Sourcerie Privacy Policy
Last updated: 23/03/2023
www.sourcerie.co (our website) is provided by Sourcerie Ltd (‘we’, ‘our’ or ‘us’), a beauty technology platform. We are the controller of personal data obtained via our website, email and certain marketing activities, meaning we are the organisation that is legally responsible for deciding how and for what purposes it is used.
At Sourcerie we take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data through your use of our website. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
When we collect and process your personal data we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to any services we provide to individuals in the European Economic Area (EEA).
Who are we?
This privacy policy is issued by Sourcerie Ltd (Sourcerie), a private limited company, incorporated and registered in England under company number 13350633.
Meaning of personal data
Personal data means any information relating to an identified or identifiable individual (known as the data subject). Personal data includes information irrespective of how it is stored. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data. Common examples of personal data include an individual’s name, address, contact information, photograph, IP address and information about the individual such as their age or employment status.
Special category personal data means personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data (when processed to uniquely identify an individual), or data concerning health, sex life or sexual orientation.
Personal data we collect about you
As further explained in this privacy policy, we may collect, use, store and transfer different kinds of personal data throughout our relationship with you. That data may include:
- Identity Data including your name and contact information, username, marital status, title, date of birth and gender.
- Contact Data including your email address and, telephone number, billing and delivery address.
- Financial Data including your payment card details.
- Transactional Data including details about payments from you and other details of products and services you have purchased from us.
- Profile Data including visual images or photographs you provide us with, your interests, preferences, feedback and survey responses, competitions and promotions.
- Usage Data information about how you use our website (which may include location data associated with your use of the website)
The above list is not exhaustive, and Sourcerie may also collect and process other personal data to the extent that this is considered necessary for providing our services or compliance with legal requirements.
If you do not provide personal data we ask for where it is requested (for example, at point of sale), it may delay or prevent us from providing services to you.
Special categories of personal data we collect about you
In addition to personal data, we may also collect, use, store and transfer special categories of personal data throughout our relationship with you. That data may include:
- Data concerning your racial or ethnic origin.
- Data concerning any physical health conditions that you disclose to us.
We collect these special categories of personal data to ensure that the service we provide is uniquely tailored to each of our customers.
How your data is collected
We collect most of your personal and special category data directly from you – in person, by creating an account on our website, by email, through customer surveys, through testing programs, or through your interaction with our website. However, we may also collect information:
- from publicly accessible sources such as online directories, social networks and internet searches
- directly from Sourcerie’s third party partners
- from cookies on our website – for more information on our use of cookies
How we use your personal data
eg:We will only use your personal data where the law allows us to. Most commonly, we will use your data in the following circumstances:
- where you have given consent;
- to comply with our legal and regulatory obligations (referred to as ‘legal and regulatory obligations’ below);
- for the performance of a contract with you or to take steps at your request before entering into a contract (referred to as ‘contractual obligations’ below); or
- for our legitimate interests or those of a third party (referred to as ‘legitimate interests’ below)
A legitimate interest is when we have a reason to use your information in connection with Sourcerie’s activities, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before processing special category data or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
The table below explains what we use your personal data for and why.
Please note that we may process your data for more than one reason depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific reason we are relying on to process your data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Reason for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer |
| Performance of a contract with you |
| To provide our personalised services to you |
| Performance of a contract with you. Please note that we will only process data concerning your health, racial or ethnic origin with your prior consent. |
To process and deliver your order including to:
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To manage our relationship with you which will include:
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| To enable you to partake in a prize draw, competition or complete a survey. |
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| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
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| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
| Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you |
| Necessary for our legitimate interests (to develop our products/services and grow our business) |
Third party links and integrations
Our website may include links to third party websites and third party plug-ins or integrations. Clicking on those links or enabling those connections may allow third parties to collect or share your personal data. We do not control those third party websites or services and we are not responsible for how they collect or use your personal data. When you leave our website, we encourage you to read the privacy policy of every third party website or service you visit.
Marketing
We may use your personal data to send you updates by email about our activities and offerings. We have a ‘legitimate interest’ in using your personal data for marketing purposes. This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at help@sourcerie.co; or
- using the ‘unsubscribe’ link in emails; or
- updating your marketing preferences via our website (if this function is applicable to you).
We will always treat your personal data with the utmost respect and will never share it with other organisations for marketing purposes without your explicit consent.
Who we share your personal data with
We may share your personal data with the parties set out below for the purposes set out in the table. We routinely share personal data with:
- third parties we use to help deliver our services and run our organisation, eg marketing and communications service providers, website hosts, IT and data analytics service providers, our bank or other financial services providers, and professional services providers such as our lawyers and accountants
- third parties specifically approved by you, eg social media channels or other third party services you choose to link your account
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may also need to:
- share personal data with external auditors, eg in relation to industry accreditations or the auditing of our accounts or operations; or
- disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
If you would like more information about who we share our data with and why, pleaseemail us.
Where your personal data is held
Personal data may be held at our offices, on our devices and via cloud services. This includes our third party agencies, service providers, representatives and agents. Some of these third parties may be based outside the UK/EEA - you can safeguard your personal data when this happens.
How long your personal data will be kept
We will keep your personal data for as long as required to continue providing services you have requested, and thereafter only for as long as is reasonably necessary (eg to respond to any questions, complaints or claims made by you or on your behalf) and in compliance with data protection laws. We will not keep your personal data for longer than necessary. When it is no longer necessary to keep your personal data, we will delete or anonymise it.
Transferring your personal data out of the UK and EEA
To deliver our services to you, it may sometimes be necessary for us to share your personal data outside the UK/EEA, eg with service providers located outside the UK/EEA; if you are based outside the UK/EEA; or where there is a European and/or international dimension to the services we are providing to you. Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:
- the UK government (or, where the EU GDPR applies, the European Commission) has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law
These are explained below.
Adequacy decision
We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include all EEA countries, Gibraltar, Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay. The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists. Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal data to another country if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects. The safeguards will usually include using legally-approved standard data protection contract clauses. To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact us.
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, eg you have explicitly consented to the proposed transfer after having been informed of the possible risks; the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request; the transfer is necessary for a contract in your interests, between us and another person; or the transfer is necessary to establish, exercise or defend legal claims. We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
Further information
If you would like further information about data transferred outside the UK/EEA, please contact us.
Your rights
You have the following rights, which you can exercise free of charge:
- Access: The right to be provided with a copy of your personal data.
- Rectification: The right to require us to correct any mistakes in your personal data.
- Erasure (also known as the right to be forgotten): The right to require us to delete your personal data in certain situations.
- Restriction of processing: The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data.
- Data portability: The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
- To object: The right to object at any time to your personal data being processed for direct marketing (including profiling); or in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.
- Request transfer:The right to request that your personal data is transferred to you or a third party.
- Automated decision making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. Sourcerie does not currently engage in such automated decision making but should it do so you have the right to object.
- Withdrawal of consent: Where are relying on consent to process your personal data, you have the right to withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
- contact us
- provide enough information to identify yourself and any additional identity information we may reasonably request from you; and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine operational need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Changes to the privacy policy
We keep our privacy policy under regular review. 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.
How to complain
Please contact us if you have any query or concern about our use of your information. We hope we will be able to resolve any issues you may have. You also have the right to lodge a complaint with the Information Commissioner or any relevant European data protection supervisory authority. The Information Commissioner may be contacted at ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
Changes to this privacy policy
This privacy policy was last updated on the ‘Effective date’ indicated at the top of the page. We may change this privacy policy from time to time—when we do we will inform you via our website or by email.
How to contact us
You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint. Our contact details are as follows: