Privacy Policy

Privacy policy

This notice sets out our privacy policy. By visiting www.EpiDermLux.com, you are deemed to accept the practices set out in this privacy notice. When you pass on personal information to us there is an implication that you have given your consent to us storing and utilising the information for the intended purpose as stated in this privacy policy. This notice sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you regarding the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

YOUR RIGHTS

You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the
details have been included below. Further information can be found here.

Right of access: You have the right to obtain from us a copy of the personal data that we hold for you.

Right to rectification: You can require us to correct errors in the personal data that we process for you if
it is inaccurate, incomplete or out of date.

Right to portability: You can request that we transfer your personal data to another service provider if you
initially provided consent for us to use the personal data or where we used the personal data to perform a contract with you.

Right to restrict or object to processing: In certain circumstances, you have the right to require that we
restrict the processing of your personal information. If you believe our processing impacts on your fundamental rights and
freedoms. However, we may demonstrate that we have legitimate grounds to process your personal data not withstanding your rights
and freedoms.

Right to be forgotten: If you would like to discontinue EpiDermLux as a patient you can email us and
we will suspend your account. Your account will become inactive with immediate effect and you will not be able to access your
account. This action cannot be undone. You acknowledge and agree that Two Face Aesthetics is required by law to archive electronic
patient records including your personal information, communication and treatments for a minimum of 10 years.

Right to stop receiving marketing information: You can ask us to stop sending you information about our
services, but please note we shall continue to contact you in relation to any matters relating to your account, if you have one.

THE BASES ON WHICH WE PROCESS INFORMATION ABOUT YOU

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.

If the basis changes then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

The Data Protection Act 2018 controls how your data is used by us. This privacy policy is applicable to the handling and controlling of the data and information in written, electronic or any other form.

INFORMATION WE MAY COLLECT FROM YOU

We collect the following types of information about you:

Contact Data includes data such as your email address, telephone number, geographical address, delivery address and billing
address
Identity Data includes data such as first name, last name, username or similar identifier, date of birth, passport number,
driving licence number;
Health Data includes GP address, patient notes, consultation notes, and any other information relating to your health
and medical status;
Financial Data includes details you provide to us so that we can process your payments through our third party payment
provider;
Transaction Data includes details of products you have purchased and payments made;
Technical Data includes data such as internet protocol (IP) address, your login data, browser type and version, cookies,
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 our website and any communications we may send to you.
Usage Data includes information about how you use our website such as information about your visit to our website,
including the full Uniform Resource Locators (URL) clickstream to and through, pages you viewed or searches you made, page
response times, download errors, length of visit, page interaction information (such as scrolling, clicks, and mouse-overs),
and methods used to browse away from the page.
Marketing Data includes your preferences in receiving marketing from us.

We do not knowingly collect personal data of children. Please do not provide personal data to us unless you are at least
18 years old.

As we are unable to verify the identity of an individual or obtain patient consent for treatment or data processing,
please do not provide to us information about other people.

We may monitor and record communications with you such as telephone conversations and emails for the purpose of training,
quality assurance, fraud prevention and compliance.

Information you voluntarily provide

You may provide information to us in a number of ways, including the following:

You access and interact with our website or with us by telephone, including by filling in forms and medical questionnaires;
You create an account on our website;
You purchase products on our website;
You apply to work with us as an employee or a consultant;
You provide feedback or reviews to us;
You respond to a survey or questionnaire although you do not have to respond to them.
You sign up for our newsletter;
You otherwise contact us including with queries, comments or complaints.

We shall process all such personal data in accordance with this Policy. Certain information is mandatory to be provided to
us in order that we can fulfil your request, for example to purchase products from us, and we shall make this clear to you at
the point of collection of the personal data.

All information that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data,
and we suspect or identify fraud, we will record this and we may also report this to the appropriate authorities.

When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call
we have with you.

Information we collect from the device you use to access our website

When you visit our website or interact with our services, we (and our advertisers and/or other service providers) may use a
variety of technologies that automatically or passively collect information about how our site is accessed and used.

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about
the types of cookies we use, why, and how you can control them, please see our Cookies Policy.

Information we receive from other sources

We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and
delivery services, advertising networks, analytics providers, search information providers, ID verification organisations and
credit reference agencies) and may receive information about you from them. We may also receive your information from other
organisations who sell products on our behalf.

To enable us to make medical decisions about you and for fraud prevention purposes, we use identity verification agents to
search the files of credit reference and fraud prevention agencies (who will record the search).

If you provide false or inaccurate information and/or we suspect fraud, we will record this and we will be unable to fulfil
your order.

