Privacy Policy & Data Rights | iBeautify Tunbridge Wells
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Privacy Policy

Version 1.0  ·  Last updated: 14 August 2026

Solicitor review flag: This policy is a first draft. It should be reviewed by a solicitor before publication, particularly the treatment record and special category data sections.

1. Who we are (controller identity)

Trading name: iBeautify
Legal / registered name: iBeautify Ltd
Address: 76 Calverley Road, Royal Tunbridge Wells, Kent TN1 2UJ
Email: info@ibeautify.co.uk
Telephone: 018922 51451
ICO registration: ZC222701

We are the data controller for personal data collected through this website and in connection with our treatments. Where we use a processor, that processor is identified below.

2. Data we collect and why

2.1 Website enquiry data (general personal data)

When you use the contact form we collect your name, email address, phone number (optional) and the content of your message. Lawful basis: legitimate interests (responding to your enquiry). Retention: 12 months from last contact, then deleted.

2.2 Booking data

When you book through Fresha, Fresha collects your name, contact details and payment information directly. Card details are never transmitted to or stored on our website. Fresha is the payment processor. Lawful basis for our use of booking records: performance of a contract. Retention: 7 years from the last appointment (accounting obligations).

2.3 Treatment records - special category health data

Treatment records, medical history forms, consultation notes, photographs taken during treatment and any blood-related records (including PRP procedures) are special category data under Article 9 UK GDPR. We process this data on the basis of Article 9(2)(a) - explicit consent, given separately before treatment begins. Retention: [PLACEHOLDER - minimum 8 years from last treatment for adults; for minors, until age 25 or 8 years from last treatment, whichever is longer - confirm with solicitor]. You may withdraw consent at any time, but withdrawal does not affect the lawfulness of processing before withdrawal, and we may retain records where we have another legal obligation to do so.

2.4 WhatsApp and telephone communications

If you contact us by WhatsApp or telephone, we may retain a record of that communication to respond to you and for the purpose of client care. Lawful basis: legitimate interests.

2.5 Marketing

We will only send you marketing communications with your explicit prior consent. You may withdraw consent at any time by emailing us or clicking unsubscribe. Lawful basis: consent.

3. Processors (named individually)

  • Fresha (Fresha.com) - online booking platform and payment processor. Processes booking and payment data. Data Processing Agreement in place.
  • Formspree (Formspree Inc, USA) - contact form submission handler. Processes enquiry data submitted through the website contact form. Transfers outside the UK: adequacy decision / Standard Contractual Clauses apply.
  • Microsoft (Microsoft Corporation, USA) - email service (Outlook / Microsoft 365). Transfers outside the UK: Standard Contractual Clauses apply.
  • WhatsApp (Meta Platforms Ireland Ltd) - client messaging. Transfers outside the UK: adequacy decision / Standard Contractual Clauses apply.
  • Hosting provider: [HOSTING PROVIDER PLACEHOLDER - confirm with developer].
  • Analytics: [ANALYTICS PROVIDER PLACEHOLDER - to be decided; see Cookie Policy].

4. International transfers

Formspree, Microsoft and WhatsApp all involve transfers of personal data outside the UK. We rely on Standard Contractual Clauses (SCCs) approved by the Information Commissioner, or on adequacy regulations, for each such transfer. You may request details of the specific mechanisms in place by contacting us at info@ibeautify.co.uk.

5. Retention periods

  • Website enquiry data: 12 months from last contact.
  • Booking records: 7 years from last appointment.
  • Treatment and health records: [PLACEHOLDER - confirm with solicitor; typically 8 years minimum for adults].
  • Marketing consent records: Until you withdraw consent, plus 1 year thereafter as evidence of consent.
  • Cookie consent records: 13 months from the date consent was given.

6. Your rights

Under UK GDPR you have the following rights. To exercise any of them, email info@ibeautify.co.uk with "Data Rights Request" in the subject line. We will respond within one calendar month.

  • Access - to receive a copy of personal data we hold about you.
  • Rectification - to have inaccurate data corrected.
  • Erasure - to have data deleted where there is no overriding lawful reason to retain it.
  • Restriction - to restrict processing in certain circumstances.
  • Portability - to receive data in a structured, machine-readable format (where applicable).
  • Objection - to object to processing based on legitimate interests or for direct marketing.
  • Withdraw consent - at any time, without affecting processing before withdrawal.

There is no automated decision-making or profiling that produces legal or similarly significant effects.

7. Internal complaints procedure (Data Use and Access Act 2025)

If you have a concern about how we handle your personal data, please contact us in the first instance:

  • Contact: Cleo Campbell-White, info@ibeautify.co.uk
  • Response timeframe: We will acknowledge your complaint within 5 business days and provide a full response within 30 calendar days.
  • Escalation: If you are not satisfied with our response, you may escalate to the Information Commissioner's Office (ICO).

8. Right to complain to the ICO

You have the right to lodge a complaint with the Information Commissioner's Office at any time:

9. Cookies

We use cookies on this website. For full details, see our Cookie Policy.

10. Changes to this policy

We may update this policy from time to time. We will notify you of material changes by updating the "Last updated" date at the top and, where appropriate, by direct notice. Continued use of the website after any change constitutes acceptance of the updated policy.

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