This is the Privacy Policy for Urban Massage Limited, with registered address, Ground Floor Left, Dorset House, 27-45 Stamford Street, London, England, SE1 9PY ("Urban Massage", "us", "we" or "our"). It explains how we, as data controller, collect, use and share the information that we receive or collect about you (that may include personal information) though our website at www.urban.co and our UK App "Urban"(collectively referred to as "the Site") which you can use to book massage therapy treatments ("Massage Treatments") and purchase related goods ("Products") (collectively referred to as "the Services"), and through other interactions with us that you may have during the course of our various marketing and other activities. It also explains the rights you as a user of our Services have to control the use of your information. Personal information means any information relating to a natural person that allows that individual to be identified either directly or indirectly from that information. In this Policy we distinguish between users of the Services on whose behalf Massage Treatment bookings are made or on whose behalf Products are purchased who we refer to as "Users" and users of the Services on whose behalf we offer the Massage Treatments who we refer to as Therapists.
Please read this Privacy Policy carefully before you start using the Website.
In addition to this Privacy and Cookies Policy, our website Terms of Use also apply to your use of the Services and are, where relevant, incorporated by reference into this Privacy Policy.
Our primary goals in collecting information are to provide our Services to our Users and Therapists and to enable us to best respond to our Users and Therapists' requests for help or information and to improve our Services and their features and content and to promote our Services both through our website and our app and through our events, newsletters, competitions and promotions where we have your permission to do so.
Relating to both Users and Therapists
Relating to Users only:
Relating to Therapists only:
We will use this information to administer the Services and for internal operations, including troubleshooting, data analysis, testing research and statistical survey purposes. We will also use this information to measure the effectiveness of how we present content and deliver our Services and how we market and advertise. This information will also be used to allow you to participate in the interactive features of our Services, when you choose to do so. It is always your choice whether or not to provide information. If you do not provide certain information however, you may not be able to use certain features of the website or app or be provided with certain Services.
Information may be gathered from our affiliates and third-party sources including without limitation our third-party service providers (such as events, marketing services and payment providers), publicly available data, other companies and referrals.
When you visit the Website we may automatically collect additional information about you, such as the type of internet browser or mobile device you use, any website from which you have come to the Website and your IP address (the unique address which identifies your device on the internet) and your operating system, which are automatically recognised by our web server. You cannot be identified from this information and it is only used to assist us in providing an effective service on the Website and to collect broad demographic information for aggregate use.
We may from time to time collect personal details from available sources, such as LinkedIn, or from a publically available online registry to which you give your details or from your company's website to contact you in our legitimate business interests with business opportunities which we think might be required from you. In our first communication with you, we will identify if we have obtained your information which we use for these purposes from a third party source.
We will use the personal information described above to:
We may review, scan, or analyse your communications on the Urban Platform between the User and the Service provider for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. In some cases, we may also scan, review, or analyse messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyse your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.These activities are carried out based on Urban’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
We have set out in the tables below a description of the ways we use your personal information, the category of information it comes under and the legal basis or bases which we rely on to process it, including where we are relying on our legitimate interests and identifying what those interests are. There may be more than one lawful basis on which we process your information depending on the specific purposes for which we are using the information. Where we rely on legitimate interests we are always careful to balance your privacy rights with those interests.
Please note that these are examples of the kinds of personal information we collect and of the uses we may make of it. We may from time to time collect other types of personal information including and not limited to information you voluntarily give us.
Please contact us if you need more information at [email protected].
