What Is This Privacy Policy For
This privacy policy (“Privacy Policy”) applies to personal and non personal data that we collect from you as a user of this Site or as a customer (“you” or “your” being interpreted accordingly). It provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation (“GDPR”) which will become applicable to us and you as of 25 May 2018.
‘Personal data’ as used in this Privacy Policy means any information that relates to you from which you can be identified.
By using our Site or submitting your personal data you are taken to accept the terms of this Privacy Policy, so please read it carefully.
Visitors to our Website
When someone visits www.bebarefaced.com we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. You can find more information on how cookies are used on this website in the Cookies Policy below.
Personal Data We Collect
We collect the following personal data about you:
- Processing your orderThe personal details you provide when submitting an order. This can include your name, address, e-mail address, business address, phone number and country. We also collect information about your debit/credit card and bank account information provided by you to our payment service providers, that we require for the purpose of recording and processing order. For further details please also refer to the section below headed “Payment Information”.
- Other Information: Personal details you choose to give when corresponding with us by phone or e-mail, participating in user/customer/member surveys or otherwise visiting and interacting with this Site.
Newsletter / BeBarefaced Club Sign Up
As part of the registration process for our BeBarefaced Club Newsletter, we collect personal information. We use that information for a few reasons: to tell you about stuff you’ve asked us to tell you about; to contact you if we need to obtain or provide additional information; to check our records are right and to check every now and then that you’re happy and satisfied. We don't rent or trade email lists with other organisations and businesses.
We always have, and always will send an email back to you after registering to confirm your consent (opting in) to join the newsletter.
We use a third party provider, Klaviyo, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see Klaviyo’s Privacy https://www.klaviyo.com/privacy.
You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of any of our emails or by emailing our data protection officer dpo@bebarefaced.com.
Automatically Collected Personal Data
- Log Data:When you visit our Site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.
How We Use Your Personal Data
We use your personal data in the following ways:
- To acknowledge, confirm and deal with your order. Such use of your data is necessary in order to implement your request.
- Where you are a customer, provide you with customer services, administer your customer account and contact you regarding your use of our services or products.
- To contact you in connection with user/customer/member surveys and use any information you choose to submit in response, provided that you gave us your consent to being contacted in this way at the time you provided us with the personal data.
- As necessary for certain legitimate business interests, which include the following:
- where we are asked to deal with any enquiries or complaints you make.
- to administer our Site, to better understand how visitors interact with our websites and ensure that our Site is presented in the most effective manner for you and for your computer/device.
- to conduct analytics to inform our marketing strategy and enable us to enhance and personalise the experience we offer to our customer and our communications, including by creating customer profiles to enable personalised direct marketing communications.
- we may anonymise, aggregate and de-identify the data that we collect and use such anonymised, aggregated and de-identified data for our own internal business purposes, including sharing it with our current and prospective customers, business partners, our affiliated businesses, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behaviour.
- for internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site, network and information systems secure.
- We may use your personal data for other purposes which you have consented to at the time of providing your data.
Disclosure Of Your Information
- Service Providers: BeBarefaced Ltd, like many businesses, sometimes hires selected third parties who act on our behalf to support our operations, such as (i) card processing or payment services (see the section below headed “Payment Information”), (ii) credit reference agencies to protect against possible fraud, (iii) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide customer services and other goods/services available on this Site or to customers, (iv) web analytics providers, (v) providers of digital advertising services and (vi) providers of CRM, marketing and sales software solutions. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.
We share your personal data with third parties in the following situations:
- Administrative and Legal Reasons: if we need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process. (ii) to enforce our Terms & Conditions, House Rules or other applicable contract terms that you are subject to or (iii) to protect us, our customers, or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organisations.
Payment Information
Any credit/debit card payments and other payments you make through our Site will be processed by our third party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that we do not ourselves directly process or store the debit/credit card data that you submit.
Security
Where we have given you (or where you have chosen) a password or log-in which enables you to access certain restricted parts of our Site, you are responsible for doing everything you reasonably can to keep these details secret. You must not share your password or log-in details with anyone else.
Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organisational security measures to protect the personal data that you submit to us against unauthorised/unlawful access or loss, destruction or damage, although we cannot 100% guarantee the security of personal data that you provide to us online.
Personal Data Retention
We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer.
Your Personal Data Protection Rights
Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the GDPR, you have the following rights in relation to your personal data:
- Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details such as the purpose of the data processing.
- Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it.
- Right to erasure: You may ask us to delete or remove your personal data, such as where our legal basis for the processing is your consent and you withdraw consent.
- Right to data portability:You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our service to you.
- Right to withdraw consent:If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
Changes To Our Privacy Policy
Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable law, we will notify you of any material or substantive changes to this Privacy Policy.
Contact
Questions, comments or requests regarding this Privacy Policy should be addressed to dpo@bebarefaced.com.
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Cookies Policy
We use a system of classifying the different types of cookies which we use on www.bebarefaced.com (the Website), or which may be used by third parties through our websites. The classification was developed by the International Chamber of Commerce UK and explains more about which cookies we use, why we use them, and the functionality you will lose if you decide you don't want to have them on your device.
What is a cookie?
Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user's device.
How long are cookies stored for?
Persistent cookies - these cookies remain on a user's device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
Session cookies - these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience.
You can find more information about cookies at www.allaboutcookies.org and www.youronlinechoices.eu.
Cookies used on the Website
A list of all the cookies used on the Website by category is set out below.
Strictly necessary cookies
These cookies enable services you have specifically asked for. These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website.
Performance cookies
These cookies collect anonymous information on the pages visited. By using the Website, you agree that we can place these types of cookies on your device.
These cookies collect information about how visitors use the Website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Website works.
Functionality cookies
These cookies remember choices you make to improve your experience. By using the Website, you agree that we can place these types of cookies on your device.
These cookies allow the Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Third party cookies
These cookies allow third parties to track the success of their application or customise the application for you. Because of how cookies work we cannot access these cookies, nor can the third parties access the data in cookies used on our site.
For example, if you choose to ‘share’ content through Twitter or other social networks you might be sent cookies from these websites. We don't control the setting of these cookies, so please check those websites for more information about their cookies and how to manage them.