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Privacy Policy

Who we are:

jane iredale is based at 12 Priestley Way London NW2 7AP.  We offer world class skin consultancy and training to salons across the UK backed up by a range of market leading skin supplements and products available both to salons and direct to end customers.

We operate conscientiously within the requirements of the General Data Protection Regulations 2018 and the Data Protection Act 2018 and other electronic marketing legislation. We work within the principles of fair data processing, namely:

  • Using information in a way that people would reasonably expect.
  • Thinking about the impact of our processing.
  • Being transparent and ensuring that people know how we’ll use their information.

 

This statement (together with our Terms and Conditions), as may be amended from time to time by updates on this page, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, as data controller and a data processor. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

 

1. What This Privacy Statement Covers

This statement covers how we treat any personal information that we collect and receive either from our website, which for the avoidance of doubt also includes the HUB (“our Website”), or as part of our broader operating processes. 

We do not sell or pass on any personal information about our customers, prospective customers, stockists or employees for marketing purposes without their express consent.  

Some data we collect may be stored on secure third-party platforms and in these cases, we have satisfied ourselves that these are robust. Some data will be shared with third party suppliers to facilitate order fulfilment – for example our finance partner and logistics providers.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy statement.

 

2. Information We Collect

 

Sending You Marketing Materials

Data Type

Belonging To

Lawful Basis / Bases

Special Condition

 

 

Name, address, email etc

End-User Prospects

Consent

n/a

End-User Customers

Consent / Soft Opt-in

n/a

B2B Salon Prospects

Consent / Legitimate Interest

n/a

B2B Salon Customers

Consent / Legitimate Interest

n/a

B2B Distributor Prospects

Consent / Legitimate Interest

n/a

B2B Distributor Customers

Consent / Legitimate Interest

n/a

Training Delegates

Consent / Legitimate Interest

n/a

College Training Delegates

Legitimate Interest / Soft Opt-in

n/a

Using and Sharing Your Data for Marketing Purposes

* see who we share your data with – when you give us consent to – in the section and table immediately below this one

Name and Town

End-User Customers

Consent

n/a

Salon End-User Customers

Consent

n/a

Supplier End-User Customers

Consent

n/a

Details of Skin Condition

End-User Customers

Consent

Consent

Salon End-User Customers

Consent

Consent

Supplier End-User Customers

Consent

Consent

Before and After Photos and Face Scans

 

End-User Customers

Consent

Consent

Salon End-User Customers

Consent

Consent

Supplier End User Customers

Consent

Consent

Details of Treatments

jane iredale End-User Customers

Consent

Consent

Salon End-User Customers

Consent

Consent

Supplier End-User Customers

Consent

Consent

Competitions

Name, address, email etc

Salon End-User Customers

Consent

n/a

Salon Therapist

Consent

n/a

Salon Customers

Consent

n/a

Details of Skin Condition

Salon End-User Customers

Consent

Consent

Before and After Photos and Face Scans

Salon End-User Customers

Consent

Consent

Details of Treatments

Salon End-User Customers

Consent

Consent

Treatment and Medical Information

Name, address, email, health information, face scan and treatments / products administered

End-User Customers

Consent

Consent

Name, address, email, health information, face scan and treatments / products administered

Training Delegate

Consent

Consent

Name, address, email, health information, face scan and treatments / products administered

jane iredale Personnel

Consent

Consent

Name, address, email, health information, face scan and treatments / products administered – and reactions reported

End-User Client and Salon End-User Customers

Consent

Consent

Processing Sales (via telephone, email and the HUB)

