CELLSAN MEDICAL SPA

Privacy Policy

1. Introduction

2. Key terms

3. Personal information we collect about you

4. How your personal information is collected

5. How and why we use your personal information

6. Promotional and Marketing communications

7. Profiling

8. Who we share your personal information with

9. Where your personal information is held

10. How long your personal information will be kept

11. Transferring your personal information out of the EEA

12. Your rights

13. Keeping your personal information secure

14. How to complain

15. Changes to this privacy policy

16. How to contact us

1. Introduction
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation (EU) 2016/679 (commonly known as the “GDPR”), which applies across the European Union and we are responsible as the controller of that personal information for the purposes of those laws.

This privacy policy applies to personal data that we collect regarding our customers and visitors to our website.

2. Key terms
It would be helpful to start by explaining some key terms used in this policy:

we, us, our
Cellsan Trading Limited with registration number HE157580, and registered office at Methonis 2, 1070 Nicosia, Cyprus.

Our medical spa is located at Spyrou Kyprianou 75, 4046 Germasogeia, Limassol, Cyprus
personal information
Any information relating to an identified or identifiable individual.
special categories of personal information
Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership,

Genetic and biometric data.

Data concerning health, sex life or sexual orientation.

3. Personal information we collect about you
We may collect and use the following personal information about you:

• Identity Data which includes your first name and last name, title, date of birth and gender and information that enables us to check and verify your identity, such as your identity card number.

• Contact Data which includes your billing address, delivery address, email address and telephone number.

• Financial Data which includes billing and payment card details.

• Transaction Data which includes details about payments and products and services you have purchased from us.

• Treatment Data which includes details regarding the treatments provided to you at our medical spa and, if relevant to the treatment requested by you, details about your health.

• Feedback Data which includes information relating to feedback provided to us and your responses to surveys.

• Usage Data which includes information relating to your use of our website.

• Marketing and Communications Data which includes your preferences in receiving marketing material from us and our third-party partners.

Where we need to collect personal information by law, or in order to be able to provide our products or services to you and you fail to provide that information when requested, this may prevent or delay us from providing our products or services to you. 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.

We do not usually collect and use personal information of children (i.e. individuals who are under the age of sixteen). Where need to collect and use such personal information, we do so only provided that we have first obtained their parents’ or legal guardian’s consent or we are otherwise permitted or required under the law.

4. How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, or email, via any forms we may ask you to fill in and via our website.

However, we may also collect information:

• from publicly accessible sources;

• from cookies on our website—for more information on our use of cookies, please see our cookies policy; and

• via our sales and IT systems.

5. How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• to comply with our legal and regulatory obligations;

• for the performance of our contract with you or to take steps at your request before entering into a contract;

• for our legitimate interests or those of a third party, where your interests and fundamental rights do not override our interests or those of a third party;

• where you have given your consent; or

• for the provision of treatment

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and the legal bases which we rely on to do so:

What we use your personal information for

To provide our products, services and treatments to you including:

(a) to process and deliver your order or request

(b) allocate the correct therapist to provide the treatment to you

(d) collect and recover money owed to us
(a) Identity Data

(b) Contact Data

(d) Transaction Data

(e) Treatment Data

Type of information

(a) Performance of a contract with you or to taking steps at your request before entering into a contract

(b) Necessary for our legitimate interests (record and administer our transactions)

(d) Your explicit consent, as far as special categories of data are concerned

(e) For the provision of treatment
To manage our relationship with you which will include:

(a) to register you as a new customer

(b) Notifying you about changes to how we operate our business or the way we deal with you

(d) Asking you to leave a review or take a survey

Lawful basis for processing

(a) Identity Data

(b) Contact Data

(a) Performance of a contract with you or to taking steps at your request before entering into a contract

(b) Necessary to comply with our legal and regulatory obligations

(c) Necessary for our legitimate interests (to inform you about our business, keep our records updated and to study how customers use our products/services)
To run, administer and protect our business which will include:

(a) Ensuring business policies are adhered to,

(b) operational reasons, such as improving efficiency, training and quality control

(d) preventing unauthorised access and modifications to systems

(e) statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures

(f) Ensuring safe working practices, staff administration and assessments

(a) Identity Data

(b) Contact Data

(d) Transaction Data

(e) Feedback Data

(f) Communication Data

(a) Necessary for our legitimate interests (for running, administering and protecting our business, monitoring and improving our business, making sure we are following our own internal procedures and working efficiently, preventing and detecting fraud and unauthorised access and modifications to systems, and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with our legal and regulatory obligations
Gathering and providing information and making filings required by law or relating to audits, enquiries or investigations by regulatory bodies or authorities
(a) Identity Data

