Skin Rocks - Privacy Policy

Privacy Policy

Welcome to our privacy policy. Our goal is to build a network or community of people who are as passionate about skincare as we are.  Our community comprises those who follow and participate with Caroline Hirons’ blog and social activities and those who buy from our Shop Floor and Skin Rocks retail platforms.  

The policy is the “Fair Processing Statement” for:

  • carolinehirons.com (Blog Site);
  • the retail site shopfloor.carolinehirons.com; 
  • the retail site Skin Rocks (www.skinrocks.com) together the “Retail Sites”;

The Blog Site; Retail Sites are referred to as “Platforms”.

The Blog Site; and www.carolinehirons.com are operated by Caroline Hirons Limited (CRN 09131128) and www.skinrocks.com is operated by Skin Rocks Limited (CRN 11155429). 

In order to utilise each of these Platforms and their services you may have to register with us by opening an account (Account). Each Platform will require a separate Account to be opened. The personal data we collect and the registration process is the same. As each platform offers different functionality or is hosted by a different company you have to register for each service. Please note that data is shared and from time to time either company will market to the customers and connections of the other. We ask for your express consent but notwithstanding that this is in the legitimate interest of both companies as the companies’ offering are complimentary and you are free to opt out. 

Please note that the two companies are separate and each has separate ICO registrations;  (ZA799464 Caroline Hirons Limited and ZB099465 Skin Rocks Limited). They are independent “data controllers”. Save for the Blog Site the processing of personal data by both companies is identical so the policy covers both companies. For the purposes of this policy reference to both companies will be to CH Ltd. 

CH Ltd. respects your privacy and is committed to protecting your personal data. This policy informs you about how we look after your personal data when you interact with us (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. In particular, the policy includes how CH Ltd. collects and processes your personal data, including any data you may provide through this website when you sign up to our newsletter; purchase a product or participate in any ancillary activity through our website. Please note the following:

  1. the Platforms are not intended for children and we do not knowingly collect data relating to children;
  2. we do not transfer data to outside the UK; EEA or Switzerland;
  3. we do not profile or use automated decision making;
  4. we keep our privacy policy under regular review. This version was last updated on 02/08/2021; 
  5. the Platforms may include links to third-party websites, plug-ins and applications. These may include affiliate links which will access the sites of third parties which will offer for sale products which are similar to those on our Retail Sites. We do not control these third-party websites and are not responsible for their privacy statements - we encourage you to read the privacy policy of every website you visit.

 

IMPORTANT INFORMATION

If you have any questions about this privacy policy or our privacy practices, please contact molly@carolinehirons.com. Our privacy manager is Molly Hirons. 

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 (www.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.

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.

1. THE DATA WE COLLECT ABOUT YOU

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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
  • 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 your username and password, purchases or orders made by you, any participation on the Blog Site, your interests, preferences, feedback and survey responses.
  • Usage Data includes information not included above as to how you use the functionality.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 policy.

Unless you share such with others on the Blog Site or you disclose to us on the Retail Sites details of allergies or products/ingredients that provoke or cause irritation skin we do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences. 

2. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data when opening an Account and then using our functionality to (for example): 
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our functionality, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties such as analytics providers such as Google based outside the EU. 
3. HOW WE USE YOUR PERSONAL DATA

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:

  • Where we need to perform the contract we are about to enter into or have entered into with you. The contract is either the purchase of goods from the Retail Sites which is detailed in the Terms of Sale (https://shopfloor.carolinehirons.com/policies/terms-of-service) or participating in the Blog Site which is the Terms of Use (https://www.carolinehirons.com/page-about). 
  • 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. 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 but from time to time we use submissions posted and shared on the Blog Site to assess the product range offered on our Retail Sites.
  • Where we need to comply with a legal obligation.
  • Where you expressly give us your consent for marketing to you. We will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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.

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.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To open your Account

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver any order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

(c) to learn more about which products are popular so our offering can be enhanced. 

To publish and make available your participation on the Blog Site.

        1. Identity
        2. Profile

(a) Performance of a contract with you

(b) Consent (you have volunteered to participate)

(c) legitimate interest – we can use your posts to improve our product selection and information

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(c) Marketing to you regarding CH Ltd. offering 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

(e) consent

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) 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)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

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)

Consent

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

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)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. Please note that as the CH Ltd. offering relates to the choice and use of beauty products and provides ancillary information CH Ltd. may from time contact you with information that it considers maybe of interest to you. 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://skinrocks.com/pages/cookie-policy. 

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.

4. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data as follows: 

  • Third party Payment Providers;
  • Third party partners such as comment sharing facilitators; 
  • Advertising partners;
  • 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 policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We conduct due diligence on their systems and processes. 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.

We are happy to disclose to you on request the identity of the third parties with whom we work. If a third party such as a comment sharing facilitator or an organiser of a promotion asks you to register then that party is a separate data controller solely responsible for handling your personal data.   

5. DATA SECURITY

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.

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. 

6. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.

Our policy is:

By law we have to keep basic information about our customers (including Contact, Identity and Transaction Data) for seven years after they cease being customers for tax and regulatory purposes.

Any data you share with us which is not necessary for the above regulatory purpose (whether participation on the Blog Site or purchase or marketing preferences or otherwise) we will keep for six months after it is posted. 

Most of the cookies we use are persistent and will expire between 30 minutes and two years, depending on their nature. 

7. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

  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.
  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.
  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.
  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.
  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:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  1. 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.
  2. 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.

If you wish to exercise any of the rights set out above, please contact us at info@skinrocks.com. 

  1. 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 could refuse to comply with your request in these circumstances;
  2. 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;
  3. We try to respond to all legitimate requests within one month. Occasionally it could 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.