This Privacy Policy explains in detail the types of personal data which Lewis Curzon Skincare (“LCS“) may collect about you when you interact with us. This Privacy Policy also explains how Lewis Curzon Skincare will store and handle that data, and – importantly – keep your personal data safe.

We hope that the following sections will answer any questions which you might have about your personal data, and what steps Lewis Curzon Skincare will take to safeguard your personal data, but – if you have any queries – please do not hesitate to get in touch with us.

This Privacy Policy may need to be updated from time-to-time. Please be assured that we will notify you of any significant changes to this Privacy Policy via email. You are able to review the most current version of this Privacy Policy at any time on this web-page.

  1. WHO ARE ‘LEWIS CURZON SKINCARE’?

Our business name is ‘Lewis Curzon Skincare’. Lewis Curzon Skincare (‘One World One Body’) is a contract manufacturer and own-brand producer of cosmetic and toiletries products.

This Privacy Policy applies to UK domestic and also international orders of Lewis Curzon Skincare products – however, there are some additional terms and provisions which apply to certain countries which supplement this Privacy Policy, and which take priority over any conflicting terms and provisions. For more information in this regard, please see Section 14.

Throughout this Privacy Policy, the words “we” and “us” mean ‘Lewis Curzon Skincare’.

  1. EXPLAINING THE LEGAL BASES WE RELY ON

The law on data protection sets out a number of different reasons for why a business might collect and process your personal data, which include :

Consent

In specific situations, LCS can collect and process your personal data with your consent. For example, if you ticked a box to consent to receiving email newsletters from Lewis Curzon Skincare, we would have your consent to collect and process your personal data for that purpose.

We will always make clear to you what personal data is necessary for us to collect in connection with a particular service.

Contractual Obligations

In certain circumstances, LCS will need your personal data in order to comply with our contractual obligations to you. For example, if you ordered a Lewis Curzon Skincare product from us for home delivery, we would collect your address details in order to deliver your purchase to you, and we would then pass those address details on to our courier for delivery.

Legal Compliance

If the law requires us to, LCS may need to collect and process your personal data. For example, we can pass on the personal data of people involved in fraud or other criminal activity affecting Lewis Curzon Skincare to the appropriate law enforcement authorities.

Legitimate Interest

In specific situations, LCS might require your personal data so that we can pursue our legitimate business interests in a way which might reasonably be expected as part of the running of our business – but, importantly, such business activity must not (and will not) materially impact upon your rights, freedom or interests.

For example : (a) LCS might use your purchase history with us to then send you personalised offers tailored to your product preferences ;

(b) LCS might send you direct marketing emails when you shop with us and you do not opt out of this business activity (known as a ‘soft opt-in’) ;

(c) LCS might combine the shopping history of many of our customers in order to identify trends, to keep up with demand, and even to develop new products/services if such business activity is indicated from this data ; and

(d) LCS might also send you direct marketing information by post, to tell you about products/services which we think might interest you.

With your consent, or when you ‘soft opt-in’ (see (b) above), we will use your personal data, preferences and transaction details to keep you informed by email, web, text and/or telephone about relevant products and services – including tailored special offers, discounts, promotions, events and competitions. This is only applicable in the United Kingdom.

  1. WHEN DO WE COLLECT YOUR PERSONAL DATA?
  • When you visit our website and use your account to make an online purchase from our store, or use your account to redeem vouchers online ;
  • When you visit our website and make an online purchase from our store as a guest (in this case LCS will just collect transaction-based data) ;
  • When you create an online account with Lewis Curzon Skincare ;
  • When you use our website, LCS will capture information through cookies and similar technologies (which you can manage via our website) ;
  • When you engage with Lewis Curzon Skincare on social media ;
  • When you contact LCS by any means to communicate queries, complaints, etc ;
  • When you ask LCS to email you information about our products/services ;
  • When you enter LCS-organised prize draws or competitions ;
  • When you choose to complete any surveys sent to you by LCS ;
  • When you comment on and/or review LCS products and services ;
  • When you have given a third-party permission to share with LCS the information they hold about you ; and
  • Lewis Curzon Skincare may collect personal data from publicly-available sources – either when you have given your consent to share this personal data or where the personal data is made public as a matter of law.
  1. WHAT SORT OF PERSONAL DATA DO WE COLLECT?