Name, address, email etc

jane iredale Customers

Contract

n/a

Payment details

jane iredale Customers

Contract

n/a

Customer service details

jane iredale Customers

Contract

n/a

Business Administration

Name, Address, Email etc

Employees

Contract

n/a

Prospective Recruits

Contract

n/a

Payroll / HMRC Details

Employees

Contract

n/a

Bank Details

Employees

Contract

n/a

Pension Data

Employees

Contract

n/a

Emergency Contacts

Employees

Contract

n/a

Salary

Employees

Contract

n/a

Holiday

Employees

Contract

n/a

Performance

Employees

Contract

n/a

Medical Information

Employees

Consent

Consent / working capacity of the employee

Criminal Record

(driving penalties)

Employees

Consent

Consent / working capacity of the employee

Qualifications and Employment History

Prospective Recruits

Contract

n/a

Qualifications and Employment History

Successful Recruits

Contract

n/a

CCTV

Visitors

Legitimate Interest

n/a

Recorded Calls

jane iredale Customers

Legitimate Interest

n/a

 

 

Sharing Your Data

When you give us consent to use your Data for Marketing Purposes (and specifically give us consent to share it with others) we will share it with:

 

(a) Our UK and Ireland Salon customers

(b) Our international distributors – who will then share it with their salon customers

 

The current list of our international distributors is at the end of this section. 

Please note: the current EU states are Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden.

EEA states are Iceland, Norway and Liechtenstein.

The EEA Joint Committee has ruled that data transfers to the above and also to the following non-EU countries are not “restricted”:

Andorra, Argentina, Guernsey, Isle of Man, Israel, Jersey, New Zealand, Switzerland and Uruguay.

The Commission has also made partial findings of adequacy about Canada and the USA:

  • The adequacy finding for Canada only covers data that is subject to Canada's Personal Information Protection and Electronic Documents Act (PIPEDA). Not all data is subject to PIPEDA. For more details please see the Commission's FAQs on the adequacy finding on the Canadian PIPEDA.
  • The adequacy finding for the USA is only for personal data transfers covered by the EU-US Privacy Shield framework.

The Privacy Shield places requirements on US companies certified by the scheme to protect personal data and provides for redress mechanisms for individuals. US Government departments such as the Department of Commerce oversee certification under the scheme.

BY GIVING US YOUR CONSENT TO SHARE YOUR DATA FOR MARKETING PURPOSES YOU ARE ALLOWING YOUR DATA TO BE TRANSFERRED TO SOME COUNTRIES THAT ARE OUTSIDE OF THE ABOVE ARRANGEMENTS – THIS ACTIVITY IS CALLED A “RESTRICTED TRANSFER”.  WE ARE ABLE TO MAKE THE RESTRICTED TRANSFER BECAUSE OF AN “EXCEPTION” – IE YOUR EXPLICIT CONSENT / PERMISSION FOR US TO DO SO.  FOR YOUR CONSENT TO BE EXPLICIT YOU NEED TO GIVE IT IN AN INFORMED CONTEXT WITH US HAVING TOLD YOU:

  • The identity of the receiver, or the categories of receiver – as per the following list
  • The country or countries to which the data is to be transferred – as per the following list
  • Why we need to make a restricted transfer – ie to share your story with others
  • The type of data – where you have indicated, your before and after photography and face scans, your conditions, treatments received, testimonials and naming convention you have given us (your contact details will not be passed on)
  • Your right to withdraw consent in the future
  • The possible risks involved in making a transfer to those countries outside of the non-restricted areas described where there may not be equivalent or adequate protection for personal data, for example, no local supervisory authority, or no (or only limited) individual data protection or privacy rights.

jane iredale makes you aware as above and also that in the interests of protecting your right to withdraw consent, we have in place data sharing agreements with distributors, who will remove your data if we request them to.

