Mandara Spa LLC
1. Important Information and who we are
A subsidiary of OneSpaWorld Holdings Limited, Mandara Spa is a separate controller in respect of your personal data.
2. The data we collect about you
Personal data means any information about an individual from which that person can be identified or identifiable. It does not include data whereby the identity has been removed by an irreversible process (i.e. anonymous data).
The personal data we collect from and about you comes from: (i) the health forms and questionnaires we request you to complete prior to receiving a spa service, (ii) information provided to us by the cruise line or resort on/at which you are receiving the spa services, such as your name, cabin number/hotel room, gender, and age; and (iii) if you purchase goods onboard and request the home delivery of such goods, the information you provide us to fulfill your order. This data may include your name, occupation, gender, age, nationality, celebration event information, voyage or travel-related information (vessel name, stateroom, date), type of service being purchased, and health-related data including information about your health history. Some forms may also include date of birth, address, country of residence, telephone, and email. Medispa doctors may take additional notes and photos before, during, and after the service pursuant to obtaining your explicit consent. Your photo will be taken in the course of the medispa services (such as BOTOX® Cosmetic) provided to you. We will also request your explicit consent to use your photo for promotional activities. We would also document any case details in the event you were involved with a health-related or social incident that required documentation under applicable law.
2.1 IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of an agreement we have with you and you fail to provide that data when requested, we may not be able to provide the service you have requested as we need certain information, particularly in respect of your health, to ensure the requested service is suitable for you.
3. How we use your personal data
We will only use your personal data when the law allows us to. We have a contractual necessity to use your personal data to fulfill our obligations to you and the cruise line or resort in order to provide the service you have requested. We also have a legitimate interest in using your personal data to determine whether the service you have requested is suitable for you or to suggest suitable alternatives to you. We may also use your personal data if you have an adverse reaction to our service to analyze whether the service may have caused the reaction and to deal with a claim by you, if any.
We will only process special category personal data (i.e. data relating to health, race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation) if we have obtained your prior explicit consent in accordance with EU data protection laws. You may withdraw this consent at any time by contacting the DPO at [email protected].
No automated decision-making, including profiling, is used when processing your personal data.
4. Disclosures and transfers of your personal data
Other entities within our corporate group;
External third parties such as our insurers, service providers, IT and hosting service providers, legal and risk management advisers, and the resort or cruise line whose vessel you were provided with the service; and
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We make sure all third parties who provide service to, or for, us, enter into an agreement with us and meet our standards for data security. 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. To the extent your personal data is transferred to countries outside the European Economic Area (the “EEA”), such transfers will only be made in accordance with applicable data privacy laws. For further information about these safeguards, please contact our DPO at [email protected].
We share your personal data within our corporate group. This involves transferring your data outside the EEA. To the extent any personal data is transferred from a OneSpaWorld entity or an affiliate within the EEA to a OneSpaWorld entity or affiliate outside the EEA, this transfer is legitimized and your personal data is adequately protected under the terms of the European Union (“EU”) controller-to-controller or controller-to-processor model contract clauses (as applicable) approved by the European Commission.
5. Data Security
We are committed to protecting the personal data you entrust to us. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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.
6. Data retention
We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorized 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 requirements.
The data retention period in respect of the health consultation forms is in part influenced by the rules and regulations governing the pertinent vessel’s operations. OneSpaWorld has implemented a data retention policy which details the periods of time it retains different categories of personal data.
For further information about how long we will keep your personal data, please contact [email protected].
7. Your Rights under the GDPR
7.1 YOUR LEGAL RIGHTS
If you are located in the EU or if the GDPR otherwise applies to the processing of your personal data by us, you may have certain rights as detailed below.
If you wish to exercise any of the rights set out below, please contact our DPO at [email protected].
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 free of charge, however we may charge a reasonable fee if we think that your request is excessive.
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 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 upon your request.
Object to processing of your personal data where we are relying on a legitimate interest 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 (other than storing it) in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where you believe 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 interest 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.
7.2 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 share your request with third parties and may share with them any data related to responding to your request. We may also contact you to ask you for further information in relation to your request to speed up our response.
8. Notification of Changes
If you have any complaints concerning Mandara Spa or One Spa World’s processing of your personal data please contact us at [email protected].
You have the right to lodge a complaint with the supervisory authority which is responsible for the protection of personal data in the country where you live or work, or in which you think a breach of data protection laws might have taken place.
Report of Organizational Actions Affecting Basis of Security
10. Tax Strategy
This strategy applies to World of Wellness Training Limited (FKA Steiner Training Limited) and its UK subsidiaries. World of Wellness Training Limited’s parent company is OneSpaWorld Holdings Ltd.
Tax Strategy Disclosure: Financial year ending December 31, 2018