- Important information and who we are....................................................................................................... 1
- The data we collect about you ................................................................................................................... 3
- How is your personal data collected?........................................................................................................ 4
- How we use your personal data................................................................................................................. 6
- Purposes for which we will use your personal data................................................................................... 6
- Marketing.................................................................................................................................................... 8
- Disclosures of your personal data.............................................................................................................. 9
- International transfers............................................................................................................................... 10
- Data security............................................................................................................................................. 10
- Data retention........................................................................................................................................... 10
- Your legal rights....................................................................................................................................... 11
- Glossary................................................................................................................................................... 12
1. IMPORTANT INFORMATION AND WHO WE ARE
- Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: Forte Organics Ltd
Postal address: 22 Chancery Lane, London, WC2A 1LS
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
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, maiden name, last name, 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, 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 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.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
Listed here are some further examples of the ways that we collect personal information directly from you and how we use it. We use different methods to collect data from and about you including through:
- Online and Instore.
- Request or complete your transaction and communicate with you regarding your purchase
- Provide certain services, including delivery services, reserve and pick-up
- Sending an e-receipt
- Request promotional information
- Returns and Exchanges.
- Our goal is to ensure that you are completely satisfied with your purchase and to this end, we offer a Return Policy. For Irene Forte Skincare to continue to offer our Return Policy, we ask for personal information such as your name, address, and telephone number for the purposes of detecting and preventing fraud. You may also be asked to produce a photo ID for verification purposes only.
- Purchase Follow-Up, Surveys, and Customer Research
- Following a purchase, we may send you a follow-up letter to thank you for your business, or we may contact you to ensure that you are completely satisfied with your new product or our services.
- We may use contact information collected in-store, online, or via our call centres to conduct occasional surveys and other customer research. These surveys are entirely voluntary and you may easily decline to participate. The information obtained through our surveys and customer research is used to help us understand our customers, to enhance our product and service offerings, promotions and events, and/or to assist in the selection of store locations.
- Online Accounts
- To engage in certain special features or functions of our websites, or to order products and services from our websites, you may be asked to provide certain personal information, such as your name, email address, postal address, telephone number, or payment card information. We use this information to create your account, process your payment, contact and correspond with you about your order, respond to your inquiries, and monitor functions of our websites that you choose to use, such as Customer Reviews.
- If you purchase an e-gift card, we collect the recipient’s name, email address, and any message you provide in order to send the gift card on your behalf. We rely on you to ensure that you have obtained all necessary consents to provide this information to us.
- If you choose to ship an order to a third party, you represent and warrant that you have obtained all necessary consents from the third party to permit Best Buy to collect, use, and disclose the third party’s personal information for the purposes of fraud prevention and processing and shipping the order.
- Customer Reviews
- The Customer Review functionality is provided as a rating system that offers you the chance to share your thoughts on a product. These reviews are accessible to all website visitors so please use discretion when posting information to them and do not post personal information.
- Newsletters, Updates or Promotional Communications
- We offer a variety of newsletters and promotional communications. If you sign-up or are subscribed for our newsletter or other promotional communications, we will send you communications that may be tailored based on your interests, preferences, and behaviour. You may choose to stop receiving these communications at any time. Each marketing or promotional message we send to you will include a link or other method to quickly and easily unsubscribe and decline further similar messages.
- You may unsubscribe from promotional emails clicking the “Unsubscribe” link at the bottom of the email. Please note that even if you unsubscribe from receiving our promotional communications, you may continue to receive certain transactional or account-related communications from us. Our subscriber list is not sold or rented to other parties.
- Participate in a Contest or Promotion
- You may be asked for contact information as well as additional optional survey information (for example, product preferences) if you choose to participate in our contests or promotions, we may run from time to time. Personal information from contest entries will be used to administer the contest and contact you if you win.
- Email a Friend
- You may wish to share our website to inform your friend about our products of interest to you. By using the "Email a Friend", the information you provide will be used to send a one-time email to your friend, inviting them to our website. We will not add your friend to a mailing list and will not send them further email unless they choose to receive such communications from us or where otherwise legally permitted.
- If you provide us with personal information concerning another individual (e.g., email address), you represent and warrant that you have a personal or family relationship with the recipient and obtained all necessary consents from that individual to enable us to use that personal information for the identified purpose.
- Subscription Services
- We may offer subscription services that may require that certain contact and financial information be collected and provided by ourselves to the respective service providers as part of the Subscription process.
