GROW YOUR BUSINESS WITH US

Who we are:
The International Institute for Anti-Ageing (“iiaa”) is based at Riverside House, 2a Southwark Bridge Road London SE1 9HA. We offer world class skin consultancy and training to salons across the UK backed up by a range of market leading skin supplements and products available both to salons and direct to end customers.

We operate conscientiously within the requirements of the General Data Protection Regulations 2018 and the Data Protection Act 2018 and other electronic marketing legislation. We work within the principles of fair data processing, namely:

Using information in a way that people would reasonably expect.
Thinking about the impact of our processing.
Being transparent and ensuring that people know how we’ll use their information.

This statement (together with our Terms and Conditions), as may be amended from time to time by updates on this page, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, as data controller and a data processor. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1. What This Privacy Statement Covers

This statement covers how we treat any personal information that we collect and receive either from our website, which for the avoidance of doubt also includes the HUB (“our Website”), or as part of our broader operating processes.

We do not sell or pass on any personal information about our customers, prospective customers, stockists or employees for marketing purposes without their express consent.

Some data we collect may be stored on secure third-party platforms and in these cases, we have satisfied ourselves that these are robust. Some data will be shared with third party suppliers to facilitate order fulfilment – for example our finance partner and logistics providers.We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy statement.

2. Information We Collect

Sending You Marketing Materials
Data Type	Belonging To	Lawful Basis / Bases	Special Condition
Name, address, email etc	End-User Prospects	Consent	n/a
	End-User Customers	Consent / Soft Opt-in	n/a
	B2B Salon Prospects	Consent / Legitimate Interest	n/a
	B2B Salon Customers	Consent / Legitimate Interest	n/a
	B2B Distributor Prospects	Consent / Legitimate Interest	n/a
	B2B Distributor Customers	Consent / Legitimate Interest	n/a
	Training Delegates	Consent / Legitimate Interest	n/a
	College Training Delegates	Legitimate Interest / Soft Opt-in	n/a
Using and Sharing Your Data for Marketing Purposes * see who we share your data with – when you give us consent to – in the section and table immediately below this one
Name and Town	End-User Customers	Consent	n/a
	Salon End-User Customers	Consent	n/a
	Supplier End-User Customers	Consent	n/a
Details of Skin Condition	End-User Customers	Consent	Consent
	Salon End-User Customers	Consent	Consent
	Supplier End-User Customers	Consent	Consent
Before and After Photos and Face Scans	End-User Customers	Consent	Consent
	Salon End-User Customers	Consent	Consent
	Supplier End User Customers	Consent	Consent
Details of Treatments	iiaa End-User Customers	Consent	Consent
	Salon End-User Customers	Consent	Consent
	Supplier End-User Customers	Consent	Consent
Competitions
Name, address, email etc	Salon End-User Customers	Consent	n/a
	Salon Therapist	Consent	n/a
	Salon Customers	Consent	n/a
Details of Skin Condition	Salon End-User Customers	Consent	Consent
Before and After Photos and Face Scans	Salon End-User Customers	Consent	Consent
Details of Treatments	Salon End-User Customers	Consent	Consent
Treatment and Medical Information
Name, address, email, health information, face scan and treatments / products administered	End-User Customers	Consent	Consent
Name, address, email, health information, face scan and treatments / products administered	Training Delegate	Consent	Consent
Name, address, email, health information, face scan and treatments / products administered	iiaa Personnel	Consent	Consent
Name, address, email, health information, face scan and treatments / products administered – and reactions reported	End-User Client and Salon End-User Customers	Consent	Consent
Processing Sales (via telephone, email and the HUB)
Name, address, email etc	iiaa Customers	Contract	n/a
Payment details	Iiaa Customers	Contract	n/a
Customer service details	Iiaa Customers	Contract	n/a
Business Administration
Name, Address, Email etc	Employees	Contract	n/a
Name, Address, Email etc	Prospective Recruits	Contract	n/a
Payroll / HMRC Details	Employees	Contract	n/a
Bank Details	Employees	Contract	n/a
Pension Data	Employees	Contract	n/a
Emergency Contacts	Employees	Contract	n/a
Salary	Employees	Contract	n/a
Holiday	Employees	Contract	n/a
Performance	Employees	Contract	n/a
Medical Information	Employees	Consent	Consent / working capacity of the employee
Criminal Record (driving penalties)	Employees	Consent	Consent / working capacity of the employee
Qualifications and Employment History	Prospective Recruits	Contract	n/a
Qualifications and Employment History	Successful Recruits	Contract	n/a
CCTV	Visitors	Legitimate Interest	n/a
Recorded Calls	Iiaa Customers	Legitimate Interest	n/a

Sharing Your Data
When you give us consent to use your Data for Marketing Purposes (and specifically give us consent to share it with others) we will share it with:
(a) Our UK and Ireland Salon customers
(b) Our international distributors – who will then share it with their salon customers

The current list of our international distributors is at the end of this section.