Purpose | Type of data | Lawful basis for processing |
---|---|---|
To register a new User | Identity, contact, technical | Necessary for the performance of our contract with you; in our legitimate interests in operating our Services to analyse how our Services are being used and develop these further. |
To identify you as a User when you sign in to your account | Identity, Technical data | Necessary for the performance of our contract with you; in our legitimate interests in operating our Services to analyse how our Services are being used and develop these further. |
To process and deliver a massage request from a User | Identity, contact, profile data, assessment data, location data, technical data, transaction data, operational data | Necessary for the performance of our contract with you; in our legitimate interests in operating our Services to analyse how our Services are being used and develop these further. |
Managing collection of payment for Massage Treatments booked by Users on behalf of Therapists or Products purchased by Users on behalf of Retailers | Identity, contact, financial data, transaction data, operational data | Necessary for performance of the contract with Users, Therapists and Retailers |
Assisting Users with queries and problems in live chats on site | Technical data, operational data, identity, contact | Necessary for the performance of the contract with our Users;, in our legitimate interests to resolve problems to ensure our Services run as smoothly as possible to increase User satisfaction |
To administer and protect the website and app and Services (including troubleshooting, data analysis, testing and system review) | Identity, contact, technical data | In our legitimate interests to run our website, app and services, manage administration and IT services and safeguard network security |
To manage our relationship with Users by sending emails to confirm bookings for Massage Treatments or cancellations of bookings or Products purchased | Identity, contact, technical data, transaction data | Necessary for the performance of a contract with the User; in our legitimate interests in maintaining and improving the running of the Services |
Asking Users to complete ratings reviews and feedback surveys on Therapists and treatments received | Identity, contact, usage, , profile data | In our legitimate interests to understand how Users use, enjoy and rate the Services to ensure Massage Treatment standards are maintained |
Inviting Users to take part in any promotions, events or competitions | Identity, contact, usage data, marketing and communications data | With consent where required by law in or where Users have not objected; in the legitimate interests of the business to encourage Users to use the Services |
To make recommendations and suggestions to Users | Identity, contact data, usage data, profile data, marketing and communications data, aggregated data | In the legitimate interests of the business to develop and grow |
To advertise and market our site and app and services to Users | Usage data, marketing and communications data, aggregated data | With consent where required by law in or where Users have not objected the case of direct marketing email communications ;in the case of analysis and evaluation of our Services and campaigns in the legitimate interests of the business to develop and grow |
To send Users information about products or services, special offers or promotions, events or competitions of carefully selected Business Partners. | Identity, contact, usage, profile, marketing and communications, aggregated data | With consent as required by law, in the legitimate interests of the business to encourage Users to use our Business Partners' Products and Services |
To notify Users about any changes to our website and/or app and /or Products and/or Services | Identity data, contact data | Necessary for the performance of a contract with the User and in the legitimate interests of the business in the smooth running of the Services |
To notify Users of any changes to the Privacy Policy or changes to our Terms and Conditions | Identity data, contact data | Compliance with a legal obligation |
To maintain a blacklist/fraud identity system | Identity data, contact data, financial data, | In the legitimate interests of the business to protect the business from fraud |
To record Treatment Reports by Therapists which could from time to time include health data | Treatment report assessment data (which may includehealth data), information regarding aftercare tips, treatment specifics and wellness information | Consent is required from Users to collect Treatment Reports |
To record Service Notes which are used to provide information to Therapists to deliver treatments | Information provided by users which may include access information | In our legitimate interests to provide Services that are as efficient and smooth running as possible . This information is provided voluntarily. |
To gather location data on Users in order to inform the Therapists of the location in which to perform the treatment | Identity data, contact data, Location data | Necessary to fulfil the contract for services for the User, in our legitimate interests to provide Services that are as efficient and smooth running as possible . If this is collected automatically through your device, you will be asked if you permit us access to your location. We need your location in order to inform the Therapists where the treatment needs to be performed. |
To provide mediation between User and Therapist in the event of a User complaint of unsatisfactory treatment | Identity, contact, assessment, financial data | Necessary to fulfil the contract for services for the User, in our legitimate interests to provide Services |
Purpose | Type of data | Lawful basis for processing |
---|---|---|
To register a new Therapist | Identity, contact, technical | Necessary for the performance of our contract with Therapists,in our legitimate interests in operating our Services |
To identify a Therapist when they sign in to their account | Identity, Technical data | Necessary for the performance of our contract with the Therapist |
