1.1 Welcome to SkinSpirit’s privacy notice.
1.2 We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data we collect from you both when you visit our website (regardless of where you visit it from) and where we carry out services for you. This privacy notice tells you about your privacy rights and how the law protects you.
1.3 This privacy notice explains how we may collect and process information about:
1.3.1 visitors to our website;
1.3.2 people who purchase our products and services and their employees, consultants, clients or other subscribers to our communications;
1.3.3 job applicants and our current employees; and
1.3.4 third parties who are involved in the chain of our supply of our products (manufacturers and other suppliers).
1.4 Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
2. Purpose of this Privacy Notice
2.1 This privacy notice aims to give you information on how SkinSpirit collects and processes your personal data. We may collect data:
2.1.1 through your use of our website, including any data you may provide through our website;
2.1.2 when you contact us in respect of our products and services;
2.1.3 when you sign up to our updates or other communications;
2.1.4 when you agree to attend any of our events or visit us at events as our guests; or
2.1.5 as set out in paragraphs 1.3.1 to 1.3.4 above.
2.2 Our services sometimes require us to collect data relating to children for example where a product or services are aimed at children. We will process such information relating to children strictly on the basis of our legitimate interests in providing our services balancing the rights of such persons.
2.3 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
SkinSpirit is distributed in the UK by SkinSpirit Limited, a limited liability company incorporated and registered in England and Wales under registered number 05660388 and whose registered office is situated at Unit 20, Trade City, Avro Way, Brooklands, Weybridge, Surrey KT13 0YF is the controller and responsible for our personal data (collectively we will be referred to as “Company”, “we“, “us” or “our” in this privacy notice).
4. Contact Details
Call us on: +44 1932 339 160
Email us at: firstname.lastname@example.org
Find us at: Unit 20, Trade City, Avro Way, Brooklands, Weybridge, Surrey KT13 0YF
5.1 You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (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.
6. Changes to the Privacy Notice
6.1 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.
7. Website Third-Party Links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections through our website 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.
8. The Data We Collect About You
8.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
8.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes your email address and telephone numbers and where you are a private individual client your home address.
Financial Data includes bank account and payment card details and associated information allowing us to verify payment.
Sales Data includes details of products and services you have received from SkinSpirit Ltd.
Product Reaction Data where clients of our customers have an adverse reaction to any of the products we supply we will record data relating to such reaction including descriptions of the reaction, images and details as to how, when and how often the product was applied and any procedures or other relevant information in connection with our assessment of the cause and severity of any reaction.
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 and other technology on the devices you use to access this website.
Profile Data includes preferences, feedback and survey responses.
Usage Data includes information about how you use our website.
Marketing and Communications Data includes your preferences in receiving marketing or other communications from us which are in addition to the services for which you engage us.
8.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
8.4 We routinely collect information about race or ethnicity as part of our services as this will have a bearing on the most suitable products we can provide and and reactions that may arise. Such information is categorised as a Special Category of Personal Data about you (special categories includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about criminal convictions and offences.
8.5 When you let us know of information which is special category personal data for the purpose of us providing the most appropriate product or services or for monitoring our workplace diversity or when we are required to receive this data as part of our services, you we process this data to perform our contract with you and provide our services and you consent to us processing it in order to perform the services. Where such information is received about non clients for the purpose of our services, we will process it on the basis of our legitimate interests in providing our services and on the basis in some cases the processing is necessary for the establishment, exercise or defence of legal claims, in others the information may be made public.
9. 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 services). In this case, we may have to cancel the service you require but we will notify you if this is the case at the time.
10. How is Your Personal Data Collected?
10.1 We use different methods to collect data from and about you including through:
10.2 Direct interactions. You may give us your Identity, Contact, Product Reaction and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
10.2.1 request information about our products and services;
10.2.2 subscribe to our newsletters, updates, events or other news;
10.2.3 complete a survey; or
10.2.4 give us some feedback.
10.3 On occasions, an individual’s personal data may be given to us by our customers regarding their clients for the purposes of us providing or improving our products and services. For example details relating to a Product Reaction or frequency of use. We will record such information as is necessary for the products and services and use the information solely in connection with the supply of products and the provision of our services, which is our legitimate business interest. We may for the purposes of analysis or updating our suppliers pass this information to overseas organisations. Where we do so, the information will be anonymised as far as is possible.
10.5 Technical Data from the following parties:
i) analytics providers such as Google based within or outside the European Economic Area; and
ii) search information providers credit providers based inside the European Economic Area.
11. How We Use Your Personal Data
11.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
11.1.1 where we need to carry out our services such as training pursuant to our agreement with you which we have or are about to enter into.
11.1.2 where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests are in supplying you with our products and services and in promoting or furthering our products and services.
11.1.3 where we need to comply with a legal or regulatory obligation.
11.1.4 generally we do not rely on consent as a legal basis for processing your personal data but may do so for our communications to existing customers or business contacts as at 25 May 2018 where consent is required under the Privacy and Electronic Communications (EC Directive) Regulations 2003. Where we rely on consent, you have the right to withdraw consent to marketing at any time by contacting us.
11.1.5 as set out in paragraphs 8.5 and 10.3.
12. Purposes for Which We Will Use Your Personal Data
12.1 We have set out below, in a table format, a description of all the ways we plan to use 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.
12.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
The table below lists the cookies we collect and what information they store.
|Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer or website user||
|Performance of a contract with you|
To manage our relationship with you which will include:
(a) Processing your details for payment
(c) Asking you to give feedback at the end of a transaction or piece of work
Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To register and manage our relationship with you as a business contact||
Marketing and Communications
|Necessary for our legitimate interests (to keep our records updated and to communicate with you for the purpose of providing our services or matter reasonably to be expected in connection with our services)|
|To enable you to complete a survey or enter into a competition||
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
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)
Necessary to comply with a legal obligation
|To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you||
Marketing and Communications
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)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
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)
We provide you with choices regarding certain personal data uses, particularly around marketing. You will receive marketing communications from us if you have requested information from us or signed up for such communications and, in each case, you have not opted out of receiving that marketing.
14. Opting Out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
16. Change of Purpose
16.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
16.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
16.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
17. Disclosures of Your Personal Data
17.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 12
17.1.1 External Third Parties as set out in the Glossary.
17.1.2 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.
17.2 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.
18. International Transfers
We do not transfer your personal data outside the European Economic Area other than for the purpose of analysing any Product Reactions and will anonymise such data as far as possible.
19. Data Security
19.1 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.
19.2 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.
20. Data Retention
20.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
20.2 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 requirements.
20.3 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
20.4 In some circumstances you can ask us to delete your data: see Request Erasure below for further information.
20.5 In some circumstances we may 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.
21. Your Legal Rights
21.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below after the Glossary please contact us.
21.2 No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
21.3 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.
21.4 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may 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.
22. Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
23. Third Parties
External Third Parties
23.1 Service providers acting as processors based in the United Kingdom and European Economic Area who provide IT and system administration services.
23.2 Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
23.3 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom.
YOUR LEGAL RIGHTS
23.4 You have the right to:
23.4.1 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.
23.4.2 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.
23.4.3 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, at the time of your request.
23.4.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) 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.
23.4.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where 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 grounds to use it.
23.4.6 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.
23.4.7 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.