Privacy Policy

When you provide Circa Skin Limited (“Us”, “We”;) with information through this website,

kysense.com (“this Site”), we respect your privacy. Circa Skin Ltd have therefore developed this

keep it secure as well as the rights and choices you have in accordance with the Data Protection Act

2018 (DPA2018), United Kingdom General Data Protection Regulation (UK GDPR), and the Privacy

and Electronic Communications (EC Directive) Regulations 2003. Where data is processed by a

controller or processor established in the European Union or comprises the data of people of the

European Union, it also includes the EU General Data Protection Regulation (EU GDPR). This

includes any replacement legislation coming into effect from time to time. Your visit to this Site is

subject to this Privacy Policy and our Terms of Service. Please note that this Privacy Policy governs

only information provided to this Site.

1. Information Collection

We do not collect personally identifiable information about you, except when you provide it to us

directly via our services with which you interact or through a third party. For example, if you

decide to complete a user registration form, complete an online survey or make a purchase, you

may be asked to provide certain information such as your contact information (name, email

address, mailing address and telephone number), birthday, gender and product and/or skincare, or

cosmetic concerns, and the brands and products you use. If you decide to place an order, we will

also need to know your delivery and billing address, credit card number and expiry date.

Visitors are under no statutory or contractual requirement or obligation to provide us with your

personal information; however we require at least the information above in order for us to deal

with you as a customer in an efficient and effective manner.

Sensitive information is not generally sought through this site. Sensitive information includes data

relating to: race or ethnic origin; political opinions; religious or other similar beliefs; physical or

mental health. If you do provide sensitive information, by providing this you explicitly consent to

us using it in accordance with the Data Protection legislation and this Privacy Policy.

The legal basis for processing your data is based on Legitimate interest that we will have

requested at the point the information was initially provided, therefore we will not store, process

or transfer your data unless we have an appropriate lawful reason or written consent to do so.

If you would prefer that we do not collect any personally identifiable information from you,

please do not provide us with any such information. Please note that if you do not wish to provide

any personal information, you will not be able to make purchases on this site. To protect your

personal information, users registering at this site must also enter a user name and password.

Prior to your submission of your personally identifiable information to this Site, you will be asked

whether you consent to the processing and transfer of your personal information in accordance

with this Privacy Policy. If you consent, you will be able to submit your information to this Site.

2. Use of Personally Identifiable Information

We strive to provide you with a full range of personalised skin care and cosmetic

recommendations designed to meet your needs. In order to provide you with this level of service,

we may use your personal information in the manner described below:

2.1 Communications to Serve You

If you have elected to provide us with your contact information, e.g. by registering at this Site or

by placing an order, we may contact you either by email or phone with updates regarding this Site

or your order. For example; all registered users will receive a welcome email to confirm their

registration to our site and confirmation emails will be sent to all registered users on completion

of an online order and to announce to users that their order has been shipped. We may also contact

you to respond to any customer care queries (e.g. lost orders, returns, questions about product

usage).

2.2 Opt-In Communications

In addition to the essential service related announcements that we will send you, if you opt-in

during this Site’s registration process or at other times when you may submit personally

identifiable information, the information you provide may be used to create and deliver to you our

regular mailing list, which is sent out multiple times a week, and which may consist of promotion

alerts, special discounts, new product launches, coming soon updates, skin care advice, product

recommendations and other relevant information (“Opt-In Communications”).

2.3 Text Marketing and notifications:

By subscribing to text notifications you agree to receive recurring automated marketing text

messages at the phone number provided. Consent is not a condition of purchase. Text STOP to

unsubscribe or HELP for help. Message and data rates may apply. View Terms of use and privacy

policy.

3. No Disclosure of Personally Identifiable Information for Third Party Marketing

Without Your Consent. Circa Skin Ltd comply with the General Data Protection (“GDPR”) to

provide a trusted method of safeguarding consumer data. We will never share your personal

details with any third parties for their use in marketing their products or services to you without

your consent.

4. Disclosure of Personally Identifiable Information – Fraud Protection and Compliance with Law

We may disclose any information, including personally identifiable information, we deem

necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or

governmental request. We may also exchange information, including personally identifiable

information, with other companies and organisations for credit fraud protection and risk

reduction.

5. Service Providers

We may retain other companies and individuals to perform functions consistent with our Privacy

Policy on our behalf. Examples include customer support specialists, webhosting companies,

credit card processing companies, fulfilment companies (e.g., companies that fill product orders

or coordinate mailings), data analysis firms and email service providers. Such third parties may be

provided with access to personally identifiable information needed to perform their functions, but

may not use such information for any other purpose. We will not share your information with any

third parties for the purposes of direct marketing.

6. Business Transfers

As we continue to develop our business, we might sell certain parts of our assets. In such

transactions, user information, including personally identifiable information, generally is one of

the transferred business assets, and by submitting your personal information on this Site you agree

that your data may be transferred to such parties in these circumstances. Data originally collected

by Circa Skin Ltd will be the only permitted data transferred.