To assign and transmit a transmit a Massage Treatment booking to the appropriate Therapist (according to location and/or profile, rating or User choice) | Identity, contact, profile data, assessment data, location data, technical data, transaction data, operational data | Necessary for the performance of the User contract, fulfilling our contract with the Therapist by sending appropriate bookings |
Managing collection of payment by Users for Massage Treatments on behalf of Therapists and management of transfer of payments to Therapists | Identity, contact, financial data, transaction data, operational data | Necessary for performance of our contract with both Therapist and User, (obligation to process payment by User and obligation to collect payment on behalf of the Therapist for Massage Treatments booked by User. |
Assisting Therapists with queries and problems in live chats on site | Identity, contact, Technical data, operational data | Necessary for the performance of the contract with Therapists, in our legitimate interests to resolve problems to ensure the Services run as smoothly as possible to increase User satisfaction |
To administer and protect the site and app and Services (including troubleshooting, data analysis, testing and system review) | Identity, contact, technical data | In our legitimate interests to run our website, app and Services, manage administration and IT services and ensure network safety and security |
To manage our relationship with Therapists by sending confirmatory emails of bookings or cancellations with Users | Identity, contact, technical data, transaction data | Necessary for the performance of a contract with the User, necessary for the fulfilment of a contract with the Therapist, in our legitimate interests in maintaining and improving the running of the Services |
To maintain profiles on Therapists including photograph(s), biography, treatments offered, languages spoken. | Identity, contact, assessment, profile data | Necessary for the performance of a contract with the Therapist and User, in our legitimate interests in maintaining and improving the running of the Services |
To review Therapists use of the App and User experience with the Therapist. For example, we may analyse average ratings obtained from our evaluations, using algorithms applied to ratings and reviews. We take all of the ratings you have received from your past appointments with customers, apply a weighted rating upon them, and use this to display both in your profile and as part of the sorting algorithm when returning a list of therapists available to customers when they are searching/booking. | Number of appointments, User rating review | In our legitimate interests in maintaining and improving the quality and the running of the Services |
Providing Therapists with feedback from Users including results of ratings reviews and feedback surveys | Providing Therapists with feedback from Users including results of ratings reviews and feedback surveys Identity, contact, assessment, profile data | Necessary for the performance of a contract with the Therapist, in our legitimate interests in maintaining and improving the running of the Services |
Inviting Therapists to take part in any promotions, events or competitions | Identity, contact, usage data, marketing and communications data | With consent as required by law, In the legitimate interests of the business to encourage Therapists to use the Services |
To advertise and market our website, app and Services | Identity, contact, Usage, marketing and communications, aggregated data | With consent as required by law, in the legitimate interests of the business to develop and grow |
To send Therapists' information about products or services, special offers or promotions, events or competitions of carefully selected Business Partners. | Identity, contact, usage, profile, marketing and communications, aggregated data | With consent as required by law, in the legitimate interests of the business to encourage Therapists to use our Business Partners' Products and Services |
To notify Therapists about any changes to our website, and/or app and /or Services | Identity, contact data | Necessary for the performance of a contract with the Therapist and in the legitimate interests of the business to ensure the smooth running of the Services |
To notify Therapists of any changes to our Privacy Policy or changes to our contract terms and conditions | Identity, contact data | Compliance with a legal obligation |
To maintain a blacklist/fraud identity system | Identity, contact, financial data, | In the legitimate interests of the business to protect the business from fraud |
To gather location data on Therapists to share with Users to inform them as to when the Therapist may arrive to deliver the Treatments | Identity data, contact data, Location data | Necessary to fulfil the contract for Services for the User, in our legitimate interests to provide Services that are as efficient and smooth running as possible |
To record Treat Reports if a User enables this feature, some Therapist personal data will be captured against this Treatment report. | Identity data | Necessary to fulfil the contract for Services for the User, in our legitimate interests to provide Services that are as efficient and smooth running as possible If this is collected automatically through your device, you will be asked if you permit us access to your location. |
To provide mediation between User and Therapist in the event of a User complaint of unsatisfactory treatment | Identity, contact, assessment, financial data | Necessary to fulfil the contract for services for the User, in our legitimate interests to provide Services |
To monitor correct use by Therapists of our proprietary technology and Users' personal data | Identity, contact, technical, usage data | In our legitimate interests to monitor correct use of our proprietary technology and Users' personal data and for record-keeping purposes |
If you are a Therapist, you are responsible for ensuring that you comply with applicable data protection law in respect of any personal information that you collect about Users in the course of your provision of the Services. Urban Massage does not accept any responsibility for this processing of personal data.