If you have an online account with us, Lewis Curzon Skincare will collect the following personal data: i. your name; ii. gender; iii. date of birth; iv. billing/delivery address; v. orders and receipts; vi. an email address; and vii. a contact telephone number. For your security, we will also keep an encrypted record of your account log-in password.

Lewis Curzon Skincare may also collect :

  • Details of your interactions with us – such as (but not limited to) notes from our verbal conversations with you, any written complaints/comments we receive from you, any purchases which you make from us, items on our website which you have viewed and/or added to your basket, voucher redemptions, which pages on our website you have visited, and how and when you have contacted us ;
  • Details of your shopping preferences ;
  • Details of your visits to our website, and which website(s) you came from/via to ours ;
  • Personal details which help us to recommend products/services which might be of interest to you. It is always your choice whether or not to share such personal details with us ;
  • Payment card information ;
  • Your comments and product reviews ; and
  • Your social media username – if you interact with us via social media – so that we can respond to your comments, questions and/or feedback.

To deliver the best possible web experience for you, LCS may collect technical information about your internet connection and browser – as well as the country and telephone code where your computer is located, the webpages viewed during your visit and any search terms entered. For more information in this regard, please refer to our Cookies Policy.

  1. HOW AND WHY DO WE USE YOUR PERSONAL DATA?

Lewis Curzon Skincare wants to provide its customers at-all-times with the best possible customer experience. With this in mind, we work to collate the most-complete and detailed picture we possibly can of who you are in order to offer you tailored promotions, and products/services most likely to be of interest and relevance to you.

The law on data protection allows this – as part of our legitimate business interest in understanding our customers and – importantly – seeking to provide you with the highest levels of customer service. Remember – it is always your choice whether or not to share such personal data with us.

Below are some examples of how LCS might use your personal data, and why :

  • To process any orders which you make via our website – if LCS did not collect your personal data during the checkout process, we could not process your order and comply with our contractual obligations owed to you. Your personal data may therefore need to be passed on to a third-party (such as delivery couriers) so that we can supply or deliver to you the product/service ordered. LCS might keep your personal data for a reasonable period of time in case we need to fulfil any contractual obligations owed to you such as refunds, guarantees, etc.
  • To respond to your queries, refund requests or complaints – handling the information you send to LCS enables us to respond. We might also keep a record of such information to help inform any future communications between us. LCS does this on the basis of its contractual obligations owed to you, its legal obligations as a business and also its legitimate business interests in providing its customers with the best possible customer service.
  • To send you email notifications when you place a product in your basket but then fail to complete the purchase – LCS does this on the basis of its legitimate business interests.
  • To protect our business and your account from fraud and other illegal activities – this includes using your personal data to maintain, update and safeguard your account. LCS might also monitor your browsing activity in order to quickly identify and resolve any problems and to protect the integrity of our website. LCS does this on the basis of its legitimate business interests.
  • To process payments and to prevent fraudulent transactions – LCS does this on the basis of its legitimate business interests and to protect our business and your account from fraud and other illegal activities. If we discover any actual/alleged criminal activity through our use of fraud-monitoring and suspicious transaction-monitoring procedures, we will process personal data to prevent or detect unlawful acts.
  • With your consent, or when you ‘soft opt-in’ – LCS will use your personal data, preferences and transaction details to keep you informed by email, web, text and/or telephone about relevant products and services – including tailored special offers, discounts, promotions, events and competitions. This is only applicable in the United Kingdom. Remember – it is always your choice to share such personal data with us.
  • To send you communications required by law, or which are necessary to inform you about changes to our services – Such communications might include updates to our Privacy Policy, product-recall notices, or legally-required information relevant to your purchases. Such communications will not include any promotional content, nor require your prior consent if sent to you by email or text.
  • To administer any LCS-organised prize draws or competitions – your consent having been given to us at the time of entry.

