Our Privacy Policy
www.theskinhub.co.uk (our website) is provided by The Skindustry trading as The Skin Hub (‘we’, ‘our’ or ‘us’).
We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
This version of our privacy policy is primarily written for adults, including parents and guardians of child users. If you are a child (under 18 years old) you are welcome to read this policy if you find it useful, but we recommend you click [here, eg insert link to pages with policies written for different age groups likely to use the website] to see the key information in a form written for kids.
This privacy policy is divided into the following sections:
1. What this policy applies to
2. Personal data we collect about you
3.How your personal data is collected
4. How and why we use your personal data
5. Marketing
6. Who we share your personal data with
7. How long your personal data will be kept
8. Cookies[ and other tracking technologies]
9. Your rights
10. Keeping your personal data secure
11. How to complain
12. Changes to this privacy policy
13. How to contact us
1. What this policy applies to
This privacy policy relates to your use of our website only.
2. Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
• your name, address and contact information, including email address and telephone number
• any delivery addresses specified for your order
• information to check and verify your identity, eg date of birth
• your gender[, if you choose to give this to us
• location data if you choose to give this to us
• your billing information, transaction and payment card or other payment method information
• bank account and payment details
• details of any information, feedback or other matters you give to us by phone, email, post or via social media
• your account details, such as username and login details
• your activities on, and use of, our website
• information about the services we provide to you
• your contact history, purchase history and saved items
• information about how you use our website and technology systems
• your responses to surveys, competitions and promotions
If you do not provide personal data we ask for where it is indicated to be ‘required’ at the point of collection, it will delay or prevent us from providing products to you as explained
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
3. How your personal data is collected
We collect personal data from you:
• directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase products or services via our website, post material to our website and complete customer surveys or participate in competitions via our website, and
• indirectly, such as your browsing activity while on our website; we will [usually] collect information indirectly using the technologies explain in the section on ‘Cookies[ and other tracking technologies]’ below
4. How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
•where you have given consent
•to comply with our legal and regulatory obligations
•for the performance of a contract with you or to take steps at your request before entering into a contract, or
•for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
What we use your personal data for Our reasons?
• Create and manage your account with us [to enable us in providing products to you]
• Conduct checks to identify you and verify your identity or to help prevent and detect fraud against you or us [and to comply with our legal and regulatory obligations]
• Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website Depending on the circumstances:
—your consent as gathered [insert, eg by the separate cookies tool on our website]—see ‘Cookies[ and other tracking technologies]’ below
—where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
5. Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
• contacting us at info@theskinhub.co.uk
•using the ‘unsubscribe’ link in emails
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services] in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
6. Who we share your personal data with
We routinely share personal data with:
• third parties we use to help deliver to you, eg payment service providers, warehouses and delivery companies
• other third parties we use to help us run our business, eg website hosts and website analytics providers
• our bank
• We or the third parties mentioned above occasionally also share personal data with:
•our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
•other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
7. Cookies
A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These insert details, eg help us recognise you and your device and store some information about your preferences or past actions.
8. Your rights
You generally have the following rights, which you can usually exercise free of charge:
• Access to a copy of your personal data, the right to be provided with a copy of your personal data
• The right to withdraw consents If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time
Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
If you would like to exercise any of those rights, please write to us—see below: ‘How to contact us’. When contacting us please:
• provide enough information to identify yourself [(eg your full name, address and customer or matter reference number)] and any additional identity information we may reasonably request from you, and
• let us know which right(s) you want to exercise and the information to which your request relates
8. Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
9. How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
• the Information Commissioner [in the UK]
The [UK’s] Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
10. Changes to this privacy policy
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via [insert mechanism for informing the data subject of changes to the policy, eg by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email].
11. How to contact us
Individuals in the UK
You can contact us by email info@theskinhub.co.uk if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.