If you are a User, you are responsible for any misuse of personal information that you may collect in the course of your receipt of the Services. Urban Massage does not accept any responsibility for this processing of personal data.
The Site also uses cookies or similar technology to collect information about your access to the Site. Cookies are small text files that include a unique reference code that a website transfers to your device to store and sometimes track information about you. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Site and will last for longer. For more information on the cookies we use, how we use them and how to disable them please see our Cookie Policy.
The Site may, from time to time, make chat rooms, message boards, news groups and/or other public forums available to Users and Therapists. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these and never disclose your personal information.
Protecting the safety of children when they use the internet is very important to us. Our Site and Services are not intended for nor directed towards children and we do not knowingly collect personal information from children. If you believe that your child may have provided us with personal information without your consent, you may alert us at [email protected].
The Site may, from time to time, contain links to external websites. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We have no control over these third parties and we are not responsible for the content of such websites or for the privacy policies or practices of such third parties. You should review the privacy policy of any third party website carefully that you visit.
All payments transactions made through the Services are conducted through our payment providers, Braintree (owned by PayPal), Checkout.com and Shopify. You will be providing credit or debit card information directly to these providers who process payment details, encrypting your credit/debit card information and authorising payment. If you use Braintree or Checkout.com to process your payment, you will stay on our Site / App but will provide your information directly to the payment providers, we only see a tokenised version of the information. If you make a payment using Shopify, you will be directed to Shopify's own website. The processing of your payment information is done so in accordance with these third parties' own privacy policies and terms :
https://www.braintreepayments.com/en-gb/legal/braintree-privacy-policy
https://www.checkout.com/legal/privacy-policy
https://www.shopify.com/legal/privacy
Information that you submit via the Services is sent to and stored on secure servers located inside and outside the European Economic Area (“EEA”), for example in the United States. Where we transfer your information outside the EEA in this way, we will take steps to require that that your privacy rights continue to be protected. By way of example, and as mentioned above, we work with key service providers such as Google, Facebook, Amazon Web Services and Salesforce and we have signed data processing addendums which reflect data transfer mechanisms to provide adequate protection to the personal data transferred outside the EEA.If you would like further information on this, please do contact us.
Where we have your consent, or where you have not objected to receiving (as applicable) we will use your personal information to send you marketing and promotional communications by email about our products/services or to send you feedback surveys and ratings review requests on treatments provided, you. As mentioned above, where we partner and work with carefully selected Business Partners, our email communications may also contain information from our Business Partners.
You can object to further marketing communications at any time by clicking on the unsubscribe link included in each such communication or notify us by email at [email protected].
We need to retain your information (including your personal information, where applicable) for as long as you remain an active user of the Services in order for us to meet our contractual obligations to you, and for such longer periods as are legally required or permitted.
We may need to retain certain personal information even once a User account has been closed for differing periods, depending on the category of personal information concerned, for example, to enforce our terms, for fraud prevention, to identify, issue or resolve any legal claims, for proper record-keeping purposes and/or as required for our business operations or by applicable law.
We may also retain certain personal information following any objection indicated by you to receiving Urban Massage marketing communications for the purpose of ensuring that your wishes continue to be respected and we do not to contact you further.
We may also retain aggregated information beyond this time for research purposes and to help us to develop and improve Services. You cannot be identified from aggregate information retained or used for these purposes.
You have the right under certain circumstances:
If your request or concern is not satisfactorily resolved you may approach the local data protection authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html). In the UK this is the Information Commissioner (https://ico.org.uk/).
We may change this Privacy Policy from time to time. If a revision is material we shall notify you before they take effect either through the Site or by sending you a notification (as required). Any such material changes will only apply to personal information collected after the revised Privacy Policy takes effect.
Please submit any questions or concerns regarding our Privacy Policy or any questions about the security of our Site or Services to:
Giles Williams
Re: Privacy Policy
Urban HQ
Ground Floor Left
Dorset House
27-45 Stamford Street
London
SE1 9PY
This Privacy Policy was last updated on 27 August 2020