Please note: the current EU states are Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden.

EEA states are Iceland, Norway and Liechtenstein.

The EEA Joint Committee has ruled that data transfers to the above and also to the following non-EU countries are not “restricted”: Andorra, Argentina, Guernsey, Isle of Man, Israel, Jersey, New Zealand, Switzerland and Uruguay.

The Commission has also made partial findings of adequacy about Canada and the USA:

The adequacy finding for Canada only covers data that is subject to Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). Not all data is subject to PIPEDA. For more details please see the Commission’s FAQs on the adequacy finding on the Canadian PIPEDA.
The adequacy finding for the USA is only for personal data transfers covered by the EU-US Privacy Shield framework.

The Privacy Shield places requirements on US companies certified by the scheme to protect personal data and provides for redress mechanisms for individuals. US Government departments such as the Department of Commerce oversee certification under the scheme.

BY GIVING US YOUR CONSENT TO SHARE YOUR DATA FOR MARKETING PURPOSES YOU ARE ALLOWING YOUR DATA TO BE TRANSFERRED TO SOME COUNTRIES THAT ARE OUTSIDE OF THE ABOVE ARRANGEMENTS – THIS ACTIVITY IS CALLED A “RESTRICTED TRANSFER”. WE ARE ABLE TO MAKE THE RESTRICTED TRANSFER BECAUSE OF AN “EXCEPTION” – IE YOUR EXPLICIT CONSENT / PERMISSION FOR US TO DO SO. FOR YOUR CONSENT TO BE EXPLICIT YOU NEED TO GIVE IT IN AN INFORMED CONTEXT WITH US HAVING TOLD YOU:

The identity of the receiver, or the categories of receiver – as per the following list
The country or countries to which the data is to be transferred – as per the following list
Why we need to make a restricted transfer – ie to share your story with others
The type of data – where you have indicated, your before and after photography and face scans, your conditions, treatments received, testimonials and naming convention you have given us (your contact details will not be passed on)
Your right to withdraw consent in the future
The possible risks involved in making a transfer to those countries outside of the non-restricted areas described where there may not be equivalent or adequate protection for personal data, for example, no local supervisory authority, or no (or only limited) individual data protection or privacy rights.

iiaa makes you aware as above and also that in the interests of protecting your right to withdraw consent, we have in place data sharing agreements with distributors, who will remove your data if we request them to.

Our current international distributors are:

Country	Company Name
Greece & Cyprus	Skin Devotion
Germany	Care Concept GmbH
Canada	Stogryn Sales Ltd
Poland	Protea Anti-Ageing SP zoo
USA	Jane Iredale Mineral Cosmetics
New Zealand	Beauty Care Ltd
Finland	Apellis Oy
Russia	ERSTA
Croatia	Dispomed Promet d.o.o
Belgium	Environ Benelux NV
France	Environ Benelux NV
Luxembourg	Environ Benelux NV
The Netherlands	Environ Benelux NV
Norway	Skintific AS
Hong Kong	STP Mineral Therapy
Japan	MRI inc

Opting Out of Marketing Communications
Subject to paragraph 8, you can follow this link to contact us and unsubscribe to iiaa marketing emails.

IP Addresses and Cookies
We may also collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

We use Google Analytics to analyse the use of this Website. Google Analytics generates statistical and other information about Website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the Website. Google will store this information. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.

We may also obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. Our cookie policy can be viewed here.

Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. You may refuse to accept cookies by activating this setting on your browser, however, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 data transmitted to our site; any transmission is at your own risk. Uses made of the information

Uses made of the information
We use this information held about you in the following ways:

To ensure that content from our site is presented in the most effective manner to you and to your computer
To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
To carry out our obligations arising from any contracts entered into between you and us.
To allow you to participate in interactive features of our service, when you choose to do so.
To notify you about changes to our service.

We may also contact you by email, post or telephone. Please note that where you have provided sensitive data to us, we shall only use your sensitive data for the purpose for which the data was provided to us.

If you do not want us to use your data in this way, or wish to withdraw your consent for use of the data, you can do so by contacting us via telephone on 0208 450 2020 or email at [email protected].

Please note that at the time you contact us, it may be the case that we no longer process, hold or store your personal information/data as data processor, in which case we would advise you of this and the need to contact the data controller.

Disclosure of this information
We may disclose your personal information to third parties:

If iiaa or substantially all of our assets are acquired by a third party, in which case personal data held by it about our customers, prospective customers, stockists, employees or others will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of our customers, prospective customers, stockists or others.
Our site may, from time to time, contain links to and from the websites of our partner networks, clients, affiliates or other external websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these privacy policies. Before you submit any personal data to our site, you may want to check the policies of our client, for whom we are collecting the data, and whom for your purposes is the data controller. In the absence of any details being listed on our site, you may contact us at or on the details provided below.

3. Sharing, Disclosure, and Retention

(a) Sharing. iiaa does not share, sell, rent or trade personal information with any third parties for marketing or promotional purposes unless express consent has been given (see previously).

