Brightlife Limited – privacy statement

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This Privacy Statement is addressed to our customers at the spa and at events whether organised by us or a third party.  It is also addressed to our business contacts, our suppliers, job applicants and people who make an enquiry about our services.

 

The privacy statement is designed to help you understand how your personal data is processed by Brightlife Limited (“Brightlife”) and why. 

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Personal data is data which relates to you when you can be identified from that data or from that data when combined with other information which is in the possession of or is likely to come into the possession of Brightlife.  The definition of personal data includes any expression of opinion about you and any indication of the intentions of Brightlife or any other person in respect of you.

 

What personal data is processed and how is it used?

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If you are a customer at the spa or an event, we will obtain information from you including your name, address and contact details.  We will use these to process your booking and to keep in touch with you about it which may include asking you for feedback.  We may ask for your dietary requirements and we may also need your bank details in the event that we need to refund you by bank transfer.  Your name may be shared with the person running the event so that they have the delegate list.  The presenter of the event is not, however, permitted to use this information for any other purpose.

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You should be aware that if you are attending an event, photos of the event may be taken by us or the presenter for use on our or their web site or our or their social media channels.   

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If you are visiting the venue, you will be asked to complete an online form.  The form requests certain information from you and some of this information is about your health, particularly where you are a spa customer.  We may also ask for a letter from your GP if we have any concerns about providing you with services at the spa.  The form also includes your COVID-19 vaccination status and a COVID-19 declaration. We will use this information to mitigate any arising COVID-19 risks to staff and other customers.

Upon arrival to the venue, we will be taking temperature checks of all customers. Temperatures will not be recorded once taken but access to the venue will be refused if the temperature is higher than 37.8

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If you request information about our services, we will use your contact details to send this to you.  If you attend an event, we will use your contact details to send you a brochure on an annual basis about forthcoming events.  You will always have the option to opt out of receiving this. 

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If you are a business contact, a supplier or a referee for a potential staff member, we will hold contact information for you as well as relevant correspondence.  We might also hold your bank account details if you are an individual supplier of services to us. 

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If you are a job applicant, we will use the information provided by you to assess your suitability for employment.  This will include your contact information, your employment history and your CV. 

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Where is the data stored?

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All of the data that we process about you is held in the Isle of Man office in paper form and/or electronically. We do use an archive provider on the Isle of Man to hold paper records for us and have applied appropriate standards of due diligence to their data protection standards. 

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Who can see the information?

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If you are a customer at the spa or an event, your information will only be shared with those Brightlife staff who need to see it.  If you are attending an event, your name might be shared with the person hosting the event.  If you are attending the spa and you are taken ill, we reserve the right to share your medical information with any medical staff who attend in the event that you are not in a position to share that information yourself. 

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Please note that where group bookings are made, booking confirmations for each member of the group will be sent to the person making the booking on behalf of the group.

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If you are a business contact, a supplier or a referee for a potential staff member your data will only be visible to those Brightlife staff who need to have access to it. 

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If you are a job applicant, your data will only be visible to those Brightlife staff who need to have access to it.  We may also share information with the recruitment agency representing you when requested to do so. 

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Do we use your data for marketing purposes?

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If you have an attended an event, we will use your contact details to send you a brochure on an annual basis about forthcoming events.  You will always have the option to opt out of receiving this. We will not otherwise use your personal data for marketing purposes and we won’t provide your data to third parties for them to market their goods and services to you.

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How long is the data kept for?

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We will maintain records and data to comply with our statutory, legal and regulatory responsibilities as well as what we deem to be reasonable practice where there is no record keeping period set down in law or other rules.  We will destroy customer data in line with these retention periods. 

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We will destroy business contact data when our business relationship with you comes to an end.

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We will destroy data about job applicants six months after the recruitment exercise has been completed. 

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If you have specific queries in relation to retention periods, please contact the Managing Director on brightlife@brightlife.com or on 01624 880318.

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Your rights

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If you wish to see the data processed about you by Brightlife, please contact the Managing Director on brightlife@brightlife.com or on 01624 880318.

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You have additional rights under the Data Protection Act 2002 and any legislation which replaces it such as the right to rectification of incomplete data and the right of erasure of data. 

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An important right that you have is the right to object to processing.  This right applies where, after careful consideration, we have decided that is in the legitimate interests of Brightlife to process data about you. 

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• If you are a customer at the spa or an event, we process data for our legitimate interests when ask for your dietary requirements, when we use your contact details to keep in touch with you or respond to an enquiry, when we use your financial information to process any refund and when you have attended an event and we use your contact details to send you our annual brochure;

• If you are a job applicant, we process data for our legitimate interests when we use it for recruitment purposes.

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You also have the right to withdraw your consent to the processing of your vaccination status, your COVID declaration and your temperature.  You should be aware that this may affect your ability to access the venue.

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You have the right to receive the personal data you provide to us in a structured, commonly used and machine readable format and have the right to transmit this data to another controller, without hindrance from us. 

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If you wish to exercise any of these rights, please contact the Managing Director on brightlife@brightlife.com or on 01624 880318.

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If you wish to make a complaint about how we have processed your data, please contact the Managing Director on brightlife@brightlife.com or on 01624 880318.  You can also contact the Information Commissioner on 01624 693260 or by emailing ask@inforights.im

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26 July 2021