Privacy policy

1. Important Information and Who We Are

The purpose of this Policy

We are Nails By Annabel Limited, a limited company registered in England and Wales under company registration number 10766890 and our registered office is at c/o The Glades, Festival Way, Stoke-on-Trent ST1 5SQ with our main trading address being at Lower Street, Newcastle-under-Lyme, Staffordshire ST5 2RH. In this privacy and cookies policy (“Policy”), Nails By Annabel Limited is referred to as “NBA”, “we”, “us” or “our”, as appropriate.

We respect your privacy and are committed to protecting your personal data. This Policy, amongst other matters, will inform you as to how we look after your personal data when you use our website at www.glitterbels.com and, where applicable, our mobile application. Our mobile application is for use by our third-party Educators (being those third parties appointed by us to deliver our training courses) only.

This Policy further explains when and why we collect personal information about website and/or app users, NBA customers, people who contact or interact with us, and our third-party Educators, how we use that personal information, the conditions under which we may disclose it to others and how we keep it secure. Neither our website nor our app is intended for children and we do not knowingly collect data relating to children.

It is important that you read this Policy 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 Policy supplements the other notices and is not intended to override them.

References in this Policy to a ‘section’ shall be to the relevant section of this Policy.

Controller

We are the controller and responsible for your personal data. By this, we mean that we determine the purposes for which and the manner in which your personal data is, or is to be, processed.

Contact details

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, our privacy practices or want to submit a request to exercise your legal rights (as set out in section 10 below), please contact our data privacy manager using the details set out below:

Full name of legal entity: Nails By Annabel Limited

Name of Data Privacy Manager:  Mac Maginnis, Finance Director

Email address: mac@nailsbyannabel.co.uk

Postal address: Lower Street, Newcastle-under-Lyme, Staffordshire ST5 2RH

Telephone number: 07780 766589

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). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to this Policy and your duty to inform us of changes

We keep this Policy under regular review. This Policy was last updated in April 2022 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is current and accurate. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website and/or our app 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 applications and are not responsible for their privacy statements. When you leave our website or our app, we encourage you to read the privacy notice of every website that you visit or app that you use.

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 as follows: 

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 will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website/app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

We do not collect any 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, information about your health, and 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, or in order to provide you with information or products or services that you have requested from us, 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 products or services) or provide you with the information requested. 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.

3. How do we collect personal information from you?

You may provide this to us through our website forms and/or our app, emails, phone conversations, documents that you provide to us, or when you contact us for any other reason by any media, for example when you:

• Create an account on our website and/or our app
• Purchase products and/or training courses from us
• Contact or interact with us through our website and/or our app
• Provide feedback to us
• Request marketing and/or other communications to be sent to you

This includes Identity, Contact, Financial, Profile, Usage and Marketing and Communications Data.

Automated technologies or interactions

We also obtain personal information relating to you (including about your equipment, browsing actions and patterns) using automated technical means when you visit our website and/or our app.  We collect this personal data using cookies, server logs and other similar technologies. Our website and our app use cookies to distinguish you from other users of our website and/or our app. This helps us to optimise your experience of our website and/or our app and services and also allows us to improve our website and/or our app. For detailed information on the cookies we use, and the purposes for which we use them, please see section 5 below.

Information we receive from other sources.

We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data and Usage Data from analytics providers and search information providers.
• Contact Data from providers of technical services.
• Identity and Contact Data from publicly availably sources.

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 (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
• Where we need to comply with a legal obligation.

The table below describes all the ways in which 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 using the details set out in section 1 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.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

• We may use your Identity, Contact, Technical, Usage, Profile and Marketing and Communications 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 services and offers may be relevant for you (we call this marketing).
• You will receive marketing communications from us if you have requested information from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
• Third-party marketing: We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes.
• Opting out: You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service, service experience or other transactions.

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (using the details set out in section 1).

If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Cookies

Our website and our app use cookies. Cookies are tiny text files that identify your computer to our server as a unique user when you visit certain pages on our website and/or our app and they are stored by your Internet browser on your computer's hard drive. Cookies can be used to recognise your Internet Protocol address, saving you time while you are on our website and/or our app.

We only use cookies for your convenience in using our website and/or our app and not for obtaining or using any other information about you (for example targeted advertising). Your browser can be set to not accept cookies, but this would restrict your use of our website and/or our app.

If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html.

Please note that we collect data from our website and our app about the use of our website and our app (as applicable) using a web analysis tool that uses cookies that are (able to be) used to generate pseudonyms for a user’s profile. This means that using cookies (which may be stored on your computer after you leave our website and our app) can store information about your visit.

As set out in section 6 below, we use services provided by Shopify to allow us to operate an e-commerce platform for the sale of our products and/or services. For a complete list of Shopify cookies, please see the ‘Merchant Storefronts’ section of the Shopify cookie policy which can be accessed via www.shopify.co.uk/legal/cookies.

We also use services provided by Book That App by Zetya to allow us to make available to our third-party Educators a mobile application that helps us to manage training course bookings with our Educators. If you want to find out more information about cookies used on our app, we recommend that you contact Zetya direct (https://www.zetya.com/).

6. Disclosures of Your Personal Data

We may share your personal data with third parties we use to help deliver our products and/or services to you. For example, where you have purchased a training course from us, we will share your name, address and contact details with our Educators, who are appointed by us as independent third parties to deliver our training courses. Also, we use third-party service providers to deliver products you have ordered and to manage any returns.

If you are one of our Educators, we may display your personal data (including name, contact details and a profile picture) so that NBA customers can make an informed choice about what training course to enrol on.

We may also share your personal data with the parties set out below for the purposes set out in the table in section 4 above. If any of these organisations are based, or have a group or affiliated companies that are based, outside of the United Kingdom, then section 7 below sets out the basis on which your personal data is transferred to them.

If you require further information on how our third parties (set out in the table below) are processing your personal data, we recommend that you consult their privacy policies or contact them directly.

We may also share your personal data with other third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

Further, we may need to disclose your information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use; or to protect the rights, property or safety of our business, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

We will take all reasonable steps to ensure that third parties respect the security of your personal data and 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.

7. International Transfers

Some of the third parties identified in section 6 above are based outside the United Kingdom (UK) or have a group or affiliated companies based outside of the UK, so their processing of your personal data may involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

Please contact us using the details set out in section 1 if you want further information on the specific mechanism used by us when transferring your personal data out of the UK. You can also obtain further information about international data transfers by visiting the ICO’s website at www.ico.org.uk.

8. Data Security

All information you provide to us is stored on our secure servers.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website and/or our app, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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.

Certain services may include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

The transmission of unencrypted (or inadequately encrypted) data over the Internet is inherently insecure, and for this reason, we cannot guarantee the security of data sent between us over the Internet.

9. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In some circumstances you can also ask us to delete your data: see section 10 for further information.

In the event that you create an account on our website and/or our app and do not use the account for a period of one (1) year, then we will treat the account as expired and your personal data may be deleted.

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data 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 data 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.
• Object to processing of your personal data 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 data 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data 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 data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that 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.
• Withdraw consent at any time where we are relying on consent to process your personal data. 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.

To exercise any of these rights, please contact us (using the details set out in section 1).

No fee is usually required

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 could refuse to comply with your request in these circumstances.

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 could 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.

Further information

You can obtain further information about data protection laws by visiting the ICO’s website at www.ico.org.uk.