privacy-policy

Effective Date: August 1, 2024

This Privacy Policy describes how Revu Skin Limited, ta Revu and our brands and subsidiaries (“Revu”, “we”, “us”, or “our”) collect, use and share information about you. This policy applies to information we collect when you use our websites, apps, shop in our online stores or otherwise interact with us as described below (collectively, the “Site”). We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some cases, we may provide you with additional notice (such as adding a statement to the homepages of our websites or sending you an email notification). We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy. Capitalised terms not defined herein shall have the meanings ascribed thereto in our Terms & Conditions.

Acceptance Of These Terms

By using this Site, you signify your acceptance of this policy and any changes to this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Collection Of Information

We collect information from you directly, automatically when you visit the Sites, and sometimes from third parties. Some of this information may be considered "Personal Information" or “Personal Data,” and some of which may be considered “sensitive,” under various applicable laws. We consider information that identifies you as a specific, identified individual to be personal information (such as your name, phone number, email address), and we treat additional information, including IP addresses and cookie identifiers, as "personal information" where required by applicable law. And, if we combine information that we consider to be non-personal with personal information, we will treat that combined information as personal information under this Privacy Policy. Note that we may de-identify or pseudonymous personal information so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using a function commonly known as a "hash". We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. We will treat de-identified or pseudonymized information as non-personal to the fullest extent allowed by applicable law. 

Information You Provide to Us. We collect information you provide directly to us. For example, we collect information when you use our websites, shop in our online stores, call us on the phone, create an online account, join our subscription and loyalty programs, sign up to receive our emails, participate in a sweepstakes, contest, promotion or survey, communicate with us via third party social media sites, request customer support, apply for a job or otherwise communicate with us. This Site collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The types of Personal Information we may collect includes your name, email address, post code, billing address, shipping address, phone number, payment card information, product preferences, demographic information and any other information you choose to provide. In some cases, we may also collect information you provide about others, such as when you purchase a gift card for someone and request that we deliver it electronically, create and share a “wish list” or decide to purchase and ship products to someone. We will use this information to fulfil your requests and may also use that information to send marketing communications to your contact, unless he or she has previously opted out of marketing communications from Revu.

Information We Collect Automatically. We automatically collect certain information about you when you access or use our websites or transact business with us, including: (i) information about your use of our websites, such as the type of browser you use, access times, pages viewed, your IP address and the referring link through which you accessed our websites; (ii) information about the transaction, such as product details and the date and location of the purchase/return; and (iii) we may use cookies, web beacons, also known as “tracking pixels”) and other tracking technologies to collect information about you when you interact with our websites or emails, including information about your browsing and purchasing behaviour. We may combine this information with other information we collect about you and use it for various purposes, such as improving our websites and your online experience, understanding which areas and features of our sites are popular, counting visits, understanding campaign effectiveness, tailoring our communications with you, determining whether an email has been opened and links within the email have been clicked and for other internal business purposes.

Retention and Transfer of Personal Information.  We retain Personal Information that you provide us as long as we consider it potentially useful in contacting you about our products and services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements. We will delete this information from the servers at an earlier date if you so request by unsubscribing, opting-out, or emailing us at hello@revuskin.com. Personal Information may be transferred and stored to secure servers in the United Kingdom.

Use Of Information 

We may use information about you for various purposes, including to: (i) facilitate and improve your online shopping experience; (ii) provide the products and services you request, process transactions and send you related information, including confirmations and receipts; (iii) respond to your comments, questions and requests and provide customer service; (iv) communicate with you about products, services, offers, promotions, rewards and events and provide news and information we think will be of interest to you; (v) manage your online account(s) and send you technical notices, updates, security alerts and support and administrative messages; (vi) personalise your online experience and provide advertisements, content or features that match your profile and interests; (vii) monitor and analyse trends, usage and activities; (viii) process and deliver contest, promotion and sweepstakes entries and rewards; (ix) link or combine with information we get from others to help understand your needs and provide you with better service; and (x) carry out any other purpose for which the information was collected. We are based in the United Kingdom and the information we collect is governed by UK law. By accessing or using our websites or otherwise providing information to us, you consent to the processing and transfer of information in and to the UK and other countries.

