The Chelsea Laboratory

Last updated 3 October 2024.

1. Introduction
   1. We are Stillbloom Ltd trading as The Chelsea Laboratory, a company registered in England and Wales under company number 08039876 with its registered office at Kemp House, 152 - 160 City Road, London, England, EC1V 2NX (we, us or our). We are the controller responsible for your personal data.
   2. We comply with “Data Protection Laws”, which means the General Data Protection Regulation (EU) (2016/679) (“GDPR”), and any applicable laws, regulations, and other legal requirements relating to:
      1. Privacy, data security, and protection of personal data; and
      2. The processing of any personal data, which may include, but are not limited to, the EU law retained version of the GDPR (“UK GDPR”), the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”).
      We also strive to comply with other state-specific privacy laws as they apply, including the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), and the Utah Consumer Privacy Act (“UCPA”).
   3. We are registered with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk), and our registration number is ZA682434. If you have any concerns about data protection, we would appreciate if you contacted us first so we can discuss these with you before you approach the ICO. For data protection matters, please email us at [email protected].
   4. We respect your privacy and are committed to protecting your personal data. This policy explains the terms on which we collect and process your personal data, and how we protect your personal data, such as when you:
      1. Visit our website at https://thechelsealaboratory.com,
      2. Make a purchase on our website,
      3. Create a subscription on our website,
      4. Contact us with any enquiry, or
      5. Engage with us in any other way.
2. The Data We May Collect About You
   1. Personal data/information means any information about an individual from which that person can be identified. It does not include anonymous data. We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
      1. Identity Data includes your full name, marital status, title, date of birth, and gender.
      2. Contact Data includes home address, delivery address, billing address, email address, and telephone number.
      3. Financial Data includes bank account and payment card details.
      4. Transaction Data includes details about payments to and from you and other details of the products you have purchased from us.
      5. 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 our website.
      6. Profile Data includes your username and password (if applicable), purchases or orders made by you, your interests, preferences, feedback, and survey responses.
      7. Usage Data includes information about how you use our website and services.
      8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
      9. Aggregated Data such as statistical or demographic data for any purpose is not considered personal data in law as this data will not directly or indirectly reveal your identity to us. We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
      10. Special Category Data means special categories of personal data and includes information about your health, race or ethnicity, criminal convictions, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data. Please note that we do not automatically include any such data.
3. How Is Your Personal Data Collected?

   We may use different methods to collect data from and about you including through:

   1. Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding or engaging with us by post, phone, email, social media, making a purchase on our website, creating a subscription, or otherwise.
   2. Automated technologies or interactions. As you interact with our website, we will 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.
   3. Public sources. We may collect personal data about you from public sources, such as Google, Companies House, or the electoral register.
4. How We Use Your Personal Data

   We will only use your personal data when we can rely on a legitimate (lawful) basis, such as:

   1. Contract: Where we need to perform the contract, we are about to enter into or have entered into with you.
   2. Legitimate Interests: 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.
   3. Legal Obligation: Where we need to comply with a legal obligation.
   4. Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example, if you subscribe to an email newsletter.
5. 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 plan to use the various categories of 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.

