Please read this policy carefully before using this site.
This privacy notice provides you with details of how we collect and process your personal data through your use of our site, TheSkincareEdit.com.
By providing us with your data, you warrant to us that you are over 13 years of age.
The Skincare Edit is the data controller and we are responsible for your personal data (referred to as "we," "us" or "our" in this privacy notice).
Name: The Skincare Edit
Email address: firstname.lastname@example.org
Mailing address: 500 King Street West, Suite 300, Toronto, ON M5V 1L9 Canada
It is important that the information we hold about you is accurate. Please let us know if your personal information changes by emailing us at email@example.com.
2. Personal Data We Collect and How We Use It
Personal data means any information capable of identifying an individual. It does not include anonymized data.
We may process the following categories of personal data about you:
- Communication data: This includes any communication that you send to us, whether through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you; for record-keeping; and for the establishment, pursuance or defence of legal claims. Our lawful grounds for this processing are our legitimate interests, which in this case are to reply to communications sent to us; to keep records; and to establish, pursue or defend legal claims.
- Customer data: This includes data relating to any purchases of goods and/or services, such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful grounds for this processing are the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- User data: This includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you; to ensure the security of our website; to maintain back-ups of our website and/or databases; and to enable publication and administration of our website, other online services and business. Our lawful grounds for this processing are our legitimate interests which in this case are to enable us to properly administer our website and our business.
- Technical data: This includes data about your use of our website and online services, such as your IP address; your login data; details about your browser; length of visit to pages on our website; page views and navigation paths; details about the number of times you use our website; time zone settings; and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our website and other online services; to administer and protect our business and website; to deliver relevant website content and advertisements to you; and to understand the effectiveness of our advertising. Our lawful grounds for this processing are our legitimate interests which in this case are to enable us to properly administer our website and our business; to grow our business; and to determine our marketing strategy.
- Marketing data: This includes data about your preferences in receiving marketing from us and our third parties, and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways; to deliver relevant website content and advertisements to you; and to measure or understand the effectiveness of this advertising. Our lawful grounds for this processing are our legitimate interests which in this case are to study how customers use our products and services; to develop products and services; to grow our business; and to decide our marketing strategy.
- We may use customer data, user data, technical data and marketing data to deliver relevant website content and advertisements to you (including Facebook advertisements or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful grounds for this processing are our legitimate interests which are to grow our business. We may also use such data to send other marketing communications to you. Our lawful grounds for this processing are either consent or legitimate interests (namely to grow our business).
We do not collect any sensitive data about you. Sensitive data refers to data that 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.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at firstname.lastname@example.org. In case we need to use your details for an unrelated new purpose, we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision-making or any type of automated profiling.
3. How We Collect Personal Data
We may receive data from third parties such as analytics providers (such as Google based outside the EU); advertising networks (such as Facebook based outside the EU); search information providers (such as Google based outside the EU,); and providers of technical, payment and delivery services (such as data brokers or aggregators).
We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. Marketing Communications
Our lawful grounds of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications, and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at email@example.com at any time.
If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, etc.
5. Disclosures of Your Personal Data
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report processing activities
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission, which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
7. Data Security
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
To use certain features of this website or its content, you may need a username and password. You are responsible for maintaining the confidentiality of the username and password, and you are responsible for all activities, whether by you or by others, that occur under your username or password and within your account. You agree to notify us immediately of any unauthorized or improper use of your username or password or any other breach of security. To help protect against unauthorized or improper use, make sure that you log out at the end of each session requiring your username and password.
It is your responsibility to protect your own username and password from disclosure to others. We cannot and will not be liable for any loss or damage arising from your failure to protect your username, password or account information. If you share your username or password with others, they may be able to obtain access to your personal information at your own risk.
By using our website and its content, you agree to enter true and accurate information on the website and its content. If you enter a bogus email address, we have the right to immediately deactivate your account.
We will use our best efforts to keep your username and password(s) private and will not otherwise share your password(s) without your consent, except as necessary when the law requires it or in the good faith belief that such action is necessary, particularly when disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to others or interfering with our rights or property.
9. Data Retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
When deciding what the correct time is to keep the data for, we look at its amount; nature and sensitivity; potential risk of harm from unauthorized use or disclosure; and the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances, we may anonymize your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. Your Legal Rights
Under data protection laws, you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction or transfer; to object to processing; to portability of data; and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights here.
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
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, or we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and to 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.
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 if you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. If you do have a complaint, we would be grateful if you would contact us first so that we can try to resolve it for you.
Last Updated: July 2018