Text marketing: With your permission, we may send text messages about our store, new products, and other updates. Updates include Checkout Reminders. Webhooks will be used to trigger the Checkout Reminders messaging system. 

Your Information Choices and Control

Revu respects your need to access and control your Personal Information, so we give you certain choices that you may exercise, including:

  • You may correct, update, and delete your account.
  • You may change your choices for subscriptions, newsletters, and alerts.
  • You may choose whether to receive from us offers and promotions for our products and services, or products and services that we think may be of interest to you.
  • You may request access to the Personal Information we hold about you and that we amend or delete it. Please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but residual copies may remain in our Site’s back-up systems due to the nature of those systems’ operations.
  • We may also retain your information for fraud or similar purposes.

You can exercise these controls and choose to opt in or out of services and communications through the website or following the instructions directly provided in the communications we send you. Please email hello@revuskin.com if you need assistance. 

Sharing of Information

We may share information about you as follows: (i) with vendors, consultants and other service providers who need access to such information to carry out work on our behalf; (ii) in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process or as otherwise required by any applicable law, rule or regulation; (iii) if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of us or any third party; (iv) in connection with, or during negotiations of, any merger, sale of company assets, financing or transfer of all or a portion of our business to another company; or (v) with your consent or at your direction. We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. We do not share your personal information that we have collected directly from you on our Site with third parties for those third parties’ direct marketing purposes unless you have consented (either through an opt-in or opt-out opportunity) at the time you provide your personal information.

Advertising and Analytics 

We engage third parties to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of our websites, such as your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by us and others to, among other things, analyse and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our websites and other websites and better understand your online or offline activity. We may also work with third parties to serve ads to you as part of a customised campaign on other websites or platforms. For a detailed description of the ways in which we and third parties collect information automatically and how it is used, please see our Cookie Policy.

Links To 3rd Party Websites

Our Site may contain links to other websites. Our Privacy Policy does not apply to the practices of other websites and Revu is not responsible for the actions and privacy policies of third parties. We encourage you to be aware of when you leave our Site and to read the privacy policies of each website that you visit.

Security

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction.  We use organisational, procedural, and technical safeguards to secure data in our possession, consistent with the sensitivity level of such data. When sensitive information (such as a credit card data) is collected on our Site it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol and may be processed by third parties using similar levels of protection. Regardless of the precautions we take, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. While we strive to protect Personal Information, we cannot ensure or warrant the security of any information you transmit to us.

Other Data Protection Rights

Under certain international data privacy laws, including the General Data Protection Regulation (GDPR), the Personal Information Protection and Electronic Documents Act (PIPEDA) you may have additional data protection rights. If you are in the EU or UK, you have certain additional rights and protections under the law regarding the collection and processing of your Personal Data. We will comply with applicable data protection laws anytime that we transfer your Personal Data outside of the European Economic Area (“EEA”). You may have the following data protection rights:

  • To access, correct, update or request deletion of Personal Information. We take reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. As a registered user, you can manage many of your individual account and profile settings within your account provided through the Site using the cookie banner, or you may contact us directly by emailing us at hello@revuskin.com. We will consider your request in accordance with applicable laws.
  • In addition, individuals who are residents of the EEA can object to processing of their Personal Information, ask to restrict processing of their Personal Information or request portability of their Personal Information. You can exercise these rights by using the cookie banner provided through the site.
  • Similarly, if Personal Information is collected or processed on the basis of consent you can withdraw consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
  • EEA residents have the right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority.

Contact details for data protection authorities in the EEA are available at the Data Protection Authorities web page.

