We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this policy:
We, us, our : - The Nutricosmetic Company Ltd. We are incorporated and registered in England and Wales with company number 11855907 and registered office is at 85 Great Portland Street, London, W1W 7LT, United Kingdom You can contact The Nutricosmetic Company Data Protection Officer at firstname.lastname@example.org
Personal information : - Any information relating to an identified or identifiable individual
Special category personal information ation : - Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation.
We may collect and use the following personal information about you:
• your name, photograph and contact information, including email address and telephone number
• Information to enable us to check and verify your identity, eg your date of birth
• your gender information, if you choose to give this to us
• location data, if you choose to give this to us
• your billing information, transaction and payment card information
• your contact history, purchase history and saved items
• information from accounts you link to us, eg Facebook
• information to enable us to undertake credit or other financial checks on you
• Information about how you use our website, IT, communication and other systems
• your responses to surveys, competitions and promotions
This personal information is required to provide products and services to you for example by way of our websites (e.g. thenutricosmeticcompany.com and thenutricosmeticcompany.co.uk). If you do not provide personal information we ask for, it may delay or prevent us from providing products and services to you.
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:
• from publicly accessible sources, eg Companies House or HM Land Registry;
• directly from a third party, eg:
– sanctions screening providers
– credit reference agencies
– customer due diligence providers
– social media providers such as Facebook
• from a third party with your consent, eg your bank or building society
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for / Our reasons
To provide products and to you : - For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you o : - For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you
Ensuring business policies are adhered to, eg policies covering security and internet use : - For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency,training and quality control : - For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information : - For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business,eg in relation to our financial performance, customer base, product range or other efficiency measures : - For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems : - For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records : - For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns : - To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments : - To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to:
—existing and former customers;
—third parties who have previously expressed an : - For our legitimate interests or those of a third party, ie to promote our business to existing and former customers
interest in our services; : -
—third parties with whom we have had no previous dealings.
Credit reference checks via external credit reference agencies : - For our legitimate interests or those of a third party, ie to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts : - For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations
The above table does not apply to special category personal information, which we will only process with your explicit consent.
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services. We keep a tracking of your spend on our platform to see if you can benefit from our exclusive loyalty programs or offers.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by changing your marketing preferences in “My Account” or by unsubscribing at the bottom of each email received or by writing emailing us - see below: ‘How to contact us’;
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We routinely share personal information with:
• third parties we use to help deliver our products and services to you, eg payment service providers, warehouses and delivery companies;
• other third parties we use to help us run our business, eg marketing agencies, website hosts and the partners and brands we work with;
• third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
• credit reference and anti-fraud agencies;
• courier and delivery companies;
• marketing tools providers that help us to enable our marketing;
• performance marketing and recommendations providers and research companies;
• IT/technology support providers;
• advertisers for marketing purposes; and
• third party service providers to enrich data.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK and EEA’.
We will keep your personal information while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:
• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
To deliver services to you, it is sometimes necessary for us to share your personal information outside the UK and/or European Economic Area (EEA), eg:
• with our offices or other companies within our group located outside the UK/EEA;
• with your and our service providers located outside the UK/EEA;
• if you are based outside the UK/EEA;
• where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law. This means we can only transfer your personal information to a country or international organisation outside the UK/EEA where:
• the European Commission has issued an ‘adequacy decision’ in relation to that country or international organisation; or
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• a specific exception applies under data protection law
These are explained below.
The European Commission has the power to determine whether a country or international organisation provides an adequate level of protection for personal information and, if it does, to issue an ‘adequacy decision’. The effect of such a decision is that personal information can flow from the UK/EEA to that country without any further safeguards being necessary.
It can take several years for the European Commission to issue an adequacy decision and only a small number of countries currently benefit from one.
We may transfer your data to a third country or international organisation on this ground where we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using standard data protection contract clauses approved by the European Commission.
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal information to a third country or international organisation where an exception applies under relevant data protection law, eg:
• you have explicitly consented to the proposed transfer after having been informed of the possible risks;
• the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
• the transfer is necessary for a contract in your interests, between us and another person; or
• the transfer is necessary to establish, exercise or defend legal claims.
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal information on this ground.
If you would like further information about data transferred outside the UK or EEA, please contact our Data Protection Officer (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
Access : - The right to be provided with a copy of your personal information (the right of access)
Rectification : - The right to require us to correct any mistakes in your personal information
To be forgotten : - The right to require us to delete your personal information—in certain situations
Restriction of processing : - The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data
Data portability : - The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object : - The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making : - The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
• email, call or write to our Data Protection Officer—see below: ‘How to contact us’;
• let us have enough information to identify you;
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on Wednesday 18th August 2021. We may change this policy from time to time, when we do we will inform you via email.
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).