1. INFORMATION WE PROCESS BECAUSE WE HAVE A CONTRACTUAL OBLIGATION WITH YOU

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a legally binding contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

1.1. verify your identity for security purposes

1.2. sell products to you

1.3. provide you with our services

1.4. provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a legally binding contract between us, or that you have requested we use the information before we enter a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

2. INFORMATION WE PROCESS WITH YOUR CONSENT

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us via email – admin@epidermlux.com, However, if you do so, you may not be able to use our website or our services further.

3. INFORMATION WE PROCESS FOR THE PURPOSES OF LEGITIMATE INTERESTS

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having considered:

whether the same objective could be achieved through other means
whether processing (or not processing) might cause you harm
whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

record-keeping for the proper and necessary administration of our business
responding to unsolicited communication from you to which we believe you would expect a response
protecting and asserting the legal rights of any party
insuring against or obtaining professional advice that is required to manage business risk
protecting your interests where we believe we have a duty to do so

4. INFORMATION WE PROCESS BECAUSE WE HAVE A LEGAL OBLIGATION

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

SPECIFIC USES OF INFORMATION YOU PROVIDE TO US

5. INFORMATION PROVIDED ON THE UNDERSTANDING THAT IT WILL BE SHARED WITH A THIRD PARTY

Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

Examples include:

5.1. posting a message our forum

5.2. tagging an image

5.3. clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do not specifically use this information except to allow it to be displayed or shared.

We do store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at admin@epidermlux.com

6. COMPLAINTS REGARDING CONTENT ON OUR WEBSITE

Our website is a publishing medium, anyone may register.

If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we must make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

7. INFORMATION RELATING TO YOUR METHOD OF PAYMENT

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it. Nor is such information retained and stored by us.

At the point of payment, you are transferred to a secure page on the website of Sage Pay/Elavon/Opayo or PayPal. That page may be branded to look like a page on our website, but it is not controlled by us.

8. INFORMATION ABOUT YOUR DIRECT DEBIT

We do not offer this facility.

9. JOB APPLICATION AND EMPLOYMENT

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you later.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

10. SENDING A MESSAGE TO OUR SUPPORT TEAM

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business.

We keep personally identifiable information associated with your message, such as your name and email address to be able to track our communications with you to provide a high-quality service.

11. COMPLAINING

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

12. AFFILIATE AND BUSINESS PARTNER INFORMATION

This is information given to us by you in your capacity as an affiliate of us or as a business partner.

It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and of the terms of our relationship.

We expect any affiliate or partner to agree to reciprocate this policy.

USE OF INFORMATION WE COLLECT THROUGH AUTOMATED SYSTEMS WHEN YOU VISIT OUR WEBSITE

13. COOKIES

Our website uses “cookies” in order to provide a better service to its users They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

13.1. to track how you use our website

13.2. to record whether you have seen specific messages we display on our website

13.3. to keep you signed in our site

13.4. to record your answers to surveys and questionnaires on our site while you complete them

13.5. to record the conversation thread during a live chat with our support team

We do not use cookies to store any personally identifying information from users except to identify a user who has chosen to log into the site. We do not use cookies beyond our web site.

14. PERSONAL IDENTIFIERS FROM YOUR BROWSING ACTIVITY

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed into our website.

15. OUR USE OF RE-MARKETING

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

DISCLOSURE AND SHARING OF YOUR INFORMATION

16. INFORMATION WE OBTAIN FROM THIRD PARTIES

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.

No such information is personally identifiable to you.

17. THIRD PARTY ADVERTISING ON OUR WEBSITE

Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.

They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.

We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

18. CREDIT REFERENCE

To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

19. DATA MAY BE PROCESSED OUTSIDE THE EUROPEAN UNION

Our websites are hosted in United Kingdom

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly, data obtained within the UK or any other country could be processed outside the European Union.

For example, some of the software our website uses may have been developed in the United States of America or in Australia.

We use the following safeguards with respect to data transferred outside the European Union:

19.1. the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.

19.2. the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union

19.3. we comply with a code of conduct approved by a supervisory authority in the European Union

19.4. we are certified under an approved certification mechanism as provided for in the GDPR

19.5. both our organisation and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to protection of your information

ACCESS TO YOUR OWN INFORMATION

20. ACCESS TO YOUR PERSONAL INFORMATION

20.1. At any time, you may review or update personally identifiable information that we hold about you, by signing into your account on our website.

