Privacy policy
This privacy policy sets out how Trinny London Limited uses and protects your personal data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
1. IMPORTANT INFORMATION AND WHO WE ARE (paragraph 1)
2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU (paragraph 2)
3. HOW IS YOUR PERSONAL DATA COLLECTED? (paragraph 3)
4. HOW WE USE YOUR PERSONAL DATA (paragraph )
5. DISCLOSURES OF YOUR PERSONAL DATA (paragraph 4)
6. INTERNATIONAL TRANSFERS (paragraph 5)
7. DATA SECURITY (paragraph 6)
8. DATA RETENTION (paragraph 7)
9. YOUR LEGAL RIGHTS (paragraph 8)
10. CONTACT DETAILS (paragraph 9)
12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES (paragraph 11)
13. THIRD PARTY LINKS (paragraph 12)
1. Important information and who we are
This privacy policy gives you information about how Trinny London Limited collects and uses your personal data through your use of this website, including any data you may provide when you register with us, sign up to our newsletter, purchase a product, use our services, take part in a competition, or come to one of our events.
This website is not intended for children and we do not knowingly collect data relating to children.
Trinny London Limited of 2nd Floor 5 Jubilee Place, Chelsea, London, England, SW3 3TD is the controller and responsible for your personal data (collectively referred to as Trinny London, "we", "us" or "our" in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 8), please contact the us using the information set out in the contact details section (paragraph 9).
2. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity Data includes first name, last name, any previous names, 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 bank account and payment card details.
· Transaction Data includes details about payments to and from you and other details of products and services 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, device ID and other technology on the devices you use to access this website.
· Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
· Usage Data includes information about how you interact with and 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.
Processing of Sensitive Information (Special Category Data) If you use our Match2Me services, in order to provide you with highly tailored recommendations, we collect and process details regarding your health (such as skin conditions, allergies, or dermatological history) and your racial or ethnic origin (as it relates to skin tones, pigmentation, and specific care needs).
We process this data based on your Explicit Consent only and such data is strictly used to analyse your profile and generate automated or [manual] product customisation options. You have the right to withdraw your consent to such processing at any time. If you withdraw consent, we will immediately delete this sensitive data, though we may no longer be able to provide custom product recommendations.
· Automated Product Recommendations & Profiling We use fully automated algorithms to analyse the health and race data you provide (such as skin conditions and skin tones) to instantly match you with the best products. We do this based on your Explicit Consent only. As this process relies entirely on technology without human review, you have the right to challenge any automated recommendation, express your point of view, and request that a human specialist review your data to provide manual recommendations. You can exercise this right by contacting us at tlc@trinnylondon.com.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
· Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, 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 services or publications;
· request marketing to be sent to you;
· enter a competition, promotion or survey; or
· give us feedback or contact us.
· 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. Please see cookie section below for further details.
· Third parties or publicly available sources.
Service Providers: We share your personal data with trusted third parties who process personal data on our behalf (for example, hosting, IT support, analytics, payment processing, delivery, customer care tools, fraud prevention, advertising/marketing partners, event providers and technology providers supporting features such as skin analysis). Where service providers process personal data on our behalf, we require them to process data only on our instructions, apply appropriate security measures, and maintain confidentiality.
We may also share personal data:
· with fraud prevention and security providers to help detect and prevent criminal activity (for example, suspicious transactions);
· in connection with a business transaction (such as a merger, acquisition, or sale of assets), with appropriate safeguards; and
· with regulators, law enforcement, courts and authorities where required by law or where necessary to protect rights, safety or prevent fraud.
Profiling and personalised advertising
Building up a picture of you We analyse information about how you use our services (for example, the products you view or buy and how you interact with our website/app) to understand customer preferences, measure marketing effectiveness and provide more relevant content and offers across channels, including online advertising and social media
Personalised advertising and audiences
We may work with advertising and social media partners to show you adverts that are more likely to be relevant and to measure campaign performance. Depending on your choices (including cookie preferences, where required), this may involve:
- using cookies/trackers on our website/app; and/or
- sharing certain identifiers with partners (including hashed identifiers) to create “custom audiences” or similar audience models (including “lookalike” audiences).
You can manage your preferences using our cookie management tool and, where available, via settings on the relevant third-party platforms. For more information, see our cookie section below.
Advertising on third-party platforms
We may run campaigns on third-party platforms (such as Facebook, Instagram, Google, TikTok, Snapchat, Pinterest). In some cases, we may share a hashed version of your contact details (such as email address or phone number) so the platform can match it to its users and help us:
- show our adverts to existing customers; and/or
- reach new audiences with similar characteristics (lookalike audiences).
We do not receive the identity of individuals in a lookalike audience unless they engage with our adverts. We do not share personal data collected directly from you on our site with third parties for their direct marketing purposes unless you have consented.
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
· Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
· Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
· Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
· 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.