In addition, LCS might also use your personal data :

  • to develop, test and improve the systems, services and products which we provide to you;
  • to comply with our contractual and/or legal obligations to share data with law enforcement authorities; and
  • to send you survey and feedback requests to help improve the customer experience and the services and products which we provide to you.
  1. COMBINING YOUR PERSONAL DATA FOR PERSONALISED DIRECT MARKETING

Lewis Curzon Skincare wants to provide its customers at-all-times with the best possible customer experience. With this in mind, we work to collate the most-complete and detailed picture we possibly can of who you are in order to offer you tailored promotions, and products/services most likely to be of interest and relevance to you. As well as personal data which we ourselves have collected about you, we might choose to combine this data with personal data obtained from third-parties to whom you have given permission to share with us the information they hold about you.

The law on data protection allows this – as part of our legitimate business interest in understanding our customers and – importantly – seeking to provide you with the highest levels of customer service. Remember – it is always your choice whether or not to share such personal data with us.

  1. HOW DOES LEWIS CURZON SKINCARE PROTECT YOUR PERSONAL DATA?

Lewis Curzon Skincare respects and understands how important data security is to our customers. Please be assured that we treat your personal data with the utmost care – taking all appropriate steps in order to protect it. LCS secures access to all transactional areas of our website using ‘https’ technology. Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured and tokenised.

LCS regularly monitors its system for possible vulnerabilities and attacks, and periodically conducts penetration-testing in order to identify ways to further strengthen our data security.

  1. FOR HOW LONG WILL MY PERSONAL DATA BE KEPT FOR?

Whenever LCS collects and/or processes your personal data, we will only keep such data for as long as is necessary – and only for the purpose for which such data was collected. For example, we might keep your personal data for a period of five years following the placing of an order with us, in case we need to fulfil any contractual obligations owed to you such as refunds, guarantees, etc.

At the end of the necessary data-retention period, your personal data will either be deleted completely, or will be anonymised so that it can still be used – in a non-identifiable way – for statistical analysis and business planning.

  1. WHO DOES LEWIS CURZON SKINCARE SHARE MY PERSONAL DATA WITH?

a. LCS might sometimes need to share your personal data with trusted third-parties. In such cases, we will only provide such information as is strictly necessary to enable them to perform their specific service(s), and your personal data will only be used for the exact purpose(s) specified in our contractual arrangements with them. Please be assured that we work closely with trusted third-parties to ensure our customers’ privacy is respected and protected at all times. If we discontinue our use of any trusted third-party, any personal data which they hold will either be deleted completely, or will be anonymised so that the personal data can still be used – in a non-identifiable way – for statistical analysis and business planning purposes.

Examples of the trusted third-parties we work with in this way might include: i. IT companies who support our website and other business systems; ii. operational companies such as delivery couriers; and iii. any direct-marketing companies which we may engage from time-to-time to manage our electronic communications with our customers.

b. We will only share your personal data with third-parties – to use for their own purposes – in very specific circumstances, including :

  • With your consent – given to LCS at the time you provide your personal data to us – to pass such personal data on to a third-party for their own direct-marketing purposes ;
  • For fraud management, LCS might share information – whether about actual/alleged fraudulent activity in our premises or systems – with appropriate law enforcement bodies for their own investigatory purposes ;
  • LCS might also be required to disclose your personal data to the police – or any other law enforcement, regulatory or Government body in the world – if we receive a valid request to do so. We shall always assess the validity and proportionality of such requests on a case-by-case basis ;
  • LCS may from time-to-time expand, reduce or sell the business, and this might involve the transfer of divisions or of the whole business to new ownership. In such circumstances, your personal data might – where relevant – be transferred to the new owner/controlling party.
  1. WHERE MIGHT MY PERSONAL DATA BE PROCESSED?

On occasion, Lewis Curzon Skincare may need to share your personal data with third-parties and suppliers based outside the European Economic Area (“EEA”). The EEA includes all EU Member countries, as well as Iceland, Liechtenstein and Norway.

