). The Data Protection Act 2018 defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
The Data Protection Principles
This Policy aims to ensure compliance with the Data Protection Act 2018. The Data Protection Act 2018 sets out the following principles with which any party handling personal data must comply. All personal data must be:
Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.
Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the Data Protection Act 2018 in order to safeguard the rights and freedoms of the data subject.
Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.
The Rights of Data Subjects
The Data Protection Act 2018 sets out the following rights applicable to data subjects
The right to be informed’
The right of access,
The right to rectification,
The right to erasure (also known as the ‘right to be forgotten’),
The right to restrict processing,
The right to data portability,
The right to object; and
Rights with respect to automated decision-making and profiling.
Lawful, Fair, and Transparent Data Processing
The Data Protection Act 2018 seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The Data Protection Act 2018 states that processing of personal data shall be lawful if at least one of the following applies:
The data subject has given consent to the processing of their personal data for one or more specific purposes;
The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;
The processing is necessary for compliance with a legal obligation to which the data controller is subject;
The processing is necessary to protect the vital interests of the data subject or of another natural person;
The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or
The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s health), at least one of the following conditions must be met:
The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);
The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
The processing relates to personal data which is clearly made public by the data subject;
The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;
Specified, Explicit, and Legitimate Purposes
The Company collects and processes the personal data set out in this Policy.
Personal data collected directly from data subjects OR
Personal data obtained from third parties.
The Company only collects, processes, and holds personal data for the specific purposes set out in this Policy (or for other purposes expressly permitted by the Data Protection Act 2018).
Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data.
Adequate, Relevant, and Limited Data Processing
The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be
Accuracy of Data and Keeping Data Up-to-Date
The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject.
The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.
The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.
When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.
The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided later in this Policy.
Accountability and Record-Keeping
The Company’s Data Protection Officer is Jemma Lamb
The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the Data Protection Act 2018 and other applicable data protection legislation.
The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;
The purposes for which the Company collects, holds, and processes personal data;
Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;
Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
Details of how long personal data will be retained by the Company; and
Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.
Data Protection Impact Assessments
The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data.
Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:
The type(s) of personal data that will be collected, held, and processed;
The purpose(s) for which personal data is to be used;
The Company’s objectives;
How personal data is to be used;
The parties (internal and/or external) who are to be consulted;
The necessity and proportionality of the data processing with respect to the
purpose(s) for which it is being processed;
Risks posed to data subjects;
Risks posed both within and to the Company; and
Proposed measures to minimize and handle identified risks.
Keeping Data Subjects Informed
The Company shall provide the information set out in section (i) below to every data subject:
Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:
a) if the personal data is used to communicate with the data subject, when the first communication is made; or
b) if the personal data is to be transferred to another party, before that transfer is
c) as soon as reasonably possible and in any event not more than one month after
the personal data is obtained.
The following information shall be provided:
Details of the Company including, but not limited to, the identity of its Data Protection Officer;
The purpose(s) for which the personal data is being collected and will be processed (as detailed in this Policy) and the legal basis justifying that collection and processing;
Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
Where the personal data is to be transferred to one or more third parties, details of those parties;
Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place,
Details of data retention;
Details of the data subject’s rights under the Data Protection Act 2018;
Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the Data Protection Act 2018);
Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and
Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.
Data Subject Access
Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.
Data subjects wishing to make a SAR may do so in writing, using the Company’s Subject Access Request Form, or other written communication. SARs should be addressed to the Company’s Data Protection Officer at Pampering Angels, Email:firstname.lastname@example.org
Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.
All SARs received shall be handled by the Company’s Data Protection Officer.
The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
Rectification of Personal Data
Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.
The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.
Erasure of Personal Data
Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:
a) It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
b) The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
c) The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so),
d) The personal data has been processed unlawfully;
e) The personal data needs to be erased in order for the Company to comply with
a particular legal obligation.
Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).
Restriction of Personal Data Processing
Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.
In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).
Objections to Personal Data Processing
Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling) and processing for scientific and/or historical research and statistics purposes.
Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.
Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.
Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Data Protection Act 2018, “demonstrate grounds relating to his or her particular situation”. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.
Personal Data Collected, Held, and Processed
The following personal data is collected, held, and processed by the Company:
Data Security – Transferring Personal Data and Communications
The Company shall ensure that the following measures are taken with respect to all
communications and other transfers involving personal data:
All emails containing personal data must be encrypted using Encryption software;
All emails containing personal data must be marked “confidential”;
Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted using deletion software;
Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using Royal Mail Registered or 1st or 2nd Class Signed For post; and
All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.
Data Security – Storage
The Company shall ensure that the following measures are taken with respect to the storage of personal data:
All electronic copies of personal data should be stored securely using passwords and data encryption;
All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;
All personal data stored electronically should be backed up at least daily with backups stored onsite. All backups should be encrypted using data encryption’
No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of the Data Protection Officer and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and
No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Data Protection Act 2018 (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).
Data Security – Disposal
When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of.
Data Security – Use of Personal Data
The Company shall ensure that the following measures are taken with respect to the use of
No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from The Data Protection Officer,
No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of The Data Protection Officer,
Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;
If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and
Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of Jemma Lamb to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.
Data Security – IT Security
The Company shall ensure that the following measures are taken with respect to IT and information security:
All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols;
Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates after the updates are made available by the publisher or manufacturer, unless there are valid technical reasons not to do so; and
No software may be installed on any Company-owned computer or device without the prior approval of the Company.
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Data Protection Act 2018 and under this Policy, and shall be provided with a copy of this Policy;
Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;
The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Data Protection Act 2018 and this Policy by contract;
All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Data Protection Act 2018; and
Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
Transferring Personal Data to a Country Outside the EEA
The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.
The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:
The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the Data Protection Act 2018); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
The transfer is made with the informed consent of the relevant data subject(s);
The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
The transfer is necessary for important public interest reasons;
The transfer is necessary for the conduct of legal claims;
The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.
Data Breach Notification
All personal data breaches must be reported immediately to the Company’s Data Protection Officer.
If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
Data breach notifications shall include the following information:
The categories and approximate number of data subjects concerned;
The categories and approximate number of personal data records concerned;
The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
The likely consequences of the breach;
Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.
This policy has been approved & authorised by:
Name: Jemma Lamb
Position: Company director
Date: 3rd July 2019
We provide online training courses. The following right to cancel terms are set out in accordance with the The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013.
1 The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 permits consumer customers to cancel a contract after it has been entered into subject to certain limitations and requirements. You have the right to cancel the contract at the end of 14 days, after the day the contract is entered into. Once you have logged into the course a refund will not be available.
2 If you have the right to cancel then:
2.1 You will need to complete our cancellation of service form stating that you wish to cancel the contract between us and you; and
2.2 You will need to send us the notice of cancellation within the 14 period starting with the day after you receive our confirmation that there is a binding contract between you and us;
2.3 After we receive your notice of cancellation we will refund any monies due to you within 14 days.