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.
|
Data Category |
What Data We May Use |
Why We Use It |
Legal Basis |
|
Identity & Contact Details |
Name, email address, postal address, telephone number, account credentials |
Account creation and management; authentication; order processing; service communications |
Contract; Legitimate Interest |
|
Demographic Information |
Age, gender, optional demographic indicators. |
Segmentation; birthday treats; service optimisation |
Legitimate interest; Consent |
|
Beauty Profile & Preferences |
Skin tone, hair/eye colour, preferences, quiz responses, beauty goals. |
Personalisation; recommendations; user experience |
Legitimate Interest; Explicit consent |
|
Skin Information |
Limited health info (e.g., allergies/reactions) |
Product safety; compliance; customer claims |
Explicit consent; Legitimate Interest, Legal obligations |
|
Transactional |
Purchases, payment method, billing details, order history, refunds |
Transactions; fraud prevention; accounting/audit |
Contract; Legal Obligation; Legitimate Interest |
|
Order Delivery |
Name, address, order details, recipient message |
Delivery via couriers/postal services |
Contract |
|
Technical and Usage |
IP address, device IDs, cookie IDs, browser/OS, logs, session data, language, referrer, usage |
Security; performance; analytics; personalisation; fraud detection |
Legitimate interest; Consent (where required for cookies) |
|
Location |
Approximate location (IP); precise location (opt-in) |
Location-based content; analytics; fraud prevention |
Legitimate interest; Consent (precise location). |
|
Customer Care and Communications |
Emails, chat, SMS/WhatsApp, call recordings (where applicable), logs and correspondence |
Responding to requests; complaint handling; quality assurance; training |
Contract; Legitimate Interest. |
|
Marketing & Communications |
Contact details, preferences, purchase/browsing activity, VIP/store/advisor preferences |
Marketing communications; tailored offers; events; back-in-stock messages |
Consent (electronic direct marketing, subject to applicable “soft opt-in” rules); Legitimate interest (postal marketing and preference/suppression management); Contract (requested service messages such as back-in-stock) |
|
Survey and Feedback |
Survey responses, reviews, ratings, contest submission |
Improve products/services; satisfaction analysis |
Consent; Legitimate Interest |
|
Social media and Public Profile |
Handles, profile information (depending on your settings), public posts and interactions with our brand accounts. |
Community engagement; social listening; complaint handling |
Legitimate Interest; Consent (platform-dependent). |
|
User-Generated Content |
Reviews, photos, videos, comments |
Publishing content; marketing (where permitted); product improvement |
Consent; Legitimate Interest |
|
Behavioural |
Behavioural profiles; predicted preferences; searches/returns |
Personalisation; product development; targeted marketing; analytics |
Legitimate Interest |
|
Optional Additional Information |
Birthday; physical characteristics; optional preferences |
Enhanced personalisation; virtual tools |
Consent; Legitimate Interest |
|
Advertising & Cross-Device Tracking |
Email/device IDs, hashed identifiers, browsing history |
Personalised advertising; measurement; cross-device targeting |
Consent |
|
Behavioural and AI-Powered Experiences |
Prompts (text/images) submitted to AI tools; outputs |
Virtual assistants; recommendations; analytics; safety monitoring |
Consent; Legitimate Interest |
|
Anti-Counterfeit & IP Enforcement Data |
ID data, contact info, purchase history, social handles |
Prevent and investigate counterfeit activity, protect IP, manage enforcement actions, and comply with legal obligations |
Legitimate interest; Legal Obligation |
|
Event/ Image Data |
Photos/videos at events/in-store or submitted |
Marketing and promotional activities |
Consent |
|
Global Account Recognition |
Account info, customer ID, transaction history, preferences |
Recognition across channels for consistent service |
Legitimate Interest |
If you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing, you will receive marketing communications from us.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
You can ask us to stop sending you marketing communications at any time by logging into your account on the website and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links within any marketing communication sent to you or by contacting us at TLC@trinnylondon.com.
Text Messages: To unsubscribe from SMS, find instructions on how to do this in any SMS message that we send you.
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 order confirmations, appointment reminders, updates to our Terms and Conditions and checking that your contact details are correct.
For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy.
4. Disclosures of your personal data
We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
· External Third Parties in the following categories:
- Service providers who provide IT, finance, logistics and system administration services;
- Professional advisers including lawyers, bankers, auditors and insurers; and
- HM Revenue & Customs, regulators and other similar authorities. Marketing agencies and researchers.
- 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 policy.
We require all third party processors 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 provider processors 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.
Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:
We 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. To obtain a copy of these contractual safeguards, please contact us at tlc@trinnylondon.com
We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
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. To obtain a copy of these contractual safeguards, please contact us at tlc@trinnylondon.com
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.
How long will you use my personal data for?
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.
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.
By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see paragraph 8 below for further information.
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.
You have a number of rights under data protection laws in relation to your personal data.
· 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.
· 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 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.
· 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.
· You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING for details of how to object to receiving direct marketing communications).
· 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 (see the table in section 4 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.
· 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:
· If you want us to establish the data's accuracy;
· Where our use of the data is unlawful but you do not want us to erase it;
· 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
· You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us at tlc@trinnylondon.com
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.
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.
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.
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our us in the following ways:
· Email address: tlc@trinnylondon.com
· Postal address: Trinny London Limited, 2nd Floor 5 Jubilee Place, Chelsea, London, England, SW3 3TD
You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. You can find submit any complaint to tlc@trinnylondon.com
11. Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. Historic versions can be obtained by contacting us tlc@trinnylondon.com
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.
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.
