1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we act as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for our website and services, we will ask you to consent to our use of cookies when you first visit our website. This allows us to provide a better service and experience to our website visitors and service users.
With that in mind, this Privacy and Cookies Policy is designed to describe:
2. Who we are and how to contact us
2.1 Who we are: This website is owned and operated by Nomoreskinpicking (referred to as either “Nomoreskinpicking”, “we”, “us” or “our” in this Privacy& Cookies Policy). Nomoreskinpicking is the Controller (for the GPR) of your Personal Data.
2.2 How to contact us: If you have any questions about our practices or this Privacy & Cookies Policy you can contact us by email, using info@nomoreskinpicking.com
2.3 Our EU Representative: We have appointed a representative based in the Netherlands, who you may address if you are located in the EU to raise any issues or queries you may have relating to our processing of your Personal Data and/or this Privacy & Cookies Policy more generally. Reach out to roos@nomoreskinpicking.com
3. Your rights relating to your personal data
3.1 In this Section 3, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
3.2 Your principal rights under data protection law are:
3.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you with a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
3.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
3.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the persona data are no longer necessary about the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes, and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information;for compliance with a legal obligation; or for the establishment, or exercise of expense of legal claims.
3.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of law claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
3.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
3.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose
3.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.
3.10 To the extent that the legal basis for our processing of your personal data is:
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
3.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.
3.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
3.13 You may exercise any of your rights about your personal data by written notice to us in addition to the other methods specified in this section 3.
3.14 Complaints
If you would like to submit a complaint regarding this Privacy Policy or our practices about your Personal Data, please contact us at: roos@nomoreskinpicking.com.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that if you are in the EU the GDPR gives you the right to contact your local data protection supervisory authority. In the UK, this is the Information Commissioner’s Office.
4. Marketing Communications Preferences
4.1 We use SendPulse to carry out our services and communications. SendPulseis used to store personal and contact information such as a person’s name, surname, email address, and company when this personal information is voluntarily provided through our services. The information gathered relating to SendPulse is used to create reports about the number of recipients who open content and the number of clicks on links. SendPulse’s privacy policy is available at https://SendPulse.com/legal/.
5. How we use your personal data
5.1 In this Section 5 we have set out:
5.2 We may process data about your use of our website and services(“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
5.3 We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed to operate our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
5.4 We may process information that you post for publication on our website or through our services (“publication data”). The publication data maybe processed for the purposes of enabling such publications and administering our website and services. The legal basis for this processing is consent.
5.5 We may process information contained in any inquiry you submit to us regarding goods and/or services (“inquiry data”). The inquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
5.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notificationdata”). The notification data may be processed to send you the relevant notifications and/or newsletter. The legal basis for this processing is consent.
5.7 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed to communicate with you and for record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
5.8 We may process any of your personal data identified in this policy wher necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
5.9 We may process any of your personal data identified in this policy where necessary for obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
5.10 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
5.11 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
6. Who we share your Personal Data with
6.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
6.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6.3 In addition to the specific disclosures of personal data set out in this Section 6, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
7. Where we store your Personal Data
7.1 In Section 7, we provide information about the countries your data may be transferred to and will highlight specific circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
7.2 We currently have offices and facilities in the Netherlands. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
7.3 The hosting facilities for our website are situated in Ireland and Germany. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
7.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
8. How long we store your Personal Data for
8.1 This Section 8 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
8.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
8.3 Personal data that you have provided through consent will be retained until you request that we remove the data.
8.4 Notwithstanding the other provisions of this Section 8, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
9. How We Protect Your Personal Data
9.1 We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We cannot, however, ensure or warrant the security of any information you transmit to Nomoreskinpicking or guarantee that your information on the Services may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, managerial, or technical safeguards.
We have put in place procedures to respond to any actual or suspected Personal Data breach. In the event that personal information is compromised as a result of such a breach of security, Nomoreskinpicking may promptly notify those persons whose personal information has been compromised by sending an e-mail to you. You may have a legal right to receive this notice in writing.
Nomoreskinpicking cannot ensure that your Personal Data will be protected if you share your login and password information with any third party, including any third party operating a website or providing other services.
10. How we use cookies
10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
11. Cookies that we use
11.1 We use cookies for the following purposes:
12. Cookies used by our service providers
12.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
12.2 We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at:https://policies.google.com/privacy. The relevant cookies are: identifycookies.
13. How to manage your cookies
13.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and fromversion to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
13.2 Blocking all cookies will hurt the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
14. Changes to our Privacy & Cookies Policy
14.1 We may update this policy from time to time by publishing a new version on our website.
14.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
14.3 We may OR notify you of significant changes to this policy by email or through the private messaging system on our website.