Privacy Policy

Updated 24th May 2018

This is our updated Privacy Policy, which sets out how we handle your personal information if you’re a Skin Matters client or visitor to our website, in accordance with the General Data Protection Regulations (GDPR), effective from 25th May 2018.

These regulations aim to increase the accountability of organisations who handle personal data. Individuals are granted specific rights regarding their personal information, and how it is collected, stored, used, shared and protected. You can read more about the GDPR requirements on the Information Commissioner’s Office website.

We’ve tried to make this policy as transparent and ‘readable’ as possible. If you don’t understand any part of it, think that something in this policy is wrong or missing, or have any questions regarding your personal data, please contact us.

Definitions

  • We, us  – this business (Skin Matters) and the people directly involved in running it.
  • Policy – this Privacy Policy.
  • Our website or site – this website.
  • Client – any person who uses our services.
  • Visitors – any person who visits our website or social media profiles.
  • Our services  – bespoke beauty and skin health treatments.
  • Our products – range of skin care products, usually sold in person to clients.

The type of personal information we collect

  • Names and email addresses via a contact form on our website.
  • Name and phone number when someone makes a general enquiry by phone.
  • Name, phone number, email address and relevant medical or skin health history when someone attends an initial consultation and becomes a client.
  • IP addresses, location (by country), browser type and other web analytics data when someone visits our website.
  • Basic contact details (usually name and email adddress) when we run online competitions or interactive promotions our blog, Facebook page or other social media accounts.
  • Public profile name and other information when someone comments on or otherwise interacts with a post on one of our social media accounts.
  • Name and email address and marketing preferences when someone subscribes to our newsletter.
  • Name, address, phone number, email address and work and/or education history when someone applies for an employment or training position with us.

How we collect personal information

We collect personal information directly when you provide it to us – as described above; automatically as you navigate through the website, or when you interact with social media or blog posts.

Personal information we collect about you from others

Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular:

  • Financial and/or transaction details from our payment provider PaySafe (located in the UK) in order to process or record a transaction.
  • Booking details and communications via our booking System software provider MindBody Inc (based in the US) used to manage client appointments.
  • Third party service providers (like Google and Facebook) who are located in the US, which may provide basic browsing information as you navigate through our site, or other information when you interact with our social media profiles. This information varies and is controlled by that service provider or as authorized by you via your privacy settings at that service provider.

Why we collect your personal information

We need to collect and use your personal information:

  • To fulfil our contractual obligations to our clients and to carry out our services.
  • To process payments for fulfilled contractual services..
  • To verify identity and prevent unauthorised access to to website or services.
  • To monitor visitor traffic to our site and to secure our site against malicious human and automated visitors.

We also need to collect personal information where this is necessary for purposes which are in our legitimate interests.

These interests include:

  • Operating our website and our business.
  • Protecting our website.
  • Protecting our staff.
  • Providing you with services described on the website and other marketing materials.
  • Verifying your identity when you sign in to any of our online services.
  • Responding to enquiries, and helping facilitate the resolution of any disputes.
  • Updating you with operational news and information about our services e.g. to notify clients about new services or holiday dates.
  • Carrying out technical analysis to determine how to improve our website and the services we provide, or resolve any technical problems.
  • Monitoring activity on this websites, in order to identify potential fraudulent activity and prevent spam and ‘hacking’.
  • To ensure compliance with our website Terms of Use.
  • Managing our relationship with you, e.g. by responding to your comments or queries submitted to us or asking for your feedback.
  • Managing our legal and operational affairs (including, managing risks relating to safeguarding and content and fraud matters).
  • Improving our products and services.
  • Providing general administrative and performance functions and activities.

We may be required by law to collect personal information when responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.

When we disclose your personal information

We do not usually need to disclose your personal information to any third party in order to deliver our services.

There may be certain circumstances in which we need to disclose your personal information, for example:

  • To regulators and government authorities in connection with our compliance procedures and obligations.
  • A purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase.
  • A third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity.
  • A third party, in order to enforce or defend our rights, or to address financial or reputational risks.
  • A rights holder in relation to an allegation of intellectual property infringement or any other infringement.
  • Other recipients where we are authorised or required by law to do so.

Where we transfer and/or store your personal information

We are based in the United Kingdom, and your local data is processed and stored in a single location (a private office) in the United Kingdom. Personal data provided to third parties (eg our payment or bookings system providers) are stored according to their Privacy Policies and procedures.