   Purpose/Use	Type of Data	Lawful Basis for Processing (Including Basis of Legitimate Interest)
   To enable you to submit an enquiry to us, whether via email, through our website or via social media, including but not limited to LinkedIn, Facebook, and Instagram	Identity, Contact	Contract, Legitimate Interests (to enable us to respond to your enquiry)
   To enable you to sign up to make a purchase on our website or to create a subscription, including: (a) Manage shipping and refunds (b) Manage payments, fees, and charges (c) Collect and recover money owed to us	Identity, Contact, Financial, Transaction, Marketing and Communications	Contract, Legitimate Interests (to enable us to recover debts due to us)
   To manage our relationship with you which will include: (a) Notifying you about changes to our terms and conditions or this privacy and cookies policy (b) Dealing with your requests, complaints, and queries	Identity, Contact, Profile, Marketing and Communications	Contract, Legal Obligation, Legitimate Interests (to keep our records updated and manage our relationship with you)
   To enable you to register for our mailing list/email marketing	Identity, Contact, Marketing and Communications	Contract, Consent, Legitimate Interests (to provide you with the newsletter/email marketing and present you with relevant information or services)
   To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)	Identity, Contact, Technical	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), Legal Obligation
   To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity, Contact, Profile, Usage, Marketing and Communications, Technical	Legitimate Interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
   To use data analytics to improve our website, services, marketing, customer relationships, and experiences	Technical, Usage	Legitimate Interests (to define types of customers for our 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	Identity, Contact, Technical, Usage, Profile, Marketing and Communications	Legitimate Interests (to develop our products/services and grow our business)

6. Direct Marketing
   1. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.
   2. We may also analyse your Identity Data, Contact Data, Technical Data, Usage Data, and Profile Data to form a view of which products, services, and offers may be of interest to you so that we can then send you relevant marketing communications.
7. Third-Party Marketing

