INTRODUCTION

This privacy notice sets out how Dr Paulina Charlesworth Aesthetics Limited, a company registered in England and Wales under registration number 14192903, whose registered address is at 7 Lindum Terrace, Lincoln, Lincolnshire, England, LN2 5RP (“the Company”, “us”, “we”, “our”) uses and protects your personal data.

1. IMPORTANT INFORMATION AND WHO WE ARE (Paragraph 1)

2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU (Paragraph 2)

3. HOW IS YOUR PERSONAL DATA COLLECTED? (Paragraph 3)

4. HOW WE USE YOUR PERSONAL DATA (Paragraph 4)

5. DISCLOSURES OF YOUR PERSONAL DATA (Paragraph 5)

6. INTERNATIONAL TRANSFERS (Paragraph 6)

7. DATA SECURITY (Paragraph 7)

8. DATA RETENTION (Paragraph 8)

9. YOUR LEGAL RIGHTS (Paragraph 9)

10. CONTACT DETAILS (Paragraph 10)

11. COMPLAINTS (Paragraph 11)

12. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES (Paragraph 12)

13. THIRD PARTY LINKS (Paragraph 13)

1. IMPORTANT INFORMATION AND WHO WE ARE

This privacy notice gives you information about how we collect and use your personal data through your use of this website, including any data you may provide when you contact us, book an appointment, register with us or sign up to our newsletter, or purchase a product or service.

We operate a website at www.drcharlesworth.co.uk (the Website) which is not intended for children or minors (ie anyone under the age of 18) and we do not knowingly collect data relating to children.

CONTROLLER

The Company is the controller and responsible for your personal data.

We are registered with the Information Commissioner’s Office in accordance with the UK’s data protection and legislation. Our registration number is ZB688903.

We have appointed a data protection manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (Paragraph 9), please contact the DPM using the information set out in the contact details section (Paragraph 10).

2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details. However, you should note that we use third party companies to facilitate payments, as set out below.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you interact with and use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Health data which includes medical consultation and medical services data which includes treatment data about the treatment you wish to (or have) received from us. ‘Health data’ is a special category of personal data and therefore requires us to take extra steps to ensure it is adequately protected. This, if relevant to your health concern and treatment planning may include information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation or information about your health and genetic and biometric data. Photographs are an important part of medical records. You will always be asked to sign a written consent before any photographs or videos are taken.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

We do not collect any other special categories of personal data about you (this includes details about your political opinions, trade union membership, or criminal records).

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

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, 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 goods or services). 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 IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by calling and speaking to us, filling in online forms or by corresponding with us by post, email or otherwise. This includes personal data you provide when you:

apply for our products or services;

create an account on our website;

subscribe to our service or publications;

request marketing to be sent to you;

enter a competition, promotion or survey; or

give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie notice for further information.

Third parties or publicly available sources. We may receive personal data about you from various third parties:

Technical Data may be collected from the following parties:

analytics providers such as Google based outside the UK;

advertising networks whether based inside or outside the UK; and

search information providers whether based inside or outside the UK.

Contact, Financial and Transaction Data may be collected from providers of technical, payment and delivery services whether based inside or outside the UK.

Identity and Contact Data may collected from data brokers or aggregators whether based inside outside the UK.

Identity and Contact Data is sometimes collected by our third party providers and partners who provide such data to us as part of their introductory services when making and/or scheduling appointments with us (whether or not on your behalf), and/or when arranging for us to contact you as part of the services you have requested to receive. These third parties include:

Soham Inc, a company registered in Delaware, US, trading as https://www.zenoti.com/;

Aesthetic Response Limited at https://aestheticresponse.co.uk/;

Shopify International Ltd at https://www.shopify.com/uk/legal/privacy;

in respect of transcribing and recording patient notes this is undertaken by Heidi Health Trading Pty Limited whose privacy policy is available at https://www.heidihealth.com/uk/legal/privacy-policy;

in respect of payments these may be processed by either:

Stripe, Inc., the US parent company operating under US law, or

Stripe Payments Europe, Limited (“SPEL”), an Irish company operating under Irish law (https://stripe.com/gb/legal/privacy-center#which-stripe-entities-are-involved), or

Dojo, which is a trading name of Paymentsense Limited, Paymentsense Ireland Limited and WalkUp Limited (https://dojo.tech/legal/privac...) .

We have no control over the data protection policies, guidelines and legal implementation that these third party companies are required to undertake. Therefore, it is your responsibility to be satisfied that your data is used by these third parties in accordance with the data protection legislation and your particular requirements. Where we are provided your personal data from third parties we will assume that your full and express consent has been provided accordingly. If this is not the case you should contact us and the relevant third party without delay.