How we keep your personal information secure

We do our best to keep all information secure, especially any personal data. Most of our data is kept in digital form. All digital personal information (including names, addresses, telephone numbers and email addresses) is stored on a protected local computer network, to which only people engaged in activities directly relating to the business have access. The internet connection, local area network (LAN), computer terminals and documents containing personal data are all password protected and never routinely shared via email or stored on ‘cloud’ services.

Our website is secured by an SSL Certificate which uses end to end encryption on every page. We have a website security package which includes a firewall, ‘brute force’ attack protection, file system and database enhanced security and an instant alert system which notifies us of any unexpected changes to our website files and database.

Our website and mail servers are located in a UK-based data centre with biometric passkeys and 24/7 security.

We also collect personal data in hard copy form, usually during an initial consultation when we’re collecting information in order to assess a client’s skin health condition, and provide the requested or recommended series of treatments. These documents are kept in a single private office location, in a locked cabinet to which only Skin Matters personel have access.

Third Party Services

We occasionally use third party services as part of providing services to our clients. Some of these have access to your personal information – either provided by us or by you. These third parties include:

PaySafe – payment processing provider. Our clients have the option to make payments via Paysafe. You can read the Paysafe Privacy Policy here.

MindBody Inc – our booking system provider. You can read the MindBody Privacy Policy here.

AwStats – website analytics application. AwStats is an ‘open source’ log file analyser, which operates on the website server, collecting and logging website traffic information. It does not use cookies, or any kind of tracking code, and collects anonymous data which helps us to monitor visitor traffic to our website.

Fredd Design – our graphic design, web development and hosting provider. Sometimes maintenance and development work requires the company to have temporary access to website and mailboxes servers, and website databases, which contain emails and contact form submission data. The Skin Matters website is managed by a single Fredd Design web developer. You can read the Fredd Design Privacy Policy here.

Communications regarding your personal information

Where we have your consent to do so (e.g. if you have subscribed to our email newsletter), we send you communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided at the bottom of the communication itself.

You also have choices about cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our sites may not work properly in your case. You can find out more about what cookies are at the All About Cookies website.

Cookies and web analytics

We use AwStats (which does not use cookies or tracking code) to collect anonymous web traffic data, such as:

  • Your IP address or proxy server IP address
  • The domain name you requested
  • The name of your internet service provider is sometimes captured depending on the configuration of your ISP connection
  • The date and time of your visit to the website
  • The length of your session
  • The pages which you have accessed
  • The number of times you access our site within any month
  • The file URL you look at and information relating to it
  • The website which referred you to our site
  • The operating system which your computer uses.

We may sometimes place cookie-based analytics and tracking code (eg Google Analytics tracking code and Facebook ‘pixels’) on our website, and there are cookies within the website framework, and for this reason we include a ‘Cookies Declaration’ (in accordance with the PECR 2011).

How you can access your personal information

Under the GDPR guidelines, you have the right to:

  • Request access to the personal data we hold about you.
  • Request corrections of any errors in that data.
  • Request erasure of the personal data we hold about you.

To make any of these requests, please contact us via our contact form.

Information about children

Our website and services are not suitable for children under the age of 16 years, so if you are under 16 we ask that youdo not use our website or give us your personal information.
If you are from 16 to 18 years, you can browse our site but you’ll need the supervision of a parent or guardian. We don’t accept clients under the age of 18. It’s the responsibility of parents or guardians to monitor their children’s use of our website.

Information you make public or give to others

If you make your personal information available to other people, we can’t control or accept responsibility for the way they will use or manage that data. There are lots of ways that you can find yourself providing information to other people, like when you post a public message on a forum thread, share information via social media, or make contact with another via a website or directly by email. Before making your information publicly available or giving your information to anyone else, think carefully. If you’re sharing information via another website, check the privacy policy for that site to understand its information management practices.

How long we keep your personal information

We retain your personal information for as long as is necessary to provide the services to you and others, and to comply with our legal obligations. If you no longer want us to use your personal information or to provide you with our services, you can request that we erase your personal information and close your Skin Matters account. Please note that if you request the erasure of your personal information we may retain some information from deleted accounts (in a static, archived form) as necessary to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Use and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

When we need to update this policy

We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices. When we do change the policy, we’ll notify you about the changes, via our newsletter (if we have your consent) or here on this page. A copy of the latest version of this policy will always be available on this page.

How you can contact us

If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact us via our contact form. Alternatively, you can write to us at: Skin Matters, Bodyism, 222-224 Westbourne Grove, London W11 2RH.

Reporting Concerns

If you have unresolved concerns you also have the right to complain to data protection authorities. In the UK, the relevant authority is the Information Commissioner’s Office.

We’re really glad you made it to the end of this policy, because knowing how your personal information is used is a step towards keeping your data secure!