Please make requests under GDPR and UK GDPR to the addresses below, respectively:

EU Representative
Osano International Compliance Services Limited
ATTN: STI3
3 Dublin Landings
North Wall Quay
Dublin 1
D01C4E0

UK Representative
Osano UK Compliance LTD
ATTN: STI3
42-46 Fountain Street
Belfast
Antrim
BT1 - 5EF

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request. Email hello@revuskin.com for further assistance.

International Transfers

We have implemented standard contractual clauses to ensure adequate safeguards are in place to protect your information where it is transferred to our affiliated companies in territories outside the European Economic Area and Switzerland. Where we share your information with a third party service provider outside of the European Economic Area and Switzerland (as detailed in the section entitled “Sharing of Information”), we contractually oblige the third party service provider to implement adequate safeguards to protect your information.


Children

We do not knowingly collect any Personal Information from children under the age of 16. We do not sell products for purchase by children and all children’s products we sell are for purchase by adults only. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at hello@revuskin.com.

Verifying Your Requests 

We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. 

In your request, you must provide enough information to allow us to verify you are the person about whom we collected personal information, or their authorised representative. You must also describe your request with enough detail so that we can understand, evaluate, and respond to it. We can’t respond to your request if we can’t verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity. 

Submitting a Request

Only you may make a request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information.

We may not be able to respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will ask you for the email information that you used to interact with us or sign up for a loyalty email or to make purchases to help verify your identity or authority to make the request and confirm that your information is in our system. Information provided to submit a request will only be used for request purposes.

Timing

We will use best efforts to respond to a verified consumer request within 45 days. If we require more time, we will inform you of the reason and extension in writing. You may only make a request for access or data portability twice within a 12-month period. 

Information We Collect

Revu uses and collects your information for the purposes described in this Privacy Policy, which include “business purposes”. We do not sell your personal information for monetary consideration. However, UK law may characterise our sharing of personal information with companies that provide services to us, such as companies that help us to market or advertise our products and services to you, as "sales”. We may “sell” or may have “sold” the following categories of personal information for valuable consideration as listed in the table below.

Our Site collects Personal Information, which is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. Personal Information does not include: (i) Publicly available information from government records; (ii) De-identified or aggregated consumer information.

In particular, the Site has collected the following categories of Personal Information from its consumers within the last 12 months:

Category

Examples

We Collect

We Sell

A. Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, National Insurance number, driver’s licence number, passport number, or other similar identifiers.

Yes

Yes

B. Personal Information Categories

A name, signature, National Insurance number, physical characteristics or description, address, telephone number, passport number, driver’s licence or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some Personal Information included in this category may overlap with other categories.

Yes

Yes

C. Protected classification characteristics

Age (40 years or older), race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Yes

Yes

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

No

No

E. Biometric information.

Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

No

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Yes

Yes

G. Geolocation data.

Physical location or movements.

Yes

Yes

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

No

No

I. Professional or employment-related information.

Current or past job history or performance evaluations.

No

No

J. Non-public education information 

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

No

No

K. Inferences drawn from other Personal Information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

Yes

Yes

L. Equipment information.

Information about your internet connection, the equipment you use to access our Site, and usage details.

Yes

Yes

 

Information You Provide to Us

Revu obtains the categories of Personal Information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our Site. 

How We Use Your Information

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

  • To fulfil or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns. If you submit a story about your experience with Revu, we may post that story on our Site without identifying you by name or address.
  • To provide, support, personalise, and develop our Site, products, and services.
  • To create, maintain, customise, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalise your Site experience.
  • For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your Personal Information 

Revu will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. 

Disclosure of Your Information

We do not sell, trade, or rent Users Personal Information to others and we have not done so during the preceding twelve (12) months.

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

We share your Personal Information with the following categories of third parties:

  • Subsidiaries and affiliates.
  • Contractors and service providers.
  • Data aggregators.
  • Third parties with whom we partner to offer products and services to you.

We may also disclose your Personal Information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

  • To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Revu, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
  • We may share aggregated information about our users without restriction.
  • Disclosures of Personal Information for a business purpose 

Right to Know

You have the right to request that we disclose information about our collection and use of your Personal Information over the past 12 months, including:

  • Categories of Personal Information we collected;
  • Categories of sources for the Personal Information we collected;
  • Our business purpose for collecting Personal Information;
  • The categories of third parties with whom we share that Personal Information; and
  • The specific Personal Information we collected about you.

