Protecting Your Privacy

This Privacy Policy explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we'll store and handle that data, and keep it safe as well as explaining your privacy rights and how the law protects you. We know that there's a lot of information here, but we want you to be fully informed about your rights, and how Medik8 BV, and the Medik8 group of companies, uses your data. We hope the following sections will answer any questions you have but if not, please do get in touch with us.

This Privacy Policy applies to all of our websites, including any websites on sub-domains, extensions and locales we own, and any online platforms, applications and software systems we operate including but not limited to www.medik8.com, and Medik8 Cloud, the Medik8 Magento Platform, and the Medik8 App (our "sites").

It's likely that we'll need to update this Privacy Policy from time to time. Wherever possible we'll notify you of any significant changes, but you're welcome to come back and check it whenever you wish. This notice was last updated on 9th September 2020.

You are probably familiar with Medik8 which is the name of our skincare brand. Medik8, is owned by UK cosmetics manufacturer Medik8 Ltd and Medik8 BV is a subsidiary of Medik8 Ltd. Medik8 BV is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this Privacy Policy).If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below:Email us at privacy (at) medik8.com or write to us at Data Privacy Manager, Medik8, 730 Centennial Park, Elstree, Herts WD6 3SZWe manufacture and sell our Medik8 skincare products throughout the world. This policy applies to you if you are one of our customers, distributors, trainers, therapists or suppliers (or if you work for any of these organisations), candidates for a job with us, or if you are a visitor to our sites. For the purposes of this policy:

Articles – means any of our products or services including but not limited to our Medik8 products,.Business Customer – means one of our business customers who purchase any Articles from us or from one of our Distributors.Candidate – an individual who is applying for a job or for work with us in any capacity including for employment, freelance work, an apprenticeship, internship or otherwise.Customer – means an individual end-customer who purchases or enquires about any Article from us, from one of our Distributors or from one of our Business Customers or otherwise, or who receives a beauty treatment from any clinic or therapist (including a Registered Medik8 Clinic or a Registered Medik8 Therapist), or who otherwise corresponds or interacts with us about our Articles.Employer – means any corporate or unincorporated entity or any other person that employs or engages a Representative.Distributor – means one of our appointed distributors authorised to sell any of our Articles.Distributor Shareholders – means the shareholders of our Distributors.Official Medik8 Stockist – means any business which has a valid and subsisting authorisation from us to use the designation "Official Medik8 Stockist".Registered Medik8 Clinic – means any business which has a valid and subsisting authorisation from us to use the designation "Registered Medik8 Clinic".Registered Medik8 Trainer – means an individual who has a valid and subsisting authorisation from us to use the designation "Registered Medik8 Trainer".Registered Medik8 Therapist – means an individual who has a valid and subsisting authorisation from us to use the designation "Registered Medik8 Therapist".Representative – means any person who acts as an employee, director, officer, partner, contractor or agent of one of our Distributors, Official Medik8 Stockists, Registered Medik8 Clinics, Registered Medik8 Trainers, Registered Medik8 Therapists, or of any other Business Customers.Supplier Personnel – business contacts in our supplier organisations.Therapist – means any person who provides any beauty or other treatment using any of our Articles including any registered Medik8 Therapist.Trainer – means any person who provides training in relation to our Articles or the use of any of our Articles, including any Registered Medik8 Trainer.