4. HOW WE USE YOUR PERSONAL DATA

LEGAL BASIS

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

General Medical Council best practice.

You have the right to withdraw consent to marketing at any time by contacting us.

Special Category Personal Data (how we may use Your Health Data)

In light of the services provided to our patients, clients and customers, it will often be vital for us to use information about your health. Even in the broadest sense of the word, ‘health’ information is a special category of personal data which requires us to have an additional lawful basis for using this information. Where we use information about your health for the purpose of providing our services to you (or in preparation for us to provide services to you), the additional lawful basis on which we shall rely will be that such use is necessary in order for us to provide you with health care or treatment.

In respect of our use of your Health Data, such use shall also be in accordance with the General Medical Council best practice.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use the various categories of 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.

Purpose/Use

Type of data

Legal basis

To register you as a new customer

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing & Communications

Performance of a contract with you:

This can include providing consultation services, the provision of products, and the operation of a loyalty account for you.

We will retain this data for a maximum of 6 years following you’re the cessation of our relationship.

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

This can include providing consultation services, the provision of products, and the operation of a loyalty account for you.

We will retain this data for a maximum of 6 years following you’re the cessation of our relationship.

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy notice

(b) Dealing with your requests, complaints and queries

(a) Identity

(b) Contact

(d) Marketing and Communications

(e) Health Data

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

This can include providing consultation services, the provision of products, and the operation of a loyalty account for you.

We will retain this data for a maximum of 6 years following you’re the cessation of our relationship.

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

This can include providing consultation services, the provision of products, and the operation of a loyalty account for you.

We will retain this data for a maximum of 6 years following you’re the cessation of our relationship.

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

This can include providing consultation services, the provision of products, and the operation of a loyalty account for you.

We will retain this data for a maximum of 6 years following you’re the cessation of our relationship.

To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

This can include providing consultation services, the provision of products, and the operation of a loyalty account for you.

We will retain this data for a maximum of 6 years following you’re the cessation of our relationship.

To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing

(a) Technical

(b) Usage

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)

This can include providing consultation services, the provision of products, and the operation of a loyalty account for you.

We will retain this data for a maximum of 6 years following you’re the cessation of our relationship.

To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) OR Consent, having obtained your prior consent to receiving direct marketing communications

This can include providing consultation services, the provision of products, and the operation of a loyalty account for you.

We will retain this data for a maximum of 6 years following you’re the cessation of our relationship.

To carry out market research through your voluntary participation in surveys

Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).

This can include providing consultation services, the provision of products, and the operation of a loyalty account for you.

We will retain this data for a maximum of 6 years following you’re the cessation of our relationship.

DIRECT MARKETING

When your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

THIRD-PARTY MARKETING

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

OPTING OUT OF MARKETING

You can ask us to stop sending you marketing communications at any time. Just write to us by post or email.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for a product/service warranty registration, appointment reminders, updates to our Terms and Conditions, checking that your contact details are correct.

COOKIES

For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Notice.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

Soham Inc, a company registered in Delaware, US, trading as https://www.zenoti.com/;

Aesthetic Response Limited at https://aestheticresponse.co.uk/;

Shopify International Ltd at https://www.shopify.com;

Heidi Health Trading Pty Limited at https://www.heidihealth.com/uk/legal/privacy-policy;

Wigmore Medical Ltd (https://www.wigmoremedical.com/privacypolicy);

Healthxchange Pharmacy UK Ltd and Pharma-e Ltd trading as Healthxchange at https://www.healthxchange.com/privacy

Bottled Science Ltd trading as Skinaide at https://skinade.com/pages/privacy-policySkin

TEOXANE SA trading as Teoxane at https://www.teoxane.com/en/privacy-policy

Certus Healthcare Ltd T/A Primed Pharmacy at https://www.primedpharmacy.com/privacy-policy/

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 privacy notice.

We require all third parties to respect the security of your personal data and to 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.

However, where your personal data has been provided to us by these specific third parties, we do not have control over the way they may use your personal data themselves and you should check their respective privacy notices and their own data protection compliance. Nonetheless should you have concerns you may contact us.

6. INTERNATIONAL TRANSFERS

When you complete a booking form on our website, your name, contact details, and address are shared with our appointment booking provider, Zenoti (Soham Inc). Zenoti is a US-based company that supports clients internationally and may process your information on secure servers outside the UK, including in the United States or other countries.

