Privacy Policy 

When you provide Circa Skin Limited (“Us”, “We”;) with information through this website, (“this Site”), we respect your privacy. Circa Skin Ltd have therefore developed this
privacy policy to inform you of the data we collect, what we do with your information, what we do to
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


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


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


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.
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.
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.
If any of the personal information we hold about you is inaccurate, incomplete or out of date, you may
ask us to correct it.
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
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.
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.
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 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 All requests
will be dealt with promptly and efficiently.
Circa Skin Ltd – Company number: 12684331.