- 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 our cookies statement for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below:
(a) analytics providers such as Google based in the US and Ireland;
(b) advertising networks such as Google Adwords based in the US and Ireland; and
(c) search information providers such as Google based in the US and Ireland or Bing based in the US.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Shopify based in Canada and PayPal based in the US.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where you have consented to use your personal data.
- Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time:
- by following the opt-out links on any marketing message sent to you or
- by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Specific third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the Irene Forte Skincare Group. This will involve transferring your data outside to countries outside of your home country or the country where you access our services
Many of our external third party service providers or business partners are located in different countries. . In such cases, we carefully assess their privacy practices and ensure that they provide an adequate level of protection for your personal data, consistent with applicable laws and regulations.
- When transferring your data internationally, we always take utmost care to ensure the appropriate safeguards and data sharing mechanisms are in place. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data or we utilise the following mechanisms in the transferring of your data: utilising standard contractual clauses approved by data protection authorities, obtaining your explicit consent for specific transfers, or relying on other lawful transfer mechanisms provided under applicable data protection laws.
Please contact us if you want further information or have concerns about the international transfer of your personal data or the safeguards we have implemented, please contact our Data Protection Officer who will be happy to assist you.
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 have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact.
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Other companies in the Irene Forte Skincare Group acting as joint controllers or processors and who are based in the US, Italy, Germany and Portugal, and provide IT and system administration services and undertake leadership reporting.
External Third Parties
- Service providers based in the US and Ireland who provide cloud-based and hosted online store which manages products, inventory, payments, and shipping
- Professional advisers including lawyers, bankers, auditors and insurers based in the US, the UK, the Netherlands and Italy who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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. 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.
Cookies StatementThis Cookie Statement explains what cookies are and how we use them, the types of cookies we use i.e, the information we collect using cookies and how that information is used, and how to manage the cookie settings.
Cookies are small text files that are used to store small pieces of information. They are stored on your device when the website is loaded on your browser. These cookies help us make the website function properly, make it more secure, provide better user experience, and understand how the website performs and to analyse what works and where it needs improvement.
You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the services and features offered through our website may not function properly if your cookies are disabled.
As most of the online services, our website uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data.
The third-party cookies used on our website are mainly for understanding how the website performs, how you interact with our website, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.
Types of Cookies we use
Strictly necessary cookies. These cookies are essential in order to enable you to move around our website and use its features. Without these cookies, services you have asked for cannot be provided. They are deleted when you close the browser. These are first party cookies.
Performance cookies. These cookies collect information in an anonymous form about how visitors use our website and apps. They allow us to recognize and count the number of visitors, see how visitors move around the site when they are using it and identify the regions that they are visiting from. These are first party cookies.
Functionality cookies. These cookies allow our website and apps to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. The information these cookies collect will be anonymized and they cannot track your browsing activity on other websites. These are first party cookies.
Analytics. We may use third party analytics services such as Google Analytics and other providers. These service providers help us analyse how users use our website and to identify user patterns. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. On our behalf Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet activity in connection with the use of the website. These service providers may retain and use anonymized, aggregated data collected from users of our website in connection with their own businesses, including in order to improve their products and services. For information on how to prevent these cookies please click here. In addition, authentication and tracking logs will be used to compile user statistics.
Targeting or advertising cookies. These cookies allow us and our advertisers to deliver information more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of advertising campaigns. They remember that you have visited our website, the length of your visit, the ads you viewed and may help us in compiling your “utilization profile”, using a pseudonym and without referring to you by name. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.
Social Media cookies. These cookies together with social media plug-ins allow you to use functionalities of social media networks such as Facebook, Google’s +1 button, Twitter, Instagram and others on our website. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion. If you use these functionalities, the plug-in and its content are loaded directly from the social media provider’s servers and included in the website by your browser. If you log into your respective social media account at the time you interact with the social media plug-ins on our website, the social media provider will connect this information with your social media user profile. We cannot influence which personal data the social media provider will collect about you. Please see their privacy notices for further information.
Manage cookie preferences
Opting in or opting out
Cookie consent is the legal requirement to obtain consent from website visitors before setting cookies on their devices. Consent is collected via a cookie banner that enables visitors to accept or decline cookies on the website.
You can change your cookie preferences any time by clicking the above button. This will let you revisit the cookie consent banner and change your preferences or withdraw your consent right away.
In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. Listed below are the links to the support documents on how to manage and delete cookies from the major web browsers.
If you are using any other web browser, please visit your browser’s official support documents.