This Policy applies as between you, the User of this Website and NaturaSKIN

the owner and provider of this Website. This Policy applies to our use of any

and all Data collected by us in relation to your use of the Website.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Data” means collectively all information that you submit to the NaturaSKIN

via the Website. This definition shall, where applicable, incorporate the

definitions provided in the Data Protection Act 1998;

“Cookie” means a small text file placed on your computer by this Website

when you visit certain parts of the Website and/or when you use certain

features of the Website. Details of the cookies used by this Website are set

out in Clause 12;


means NaturaSKIN of;

“UK and EU Cookie Law” means the Privacy and Electronic Communications

(EC Directive) Regulations 2003 as amended by the Privacy and Electronic

Communications (EC Directive) (Amendment) Regulations 2011;

“User” means any third party that accesses the Website and is not employed

by NaturaSKIN and acting in the course of their employment; and

“Website” means the website that you are currently using (

and any sub-domains of this site (e.g. unless

expressly excluded by their own terms and conditions.

2. Scope of this Policy

This Policy applies only to the actions of NaturaSKIN and Users with respect

to this Website. It does not extend to any websites that can be accessed from

this Website including, but not limited to, any links we may provide to social

media websites.

3. Data Collected

Without limitation, any of the following Data may be collected by this Website

from time to time:

3.1 [name;]

3.2 [date of birth;]

3.3 [gender;]

3.4 [job title;]

3.5 [profession;]

3.6 [contact information such as email addresses and telephone numbers;]

3.7 [demographic information such as post code, preferences and interests;]

3.8 [financial information such as credit / debit card numbers;]

3.9 [IP address (automatically collected);]

3.10 [web browser type and version (automatically collected);]

3.11 [operating system (automatically collected);]

3.12 [a list of URLs starting with a referring site, your activity on this Website,

and the site you exit to (automatically collected); and]

4. Our Use of Data

4.1 Any personal Data you submit will be retained by NaturaSKIN for six


4.2 Unless we are obliged or permitted by law to do so, and subject to Clause

5, your Data will not be disclosed to third parties. This [includes] OR [does not

include] our affiliates and / or other companies within our group.

4.3 All personal Data is stored securely in accordance with the principles of

the Data Protection Act 1998. Fore more details on security see Clause 11


4.4 Any or all of the above Data may be required by us from time to time in

order to provide you with the best possible service and experience when

using our Website. Specifically, Data may be used by us for the following


4.4.1 [internal record keeping;]

4.4.2 [improvement of our products / services;]

4.4.3 [transmission by email of promotional materials that may be of interest

to you;]

4.4.4 [contact for market research purposes which may be done using email,

telephone, fax or mail. Such information may be used to customise or update

the Website.]

5. Third Party Websites and Services

5.1 NaturaSKIN may, from time to time, employ the services of other parties

for dealing with matters that may include, but are not limited to, payment

processing, delivery of purchased items, search engine facilities, advertising

and marketing. The providers of such services [do not] have access to certain

personal Data provided by Users of this Website.

5.2 [Any Data used by such parties is used only to the extent required by

them to perform the services that NaturaSKIN requests. Any use for other

purposes is strictly prohibited. Furthermore, any Data that is processed by

third parties shall be processed within the terms of this Policy and in

accordance with the Data Protection Act 1998.]

6. Links to Other Websites

This Website may, from time to time, provide links to other websites.

NaturaSKIN has no control over such websites and is in no way responsible

for the content thereof. This Policy does not extend to your use of such

websites. Users are advised to read the privacy policy or statement of other

websites prior to using them.

7. Changes of Business Ownership and Control

7.1 NaturaSKIN may, from time to time, expand or reduce our business and

this may involve the sale and/or the transfer of control of all or part of

NaturaSKIN. Data provided by Users will, where it is relevant to any part of

our business so transferred, be transferred along with that part and the new

owner or newly controlling party will, under the terms of this Policy, be

permitted to use the Data for the purposes for which it was originally supplied

to us.

