2. Who is Medik8 (Cyprus)?
3. When do we collect your personal data?
4. What sort of personal data do we collect?
5. How do we use your personal data?
6. Why do we use your personal data what legal bases do we rely on?
7. How we protect your personal data
8. How long will we keep your personal data?
9. Who do we share your personal data with?
10. Where your personal data may be processed
11. What are your rights over your personal data?
12. How can you stop the use of your personal data for direct marketing?
13. Contacting the Regulator
14. Any questions?
This Privacy Notice 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 Scribe Commerce Ltd uses your data. We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. 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 08/05/2018.
2. WHO IS Medik8 Cyprus?
You are probably familiar with Medik8 which is the name of our skincare brand we (Scribe Commerce Ltd) distribute in Cyprus. Medik8 is owned by UK cosmetics manufacturer Pangaea Laboratories Ltd. Scribe Commerce Ltd is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice). If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below:
Email us here.
Or write to us at Data Privacy Manager, Medik8 (Cyprus), Scribe Commerce Ltd, 3 Pergamou, Germasogeia, 4041, Cyprus
3. WHEN DO WE COLLECT YOUR PERSONAL DATA?
We use different methods to collect data from and about you including through:
– When you visit our websites, and use your account to buy products.
– When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
– When you create an account with us.
– When you purchase a product by phone but don’t have (or don’t use) an account.
– When you engage with us on social media.
– When you contact us by any means with queries, complaints etc.
– When you enter prize draws or competitions.
– When you choose to complete any surveys we send you.
– When you comment on or review our products and services.
– When you request marketing to be sent to you.
Automated technologies or interactions:
4. WHAT SORT OF PERSONAL DATA DO WE COLLECT?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
– Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
– Contact Data includes billing address, delivery address, email address and telephone numbers. Financial Data includes payment card details.
– Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
– Technical 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 this website.
– Profile Data includes your username and password (encrypted), purchases or orders made by you, your interests, preferences, feedback and survey responses.
– Usage Data includes information about how you use our website, products and services.
– Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 website 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 notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
This website is not intended for children and we do not knowingly collect data relating to children.
5. HOW DO WE USE YOUR PERSONAL DATA?
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.
– 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 in relation to 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, 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
6. WHY DO WE USE YOUR PERSONAL DATA, WHAT LEGAL BASES DO WE RELY ON?
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.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
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)
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, Contact, Technical, Usage and Profile 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 products, services and offers may be relevant for you (we call this marketing).
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.
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 a product/service purchase, warranty registration, product/service 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.
7. HOW WE PROTECT YOUR PERSONAL DATA
We know how much data security matters to all our customers. 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 websites 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.
8. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
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.
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.
Example of customer data retention period:
When you place an order, we’ll keep the personal data you give us for seven years so we can comply with our legal and contractual obligations.
9. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
We sometimes share your personal data with trusted third parties.
Examples of the kind of third parties we work with are:
– IT companies who support our website and other business systems.
– Operational companies such as delivery couriers (e.g. ACS Courier).
– 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 websites. See our Cookies Policy for details.
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.
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 notice.
10. WHERE YOUR PERSONAL DATA MAY BE PROCESSED
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.
Protecting your data outside 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 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 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 Notice.
11. WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA?
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 (Cyprus), Scribe Commerce Ltd, 3 Pergamou, Germasogeia, 4041, Cyprus or email us at here. 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.
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.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must 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 Notice. 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.
12. HOW CAN YOU STOP THE USE OF YOUR PERSONAL DATA FOR DIRECT MARKETING?
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, log in into your medik8 account, visit the ‘My Account’ area and change your preferences.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
13. CONTACTING THE REGULATOR?
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 the Information Commissioner’s Office.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
You can contact them by calling 0303 123 1113. Or go online to www.ico.org.uk/concerns. Please note we can’t be responsible for the content of external websites.
14. ANY QUESTIONS?
We hope this Privacy Notice 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 here
– Write to us at Data Privacy Manager, Medik8 (Cyprus), Scribe Commerce Ltd, 3 Pergamou, Germasogeia, 4041, Cyprus
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.