   We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

8. Opting Out of Marketing
   1. You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at [email protected].
   2. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example, relating to updates to our terms and conditions and checking that your contact details are correct.
9. Cookies
   1. 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.
   2. 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.
   3. We use the following cookies:
      1. 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.
      2. Analytical or performance cookies. These 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.
      3. 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).
      4. 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 so that they can serve you with relevant advertising on their websites.
   4. Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies, performance cookies, or targeting cookies:
      1. TikTok: TikTok uses cookies to track user behaviour and activities on our website, measure the effectiveness of advertising campaigns, and personalise the user experience. These cookies help TikTok gather insights on how users interact with advertisements and track conversions to optimise ad relevance.
      2. Hyros: Hyros cookies collect analytics on how users engage with social media platforms and return to our website. This data allows us to assess the impact of our social media presence and improve the effectiveness of our campaigns.
      3. Google Analytics: Google Analytics is a web analytics service that tracks and reports website traffic. It uses cookies to collect information about how users interact with our website, including how many users visit, which pages they view, how long they stay, and how they arrive (e.g. through a search engine or direct link). This information helps us understand user behaviour and improve our website’s functionality.
      4. Google Tag Manager: Google Tag Manager sets cookies to experiment with the efficiency of advertisements on our website. These cookies allow us to evaluate the performance of advertising efforts and make adjustments to enhance targeting.
      5. Facebook: Facebook uses cookies to display relevant advertisements on its platform or other digital platforms powered by Facebook advertising. These cookies help track user behaviour after visiting the website, allowing for more targeted and personalised ads.
      6. Sourcebuster: Sourcebuster cookies identify the source of user visits (e.g. search engine, referral link) and store behavioural data. These cookies help us better understand user actions and improve the visitor experience by optimising the website's functionality.
   5. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
   6. Information about how to configure your browser to block cookies can be found at:
      1. Google Chrome
      2. Microsoft Edge
      3. Internet Explorer
      4. Firefox
      5. Safari
      6. Safari Mobile
      7. Opera
10. Disclosures of Your Personal Data
    1. We may disclose your information in the following cases:
       1. We can disclose your personal data to staff members in order to facilitate the provision of products to you.
       2. We can disclose your personal data to courier services we engage to deliver the products to you.
       3. We can disclose your personal data 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 policy.
       4. We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006.
       5. We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety, or rights.
       6. We can exchange information with others to protect against fraud or credit risks.
    2. We use a variety of third-party services (sub-processors) as part of our business activities, and you/we will therefore share your personal data with these sub-processors. The types of sub-processors we might use fall into different categories, as follows:
       1. Payment processing services
       2. Order fulfilment service providers
       3. Courier services
       4. Analytics service providers
       5. Event/campaign management service providers
       6. Website management service providers
       7. Information technology and related infrastructure provision
       8. Email delivery services
       9. Our auditors and legal advisors
    3. 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.
11. Data Security
    1. Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data we collect. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business 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.
    2. If there is an incident where we become aware that there has been a data breach, we will let you know without undue delay. We will then take all necessary steps, including informing the ICO, to limit the extent of the breach and to prevent a further recurrence.
    3. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
    4. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our website; any transmission is at your own risk.
12. International Transfers
    1. We may transfer your personal data outside of the UK or the European Economic Area (EEA) where we engage third parties to provide services on our behalf, such as to receive services or deal with payment. Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
       1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
       2. We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.
    2. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.
13. Data Retention
    1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
    2. 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, regulatory, tax, accounting, or other requirements.
    3. 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.
    4. In some circumstances, you can ask us to delete your data: see section 14 below for further information.
    5. In some circumstances, we will 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.
14. Your Legal Rights
    1. You have a number of rights under Data Protection Laws in relation to your personal data. You have the right to:
       1. 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 lawfully processing it.
       2. 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.
       3. Request erasure of your personal data in certain circumstances. 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.
       4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
       5. You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of marketing’ in section 8 for details of how to object to receiving direct marketing communications).
       6. 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.
       7. Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 5 for details of when we rely on your consent as the legal basis for using your 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.
       8. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
          1. If you want us to establish the data's accuracy;
          2. Where our use of the data is unlawful but you do not want us to erase it;
          3. 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;
          4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    2. If you wish to exercise any of the rights set out above, please contact us at [email protected].
    3. 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 could refuse to comply with your request in these circumstances.
    4. 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.
    5. We try to respond to all legitimate requests within one month. Occasionally, it could 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.
15. Notice for California and Other State Residents of Privacy Practices and Rights
    1. If you are a resident of California, Virginia, Colorado, Connecticut, or Utah, you have specific rights regarding your personal information. This section describes your rights and how to exercise them.
    2. California Residents
       1. Right to know and access. You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
          • The categories of personal data we collected about you.
          • The categories of sources for the personal data we collected about you.
          • Our business or commercial purpose for collecting or selling that personal data.
          • The categories of third parties with whom we share that personal data.
          • The specific pieces of personal data we collected about you (also called a data portability request).
       2. Right to delete. You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal data from our records, unless an exception applies.
       3. Right to non-discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
          • Deny you goods or services.
          • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
          • Provide you a different level or quality of goods or services.
          • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
       4. Do not sell my personal data. We do not sell your personal data. However, if in the future we decide to sell personal data, we will update this privacy policy to inform you of your right to opt-out of the sale of your personal data.
       5. Exercising your CCPA rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us. Only you, or someone legally authorised to act on your behalf, may make a verifiable consumer request related to your personal data. We may only respond to two verifiable consumer requests per consumer per 12-month period.
    3. Other State Residents (Virginia, Colorado, Connecticut, Utah)
       1. Right to access and data portability. You have the right to request access to and obtain a copy of your personal data we have collected and maintained.
       2. Right to correct. You have the right to request that we correct any inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing.
       3. Right to delete. You have the right to request that we delete the personal data we have collected from you, subject to certain exceptions.
       4. Right to opt-out. You have the right to opt-out of the processing of your personal data for purposes of:
          • Targeted advertising,
          • Sale of personal data,
          • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
       5. Exercising your privacy rights. To exercise the access, data portability, correction, and deletion rights described above, please submit a verifiable consumer request to us by contacting us. Only you, or someone legally authorised to act on your behalf, may make a verifiable consumer request related to your personal data. We may only respond to a reasonable number of verifiable consumer requests per consumer per 12-month period.
16. 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 policy of every website you visit.

17. Changes to This Privacy and Cookies Policy and Your Duty to Inform Us of Changes
    1. We keep our privacy policy under regular review. This version was last updated on 3 October 2024.
    2. 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, for example, a new address or email address.