Where consent has been given, our employees, customers and our customers’ clients are advised to read the second part of section 2 above thoroughly and to check this policy on a regular basis for updates.

Without consent, iiaa does share small quantities of employee data internally for administrative and legal purposes.

It also reserves the right to share data with relevant authorities if compelled to do so to comply with legal obligations. We will use third party payment processors for card transactions to pay for goods and services but these third parties are authorized to use the data only as necessary to provide these services to us and are prohibited from using your personal information for promotional purposes.

(b) Disclosure. iiaa may disclose personal information under the following circumstances:

In certain situations, we may disclose personal data in response to lawful requests by public authorities, including but not limited to national security or law enforcement requests. We may also disclose your personal information as required by law, such as to respond to court orders, or similar legal processes, to establish or exercise our legal rights or, defend against legal claims, or if in our judgment in such circumstances disclosure is required or appropriate.

If we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our various terms of use, or as otherwise required by law.

(c) Retention. We will retain engagement and transactional information relating to customers, stockists and employees for as long as their customer account or employment remains active or as needed to provide our services and where required to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain data that facilitates the issuing of marketing materials to customers, stockists, prospective customers and past customers ongoingly until any such time that we receive a request from them to opt-out.

4. Confidentiality and Security

We use physical, electronic, and procedural safeguards to protect personal information – Our IT arrangements aspire to “Data Protection by Design” and should be able to detect a significant data breach. Where such a breach could result in discrimination, damage to reputation, financial loss, loss of confidentiality or any other significant economic or social disadvantage we will notify the ICO. Where a breach is likely to result in a high risk to the rights and freedoms of individual data subjects, we will also notify those concerned directly and at the earliest practical opportunity. We shall then fully investigate a data breach and implement corrective action to prevent recurrence.

By using our services or providing personal information to us, you are consenting to iiaa communicating with you electronically regarding security, privacy, and administrative issues related to your use of our services. We may post a notice on our Website if a security breach occurs. In these circumstances, we may also send an email to you at the email address you have provided to us.

Data transmissions over the Internet are not 100% secure. Consequently, we cannot guarantee or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we use reasonable efforts to ensure security on our systems.

5. Right to Be Informed

We strive to ensure that all those engaging with us are informed of our arrangements for processing personal data through this Privacy Statement which is linked to from our email signatures and Website home page.

6. Right of Access

We will respond to data requests within 1 month and will only charge for requests that are manifestly unfounded or excessive. If we have grounds to refuse a request we will inform the data subject and make them aware of their right to complain to the ICO or to seek civil action – again within 1 month of receiving the request.

7. Right to Rectification

For personal data obtained directly from a data subject under the legal basis of consent – and obtained indirectly from a data subject under the legal basis of legitimate interest – we will correct any inaccuracies in a data subject’s personal data upon receipt of a request. For personal data held under the legal basis of “Contract” or “Vital Interests” or “Legal Obligations” we will endeavour to correct the data upon request but may not be able to do so if changing the data may conflict with our legal obligations or disadvantage us in a future legal action. In cases where we cannot rectify the data for these reasons we shall inform the data subject and make them aware of their right to complain to the ICO or to seek civil action.

8. Right to Erasure

For personal data obtained directly from a data subject under the legal basis of consent – and obtained indirectly from a data subject under the legal basis of legitimate interest – we will erase a data subject’s personal data upon receipt of a request / opt-out notification. For personal data held under the legal basis of “Contract” or “Vital Interests” or “Legal Obligations” we will endeavour to erase data upon request but will not be able to do so if holding the data is necessary to fulfil our legal obligations or may be necessary as evidence in a future legal action involving us. In cases where we cannot erase the data for these reasons we shall inform the data subject and make them aware of their right to complain to the ICO or to seek civil action.

9. Right to Restrict Processing

For personal data obtained directly from a data subject under the legal basis of consent – and obtained indirectly from a data subject under the legal basis of legitimate interest – we will restrict the processing of a data subject’s personal data upon receipt of a request / opt-out notification. For personal data held under the legal basis of “Contract” or “Vital Interests” or “Legal Obligations” we will endeavour to facilitate the requested restriction upon request but will not be able to do so if restricting the processing of the data prevents us from fulfilling our legal obligations or the current processing of the data may be necessary as evidence in a future legal action involving us. In cases where we cannot restrict the processing of the data for these reasons, we shall inform the data subject and make them aware of their right to complain to the ICO or to seek civil action.

10. Right to Data Portability

For personal data obtained directly from a data subject under the legal basis of consent – we shall provide, upon receiving a request, the data that we hold in a standard, widely accessible format.

11. Right to Object

12. Changes to this Privacy Statement

iiaa reserves the right to revise, modify, or update this statement at any time. We will notify you via email about material changes in the way we treat personal data or by placing a prominent notice on this Website.

13. Contacting iiaa

If you have a privacy concern regarding iiaa, or this statement, you may contact us via [email protected]