Privacy Policy
Introduction
Welcome to the Dr Michael Prager Skincare Limited’s privacy notice.
Prager Skincare respects your privacy and is committed to protecting your Personal Data. This privacy notice will inform you as to how we look after your Personal Data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy was last updated in February 2019.
1. Purpose of this privacy notice
This privacy notice aims to give you information on how Prager Skincare collects and processes your Personal Data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.
This website is 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 the other notices and is not intended to override them.
2. Controller
Dr Michael Prager Skincare Limited (registered in England and Wales number 10467516) of 195a Kenton Road, Harrow, Middlesex, HA3 0HD (telephone number (+44) (0) 20 7323 3660) is the controller and responsible for your Personal Data (collectively referred to as "we", "us" or "our" in this privacy notice).
Dr Michael Prager is member of the General Medical Council, British Medical Association and British College of Aesthetic Medicine.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please email us at contact@drmichaelprager.com or write to us at 52 Beauchamp Place, London, SW3 1NY.
3. Third-party links
This website 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.
- The data we collect about you
Personal Data 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).
In Schedule 1, we have set out, in table form, a description of the different types of Personal Data we may collect, use, store and transfer, the ways we plan to use the Personal Data, and the legal justification on which we rely in order to do so. Where we rely on the justification that it is necessary to process the Personal Data for our Legitimate Interests we have, where appropriate, also identified what we consider those Legitimate Interests to be.
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 is your Personal Data collected?
We use different methods to collect data from and about you including through:
(a) Direct interactions.
You may give us your identity, contact and financial data by filling in on-line forms or by corresponding with us by post, telephone, email or otherwise. This includes Personal Data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- give us your details at networking events; or
- give us some feedback.
(b) Automated technologies or interactions.
As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We 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.
(c) Third parties or publicly available sources.
We may receive Personal Data about you from various third parties [and public sources] as set out below
- Technical Data from the following parties:
- (a)analytics providers, such as Google Analytics, based outside the EU;
- advertising networks based [inside OR outside] the EU]; and
- search information providers such as Bing based [inside OR outside] the EU].
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as [NAME] based [inside OR outside] the EU.
- Identity and Contact Data from recommendations and referrals from existing clients and contacts based inside or outside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
6. More information about cookies
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
We use the following cookies:
- Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies or to alert you when websites set or access cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access some parts of this website or they may not function properly.
You can find more information about the individual cookies we use and the purposes for which we use in Schedule 3 below:
- How we use your Personal Data
We will only use your Personal Data when the law allows us to do so. 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.
See Schedule 1 for more details.
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.
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 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.
Generally we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending 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.
We will get your express opt-in consent before we share your Personal Data with any company outside Prager Skincare for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting us at any time.
You can opt out of targeted advertising by using the links below:
Facebook: https://www.facebook.com/settings/?tab=ads
Google: https://www.google.com/settings/ads/anonymous
Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
[INCLUDE OPT-OUT LINKS FROM ANY OTHER SERVICES BEING USED]
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
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.
- Disclosures of your Personal Data
We may have to share your Personal Data for the purposes set out in Schedule 1 with external third parties such as:
- Shopify, which powers our online store--you can read more about how Shopify uses your Personal Data at https://www.shopify.com/legal/privacy.
- Google Analytics, who help us understand how our customers use our website -- you can read more about how Google uses your Personal Information at https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics at https://tools.google.com/dlpage/gaoptout.
- Service providers acting as processors such as [NAMES] in [SPECIFIC COUNTRIES] who provide IT and system administration services, delivery couriers, warehouses, order packers, professional service providers such as advertising agencies and online consultancies and advertisers on Facebook.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
We may also share your Personal Data, in strict confidence, with 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.
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.
- International transfers
We do not transfer your Personal Data outside the European Economic Area (EEA).
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
- Data security
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 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.
- For how long will you use my Personal Data?
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.
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.
By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.
- Your legal rights
Data protection laws gives you a number of rights, under specified circumstances in relation to your Personal Data. These rights, and how to exercise them, are described in more detail in Schedule 2.
SCHEDULE 1
TYPES OF PERSONAL DATA, AND LEGAL JUSTIFICATION FOR HOW WE WILL USE IT
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.
In the table below, we use the following abbreviations:
Type of data
1 = Identity Data [for yourself and other relevant members of your family] such as first name, maiden name, last name, username or similar identifier, marital status, title, age, date of birth and gender.
2 = Contact Data such as your name, title, billing address, delivery address, email address and telephone numbers.
3 = Financial Data such as bank account and payment card details.
4 = Transaction Data such as details about payments to and from you and other details of products and services you have purchased from us.