7.2 In the event that any Data submitted by Users is to be transferred in such

a manner, you will [not] be contacted in advance and informed of the

changes. [When contacted you [not] be given the choice to have your Data

deleted or withheld from the new owner or controller.]

8. Controlling Use of Your Data

8.1 Wherever you are required to submit Data, you will be given options to

restrict our use of that Data. This may include the following:

8.1.1 use of Data for direct marketing purposes; and

8.1.2 sharing Data with third parties.

9. Your Right to Withhold Information

9.1 You may access [certain areas of] the Website without providing any Data

at all. [However, to use all features and functions available on the Website

you may be required to submit certain Data.]

9.2 You may restrict your internet browser’s use of Cookies. For more

information see Clause 12.

10. Accessing your own Data

You have the right to ask for a copy of any of your personal Data held by

NaturaSKIN (where such data is held) on payment of a small fee which will

not exceed £75.

11. Security

11.1 Data security is of great importance to NaturaSKIN and to protect your

Data we have put in place suitable physical, electronic and managerial

procedures to safeguard and secure Data collected via this Website.


12. Cookies

12.1 This Website may place and access certain first party Cookies on your

computer. First party cookies are those placed directly by NaturaSKIN via this

Website and are used only by NaturaSKIN. NaturaSKIN uses Cookies to

improve your experience of using the Website and to improve our range of

[products] AND/OR [services]. NaturaSKIN has carefully chosen these

Cookies and has taken steps to ensure that your privacy is protected and

respected at all times.

12.2 By using this Website you may receive certain third party Cookies on

your computer. Third party cookies are those placed by websites and/or

parties other than NaturaSKIN. Third party cookies are used on this Website

for advertising services. These cookies are not integral to the services

provided by the Website.

12.3 All Cookies used by this Website are used in accordance with current UK

and EU Cookie Law.

12.4 Before [any] Cookies are placed on your computer[, subject to sub-

Clause 12.5] AND/OR [sub-Clause 12.8], you will be presented with a pop-up.

requesting your consent to set those Cookies. By giving your consent to the

placing of Cookies you are enabling NaturaSKIN to provide the best possible

experience and service to you. You may, if you wish, deny consent to the

placing of Cookies; however certain features of the Website may not function

fully or as intended. [You will be given the opportunity to allow only first party

Cookies and block third party Cookies.]

12.5 [Certain features of the Website depend upon Cookies to function. UK

and EU Cookie Law deems these Cookies to be “strictly necessary”. These

Cookies are shown below. Your consent will not be sought to place these

Cookies. You may still block these cookies by changing your internet

browser’s settings as detailed below.]

12.6 This Website uses analytics services provided by Google. Website

analytics refers to a set of tools used to collect and analyse usage statistics,

enabling us to better understand how Users use the Website. This, in turn,

enables us to improve the Website and the [products] AND/OR [services]

offered through it. You do not have to allow us to use these Cookies, as

detailed below, however whilst our use of them does not pose any risk to your

privacy or your safe use of the Website, it does enable us to continually

improve our business.

12.7 The analytics services used by this Website use Cookies to gather the

required information. [Certain of these Cookies may be placed immediately

when you decide to visit the Website and it may not be possible to obtain your

prior consent. You may remove these Cookies and prevent future use of them

by following the steps set out below.]

12.8 The analytics services used by this Website use the following Cookies:

12.9 You can choose to enable or disable Cookies in your internet browser.

Most internet browsers also enable you to choose whether you wish to disable

all cookies or only third party cookies. By default, most internet browsers

accept Cookies but this can be changed. For further details, please consult

the help menu in your internet browser.

12.10 You can choose to delete Cookies at any time however you may lose

any information that enables you to access the Website more quickly and

efficiently including, but not limited to, personalisation settings.

12.11 It is recommended that you ensure that your internet browser is up-to-

date and that you consult the help and guidance provided by the developer of

your internet browser if you are unsure about adjusting your privacy settings.

13. Changes to this Policy

NaturaSKIN reserves the right to change this Policy as we may deem

necessary from time to time or as may be required by law. Any changes will

be immediately posted on the Website and you are deemed to have accepted

the terms of the Policy on your first use of the Website following the