Nouveau Skin Therpy respects your privacy and is committed to protecting your personal data. Please take the time to review this notice which explains what information we collect about you, how we use it, and your rights.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. Important Information & Who We Are
2. The Data We Collect About You
3. Health Related Data
4. How Your Personal Data Is Collected
5. How We Use Your Personal Data
6. Disclosures Of Your Personal Data
7. International Transfers
8. Data Security
9. Data Retention
10. Your Legal Rights
11. Glossary
Nouveau Skin Therpy respects your privacy and is committed to protecting your personal data. Please take the time to review this notice which explains what information we collect about you, how we use it, and your rights
Purpose of this privacy notice
This privacy notice aims to give you information on how Nouveau Beauty collects and processes your personal data including any data you may provide through our websites or on the telephone or when you sign up to our newsletter, sign up for a cosmetic treatment or a training course, purchase a product or service or take part in a competition.
Our websites are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other such notices, if any, and is not intended to override them.
Consent to transfer of personal data outside of the EEA
Many of our external third parties which provide services to us are based outside the European Economic Area (EEA) or have operations and service centres based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Further information is provided in section 7 below under the heading ‘INTERNATIONAL TRANSFERS’.
By this privacy notice we are informing you that your data may be processed outside the EEA and you are consenting to such processing.
Controller
Nouveau HD Beauty Group Limited is the controller and responsible for your personal data (collectively referred to as ”Nouveau Beauty”, “we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights as a Data Subject under the Data Protection Legislation, please contact the DPO using the details set out below.
Contact details
If you have any queries on any aspect of our Privacy Policy, you can contact our Data Protection Officer using the details below:
Email address: [email protected]
Postal address: Nouveau House, Barnsley Road, South Elmsall, Pontefract, West Yorkshire, WF9 2HR.
Telephone number: 01977 655090
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This privacy policy is dated 4 April 2023. Revisions and updates to our privacy policy may be made from time and time to enable us to protect your data and to comply with our legal obligations.
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.
Third-party links
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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 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.
Except as set out below under the heading ‘HEALTH RELATED DATA’, 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.
We provide treatment services to individuals such as permanent make up treatments and treatments relating to skin, brows, eyelashes and make up.
Before we provide a treatment to an individual we request that the person who is to have the treatment either discloses information about certain types of medical and health related matters or confirms that there is no such information. We will retain this information in our records.
We will obtain the express consent of the individual receiving a treatment to collect and retain this information and to use it in relation to the provision of the treatment and any aftercare or other matters arsing after the treatment.
We will request the express consent of the individual receiving a treatment to the disclosure of the medical and health related information to any Group Company in respect of any cosmetic treatments, goods or services to be provided to that individual by any Group Company.
EXCEPT AS PROVIDED ABOVE, we will not disclose medical or health related information to any other person unless permitted to do so under the Data Protection Legislation.
If you fail to provide personal data
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 contract to provide a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Background and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Facebook Pixel. We use Meta and TikTok Pixels to customise content and advertising for our website visitors and to analyse traffic to our website. We share information about your use of our site with Meta/TikTok to enable more relevant and tailored messaging in our advertising. You can control your privacy settings from here: Meta: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen TikTok: https://support.tiktok.com/en/account-and-privacy/personalized-ads-and-data
Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Braintree. We use Braintree as the provider of our checkout. This means that we might transfer your personal data in the form of contact and order details to Braintree when the checkout is loaded, in order for Braintree to manage your purchase. Your personal data transferred is processed in line with Braintree’s own privacy notice.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
(a) analytics providers including such as Google based inside and outside the EU;
(b) advertising networks which we may use in the future based inside or outside the EU; and
(c) search information providers based inside or outside the EU;
(d) Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Live Chat Inc, Sage Pay, Pay Pal, Royal Mail and UPS plus a financial services provider for credit arrangements which maybe based inside or outside the EU.
Please refer to the Glossary for some further details under the heading External Third Parties.
We will only use your personal data when the law allows us to, including the Data Protection Legislation. Most commonly, we will use your personal data in the following circumstances:
Click www.ico.org.uk to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we intend to rely on consent as the legal basis for processing your personal data. However, there may be other ways in which we may lawfully process your personal data where we do not have your consent and we will rely on these where appropriate 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. Please contact us to do so.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we will primarily rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data relying on more than one lawful ground depending on the specific purpose for which we are using your data.
Please contact us 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.
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Purpose/Activity includes
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Type of data includes
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Lawful basis for processing including basis of legitimate interest includes
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To register you as a new customer
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(a) Identity (b) Contact (c) Background
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Performance of a contract with you
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To provide treatments |
(a) Identity (b) Contact (c) Financial (d) Transaction (E) Health Related
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(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep records of customers who have received treatments in case needed after treatment) (d) Vital Interest
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To process and deliver your order for goods or services including training such as: (a) Manage payments, fees and charges (b) Collect and recover money owed to us
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(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications
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(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
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To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey
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(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Background
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(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)
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To enable you to partake in a prize draw, competition or complete a survey
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(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
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(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)
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To administer and protect our business and its websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
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(a) Identity (b) Contact (c) Technical
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(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
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To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
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(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Background |
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)
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To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
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(a) Technical (b) Usage
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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)
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To make suggestions and recommendations to you about cosmetic treatments, goods or services that may be of interest to you
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(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
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Necessary for our legitimate interests (to develop our products/services and grow our business)
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Marketing and promotional offers from us
We may use your Identity, Contact, Background, 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 cosmetic treatments, products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have given us consent or have requested information from us or purchased cosmetic treatments, goods or services 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.
Third-party marketing
Data collected is stored in the shared Nouveau HD Beauty Group database. We will get your express opt-in consent before we share your personal data with any other company.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by updating your preferences at [email protected].
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a cosmetic treatment, product or service purchase, warranty registration, product or service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
For more information about the cookies we use, please refer to our cookie policy.
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 or we where we are permitted to use it under the Data Protection Legislation.
If you want 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 may share your personal data with Group Companies and with the parties set out below for the purposes set out in the table in paragraph 4 above.
External Third Parties as set out in the Glossary.
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.
Many of our External Third Parties which provide services to us are based outside the European Economic Area (EEA) or have operations and service centres based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
The following are the main services in relation to which your personal data may be processed outside the EEA:
We will when we review the third party companies we use and services provided by them seek to ensure where possible that your personal data is only transferred outside the EEA to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission:
We have put in place appropriate policies and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
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.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
We may have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) as required or to enable us to comply with laws, regulations, and obligations imposed by local or national Governments.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under the Data Protection Legislation in relation to your personal data. These rights include the right to:
Please refer to the Glossary for more information about Your Legal Rights. If you wish to exercise any of the rights referred to above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no 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.
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.
Data protection legislation
Data Protection Legislation means all applicable privacy and data protection laws including the General Data Protection Regulation ((EU) 2016/679) and any applicable national implementing laws, regulations and secondary legislation in England and Wales relating to the processing of Personal Data and the privacy of electronic communications, as amended, replaced or updated from time to time, including the Privacy and Electronic Communications Directive (2002/58/EC) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426).
Group companies
Group Companies means HD Brows, Nouveau Lashes, Nouveau Beauty, Nouveau Beauty Group, or any subsidiary or any holding company of any of these companies from time to time.
Lawful basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External third parties
Your legal rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