5 = Technical Data about the devices you use to access this website, such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, platform and other technology.
6 = Profile Data such as your username and password, your social media user name, purchases or orders made by you, your interests, preferences, feedback and survey responses, personal information included in your entries to any competitions that we run, how you found out about us and what you typed into Google or other search engines to find us.
7 = Usage Data such as information about how you use our website, products and services and about your visits to and use of our website including your referral source, length of visit, page views and website navigation.
8 = Marketing and Communications Data such as 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.
Legal justification for processing
A = We process your Personal Data because 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.
B = We process your Personal Data because it is necessary for compliance with a legal or regulatory obligation to which we are subject.
C = We process your Personal Data because it is necessary for the legitimate interests 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
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 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.
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
To register you as a new customer |
1, 2 |
A |
To process and deliver your order including: (a) Deliver the goods or services purchased through our website (b) Send statements and invoices (c) Manage payments, fees and charges (d) Collect and recover money owed to us |
1, 2, 4, 8 |
A, C (to recover debts due to us) |
To manage our relationship with you which will include: (a) Sending you general non-marketing commercial communications; (b) Sending you email notifications which you have specifically requested; (c) Sending you our newsletter and other marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you; (d) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
1, 2, 6, 8 |
A, B, C (to keep our records updated and to study how customers use our products/services) |
To enable you to particpate in a prize draw, competition or complete a survey |
1, 2, 6, 8 |
A, C (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, dealing with enquiries and complaints made by or about you relating to the website, data analysis, testing, system maintenance, support, reporting and hosting of data, security and fraud prevention) |
1, 2, 5 |
B, C (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) |
To improve your browsing experience by personalising the website and delivering relevant website content and targeted advertising to you, to enable your use of the services available on the website, and to measure or understand the effectiveness of the advertising we serve to you |
1, 2, 5, 6, 7, 8
|
C (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 |
5, 7 |
C (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 |
1, 2, 5, 6, 7 |
C (to develop our products/services and grow our business) |
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
SCHEDULE 2
YOUR LEGAL RIGHTS
You have the following rights with regard to the Personal Data we hold about you, namely the right to:
(a) Request access to your Personal Data (commonly known as a "subject access request").
This enables you to receive a copy of the Personal Data we hold about you and to check that we are processing it lawfully.
(b) 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.
(c) 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.
(d) Object to processing of your Personal Data
This applies 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.
(e) Request restriction of processing of your Personal Data.
This enables you to ask us to suspend the processing of your Personal Data where:
(i) you want us to establish the data's accuracy;
(ii) our use of the data is unlawful but you do not want us to erase it;
(iii) you need us to hold the data even if we no longer require it because you need it to establish, exercise or defend legal claims; or
(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) Request the transfer of your Personal Data to you, or to a third party you have chosen, in a structured, commonly used, machine-readable format.
This applies only where you initially provided the Personal Data to us in electronic form and (i) we needed to use it to perform a contract with you, or (ii) we are relying on your consent to process the Personal Data.
(g) Withdraw consent at any time
This is relevant only where we are relying on such consent to process your Personal Data. It will not affect the lawfulness of any processing carried out before you withdraw your consent and it will, of course, not affect the lawfulness of any processing which is not reliant on your consent. Please note that, if you withdraw a consent on which we are relying, we may not be able to provide certain products or services to you.
If you wish to exercise any of the rights set out above, please email us at contact@drmichaelprager.com or write to us at 52 Beauchamp Place, London, SW3 1NY.
You can opt out of targeted advertising by using the links below:
Facebook: https://www.facebook.com/settings/?tab=ads
Google: https://www.google.com/settings/ads/anonymous
Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
[INCLUDE OPT-OUT LINKS FROM ANY OTHER SERVICES BEING USED]
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Notes:
1. You will not have to pay a fee to exercise any of the above rights. However, we may refuse to comply with a subject access request access or, alternatively, may charge a reasonable fee if the request is clearly unfounded, repetitive or excessive.
2. We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of the above 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.
3. We try to respond to all legitimate requests within one month but, if your request is particularly complex or you have made a number of requests, it may take us longer. In this case, we will notify you and keep you updated.
4. 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.