In order to have us provide specific pieces of information, we will require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. 

Right to Delete

You have the right to request that we delete any of your Personal Information 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 Information from our records, unless an exception applies.

We may deny a deletion request where retaining the information is necessary for us or our service providers. For example, data may need to be kept to:

  • Complete a sales transaction for which we collected the Personal Information (such as the sale of our beauty products to you);
  • Track consumer complaints or product issues;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation; and
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

Right to Correct Inaccurate Information 

UK Consumers have the right to request that we correct inaccurate information we hold about you. If you are a UK Consumer and would like to exercise your Right to Correct, please submit your request by emailing hello@revuskin.com or writing to us at: Revu Skin Limited, ta Revu, 20 Wenlock Road, London, N1 7GU. 

Right to Limit The Use and Disclosure of Sensitive Personal Information 

We do not use or disclose sensitive personal information other than to provide you our services as permitted by California law. Revu does not sell or share sensitive personal information for the purpose of cross-context behavioural advertising.

We collect sensitive personal information based on one or more of the following legal grounds:

  • You have given explicit consent to the collection for one or more specified purposes;
  • Where the collection of sensitive personal information is manifestly made public by you; and/or
  • Where the collection is necessary for exercise or defence of legal claims.

If you are a UK Consumer and would like to exercise your Right to Limit the Use and Disclosure of Sensitive Personal Information, please submit your request by emailing hello@revuskin.com or writing us at: Revu Skin Limited, ta Revu, 20 Wenlock Road, London, N1 7GU.

Do Not Sell or Share 

Right to Opt-Out of Sharing 

UK Consumers have the right to opt-out of the sharing of your Personal Information or Sensitive Personal Information to a third party for cross-context behavioural advertising (i.e., targeted advertising), whether or not for monetary or other valuable consideration. 

Right to Opt-Out of Sale 

UK Consumers have the right to opt-out of the sale of your Personal Information or Sensitive Personal Information. 

Making Requests to “Opt Out” of the “Sale” or “Sharing” of “Personal Information”

If you are a UK Consumer and would like to submit a request to opt out of the sale or sharing of your personal information, you may click on the link “Do Not Sell or Share My Personal Information” on the footer of our Site or you may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out.

Other Important Information for Do Not Sell or Share 

Revu engages in online advertising practices (and certain analytics or similar activities), which may be considered a “sale” or “share” for cross-context behavioural advertising. To disable sharing through cookies set by third parties that may be considered "sales" or “sharing”, click on “Manage Cookie Preferences” in the footer of the website. 

Non-Discrimination

We will not discriminate against you for exercising any of your rights. Unless permitted, 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.

Notice of Financial Incentive 

Under UK regulations, certain programs we offer that provide benefits to consumers may be considered financial incentive programs. We may collect personal information from you in connection with these programs, e.g., contact information (name, email address, residential address) and certain commercial information for a number of reasons, including to administer the program, contact you with regard to your account (if any), to provide the benefits to you, to better serve you, and to fulfil your requests associated with the program. 

To opt-in to the programs, you may need to provide certain information, register for an account and agree to the applicable program terms, or otherwise follow the instructions associated with that applicable program. Please also see the terms of the program you are joining for additional description of the program and any additional requirements. Participation in our programs is voluntary and you can withdraw at any time. 

To the extent that we provide a program that may be considered a financial incentive because the program is directly or reasonably related the collection, deletion or sale or retention of consumer personal information, the value is reasonably related to the overall value we receive from the personal information participants provide specific to the program minus the costs and expenses we incur in providing the program. 

Contact Us

If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, please contact us at: (i) by mail at Revu Skincare Limited, ta Revu, 20 Wenlock Road, London, N1 7GU; or (ii) by email at hello@revuskin.com.