20.2. To obtain a copy of any information that is not provided on our website you may send us a request at admin@epidermlux.com

20.3. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

You have the right to request:

information about how your personal data is processed
a copy of that personal data
that anything inaccurate in your personal data is corrected immediately

You can also:

raise an objection about how your personal data is processed
request that your personal data is erased if there is no longer a justification for it

If you have any of these requests, get in contact with our Privacy Team.

21. USES MADE OF YOUR DATA

We will only use your personal data where we have a lawful basis to do so. The lawful purposes that we rely on under this
Privacy Policy are:

consent (where you choose to provide it);
performance of a contract with you;
compliance with legal requirements; and
legitimate interests. When we refer to legitimate interests we mean our legitimate business interests in the normal running
of our business which do not materially impact your rights, freedom or interests.

PURPOSE/ACTIVITY	TYPE OF DATA	LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
To register you as a customer and/or create your account	(a) Contact (b) Identity	Performance of a contract with you
To manage your account and orders for products including considering prescriptions and managing payments, cancellations, returns and refunds	(a) Contact (b) Identity (c) Financial (d) Transaction (e) Health	Performance of a contract with you Legitimate interests (fraud-checking)
To manage our relationship with you such as notifying you about changes to our terms or this Privacy Policy	(a) Contact (b) Identity	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests
To administer and protect our business and this website (including improving and fixing our service, analysis, testing, system maintenance, support, reporting)	(c) Technical	Necessary for our legitimate interests (for running our business and site securely, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure and understand the effectiveness of the advertising we serve to you	(a) Contact (b) Identity (d) Usage (d) Marketing (e) Technical	Necessary for our legitimate interests (to analyse how customers use our website and manage our business accordingly)
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 site updated and relevant, to develop our business and to inform our marketing strategy)

22. REMOVAL OF YOUR INFORMATION

In addition to the Company’s safeguards, your personal data is protected by the Data Protection Act 2018. This provides, amongst other things, that the data which we hold about you should be processed lawfully and fairly. It should be accurate, relevant and not excessive. The information should not be retained for longer than is necessary. It should be kept securely to prevent unauthorised access by other people.

If you have any concerns about the processing of your personal data or wish us to remove personally identifiable information from our website, you may contact us at admin@epidermlux.com

This may limit the service we can provide to you. If you find any inaccuracies, we will delete of correct them promptly.

22. VERIFICATION OF YOUR INFORMATION

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps
to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your
information.

OTHER MATTERS

23. USE OF SITE BY CHILDREN

23.1. We do not sell products or provide services for purchase by children, nor do we market to children.

23.2. If you are under 18, you may use our website only with consent from a parent or guardian

24. ENCRYPTION OF DATA SENT BETWEEN US

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

25. HOW YOU CAN COMPLAIN

25.1. If you are not happy with our privacy policy or if have any complaint, then you should tell us by email. Our address is admin@epidermlux.com

25.2. If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

25.3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/

26. RETENTION PERIOD FOR PERSONAL DATA

We will retain personal data in accordance with applicable laws.

We may also be required to retain personal data for a particular period of time to comply with legal, auditory or statutory
requirements, including requirements of HMRC in respect of financial documents and in order to deal with any dispute you might
raise. To determine the appropriate retention period for personal data, we consider the type of the personal data, the potential
risk of harm from unauthorised use or disclosure of the personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means.

In particular, as noted above, you acknowledge and agree that EpiDermLux is required by law to archive electronic
patient records including your personal information, communication and treatments for a minimum of 10 years.

Where we have no legal basis for continuing to process your personal data, we shall either delete or anonymise it or, if this
is not possible (for example, because your personal information has been stored in backup archives), then we will securely store
your personal information and isolate it from any further processing until deletion is possible.

For the avoidance of doubt, we may use anonymous data, such as usage data for research or statistical purposes indefinitely
without further notice to you.

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

26.1. to provide you with the services you have requested;

26.2. to comply with other law, including for the period demanded by our tax authorities;

26.3. to support a claim or defence in court.

27. SERVICE INTERRUPTION

The Company shall have no liability to you for any interruption or delay in access to this site irrespective of the cause.

28. COMPLIANCE WITH THE LAW

Our privacy policy has been compiled to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

29. REVIEW OF THIS PRIVACY POLICY

We reserve the right to modify this privacy notice from time to time as necessary. Any such modifications will be posted on www.epidermlux.com. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us.

Acceptance

30. DISCLAIMER

The advice and information given on this site is of a very general nature and may not deal with your individual requirements. It is believed to be accurate, but the Company cannot be held responsible for any action that may or may not be taken by anyone accessing this site and acting on the information contained in it. Our liability can only extend to specific advice given by authorized members of the Company after the completion and acceptance of a formal order.

Age Check