SCHEDULE 3
COOKIES ON OUR WEBSITE
Shopify places the following cookies for visitors of our website
Necessary for the Functioning of the Store |
|
Name |
Purpose |
_ab |
Used in connection with access to admin. |
_orig_referrer |
Used in connection with shopping cart. |
_secure_session_id |
Used in connection with navigation through a storefront. |
Cart |
Used in connection with shopping cart. |
cart_sig |
Used in connection with checkout. |
cart_ts |
Used in connection with checkout. |
checkout_token |
Used in connection with checkout. |
Secret |
Used in connection with checkout. |
Secure_customer_sig |
Used in connection with customer login. |
storefront_digest |
Used in connection with customer login. |
Reporting and Analytics |
|
Name |
Purpose |
_landing_page |
Track landing pages. |
_orig_referrer |
Track landing pages. |
_s |
Shopify analytics. |
_shopify_fs |
Shopify analytics. |
_shopify_s |
Shopify analytics. |
_shopify_sa_p |
Shopify analytics relating to marketing & referrals. |
_shopify_sa_t |
Shopify analytics relating to marketing & referrals. |
_shopify_uniq |
Shopify analytics. |
_shopify_visit |
Shopify analytics. |
_shopify_y |
Shopify analytics. |
_y |
Shopify analytics. |
tracked_start_checkout |
Shopify analytics relating to checkout. |
In addition, when visitors load Shopify’s websites, Shopify generally places the following cookies: |
|
Necessary for the Functioning of the Store |
|
Name |
Purpose |
_Brochure_session |
Used in connection with browsing through site. |
Name |
Purpose |
_landing_page |
Track landing pages. |
_orig_referrer |
Track landing pages. |
_s |
Shopify analytics. |
_shopify_fs |
Shopify analytics. |
_shopify_s |
Shopify analytics. |
_shopify_sa_p |
Shopify analytics relating to marketing & referrals. |
_shopify_sa_t |
Shopify analytics relating to marketing & referrals. |
_shopify_uniq |
Shopify analytics. |
_shopify_visit |
Shopify analytics. |
_shopify_y |
Shopify analytics. |
_y |
Shopify analytics. |
ab_test_3190590030 |
Shopify analytics. |
cart_sig |
Shopify analytics. |
ki_r |
Shopify analytics. |
ki_r |
Shopify analytics. |
ki_t |
Shopify analytics. |
ki_t |
Shopify analytics. |
Additionally, Shopify uses pixels and tags from the following third parties, which may in turn place cookies For more information, see the third party Privacy Policies at the addresses indicated below |
|
Name |
Purpose |
Alexa Metrics
|
To help measure how users interact with Shopify’s websites. |
Bugsnag
|
To help Shopify troubleshoot and fix issues with its websites. |
Chartbeat
|
To help measure how users interact with Shopify’s websites. |
Crazy Egg
|
To help measure how users interact with Shopify’s websites. |
Fullstory
|
To help measure how users interact with Shopify’s websites. |
Google Analytics
|
To help measure how users interact with Shopify’s websites. |
Hotjar |
To help measure how users interact with Shopify’s websites. |
KissInsights
|
To help measure how users interact with Shopify’s websites. |
LinkedIn Analytics
|
To help measure how users interact with Shopify’s websites.
|
New Relic
|
To help measure how users interact with Shopify’s websites. |
Optimizely
|
To help Shopify test improvements or changes to its websites. |
Advertising |
|
Name |
Purpose |
Bing Ads
|
To deliver targeted advertisements to individuals who visit Shopify’s websites. |
Drift
|
To help Shopify with conversational marketing to customers while they visit its websites https://www.drift.com/privacy-policy/
|
Facebook Custom Audiences
|
To deliver targeted advertisements to individuals who visit Shopify’s websites. https://www.facebook.com/policy.php
|
Google Doubleclick
|
To deliver targeted advertisements to individuals who visit Shopify’s websites. https://policies.google.com/privacy
|
Intercom
|
To manage Shopify’s relationships with its customers. https://www.intercom.com/terms-and-policies#privacy
|
Marketo
|
To manage Shopify’s relationships with its customers. https://documents.marketo.com/legal/privacy/
|
SourceKnowledge
|
To deliver targeted advertisements to individuals who visit Shopify’s websites. http://www.sourceknowledge.com/privacy
|
Quora
|
To deliver targeted advertisements to individuals who visit Shopify’s websites. https://www.quora.com/about/privacy
|
Social Media & Content |
|
Name |
Purpose |
Disqus
|
To provide commenting capabilities on posts on Shopify’s websites. https://help.disqus.com/terms-and-policies/disqus-privacy-policy
|
Facebook Connect
|
To allow visitors to Shopify’s website to interact with and share content via Facebook’s social media platform. https://www.facebook.com/policy.php
|
Gravatar
|
To allow visitors to Shopify’s websites to create avatars. |
|
To allow visitors to Shopify’s website to interact with and share content via Twitter’s social media platform. |
Wistia
|
To display video content. |