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We are committed to protecting your information and your right to privacy. If you have any questions or concerns about our Policy, or our practices with regards to your personal information, please contact us via firstname.lastname@example.org.
When you use the Services, you trust us with your information and we take your privacy very seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue your use of the Services.
We review this Policy regularly and it is your responsibility to check regularly and determine whether you still agree to comply with the Policy. If you do not agree to any changes to this Policy then you must immediately stop using the Services. In the event we make any significant changes to this Policy we will use our reasonable endeavours to inform you of such changes in advance in writing.
It is important that the personal information we hold about you is true, complete, accurate and current. Accordingly, you must notify us of any changes to your personal information (for example, if you change your email address).
The Services are owned and operated by LionneLtd(trading as “Lionne”), a company registered in England and Wales with company number 11183585, registered office address Soho Works, 7thFloor, 2 Television Centre, 101 Wood Lane, London, W12 7FR(Lionne/we/us/our). We are the controller (also known as a data controller) of, and is responsible for, your personal information. The term “you” refers to the user wishing to access and/or use the Services.The Platform provides a platform for you to book skin consultations with our skin mentors, refer to skincare advice, and shop for skincare products specially selected by us for you.
4.1 Personal information you disclose to us
In Short: We collect personal information that you provide to us including information such as your name, address, contact information,date of birth,job title, social media handles/URLs and payment card information.
(a) Where and how we collect personal information
We collect personal information that you voluntarily provide to us when registering to use and actually using the Services, or otherwise contacting us.
If you apply for a job with us, or work with us for any period of time, or take part in the Lionne Skin School, we also collect your personal information, which may include your contact details, financial and payment details, details of your education, qualifications and skills, your nationality, your NI number, your job title and your CV.
If you give us information on behalf of another individual, for example when putting that individual forward as your emergency/alternate contact or referee or next of kin, or by acting as that individual’s emergency/alternate contact, referee or next of kin, in providing that information to us you are confirming that you have sought and obtained, from that individual, permission for you to:
and you shall indemnify us and hold us harmless against any claims, actions, proceedings, losses, damages, costs (including reasonable legal costs) and expenses (including taxation), in each case of any nature whatsoever, arising out of or in connection with your failure to obtain these permissions.
(b) The types of personal information we may collect
When you use the Services and/or when you otherwise deal with us, we may collect the following information about you (the Information):
4.2 Sensitive personal information
In Short: as part of our consultations, we need to ask you to provide sensitive personal data. If we do, we will explain why we are requesting it and how we will use it.
Sensitive personal information includes information relating to your ethnic origin, political opinions, religious beliefs, whether you belong to a trade union, your physical or mental health or condition, sexual life, and whether you have committed a criminal offence. We will only collect your sensitive personal information with your explicit consent.
We will need to collect sensitive information about your health and lifestyle from you when you have consultations will our skin mentors in order to provide you with skincare advice. When you sign up to the consultation package, we will obtain your specific consent to process this information. You may choose not to answer any of the questions we ask about your health and lifestyle as part of the skin consultation.
4.3 Personal information from third parties
In Short: We may receive information about you from third parties, and we may use this information to provide, improve and personalise the Services.
Occasionally we may receive information about you from other sources which we will add to the information we already hold about you in order to help us provide, improve and personalise the Services. If you apply for a job or role with us, we may also receive information from those who provide references relating to your prospective or actual employment.
4.4 Information automatically collected
In Short: Some Information – such as IP addresses and/or browser and device characteristics – is collected automatically when you use the Platform.
We automatically collect certain Information when you visit, use or navigate the Platform. This Information does not reveal your specific identity (unless your device name is the same as your name) but may include device and usage Information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, Information about how and when you use the Platform and other technical Information. This Information is primarily needed to maintain the security and operation of the Platform, and for our internal analytics and reporting purposes.
Like many businesses, we also collect Information through cookies and similar technologies. You can find out more about this in our Cookies Policy.
In Short: We process your Information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.
We use your Information collected via the Services for a variety of business purposes described below. We process your Information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual Reasons), with your consent (Consent), and/or for compliance with our legal obligations (Legal Reasons). We indicate the specific processing grounds we rely on next to each purpose listed below.
We may process your Information for the following purposes:
In Short: We only share Information for Contractual Reasons, to fulfil our Business Purposes, or with your Consent.
We only share and disclose your Information in the following situations:
We may disclose aggregated, anonymous Information (i.e. Information from which you cannot be personally identified), or insights based on such anonymous Information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Services. In such circumstances we will not disclose any Information which can identify you personally.
In Short: We may transfer, store, and process your Information in countries other than your own, but will take all reasonable steps to ensure it is protected
Whenever we transfer your Information outside of the UK, we will take all reasonably practicable measures to protect your Information in accordance with this Policy and applicable laws. To the extent that any transfer requires approved safeguards to be in place (for example, using the EU model contract clauses in connection with transfers outside of the European Economic Area, or other appropriate safeguards) we will ensure these measures are in place.
