Privacy Policy

Introduction

Welcome to Skin & Tonic's privacy policy.

This privacy policy will inform you as to how we look after your personal data when you visit our website at skinandtonic.uk (“Website”) (regardless of where you visit it from) our online shops and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Skin & Tonic collects and processes your personal data through your use of our Website and online shops, including any data you may provide through our website when you sign up to our newsletter, purchase a product or service, take part in a competition or provide a review.

The Website and our shops are not intended for children and we do not knowingly collect data relating to children.

Controller

Nashes Beauty Ltd t/a Skin & Tonic is the controller and responsible for your personal data (collectively referred to as “Skin & Tonic”, "we", "us" or "our" in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager by email using hello@skinandtonic.uk.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 14 October 2023.

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.

2. 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, social media username and title.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes bank account and / or payment card details.

• 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.

• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products). In this case, we may have to cancel an order for a product you have with us but we will notify you if this is the case at the time.

3. 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 by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• order our products;
• create an account on our Website or online shops;
• subscribe to our newsletter;
• request marketing to be sent to you;
• give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.

• Third parties or publicly available sources. We may receive personal data about you from various third parties.

4. 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.
• 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.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although 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.

Purposes for which we will use your personal data

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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges, and administer returns (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
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	(a) Identity (b) Contact (c) 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)
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 grouprestructuring exercise) (b) Necessary to comply with a legal obligation
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)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

i) Promotional offers from us

We may use your Identity, Contact and Technical Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

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

ii) Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

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 purchase or other transactions.

Cookies

What are cookies?

Cookies are files or pieces of information that may be stored on your computer (or other internet-enabled devices, such as a smartphone or tablet) when you visit the Website. A cookie will usually contain the name of the website from which the cookie has come from, the "lifetime" of the cookie (i.e. how long it will remain on your device) and a value, which is usually a randomly generated unique number.

What do we use cookies for?

We use cookies to make the Website easier to use and to better tailor our web presence and products to your interests and needs. Cookies may also be used to help speed up your future activities and experience on the Website. We also use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our web properties and to help us improve web structure and content. We cannot identify you personally from this information.

How can I control or delete 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 our Website or online shops may become inaccessible or not function properly. For more information about the cookies we use, please see below.

If you do not agree to our use of cookies, you should set your browser settings accordingly or not use the Website. Please be aware that if you disable the cookies that we use, this may impact your user experience while using the Website.

If you use different devices to view and access the Website (e.g. your computer, smartphone, tablet etc.), you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.

What cookies do we use?

Please see the section headed “Default Cookies” at the end of this Privacy Policy.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above:

• Service providers acting as processors who provide IT and system hosting and administration services.

• Third party delivery services acting as controllers.

• Professional advisers, acting as controllers, including lawyers, bankers, auditors and insurers based in the UK who provide banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities based in the United Kingdom, acting as controllers, who require reporting of processing activities in certain circumstances.

• 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 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.

6. International transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. 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.

8. Data retention

How long will you use my personal data for?

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

In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

Under certain circumstances, you also have the following rights under data protection laws in relation to your personal data.

You have the right to:

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.

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.

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.

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.

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.

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.

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 hello@skinandtonic.uk 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 isclearly unfounded, repetitive or excessive. Alternatively, we could 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 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.

Time limit to respond

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.

Default Cookies

The default cookies in Adobe Commerce and Magento Open Source are classified as Exempt / Non-Exempt to help merchants meet the requirements of privacy regulations such as the GDPR. Merchants should use this information as a guide, and consult with legal advisors to update their Privacy and Cookie Policies as part of a comprehensive privacy regulation compliance strategy.

The following cookies are used by Commerce “out of the box” for on-premise and cloud installations. These cookies may be required by functionality that is explicitly requested by the customer. To learn about the lifetime of session cookies, see Session Lifetime.

Some of these cookies may provide configuration options, including enable/disable, as needed.

Requested functionality cookies (exempt)

add_to_cart

(Adobe Commerce only) Used by Google Tag Manager. Captures the product SKU, name, price and quantity removed from the cart, and makes the information available for future integration by third-party scripts.

guest-view

Stores the Order ID that guest shoppers use to retrieve their order status. Guest orders view. Used in Orders and Returns widgets.

Is Secure? No
HTTP Only: Yes
Expiration Policy: Session
Module: Magento_Sales

login_redirect

Preserves the destination page that was loading before the customer was directed to log in. A login redirect is used with the mini cart for logged-in customers if the Display Mini Cart configuration option is set to Yes.

Is Secure? No
HTTP Only: No
Expiration Policy: Session
Module: Magento_Customer

mage-banners-cache-storage

(Adobe Commerce only) Stores banner content locally to improve performance.

mage-messages

Tracks error messages and other notifications that are shown to the user, such as the cookie consent message, and various error messages. The message is deleted from the cookie after it is shown to the shopper.

There is not an option to disable this cookie.

Is Secure? No
HTTP Only: No
Expiration Policy: Duration 1 year. Cleared on frontend when the message is displayed to the user.
Module: Magento_Theme

mage-translation-storage (local storage)

Stores translated content when requested by the shopper. Used when Translation Strategy is configured as “Dictionary (Translation on Storefront side)”.

Is Secure? No
HTTP Only: No
Expiration Policy: Per local storage rules
Module: Magento_Translation

mage-translation-file-version (local storage)

Tracks the version of translations in local storage. Used when Translation Strategy is configured as Dictionary (Translation on Storefront side).

Is Secure? No
HTTP Only: No
Expiration Policy: Per local storage rules
Module: Magento_Translation

product_data_storage (local storage)

Stores configuration for product data related to Recently Viewed / Compared Products.

Is Secure? No
HTTP Only: No
Expiration Policy: Per local storage rules
Module: Magento_Catalog

recently_compared_product (local storage)

Stores product IDs of recently compared products.

Is Secure? No
HTTP Only: No
Expiration Policy: Per local storage rules
Module: Magento_Catalog

recently_compared_product_previous (local storage)

Stores product IDs of previously compared products for easy navigation.

Is Secure? No
HTTP Only: No
Expiration Policy: Per local storage rules
Module: Magento_Catalog

recently_viewed_product (local storage)

Stores product IDs of recently viewed products for easy navigation.

Is Secure? No
HTTP Only: No
Expiration Policy: Per local storage rules
Module: Magento_Catalog

recently_viewed_product_previous (local storage)

Stores product IDs of recently previously viewed products for easy navigation.

Is Secure? No
HTTP Only: No
Expiration Policy: Per local storage rules
Module: Magento_Catalog

remove_from_cart

(Adobe Commerce only) Used by Google Tag Manager. Captures the product SKU, name, price, and quantity added to the cart, and makes the information available for future integration by third-party scripts.

stf

Records the time messages are sent by the SendFriend (Email a Friend) module.

Is Secure? Yes
HTTP Only: Yes
Expiration Policy: Session
Module: Magento_SendFriend

X-Magento-Vary

Configuration setting that improves performance when using Varnish static content caching.

Is Secure? Yes
HTTP Only: Yes
Expiration Policy: Based on PHP setting session.cookie_lifetime
Module: Magento_PageCache

form_key

A security measure that appends a random string to all form submissions to protect the data from Cross-Site Request Forgery (CSRF).

Is Secure? No
HTTP Only: No
Expiration Policy:

PHP: Based on PHP setting session.cookie_lifetime
JS: Session

Module: Page Cache

mage-cache-sessid

The value of this cookie triggers the cleanup of local cache storage. When the cookie is removed by the backend application, the Admin cleans up local storage, and sets the cookie value to true.

Is Secure? No
- HTTP Only: No
- Expiration Policy: Session
- Module: Magento_Customer
mage-cache-storage

Local storage of visitor-specific content that enables ecommerce functions.
- Is Secure? No
- HTTP Only: No
- Expiration Policy: Session
- Module: Magento_Customer, Magento_Persistent
mage-cache-storage (local storage)

Local storage of visitor-specific content that enables ecommerce functions.
- Is Secure? No
- HTTP Only: No
- Expiration Policy: Session
- Module: Magento_Customer, Magento_Persistent, Magento_NegotiableQuote
mage-cache-storage-section-invalidation (local storage)

Forces local storage of specific content sections that should be invalidated.
- Is Secure? No
- HTTP Only: No
- Expiration Policy: Per local storage
- Module: Magento_Customer
persistent_shopping_cart

Stores the key (ID) of persistent cart to make it possible to restore the cart for an anonymous shopper.
- Is Secure? Yes
- HTTP Only: Yes
- Expiration Policy: Based on Persistent Shopping Cart - Persistence Lifetime (seconds) configuration
- Module: Magento_Persistent
private_content_version

Appends a random, unique number and time to pages with customer content to prevent them from being cached on the server.

It is set in multiple places: in PHP, in JavaScript as a cookie, and in JavaScript to local storage.

For HTTP Only=Yes (based on request), it means that the cookie is secure if set during HTTPS request and unsecure if set during HTTP request.
- Is Secure? Yes (based on request), No
- HTTP Only: No
- Expiration Policy: Based on Persistent Shopping Cart - Persistence Lifetime (seconds) configuration

Privacy Policy

Requested functionality cookies (exempt)

add_to_cart

guest-view

login_redirect

mage-banners-cache-storage

mage-messages

mage-translation-storage (local storage)

mage-translation-file-version (local storage)

product_data_storage (local storage)

recently_compared_product (local storage)

recently_compared_product_previous (local storage)

recently_viewed_product (local storage)

recently_viewed_product_previous (local storage)

remove_from_cart

stf

X-Magento-Vary

form_key

mage-cache-sessid

mage-cache-storage

mage-cache-storage (local storage)

mage-cache-storage-section-invalidation (local storage)

persistent_shopping_cart

private_content_version

section_data_ids

store

mage-banners-cache-storage - local storage