Lewis Curzon Skincare may also transfer personal data collected from you to third-party data processors in countries that are outside of the EEA – for example, in order to fulfil your order, process your payment details and/or to provide support services. If we deem such action to be necessary, please be assured that there are adequate procedures in place to ensure your personal data receives the same protection as if it were being shared within the EEA. For example, our contractual arrangements with all third-parties stipulate the standards to follow and adhere to at all times.

  1. WHAT RIGHTS DO YOU HAVE OVER YOUR PERSONAL DATA?
  • Access to your personal data which Lewis Curzon Skincare holds about you – free-of-charge in most cases ;
  • The correction of your personal data when it is incorrect, out-of-date or incomplete ;
  • The deletion of your personal data in specific circumstances (such as when you withdraw your consent, or the purpose for which your personal data was being held has come to an end) ;
  • The receipt of a computer file in a common format (CSV or similar) which contains your personal data held by LCS, and to transfer your personal data from LCS to another entity where this is technically possible ;
  • The restriction on the use of your personal data by LCS in specific circumstances (generally, whilst we consider any objections made) ;
  • That LCS stops processing your personal data in specific circumstances (such as when you withdraw your consent, or object for reasons related to your individual, specific circumstances) ;
  • That LCS stops using your personal data for direct-marketing purposes (whether through specific/all communication channels) ;
  • That LCS stops any consent-based processing of your personal data after you have withdrawn that consent ; and
  • The human review by LCS of any automated data-processing decision relating to your personal data.

You may contact us to request the exercise of any of these rights at any time by completing an online enquiry form.

Any refusal by Lewis Curzon Skincare to action your request will be set out in writing.

Your right to withdraw consent : Whenever you have given your consent for us to use your personal data, you have the right to change your mind at any time and withdraw consent.

Where we rely on our legitimate business interests : When LCS is processing your personal data on the basis and justification of our legitimate business interests, you may ask at any time for us to stop for reasons related to your individual, specific circumstances. Please note that we may however continue to process your personal data in such circumstances if we believe there to be a legitimate overriding reason which entitles us to continue processing your personal data in this way.

Direct marketing : You may at any time stop the use of your personal data for direct-marketing activity – whether through specific/all communication channels.

In order to protect and safeguard the confidentiality of your personal data, we will always ask you to verify your identity before we proceed to consider any request made under the terms of this Privacy Policy. In cases where you have authorised a third-party to submit a request on your behalf, we will always ask that third-party to prove that they have your permission and consent to act.

  1. HOW CAN I STOP THE USE OF MY PERSONAL DATA FOR DIRECT MARKETING?

There are several ways you can stop direct marketing communications from Lewis Curzon Skincare :

  • Click the ‘Unsubscribe’ link in any email communication which we have sent you. Lewis Curzon Skincare will then stop any further emails being sent to you from that particular division of the business ;
  • If you have an account with Lewis Curzon Skincare, you may access your account via our website and change your preferences ;
  • Write to us at : Lewis Curzon Skincare, PO Box 71, ETCHINGHAM TN19 7YR.

Please note that you may continue to receive direct-marketing communications for a short period of time after changing your preferences, whilst our systems are fully-updated.

  1. CONTACTING THE REGULATOR

If you feel that your personal data has not been handled correctly by Lewis Curzon Skincare, or you are unhappy with our response to any requests made regarding the use of your personal data, please note that you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact the Information Commissioner’s Office by calling 0303 123 1113. Alternatively, you can go online to www.ico.org.uk/concerns (please note that Lewis Curzon Skincare cannot be responsible for the content of external websites).

If you are based outside of the United Kingdom, please note that you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 14 below.

  1. IF YOU ARE BASED OUTSIDE OF THE UNITED KINGDOM

For all non-UK customers

This Privacy Policy can be provided in English, French, Spanish, Portuguese, Malay and Chinese languages. In the event of any conflict in the meanings between the English and translated version, please note that the English version shall prevail. Copies of foreign language versions of this Privacy Policy are available from our Data Protection Officer.

