Privacy Policy

01 – INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site: https://newfaces.ie/.

By providing us with your data, you warrant us that you are over 18 years of age.

Our full contact details are as follows:

• Full name of legal entity:   New Faces Ltd
• Name of Data Protection contact:   Sinead Hiney
• Email address:   info@newfaces.ie
• Postal address:  42 Dublin Street, Dundalk, Co Louth

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@newfaces.ie.

02 – WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND DO WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

• Communication Data, which includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
• Customer Data, which includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
• User Data, which includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
• Technical Data, which includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
• Marketing Data, which includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
• We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
• Sensitive Data:  New Faces Ltd does collect sensitive data during the course of performing their services. For your information sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences. To perform our contract, we require clients to complete an intake & consent form to ensure that they are able to receive the treatments we provide. This form will ask for personal data covered under the health category of sensitive data. The information that is provided in this form is used to create the advice and treatments we provide.
• Creating An Online Account:  If you choose to create an account with New Faces Ltd, then you are responsible for the accuracy of the information that is stored. This account will only be active when you use it and if you would like this account to be deactivated at any stage please email us at info@newfaces.ie to advise of this request.  Consent is given freely when you sign up to this website and create an account- all account holders must obtain the permission of the cardholder before paying for any online courses.

03 – HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site, or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this:  https://newfaces.ie/cookie-policy/.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

As a visitor to this website, we may be using Google fonts and as such your IP address will be made available to Google. Please note that Google can have access to your IP address and/or personal when their platform is used in the performance of the website. Many websites and apps use Google services to improve their content and keep it free. When they integrate our services, these sites and apps share information with Google. In order to learn more about the kind of information that is used please click on https://policies.google.com/technologies/partner-sites?hl=en-US

04 – MARKETING COMMUNICATIONS 

Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by emailing us at info@newfaces.ie.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc. 

05 – DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal data with the parties set out below:

• Service providers who provide IT and system administration
• Professional advisers including lawyers, bankers, auditors and insurers.
• Third parties to whom we sell, transfer or merge parts of our business or our assets.
• Phorest platform who we use to book appointments and manage our administrative duties. All of your data in Phorest is securely stored in real-time in a state-of-the-art IT system that is provided by Amazon Web Services (AWS). To read more please visit: https://www.phorest.com/privacy/.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

06 – TRANSFER OF PERSONAL DATA

New Faces Ltd website has been built on the WordPress platform who have servers in a variety of EU countries including Ireland. The hosting is also carried out by Siteground who have servers in a variety of EU countries.

07 – INTERNATIONAL TRANSFERS

Your personal data may be processed by us or one of our trusted third-party partners outside of the European Economic Area (“EEA”). Data privacy laws in the countries to which your personal data is transferred may not be equivalent to, or as protective as, the laws in the EEA.

We will implement appropriate measures to ensure that your personal data remains protected and secure when it is transferred outside of the EEA, in accordance with applicable Data Protection Law. Because many countries to which personal data may be transferred have not received an “adequacy finding” regarding their privacy laws from the European Commission, we will either rely on Standard Contractual Clauses as approved by the European Commissioner protecting the privacy and security of the information transferred or we will rely on derogations in Article 49 of the GDPR to transfer your personal data to such countries.

We continue to monitor all developments regarding the legal bases for the international transfer of personal data and shall update its processes as necessary. Remote access to our systems is on authorised devices only and appropriate technical safeguards are applied to protect personal data.

You have the right to request information about appropriate safeguards. 

08 – DATA SECURITY  

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions, and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to. New Faces Ltd website has integrated SG Site Scanner that runs daily and is used to detect domain blacklisting and malware.

09 – DATA RETENTION  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

During the performance of our contract, some personal data may be transferred through our operating systems. This information can be both in telephone and text formats and also verbally. We treat this information with the utmost importance and given the sensitivity and possible legal consequences which could be attached to the retention of this material, we operate a specific retention period for this area. We will store this information for seven calendar years after it has been captured and the services we offer have been completed and upon which time it will then be deleted.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years (six calendar years) after they stop being customers.

In some circumstances, we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Gift Vouchers

• Gift Vouchers should be used within 5 years of the issue date.
• Vouchers must be used for stated purposes only.
• Vouchers are the sole responsibility of the holder. Neither New Faces Ltd nor any representatives of New Faces Ltd accept responsibility for vouchers that are lost or mislaid.
• Holders must identify themselves as voucher holders when contacting New Faces Ltd and quote voucher numbers and/or any specific offer at the time of booking.

10 – YOUR LEGAL RIGHTS  

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at: https://www.dataprotection.ie/

If you wish to exercise any of the rights set out above, please email us at info@newfaces.ie. 

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 or refuse to comply with your request in these circumstances.

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.

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.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office https://www.dataprotection.ie/. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

11 – 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. When you leave our website, we encourage you to read the privacy notice of every website you visit. Examples of our third-party links are Facebook, Instagram, Phorest and Paypal. This is not an extensive link and some of these platforms may not be in operation at the current time. There will also be other third-party links attached to the WordPress platform which are used to enhance the performance of the website. Please note this is not an exhaustive list and can be added to or deleted as this website evolves.

12 – COOKIES  

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.