Personal data, or personal information, means any information about an individual from which that person can be directly or indirectly identified. It does not include data where the identity has been removed (anonymous and pseudoanonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity and Contact Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, billing address, delivery address, email address and telephone numbers.Transaction Data includes details about payments to and from you and other details of Articles you have purchased from us, and may include your payment card details and/or bank account details.Candidate Data includes your CV, covering letter and application form, details of your qualifications, skills, experience and employment history, details of your current level of remuneration and benefit entitlements, your entitlement to work in the UK, your photograph and information you provide to us during your interview.Representative Data includes names, addresses, contact and identity details (including social media handles, profile picture and any ratings (whether given by consumers, us or others)) of any Representative including any details registered on the Medik8 Cloud.Distributor Shareholder Data includes names, addresses and details of shareholdings of the Distributor's shareholders.Trainer Data includes name, job title and contact details (including social media handles and profile picture) of any trainer, including Registered Medik8 Trainers, details of training undertaken by any trainer, including Registered Medik8 Trainers, records of any assessments taken, and any ratings (whether given by consumers, us or others).Therapist Data includes name, job title and contact details (including social media handles and profile picture) of any therapist, including Registered Medik8 Therapists, details of training undertaken and qualifications achieved by any therapist, including Registered Medik8 Therapists, and records of any assessments taken, ratings (whether given by consumers, us or others) and details of any complaints made about any therapists, including Registered Medik8 Therapists in respect of treatments provided to Customers.Technical and Usage Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access one of our sites, and information about how you use our sites.Profile Data includes your site username and password (encrypted), purchases or orders made by you, your interests, preferences, feedback and survey responses.Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.Special categories of data includes (1) in respect of Customers, a Customer's health details or philosophical beliefs and information in relation to a complaint of an adverse reaction to any of our Articles (including any photo thereof and the Customer's profile picture), and (2) in respect of Candidates, whether or not a Candidate has a disability for which we need to make reasonable adjustments during the recruitment process, and information about a Candidate's race or ethnicity, religious beliefs, sexual orientation and political opinions for equal opportunities monitoring purposes.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. Our sites are not intended for children under the age of 18 and we do not knowingly collect data relating to children under the age of 18.

We use different methods to collect data from and about you.

A. Customers

Direct Interactions. You may give us your Identity and Contact Data, Profile Data, Transaction Data, Marketing and Communications Data and/or Special Categories of Data when you visit our sites to purchase or enquire about our Articles, create an account with us or purchase an Article by phone but don't have (or don't use) an account. You may also give us your information when you engage with us on social media, contact us by any means with queries or complaints, enter prize draws or competitions, complete any surveys, comment on or review our Articles or request marketing information from us.Information from third parties. We may receive your Identity and Contact Data, Profile Data, Customer Data, Marketing and Communications Data and Special Categories of Data from third parties, including from one of our Distributors, Registered Medik8 Clinics, Registered Medik8 Therapists or Business Customers, if you purchased our Articles or received any service from them.
B. Representatives

Direct Interactions. You may give us your Identity and Contact Data, Representative Data, Transaction Data, Marketing and Communications Data when your Employer enters into an agreement with us, when you purchase our Articles from the Medik8 Cloud or from one of our other sites or otherwise and when we correspond with you about our Articles.Information from third parties. We may receive your Representative Data from publicly available sources, such as Companies House. We may also receive Representative Data from your Employer, or from social media platforms.
C. Trainers

Direct Interactions. We collect your Identity and Contact Data and Trainer Data when we correspond with you about our Articles.Information from third parties. We may also receive this data from your employer, who may be one of our Distributors or Business Customers.
D. Therapists

Direct Interactions. We collect your Identity and Contact Data and Therapist Data when we correspond with you about our Articles.Information from third parties. We may also receive this data from your employer, who may be one of our Distributors or Business Customers.
E. Candidates

Direct Interactions. You may give us your Identity and Contact Data, Candidate Data and Special Categories of Data by sending your application and CV to us and when you attend interviews or complete other forms of assessment.Information from third parties. We may receive Identity and Contact Data and Candidate Data from third parties such as your employer, third party databases or from your recruiter.
F. Supplier Personnel

We collect your Identity and Contact Data and Financial Data when we correspond with you about our services, and from publicly available sources such as Companies House.

G. Distributor Shareholders

We collect your Distributor Shareholder Data from our Distributors and from publicly available sources such as Companies House.

H. Automated technologies or interactions:

As you interact with our site, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, traffic logs and other similar technologies. Please see our cookies policy for further details,, a copy of which can be found by accessing the 'Cookies Policy' link within the footer of the site from which you accessed this Privacy Policy.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. The legitimate interests we rely on are set out next to each purpose below.Where we need to comply with a legal or regulatory obligation.
To find out more about the types of lawful basis that we will rely on to process your personal data see section 6.

