Privacy Policy | Spa Elite Limited

Spa Elite Limited is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

  1. Data Controller

Spa Elite Limited is the Data Controller for the purposes of UK data protection law.

We are registered with the Information Commissioner’s Office (ICO):

  • Registration Reference: Z189476X
  • Registration Expiry: 14 September 2026
  • Payment Tier: Tier 1

Registered Office:
Spa Elite Limited
Eagle Tower
Montpellier Drive
Cheltenham
Gloucestershire
GL50 1TA

Email: gm@spa-elite.com
Telephone: 03300 101515

  1. Our Lawful Basis for Processing Personal Data

We process personal data under the following lawful bases:

Contractual Necessity

To facilitate and administer temporary assignments that contractors book through our platform, including confirming availability, introducing contractors to clients, managing bookings, processing payments, and maintaining assignment records.

Legitimate Interests

To operate our recruitment and temporary booking business efficiently, match contractors to suitable assignments, maintain client relationships, and ensure service quality. We carry out Legitimate Interest Assessments where appropriate to ensure our processing does not override your rights.

Legal Obligation

To comply with tax, accounting, right-to-work, and other regulatory requirements.

Consent

Where you have opted in to receive marketing communications unrelated to specific assignments. You may withdraw consent at any time.

  1. What Personal Data We Collect

Contractor (Candidate) Data

To provide temporary assignment opportunities via our booking platform, we may collect:

  • Name and contact details
  • Professional qualifications and career history
  • Availability information
  • Assignment and booking history
  • Payment information (including bank details and invoicing details)
  • Right-to-work confirmation documentation where required

Platform Usage Data

When you use our temporary booking application, we collect account activity, booking interactions, assignment history, and system usage data to operate and improve the platform.

Client Data

We collect business contact details of individuals at hiring organisations to facilitate bookings and manage commercial relationships.

Supplier Data

We collect limited information, including contact details and bank information, necessary to manage supplier relationships and payments.

Website Data

When you use our website, we may collect:

  • Information submitted via online forms (name, email, phone)
  • Technical data such as IP address and page interaction data
  • Cookie-based analytics data (subject to consent where required)
  1. Special Category Data

Spa Elite Limited does not intentionally collect or process Special Category Data (such as health information, racial or ethnic origin data, or criminal conviction data) as part of our standard temporary recruitment services. If such information is provided to us voluntarily or inadvertently, it will only be processed where necessary and in accordance with UK data protection law.

  1. How We Collect Your Data

We collect personal data through:

  • Direct registration on our platform
  • Booking activity within our contractor app
  • Communication via email, phone, or social media
  • Submission of information via our website
  • Direct business engagement with clients
  1. Sharing Your Personal Data

We may share personal data where necessary with:

Client Organisations

Where contractors book assignments, relevant professional information is shared with the client hosting the temporary assignment.

Service Providers

Including secure CRM providers, cloud hosting providers, payment processors, IT support services, and software platform providers who support our operations.

Professional Advisers

Including accountants and legal advisers where necessary.

Legal Authorities

Where required by law or regulatory obligation. We do not sell personal data to third parties for marketing purposes.

  1. International Data Transfers

We prioritise storing data within the UK. Where we use service providers located outside the UK, we ensure appropriate safeguards are in place, such as the UK International Data Transfer Agreement (IDTA) or other legally approved mechanisms.

  1. Data Security

We implement appropriate technical and organisational measures to protect personal data from unauthorised access, loss, misuse, or alteration. These measures include secure cloud-based systems, controlled access permissions, encrypted communications, and restricted internal access on a need-to-know basis.

  1. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected.

Contractor Profiles

Contractor profiles are retained for 3 years from the date of last booking activity or meaningful contact. If there has been no meaningful engagement for 3 years, we may contact you to confirm whether you wish to remain active. If we receive no objection, we may retain your profile under our Legitimate Interest basis for a further 3-year period.

Financial Records

Payment, invoicing, and accounting records are retained for a minimum of 6 years in accordance with HMRC and statutory requirements.

Right-to-Work Documentation

Where collected, such records are retained in line with legal obligations. Data that is no longer required is securely deleted or anonymised in accordance with our internal data retention policy.

  1. Automated Decision-Making

We do not carry out automated decision-making or profiling that produces legal or similarly significant effects.

  1. Your Data Protection Rights

Under the UK GDPR, you have the following rights:

  • Right of Access – Request a copy of the personal data we hold about you.
  • Right to Rectification – Request correction of inaccurate or incomplete data.
  • Right to Erasure – Request deletion of your data where there is no lawful reason to retain it.
  • Right to Restrict Processing – Request that we suspend processing in certain circumstances.
  • Right to Data Portability – Request transfer of your data where processing is based on consent or contract.
  • Right to Object – Object to processing carried out under Legitimate Interests.
  • Right to Withdraw Consent – Withdraw consent at any time where processing is based on consent.

To exercise your rights, please contact:

Email: gm@spa-elite.com
Telephone: 03300 101515

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):
www.ico.org.uk

  1. Cookies and Advertising

Our website uses cookies to enhance functionality and analyse traffic. Non-essential cookies, including analytics and advertising cookies, are only placed on your device with your consent via our cookie banner.  We use Google Ads remarketing services, which may display Spa Elite advertisements on third-party websites based on previous website interactions. You can manage your advertising preferences through Google’s Ads Settings.