7. Cookies, IP Addresses, Pixel Tags & Tracking Technology

When using our websites or mobile applications, you may be able to share information through

social networks like Facebook and Twitter. For example, when you ‘like’, ‘share’ or review our

Services. When doing this, your personal information may be visible to the providers of those

social networks and/or their other users. Please remember it is your responsibility to set

appropriate privacy settings on your social network accounts so you are comfortable with how

your information is used and shared on them.

A cookie is a small amount of information that’s downloaded to your computer or device when

you visit certain websites. We use a number of different cookies on this Site, including strictly

necessary, performance, advertising, and social media or content cookies. Cookies make your

browsing experience better by allowing the website to remember your actions and preferences

(such as login and region selection). This means you don’t have to re-enter this information each

time you return to the site or browse from one page to another. Cookies also provide information

on how people use the website, for instance whether it’s their first time visiting or if they are a

frequent visitor. This Site uses the following cookies: A comprehensive list can be found here.

8. Children under 18

If you are under 18 years of age, you may not browse this Site. You may not provide personal

information to us. For example, you cannot register or make a purchase. This Site is not designed

for minors and we do not knowingly collect personally identifiable information from any person

under 18 years of age.

9. Links

This Site may contain links to or from other websites. Please be aware that we are not responsible

for the privacy practices of other websites. This Privacy Policy applies only to the information we

collect on this Site. We encourage you to read the privacy policies of other websites you link to

from this Site or otherwise visit.

10. Security

Circa Skin Ltd take care to protect the privacy of our customers and users of our products that

communicate online with us. We use appropriate procedures and technical security measures

(including strict encryption, anonymisation and archiving techniques) to safeguard your

information across all our computer systems, networks and websites. We implement various

security measures in accordance with industry standards to protect the security of your personal

information in accordance with the Data Protection legislation.

11. Accuracy of and Updating Your Information

We will always retain your personal information in accordance with the Data Protection

Legislation and never retain your information for longer than is necessary. Unless otherwise

required by law, your data will be stored for a period of 7 years after our last contact with you, at

which point it will be deleted. We will take reasonable steps to create an accurate record of any

personal information you have submitted through this site. However, we do not assume

responsibility for confirming the ongoing accuracy of your personal information.

You are responsible for keeping your information on file with us up to date. You may review and

change the personally identifiable information you provide to us at any time by logging into your

account and amending the details.

12. Choice/Opt-Out

You may opt out of receiving future Opt-In communications when you register at this site or

otherwise provide your contact details to us. You may change your preferences at any time by

clicking the "unsubscribe" link at the bottom of each Opt-In Communication e-mail you receive.

13. Notification of Changes

We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy or

if the law changes, then we will post the revised policy here. As we may make changes at any

time without notifying you, we suggest that you periodically consult this Privacy Policy.

YOUR RIGHTS OVER YOUR INFORMATION

You have the right to be informed about the collection and use of your personal data. We ensure we do

this with our internal data protection policies and through our external website policy. These are

regularly reviewed and updated to ensure these are accurate and reflect our data processing activities.

RIGHT TO ACCESS YOUR PERSONAL INFORMATION

You have the right to access the personal information that we hold about you in many circumstances,

by making a request. This is sometimes termed ‘Subject Access Request’. If we agree that we are

obliged to provide personal information to you (or someone else on your behalf), we will provide it to

you or them free of charge and we will respond without delay and within one calendar month of

receipt of your request. We may ask for proof of identity and sufficient information about your

interactions with us that we can locate your personal information. Please note that the time limit for

fulfilling your request does not start until we have been able to verify your identity.

RIGHT TO CORRECTION YOUR PERSONAL INFORMATION

If any of the personal information we hold about you is inaccurate, incomplete or out of date, you may

ask us to correct it.

RIGHT TO STOP OR LIMIT OUR PROCESSING OF YOUR DATA

You have the right to object to us processing your personal information for particular purposes, to

have your information deleted if we are keeping it too long or have its processing restricted in certain

circumstances.

RIGHT TO ERASURE

You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The

right is not absolute and only applies in certain circumstances.

RIGHT TO PORTABILITY

The right to portability gives you the right to receive personal data you have provided to a controller

in a structured, commonly used and machine readable format. It also gives them you the right to

request that a controller transmits this data directly to another controller.

FOR MORE INFORMATION ABOUT YOUR PRIVACY RIGHTS

The Information Commissioners Office (ICO) regulates data protection and privacy matters in the

UK. They make a lot of information accessible to consumers on their website and they ensure that the

registered details of all data controllers such as ourselves are available publicly. You can access them

here https://ico.org.uk/for-the-public. You can make a complaint to the ICO at any time about the

way we use your information. However, we hope that you would consider raising any issue or

complaint you have with us first. Your satisfaction is extremely important to us, and we will always

do our very best to solve any problems you may have.

For any further information, questions, requests and complaints regarding this policy and the

information we hold are welcome and should be addressed to us at info@circaskin.co.uk. All requests

will be dealt with promptly and efficiently.

Circa Skin Ltd – Company number: 12684331.