Third party websites
In Short: We are not responsible for the safety of any Information that you share with third party providers who feature or advertise, but are not affiliated with, the Services.
The Platform may feature links to third party websites or contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy.
We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Platform. You should review the policies of such third parties and contact them directly if you have any related questions.
In Short: We keep your Information for as long as necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is permitted or required by law.
We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax law, accounting requirements or other legal or regulatory requirements).
When we have no ongoing Business Purpose to justify the processing of your Information, we will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.
In Short: We aim to protect your Information through a system of organisational and technical security measures.
We have implemented appropriate technical and organisational security measures designed to protect the security of any Information we process. For example, we store your personal data on secure servers and company data is stored on separate secure encrypted disks when not in use.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory body of a suspected data breach where we are legally required to do so.
However, please also remember that we cannot guarantee that the Internet itself is 100% secure. Although we will use our reasonable endeavours to protect your Information, we cannot guarantee the security or integrity of personal Information that is transferred from you or to you via the Internet. Transmission of personal Information to and from the Lionne Platform is therefore at your own risk. You should only access our services within a secure environment.
In Short: We take steps to ensure that the Lionne Services are only used by those over 16 years of age and we do not knowingly collect data from or market to children under 16 years of age.
We do not knowingly solicit data from or market to children under 16 years of age. By using the Services, you represent that you are at least 16 years of age. If we learn that Information from users less than 16 years of age has been collected, we will deactivate the relevant account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under 16 years of age, please contact us immediately via email@example.com.
Summary: If you choose to register or log into our website using a social media account, we may have access to certain Information about you.
The Platform may offer you the ability to register and log-in using your third-party social media account details (e.g. Facebook, Twitter etc). Where you choose to do this, we will receive certain Information from your social media provider. The Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture and other Information that you choose to make public. If you log-in using Facebook, we may also request access to other information related to your account, such as friends, check-ins and likes, and you may choose to grant or deny us access to each individual permission.
The Information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by other users of those networks and we have no control over that viewing and use and cannot prevent further use of that Information by third parties.
f you choose to link your Lionne profile to a social media account, Information that you provide to us in the process may be included on your Lionne profile. Additionally, your contacts on the social media platform(s) (Friends) may be able to see your activity on the Platform. A link to your public profile on the social media site may be added to your Lionne profile and other members and users of the Services may be able to see any Friends or links (e.g. friends of Friends) via the social network(s) that you have in common with them.
When you interact with us through social media networks, you acknowledge that we may access your Information that is held by that account, solely in accordance with your social media privacy settings. Any links to social media are not under our control and remain solely your responsibility. You acknowledge that any Information posted via social media through the Platform, or via any third party which you allow to access your content, is posted entirely at your own risk and that by posting to a public platform you make that Information visible to third parties who can use that Information at their discretion.
Please note that we do not control, and are not responsible for, other uses of your Information by your third- party social media provider(s). We recommend that you review their privacy policies to understand how they collect, use and share your Information, and how you can set your privacy preferences on their sites and apps.
You will be required to give Consent to certain processing activities before we can process your Information. Where applicable, we will seek Consent from you when you first submit Information to or through the Services.
If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing firstname.lastname@example.org.
If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information. If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights.
Please note that if we need to process your Information in order for you to use the Services and you object or do not provide Consent to us processing your Information, you accept that the Services will no longer be available to you.
If you have given Consent to marketing we may contact you about our products, services, promotions and special offers. If you no longer wish to receive such Information, you can withdraw your Consent at any time by sending an email to email@example.com or unsubscribing from the communications.
If you have given Consent, we may share your Information with carefully selected third party organisations and business partners and they may contact you directly. If you would prefer to no longer receive direct marketing communications from third parties and partners after previously giving your Consent, please contact those third parties and partners directly to withdraw the Consent.
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us in connection with your purchase of a product or service or your involvement in other related transactions.
You may at any time review or change the Information in your account by logging into your Lionne account. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Platform, you are responsible for keeping this password confidential, notifying us immediately if you suspect that a third party may have obtained it, and regularly changing that password in the interests of keeping your account secure.
If you wish to terminate your Lionne account, please contact us via firstname.lastname@example.org and we can arrange this for you. Some Information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and/or comply with legal requirements.
In Short: You have certain rights in respect of your Information.
You have certain rights in relation to the Information that we hold about you. Details of these rights and how to exercise them are set out below. Please note that we will require evidence of your identity before we are able to respond to any requests. This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further Information in relation to your request to speed up our response. To exercise or discuss any of your rights, please contact us via email@example.com.
If we are relying on Consent to process your Information, you have the right to withdraw your Consent at any time. Please note however that this will not affect the lawfulness of the processing that occurred before the withdrawal of such Consent.
We welcome your feedback and questions on this Policy. If you wish to contact us about this Policy or have any other questions, please email us via firstname.lastname@example.org.
You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
If you would like this policy in another format (for example: audio, large print, braille) please contact us via the details given above.
Claudia Tua Clark