Seriously Beauty

Privacy Policy:

Policy version: 01.07.2024

1 INTRODUCTION

This Privacy Policy is provided by EVRSLASH LTD. (trading as Seriously Beauty), a company registered in England and Wales under company number: 15553011 with registered office at 128 City Road, London, United Kingdom EC1V 2NX (‘we’, ‘our’ or ‘us’) for use of our website, being www.seriouslybeauty.com (Website).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

2 WHAT THIS POLICY APPLIES TO

This privacy policy relates to your use of the Website and accessing the services provided through the Website.

The Website may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with the services through the Website. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies and we shall in no way be liable or responsible for any such third parties. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

3 PERSONAL DATA WE COLLECT ABOUT YOU

The personal data we collect about you depends on the particular activities carried out through the Website. We will collect and use the following personal data about you:

Category of data	In more detail
Identify and account data you input into the Website Registration is mandatory in order to post reviews on the Website	· Your name, mobile number, email address, physical address, skin condition, skin tone, age, date of birth, gender, profession, skin related concern (i.e., oily, dry, combination, normal, eczema prone etc.) · Your account details, such as username and password · Your interests, preferences, reviews, feedback and survey responses · Your social media log-in details, user name, profile photo etc., where you log-in to your account on the Website using the social media profile or connect your social media account to your account on the Website.
Data collected when you use specific functions in the Website	Data you store online with us using the Website including your usage history, review history or preferences (while such data may not always be personal data as defined by law in all cases, we will assume it is and treat it in accordance with this policy as if it were)
Data collected when you place a review on the Website	Details of the products which you browse on the Website, products for which you put a review on the Website.
Data collected when you permit the collection of location data	Details of your location with a high degree of precision, see the section ‘Location services/data’ below data concerning location is collected when using the Maps function of the Website
Other data the Website collects automatically when you use it	· Your activities on, and use of, the Website which reveal your preferences, interests or manner of use of the Website and the times of use · Other information such as entry and exit pages, CTR to third party links, affiliate links, device type, IMEA numbers, MAC address of networks, other unique device identification, device operating system, mobile network information, data usage, time zone settings etc.
Data collected when you make an enquiry with us	Your name and email address
Marketing and communications data	Your preferences in receiving marketing emails from us and our third parties and your communication preferences

If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services to you through the Website.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ usage data (including information about how users interact with and use the Website and products and services offered through the Website) to calculate the percentage of users accessing a specific feature of the Website in order to analyse general trends in how users are interacting with the Website to help improve the Website and our offerings.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

4 SENSITIVE DATA

Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.

Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.

If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Website (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public and will not be responsible for protection of any such sensitive data. In case any such sensitive data is provided by you, you may contact us for deletion of such sensitive data.

5 LOCATION SERVICES/DATA

The Website will request your consent to use location services to precisely identify your location each session (i.e. each time the Website is opened or has been placed in the background for more than 30 seconds).

If you do not provide your consent, you may use the Website but that will mean the “geo-location” feature on the Website will not be available. To withdraw your consent at any time you can turn off the localisation permissions for our app on your device.

The location services in the Website will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by turning your device’s location on “off” using the device’s settings app. When you allow your device to use location services/data, data will also be collected by Google in accordance with their Privacy Policy, as this is the map service we integrate to our app.

We exert no control over Google’s Privacy Policy and we therefore recommend that you consult their privacy policy for further information on how Google protect personal data please visit their site - https://policies.google.com/privacy?hl=en-US. For more information see the section ‘Who we share your personal data with’ below.

6 HOW YOUR PERSONAL DATA IS COLLECTED

We use different methods to collect data from and about you including by way of:

(i) Your interaction with us: We collect personal data from you directly when you sign up to the Website, post a review/rating on the Website, click on affiliate links, click on ads, share social media logins/connect to your social media profile, subscribe to our communications, participate in any giveaways or competitions, request for marketing emails to be sent to you, contact us directly or reach out to us via social media, make submissions via the Website when a forum element is available, or indirectly, such as your activity while using the Website, participate in any feedback or survey.

(ii) Automated technologies or interactions: As you interact with the Website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy available at https://seriouslybeauty.com/cookie-policy for further details.

7 HOW AND WHY WE USE YOUR PERSONAL DATA

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

(i) where you have given consent

(ii) to comply with our legal and regulatory obligations

(iii) for the performance of a contract with you or to take steps at your request before entering into a contract, or

(iv) for our legitimate interests or those of a third party

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 statutory rights. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Create and manage your account with us	To perform our contract with you or to take steps at your request before entering into a contract
Providing services and/or the functionalities of the Website to you	Depending on the circumstances: · to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Website) · the geolocation feature will use data relating to your location only based on your consent as described in ‘Location services/data’ (above)
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: · to comply with our legal and regulatory obligations · in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Sending relevant marketing communications and for making personalised suggestions and recommendations to you about the products that may be of interest to you based on your profile data	For our legitimate interests, to carry out direct marketing, improve and develop our services and offerings and grow our business and having obtained your consent to receive direct marketing communications.
Carry out market research through your voluntary participation in surveys	Necessary for our legitimate interests to study how customers use the products, use our Website and to help us improve and develop our Website and products and services offered through the Website.
Communications with you not related to marketing, including about changes to our terms or policies or updates concerning the requests submitted by you through the Website or changes to the Website or service or other important notices	Depending on the circumstances: · to comply with our legal and regulatory obligations · to keep you updated on any requests submitted by you through the Website · in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
Protect the security of systems and data	To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you
Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop the Website
Updating and enhancing user records	Depending on the circumstances: · to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Website) · to comply with our legal and regulatory obligations · where neither of the above apply, for our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Website and the products and services offered through the Website
To comply with our legal and regulatory obligations	Depending on the circumstances: · to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Website) · to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Website
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: · to comply with our legal and regulatory obligations · in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

8 MARKETING

We intend to send you email marketing to inform you of the products such as promotions, any new products, any new services offered through the Website, feedback/update on reviews submitted by other users of the Website, recommending products for your reviews etc.

We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.

You will have the right to opt out of receiving marketing communications at any time by:

o contacting us at [email protected]

o using the ‘unsubscribe’ link included in all marketing emails you may receive from us

We will always treat your personal data with the utmost respect and will not sell or share it with other organisations in violation of the applicable laws.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

9 WHO WE SHARE YOUR PERSONAL DATA WITH

We routinely share personal data with service providers we use to help us run our business, help us with fulfilment of any requests submitted through the Website, provide the services or functionalities in the Website, including developers, cloud storage providers etc.