Our current international distributors are:

Country 

Greece & Cyprus

Germany

Canada

Poland

USA

New Zealand

Finland

Russia

Croatia

Belgium

France

Luxembourg

The Netherlands 

Norway

Hong Kong 

Japan

Company Name

Skin Devotion

Care Concept GmbH

Stogryn Sales Ltd

Protea Anti-Ageing SP zoo

jane iredale Mineral Cosmetics

Beauty Care Ltd

Apellis Oy

ERSTA

Dispomed Promet d.o.o

Environ Benelux NV

Environ Benelux NV

Environ Benelux NV

Environ Benelux NV

Skintific AS

STP Mineral Therapy

MRI inc

  

 

Opting Out of Marketing Communications

Subject to paragraph 8, you can follow this link to contact us and unsubscribe to jane iredale marketing emails.

 

IP Addresses and Cookies

We may also collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

We use Google Analytics to analyse the use of this Website. Google Analytics generates statistical and other information about Website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the Website. Google will store this information. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.

We may also obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. Our cookie policy can be viewed here.

Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. You may refuse to accept cookies by activating this setting on your browser, however, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Uses made of the information

 

Uses made of the information

We use this information held about you in the following ways:

  • To ensure that content from our site is presented in the most effective manner to you and to your computer
  • To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
  • To carry out our obligations arising from any contracts entered into between you and us.
  • To allow you to participate in interactive features of our service, when you choose to do so.
  • To notify you about changes to our service.

We may also contact you by email, post or telephone. Please note that where you have provided sensitive data to us, we shall only use your sensitive data for the purpose for which the data was provided to us.

If you do not want us to use your data in this way, or wish to withdraw your consent for use of the data, you can do so by contacting us via telephone on 0208 450 2020 or email at personalshopper@iiaa.eu.

Please note that at the time you contact us, it may be the case that we no longer process, hold or store your personal information/data as data processor, in which case we would advise you of this and the need to contact the data controller.

 

Disclosure of this information

We may disclose your personal information to third parties:

  • If jane iredale or substantially all of our assets are acquired by a third party, in which case personal data held by it about our customers, prospective customers, stockists, employees or others will be one of the transferred assets.

 

  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of our customers, prospective customers, stockists or others.

 

  • Our site may, from time to time, contain links to and from the websites of our partner networks, clients, affiliates or other external websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these privacy policies. Before you submit any personal data to our site, you may want to check the policies of our client, for whom we are collecting the data, and whom for your purposes is the data controller. In the absence of any details being listed on our site, you may contact us at or on the details provided below.

 

3. Sharing, Disclosure, and Retention

(a) Sharing. jane iredale does not share, sell, rent or trade personal information with any third parties for marketing or promotional purposes unless express consent has been given (see previously).

 

Where consent has been given, our employees, customers and our customers’ clients are advised to read the second part of section 2 above thoroughly and to check this policy on a regular basis for updates.

 

Without consent, jane iredale does share small quantities of employee data internally for administrative and legal purposes.

It also reserves the right to share data with relevant authorities if compelled to do so to comply with legal obligations.  We will use third party payment processors for card transactions to pay for goods and services but these third parties are authorised to use the data only as necessary to provide these services to us and are prohibited from using your personal information for promotional purposes.

(b) Disclosure. jane iredale may disclose personal information under the following circumstances:

 

  •    In certain situations, we may disclose personal data in response to lawful requests by public authorities, including but not limited to national security or law enforcement requests. We may also disclose your personal information as required by law, such as to respond to court orders, or similar legal processes, to establish or exercise our legal rights or, defend against legal claims, or if in our judgment in such circumstances disclosure is required or appropriate.
  •    If we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our various terms of use, or as otherwise required by law.

 

(c) Retention. We will retain engagement and transactional information relating to customers, stockists and employees for as long as their customer account or employment remains active or as needed to provide our services and where required to comply with our legal obligations, resolve disputes, and enforce our agreements.  We will retain data that facilitates the issuing of marketing materials to customers, stockists, prospective customers and past customers ongoingly until any such time that we receive a request from them to opt-out.