(b) Contact Data

(d) Transaction Data
(a) Necessary to comply with our legal and regulatory obligations

(b) Necessary for our legitimate interests (for protecting our rights and defending ourselves in the context of audits, enquiries or investigations administration)

External audits and quality checks
(a) Identity Data

(b) Contact Data

(d) Transaction Data
(a) Necessary to comply with our legal and regulatory obligations

(b) Necessary for our legitimate interests (for maintaining our accreditations and operating at the highest standards)

To improve our website, products and services, marketing, customer relationships and experiences
(a) Transaction Data

(b) Feedback Data

(d) Usage Data

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)
Marketing our business and making suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity Data

(b) Contact Data

(d) Feedback Data

(e) Marketing and Communications Data
(a) Your consent

(b) Necessary for our legitimate interests (to develop our products/services and market and grow our business)
The above table does not apply to special categories of personal information, which we will usually only process with your explicit consent (unless the law allows to do so without it).

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Promotional and Marketing communications
We may use your personal information to send you updates (by email, text message, telephone, app notifications or post) about our products and services, including exclusive offers, promotions or new products and services.

We rely on your consent to send you promotional and marketing communications and we will ask for this consent separately and clearly.

Where you have provided your consent for promotional and marketing communications, you have the right to withdraw it at any time by:

• emailing, calling or writing to us—see below: ‘How to contact us’

• using the ‘unsubscribe’ link in emails or ‘STOP’ number in text messages

We will always treat your personal information with the utmost respect and never share it for marketing purposes with other organisations outside our group.

7. Who we share your personal information with
We routinely share personal information with:

• service providers such as third parties we use to help deliver our products and services to you, logistics and payment service providers;

• other third parties we use to help us run our business, e.g. marketing agencies or website hosts;

• third parties approved by you, e.g. social media sites you choose to link your account to;

• professional advisers including lawyers, consultants and auditors who provide legal, consultancy and auditing services to us; and

• our insurers and banks.

We only allow third parties to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies, authorities and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

8. Where your personal information is held
Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

9. How long your personal information will be kept
We will only retain your personal information 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.

We will usually keep your personal information while we we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;

• to show that we treated you in accordance with the law; and

• to keep records required by law.

Different retention periods apply for different types of personal information. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete or anonymise it.

10. Transferring your personal information out of the EEA
To deliver our products and services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

• with our service providers located outside the EEA;

• if you are based outside the EEA; and

• where there is an international dimension to the services we are providing to you

These transfers are subject to special rules under European and Cyprus data protection law.

Whenever we transfer your personal information out of the EEA, we ensure a degree of protection similar to that afforded in EEA countries is afforded to it by ensuring at least one of the following safeguards is implemented:

· We will transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission.

· Where we transfer your personal information to countries that have not been deemed to provide an adequate level of protection for personal information by the European Commission, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe.

If you would like further information please contact us (see ‘How to contact us’ below).

11. Your rights
You have the following rights in relation to your personal information:

Access
The right to be provided with a copy of your personal information.
Rectification
The right to require us to correct any mistakes in your personal information. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
To be forgotten
The right to require us to delete your personal information (in certain circumstances). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Restriction of processing
The right to require us to restrict processing of your personal information (in certain circumstances). This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information 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 information but we need to verify whether we have overriding legitimate grounds to use it.
Data portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party. 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.
To object
The right to object to processing of your personal information 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 information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
Withdraw consent
The right to withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
For further information on each of those rights, including the circumstances in which they apply, please contact us or visit the website of the Commissioner for the Protection of Personal Data (www.dataprotection.gov.cy).

If you would like to exercise any of those rights, please:

• email, call or write to us—see below: ‘How to contact us’;

• let us have enough information to identify you;

• let us have proof of your identity; and

• let us know what right you want to exercise and the information to which your request relates.

You will not have to pay a fee to access your personal information 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.

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.

12. Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

13. How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.

The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Cyprus is the Commissioner for Personal Data Protection who can be contacted at 1 Iasonos street, 2nd floor, 1082 Nicosia; tel: 22818456; fax: 22304565; email: commissioner@dataprotection.gov.cy; www.dataprotection.gov.cy.

14. Changes to this privacy policy
This privacy policy was published on [insert date].

We may change this privacy policy from time to time. When we do we will post the updated privacy policy on our website and we will also inform you via email if you are on our mailing list.

15. How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Spyrou Kyprianou 75,

4046 Gergasmogeia,

Limassol, Cyprus

Email: info@cellsan.com.cy

Tel: 7000 0234

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