By placing an order with Lewis Curzon Skincare, browsing our website (including for analytics and website usage research), and/or agreeing to receive direct marketing electronic communications from us as described in this Privacy Policy and our Cookies Policy, you expressly consent to the processing of your personal data by Lewis Curzon Skincare or on our behalf. Of course, you have the right to ask Lewis Curzon Skincare not to process your personal data in these ways, and, if you do so, we will respect your wishes.

On occasion, Lewis Curzon Skincare may need to transfer your personal data between countries in order to enable us to supply the goods and/or services which you have requested. In the ordinary course of business, Lewis Curzon Skincare may transfer your personal data to third-parties located in the United Kingdom to your country of residence. You hereby expressly consent to such overseas use, the transferring and disclosing of your personal data outside of your country of residence for such purposes.

Lewis Curzon Skincare shall endeavour to ensure that all reasonable steps are taken to procure that all such third-parties based outside of your country of residence shall not use your personal data other than for that part of the purposes as set out above in this Privacy Policy, also to adequately protect the confidentiality and privacy of your personal data, and also that any third-parties only process your personal data in accordance with their legitimate business interests.

Please note that these third-parties may be subject to laws that differ from the laws which apply in your country of residence. Please also note that Lewis Curzon Skincare does not actively take steps to ensure that any overseas recipient of your personal data complies with the laws which apply in your country of residence.

If you have any questions, please contact our Data Protection Officer, and we will respond within your local time-frame response requirements. If you wish to complain about an alleged breach of this Privacy Policy and/or our privacy obligations at law, please provide as much detail as possible in relation to your complaint.

Lewis Curzon Skincare will treat any privacy complaint with the utmost seriousness, and any complaint will be assessed with the aim of resolving any issues in a timely and efficient manner.

Australia

For the purposes of this Privacy Policy, “personal data” means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, or opinion is recorded in a material form.

Lewis Curzon Skincare is committed to keeping your personal data secure, and we will use all reasonable precautions to protect your personal data from loss, misuse or unauthorised access or alteration.

However – except to the extent liability cannot be excluded due to the operation of statute – Lewis Curzon Skincare excludes all liability (including in negligence) for any and all consequences of any unauthorised access to, disclosure of, misuse of, or loss or corruption of, your personal data. Nothing in this Privacy Policy shall restrict, exclude or modify – or purport to restrict, exclude or modify – any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).

If you are based in Australia, you may submit a complaint to our Data Protection Officer, who will come back to you within 30 days. If we have not come back to you, or you are not happy with our response to your complaint, you may then submit a complaint to the Office of the Australian Information Commissioner.

Canada

If you submit a request to Lewis Curzon Skincare to stop direct marketing communications, it will take no longer than 10 days to action your request.

As your personal data may be transferred to third-parties outside of your country of residence, local police or other enforcement, regulatory or Government, bodies may have access to your personal data with or without Lewis Curzon Skincare’s knowledge.

The personal data which Lewis Curzon Skincare processes may be accessed by persons within our business, or by persons within our third-party service providers, who may require such access in order to carry out the purposes indicated in this Privacy Policy or such other purposes as may be permitted and/or required by the applicable law. Personal data collected by Lewis Curzon Skincare is maintained primarily in the United Kingdom.

If you feel that your personal data has not been handled correctly by Lewis Curzon Skincare, or you are unhappy with our response to any requests which you have made to us regarding the use of your personal data, please note that you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada, or, in some Canadian provinces, your local Privacy Commissioner.

  1. ANY QUESTIONS

We hope that our Privacy Policy has been helpful in setting out the ways in which Lewis Curzon Skincare will handle your personal data, and setting out your rights to control how your personal data will be handled.

If you have any questions which are not covered by our Privacy Policy, please contact our Data Protection Officer, who will be pleased to help you.

Email us at : [email protected]

Or write to us at : FAO Data Protection Officer, Lewis Curzon Skincare, PO Box 71, ETCHINGHAM TN19 7YR.

This Privacy Policy was last updated on 5 October 2021.