 

4. Confidentiality and Security

We use physical, electronic, and procedural safeguards to protect personal information - Our IT arrangements aspire to “Data Protection by Design” and should be able to detect a significant data breach. Where such a breach could result in discrimination, damage to reputation, financial loss, loss of confidentiality or any other significant economic or social disadvantage we will notify the ICO.   Where a breach is likely to result in a high risk to the rights and freedoms of individual data subjects, we will also notify those concerned directly and at the earliest practical opportunity. We shall then fully investigate a data breach and implement corrective action to prevent recurrence.

By using our services or providing personal information to us, you are consenting to jane iredale communicating with you electronically regarding security, privacy, and administrative issues related to your use of our services. We may post a notice on our Website if a security breach occurs. In these circumstances, we may also send an email to you at the email address you have provided to us.

Data transmissions over the Internet are not 100% secure. Consequently, we cannot guarantee or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we use reasonable efforts to ensure security on our systems.

 

5. Right to Be Informed

We strive to ensure that all those engaging with us are informed of our arrangements for processing personal data through this Privacy Statement which is linked to from our email signatures and Website home page.

 

6. Right of Access

We will respond to data requests within 1 month and will only charge for requests that are manifestly unfounded or excessive. If we have grounds to refuse a request we will inform the data subject and make them aware of their right to complain to the ICO or to seek civil action – again within 1 month of receiving the request.

 

7. Right to Rectification

For personal data obtained directly from a data subject under the legal basis of consent – and obtained indirectly from a data subject under the legal basis of legitimate interest – we will correct any inaccuracies in a data subject’s personal data upon receipt of a request.  For personal data held under the legal basis of “Contract” or “Vital Interests” or “Legal Obligations” we will endeavour to correct the data upon request but may not be able to do so if changing the data may conflict with our legal obligations or disadvantage us in a future legal action.  In cases where we cannot rectify the data for these reasons we shall inform the data subject and make them aware of their right to complain to the ICO or to seek civil action.

 

8. Right to Erasure

For personal data obtained directly from a data subject under the legal basis of consent – and obtained indirectly from a data subject under the legal basis of legitimate interest – we will erase a data subject’s personal data upon receipt of a request / opt-out notification.  For personal data held under the legal basis of “Contract” or “Vital Interests” or “Legal Obligations” we will endeavour to erase data upon request but will not be able to do so if holding the data is necessary to fulfil our legal obligations or may be necessary as evidence in a future legal action involving us.  In cases where we cannot erase the data for these reasons we shall inform the data subject and make them aware of their right to complain to the ICO or to seek civil action.

 

9. Right to Restrict Processing

For personal data obtained directly from a data subject under the legal basis of consent – and obtained indirectly from a data subject under the legal basis of legitimate interest – we will restrict the processing of a data subject’s personal data upon receipt of a request / opt-out notification.  For personal data held under the legal basis of “Contract” or “Vital Interests” or “Legal Obligations” we will endeavour to facilitate the requested restriction upon request but will not be able to do so if restricting the processing of the data prevents us from fulfilling our legal obligations or the current processing of the data may be necessary as evidence in a future legal action involving us.  In cases where we cannot restrict the processing of the data for these reasons, we shall inform the data subject and make them aware of their right to complain to the ICO or to seek civil action.

 

10. Right to Data Portability

For personal data obtained directly from a data subject under the legal basis of consent – we shall provide, upon receiving a request, the data that we hold in a standard, widely accessible format. 

 

11. Right to Object

For personal data obtained directly from a data subject under the legal basis of consent – and obtained indirectly from a data subject under the legal basis of legitimate interest – we will cease to process a data subject’s personal data upon receipt of a request / opt-out notification.

 

12. Changes to this Privacy Statement

jane iredale reserves the right to revise, modify, or update this statement at any time. We will notify you via email about material changes in the way we treat personal data or by placing a prominent notice on this Website.

 

13. Contacting jane iredale

If you have a privacy concern regarding jane iredale, or this statement, you may contact us via personalshopper@iiaa.eu