Privacy Policy
“We value any personal data that you entrust to us and we are committed to protecting your privacy. We ensure that any information you provide to us will be collected and used in accordance with the General Data Protection Regulation and the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003. We will not share your data with any third party except for administrative purposes relating to the services we provide and where we may be required to do so by law.” Highland Laser Clinic
INTRODUCTION
Welcome to Highland Laser Clinic’s privacy notice.
Highland Laser Clinic respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after personal data you provide to us regardless of how it is collected and tells you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Highland Laser Clinic collects and processes your personal data collected through your use of this website, electronic communications and face to face intereactions including filling out forms, clinical photography and video taken with your explicit consent
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
Highland Laser Clinic is the controller and responsible for your personal data (collectively referred to as Highland Laser Clinic, “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact Details
Our full details are:
Full name of legal entity: Highland Laser Clinic Ltd.
Phone Number: 01463 242429
Email address: clinic@lasers.scot
Postal address: Highland Laser Clinic, Torbreck, Inverness, IV2 6DJ
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). Our ICO Reference number is: ZB152973
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to this privacy notice
This policy was developed in May 2018.
This policy was updated in August 2018 and simplified to remove references to data collection methods which we do not employ. The policy was expanded to include all personal data collected by Highland Laser Clinic regardless of collection method.
This policy was updated January 2019 to reflect change in trading name from “Highland Tattoo Removal” to “Highland Laser Clinic". Other minor changes were also made at this time.
This policy was updated in October 2020 to reflect change in trading entity to a limited company.
This policy was updated in August 2021 to include our ICO reference number.
This policy was updated June 2024 to specify our 5 year data deletion cycle.
This policy was updated February 2025 to clarify our removal of all cookies
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.
Third-party links
This website may include links to third-party websites, plug-ins and applications. 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.
2. 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 (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data: may include first name, last name, username or similar identifier, and date of birth.
• Contact Data: may include home address, email address and telephone numbers.
• Financial Data: bank account and payment card details are never recorded by Highland Laser Clinic for data protection reasons and to simplify PCI DSS compliance.
• Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data: may include internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Treatment Data includes information about the treatment you wish to receive from us. This information could include 'health data' which is a special category of personal data and therefore requires us to take extra steps to ensure it is adequately protected.
• Clinical Photography includes pictures of your treatment areas before during and after your course of treatment. This photography may be given to us by yourself or may be recorded by our operators.
• Videography only occurs with your explicit written consent and includes video footage of treatments, visits to our premises and if you should so choose, footage shot by yourself and freely provided to us by you.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific service.
With the exception of Treatment Data, we do not collect any other 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, genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Highland Laser Clinic website host logs IP addresses and browser types. You can browse our site without entering any personal information, and therefore remain anonymous during your visit. However, the enquiry form asks for personal information such as name, postal address, email address and telephone number to enable us to send out the requested information, and make any future visits to our premises easier.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
a) 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 or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback
• when you send us photographs or video or when you consent to photographs or video at our premises
b) Automated technologies or interactions: As you interact with our website, we may automatically collect anonymous Technical Data about your equipment, browsing actions and patterns. We collect this data via our server logs. We also get updates from our Google Business page which provides anonymous data on how many people have clicked on our profile and gone on to look at our website
c) We do not have any cookies on our wesbite of any kind
4. 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, and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Using your health data
In light of the services which we provide to our customers, it will often be necessary for us to use information about your health. Even in the broadest sense of the word, 'health' information is a special category of personal data which requires us to have an additional lawful basis for using this information. Where we use information about your health for the purpose of providing our services to you (or in preparation for us to provide services to you), the additional lawful basis on which we shall rely will be that such use is necessary in order for us to provide you with health care or treatment. The confidentiality of your health data is extremely important to us
Purposes for which we will use your health data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:
Purpose/Activity
Type of Data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
a) Identity
b) Contact
c) Health information
d) Clinical photography
a) Performance of a contract with you
b) Necessary to deliver our duty of care to you
To process and deliver our services to you including:
a) To manage clinical risk
c) Manage payments, fees and charges
a) Identity
b) Contact
c) Health information
d) Clinical photographs / Video
e) Financial
f) Transaction
g) Marketing and communications
a) Performance of a contract with you
b) Necessary for our legitimate interests (To maintain the safety and quality of our service)
c) Necessary for us to provide health care or treatment
d) Necessary for us to comply with a legal obligation
e) Necessary for us to deliver our duty of care to you
To manage our relationship with you which will include:
a) Notifying you about changes to our terms or privacy policy
b) To enable you to partake in a prize draw or survey
c) To send you booking confirmations, reminders and follow up messages
a) Identity
b) Contact
c) Health information
d) Clinical photography
e) Marketing and communications
a) Performance of a contract with you
b) Necessary for our legitimate interests (To keep our records updated and to study how customers use our products/services. To maintain the safety and quality of our service)
c) Necessary for us to provide health care or treatment
d) Necessary for us to comply with a legal obligation
e) Necessary for us to deliver our duty of care to you
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
a) 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 improve our website, products/services, marketing, customer relationships and experiences
a) Technical
d) Usage
c) Clinical photography (only used with your written consent)
d) Videography
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, to promote our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
a) Identity
b) Contact
c) Usage
d) Clinical photography
Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may occassionally use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You may receive very occassional marketing communications from us if you have requested information from us or purchased good or services from us, if you have not opted out of receiving that marketing.
Third-Party Marketing
We have no plans to enage in third-party marketing in the future. However, we will get your express opt-in consent before we share your personal data with any company outside Highland Laser Clinic for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time following the opt-out links on any marketing message sent to you or by Contacting us at any time.
Cookies & Webtracking
Highland Laser Clinic does not use any cookies or webtracking
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. Such third parties consist of:
• IT: Service providers acting as processors who provide IT and system administration services.
• Advisors: Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Authorities: HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
7. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We are fairly old fashioned and prefer to keep your confidential data on paper files. We do not want your data outwith of our control on external servers and consequentially is much less susceptible to data breach.
8. DATA RETENTION
How long will you use my personal data?
Highland Laser Clinic 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.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In most cases we delete all of your data if we have had not had contact from you for a period of over 5 years. This is a periodic process and not continuous and there is no guarantee that your data will not persist longer than this due to operational reasons. Written documentation is securely shredded and/or incinerated and clinical photography is deleted unless used for promotional purposes with your express permission. Email communications and messaging on both Meta and Google platforms may persist for an unspecified time.
You can of course request deletion of your data at any time sooner than this, see below.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may choose to:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please Contact us.
No fee usually
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 if we consider the intent to be malicious.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.