To ensure the protection of your personal data when it is transferred internationally, we have entered into a data processing agreement with Zenoti. This agreement incorporates the European Commission’s Standard Contractual Clauses (SCCs) and the UK Addendum to the SCCs, which are approved mechanisms for transferring personal data outside the UK and European Economic Area in accordance with UK and EU data protection laws.

Zenoti may also use subprocessors located outside the UK, including in the US (for example, Amazon Web Services, which hosts Zenoti’s servers). All such subprocessors are contractually required to provide an equivalent level of protection for your personal data, and transfers to subprocessors are also governed by the SCCs and UK Addendum. Onward transfers of your data to third parties will only take place in line with these contractual safeguards and applicable law, and in accordance with documented instructions from us.

Also, we may store or back up certain types of patient data (such as clinical images or internal documentation) using Apple’s iCloud service. This is used only on encrypted and access-controlled clinic-owned devices, in line with our data protection policies.

Apple iCloud is a secure cloud storage platform that uses strong encryption protocols to protect data both in transit and at rest. Apple may store or process this data on servers located in countries outside the United Kingdom, including the United States and countries within the European Economic Area (EEA).

Where data is transferred outside of the UK or EEA, Apple ensures that appropriate safeguards are in place, including:

Encryption of all data stored in iCloud
Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner’s Office (ICO) and/or European Commission to ensure your rights and protections travel with your data
Compliance with UK GDPR and EU GDPR requirements

We only use iCloud in accordance with applicable data protection laws, and where necessary, we conduct risk assessments to ensure your privacy is protected. iCloud is never used to store or share data without device-level access controls (such as biometric or password protection). Here is a link to Apple’s privacy practices: https://www.apple.com/uk/legal/privacy/en-ww/

In some cases, we may receive personal data about you from third parties located outside the UK (for example, if you have received services abroad or are referred by an overseas provider). In all cases, we take steps to handle your information securely and in line with our privacy commitments.

For certain processing activities, we may ask for your explicit consent for international transfers. You can withdraw your consent at any time by contacting our Data Protection Manager.

If you have any questions about how your information is used or wish to exercise your rights, please contact our Data Protection Manager.

Use of Cloud Services for Data Security and Backup

To securely manage, store, and back up patient and administrative data, we use trusted UK and EU-based cloud service providers:

Microsoft 365 is used for email, document storage, and communication. Microsoft hosts your data in secure data centres located in the United Kingdom and may replicate some data to the European Economic Area (EEA) for operational resilience and compliance purposes. Microsoft does not access your personal data for marketing or advertising.
Barracuda Networks provides encrypted cloud backup services for our Microsoft 365 environment. All data backed up via Barracuda is stored exclusively in a UK-based (London region) Microsoft Azure data centre. Barracuda acts as our data processor and is contractually bound to comply with UK data protection law, including the UK General Data Protection Regulation (UK GDPR).

Both providers apply strong technical and organisational safeguards including encryption, multi-factor authentication, and regular third-party audits.

In cases where limited access by service providers may involve data access from abroad (e.g. technical support), this is governed by approved legal safeguards such as the UK International Data Transfer Agreement (IDTA) or Standard Contractual Clauses (SCCs).

7. DATA SECURITY

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.

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

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

Details of retention periods for different aspects of your personal data are set out in the table Purposes for which we will use your personal data above.

Rest assured we will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for 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 in 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Paragraph 9 below for further information.

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.

9. YOUR LEGAL RIGHTS

You have a number of 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 “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 in certain circumstances. This enables you to ask us to delete or remove personal data 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 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in Paragraph 4 for details of how to object to receiving direct marketing communications).

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 (see the table in section 4 for details of when we rely on your consent as the legal basis for using your 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.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

If you want us to establish the data’s accuracy;

Where our use of the data is unlawful but you do not want us to erase it;

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

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us: see Contact details (Paragraph 10).

FEE MAY BE REQUIRED

You may have to pay a £10.00 fee to access your personal data (or to exercise any of the other rights). However, we could refuse to comply with your request if it is clearly unfounded.

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.

10. CONTACT DETAILS

If you have any questions about this privacy notice or about the use of your personal data or you want to exercise your privacy rights, please contact our DPM as follows:

Email address: hello@drcharlesworth.co.uk

You may also contact our DPM by writing to the Company’s registered office address.

11. COMPLAINTS

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy notice under regular review and it updates from time to time. This version was last updated in August 2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

13. 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.

Privacy Policy

Use of Cloud Services for Data Security and Backup