Generally we do not rely on consent as a legal basis for processing your personal data other than where we send third party direct marketing communications to you via email or text message, where we provide your details to third parties for their direct marketing purposes, communicating with Customers in respect of Customer complaints, or where a Customer provides us with special categories of personal data in order to purchase an Article from us, from one of our Distributors or from one of our Business Customers or otherwise. You have the right to withdraw consent to marketing at any time by contacting us, details are in section 2.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Articles). In this case, we may have to cancel an Article you have with us but we will notify you if this is the case at the time.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us (see section 2) if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us
We may use your Identity and Contact, Technical and Usage, Profile Data and Medik8 Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Articles and offers may be relevant for you (we call this marketing).

If you are a site visitor but are not one of our Customers, you will receive marketing communications from us if you have consented to do so. You may opt out of receiving such marketing at any time. Formally, where we process your personal data to send you marketing communications based on your consent, we rely on the 'consent' legal basis under data protection laws to do so.

If you are a Customer, you will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. Formally, where we process your personal data to send you these marketing communications on the basis that it is in our 'legitimate interests' to do so.

If you are a Representative, you will receive marketing communications from us unless you have opted out of receiving such marketing. Formally, where we process your personal data to send you these marketing communications on the basis that it is in our 'legitimate interests' to do so.

Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of an Article purchase, warranty registration, Article experience or other transactions.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We know how much data security matters to all our Customers, Candidates, Representatives, Supplier Personnel and to anyone who visits or uses one of our sites. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We secure access to all transactional areas of our sites using 'https' technology.

Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Whenever we collect or process your personal data, we'll only keep it for as long as is necessary for the purpose for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

We may share your personal data with our group companies. We sometimes share your personal data with trusted third party service providers.

Examples of the kind of third party service providers we work with are:

IT companies who support our site and other business systems.Our payment processor, which collects and processes Customer payments on our behalf.Operational companies such as delivery couriers (e.g. Royal Mail).Direct marketing companies who help us manage our electronic communications with you (e.g. Mailchimp).Google/Facebook to show you products that might interest you while you're browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our sites. See our cookies policy for details, a copy of which can be found by accessing the 'Cookies Policy' link within the footer of the site from which you accessed this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Here's the policy we apply to those organisations to keep your data safe and protect your privacy:

We provide only the information they need to perform their specific services.They may only use your data for the exact purposes we specify in our contract with them.We work closely with them to ensure that your privacy is respected and protected at all times.If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

We may also disclose your personal data to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

Finally, we may also be required to disclose your personal data in order to comply with applicable law, or to respond to valid legal process from law enforcement or other government agencies, or to protect the users of our sites to prevent spam or attempts to defraud them, or to operate and maintain the security of our sites (e.g. to prevent or stop an attack on our systems or networks).

Sometimes we will need to share your personal data with third parties and suppliers outside the UK or the European Economic Area (EEA), such as Australia or the USA.

Protecting your data outside the UK or the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the UK or the EEA.

For example, this might be required in order to fulfil your order, process your payment details or provide support services.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the UK or the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Privacy Manager (see section 2).

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Policy.

An overview of your different rights

You have the right to request:

Access to the personal data we hold about you, free of charge in most cases.The correction of your personal data when incorrect, out of date or incomplete.That we stop using your personal data for direct marketing (either through specific channels, or all channels).That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Privacy Manager, Medik8, 730 Centennial Park, Elstree, Herts WD6 3SZ or email us at privacy (at) medik8.com. To ask for your information to be amended, please update your online account, or contact our Customer Services team.

If we choose not to action your request we will explain to you the reasons for our refusal.

In certain specified situations you also have the right to request us to port (i.e. transmit) your personal data directly to another organisation, to request your personal data be 'erased' and the right not to be subject to decisions based solely on the basis of automated processing (if applicable). Please contact the Data Privacy Manager using the details set out above if you would like any further information on your rights).

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

Where we rely on our legitimate interest In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We will always comply with your request.

Checking your identity To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

There are several ways you can stop direct marketing communications from us:
- Click the 'unsubscribe' link in any email communication that we send you. We will then stop any further emails from that particular division.
- If you have an account on any site, you may be able to change your preferences within the 'Settings' or 'My Account' area of the particular site.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with your regulator.

We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance.

We hope this Privacy Policy has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven't been covered, please contact the Data Privacy Manager using the details set out below:

Email us at privacy (at) medik8.com or write to us at Data Privacy Manager, Medik8, 730 Centennial Park, Elstree, Herts WD6 3SZ

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.