Privacy Policy

Last Updated: May 13, 2024

This is Sio Beauty’s privacy policy, which will inform you about how we look after your personal data when you visit our website at www.siobeauty.com and tell you about your personal data rights and how the law protects you. This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED?
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy This privacy policy aims to give you information on how Sio Beauty collects and processes your personal data through your use of this website and any data you may provide when you contact us for information, sign up to receive updates from us, or make a purchase through our online store.

Our website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with our Cookie Policy any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller and contact details

Renita LLC t/a Sio Beauty of 712 Fifth Avenue, 7th Floor, New York, NY, United States, 10019 is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

If you have any questions about this privacy policy or our privacy practices, please contact us at care@siobeauty.com.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. 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.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Language

We may provide a translation of this policy where you choose to access our website in a language other than English. The English language version of this policy (here), and of any policies or notices relating to it, shall prevail in the event of any ambiguity or conflict.

2. 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 your name, username or similar identifier, 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, in accordance with our Cookie Policy.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, and social media interactions with us.
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 may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. You can adjust your preferences at any time using the cookie settings tool on our website. Please see our Cookie Policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below.

Technical Data from the following parties:

Analytics, search information, and advertising network providers such as Google;
Social media providers such as Meta, ByteDance, Pinterest;
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

4. HOW WE USE YOUR PERSONAL DATA

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, such as when you purchase products form our online store.
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 we need to comply with a legal obligation.

Purposes for which we will use your personal data

We have set out below a description of all the ways we intend to use your personal data, and which of the legal bases we rely for that use. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity	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	(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: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(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	(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	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	Necessary for our legitimate interests (to develop our products/services and grow our business)
To process an application for employment with us	Performance of a contract with you

Our website contains links to our social media accounts including:

Meta (Facebook and Instagram), and in relation to those links, Facebook Ireland is a joint controller with us of your personal data, further details of which are available here: https://www.facebook.com/legal/controller_addendum Facebook Ireland is responsible for providing you with information and enabling your personal data rights relating to data held by Facebook about you, further details of which are available here: https://www.facebook.com/about/privacy.
Pinterest, and in relation to those links, Pinterest Europe Ltd. is a joint controller with us of your personal data, and further details of Pinterest’s use of your personal data are available here: https://policy.pinterest.com/en/privacy-policy
ByteDance (TikTok), and in relation to those links, TikTok Ireland is a joint controller with us of your personal data and further details can be found here: https://www.tiktok.com/legal/privacy-policy-eea

Opting out of receiving marketing messages

You can ask us 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.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose for which we use your personal data

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 we need to use your personal data for an unrelated purpose, we will notify you of the legal basis which allows us to do so.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above:

Other members of the SiO Beauty Group.

Our service providers: We may disclose your personal data to third party service providers who assist us in providing goods and services to you. We require our service providers to respect the security of your personal data and to treat it in accordance with the law and only permit them to process your personal data for specified purposes and in accordance with our instructions. For example, we use third party service providers for:

Hosting our website;
Processing your order and payment when you purchase goods from us;
Fulfilling and delivering your order;
Providing online customer service and chat functionality on our website;
Providing analytics information;
Sending communications to our customers;
Preventing fraud and helping to keep our website secure.

Professional advisers: We may need to share personal date with our advisers including, lawyers, auditors, bankers, and insurers.

For corporate transactions: If we choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

When required by law: We may share personal data if we are also under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of our business, our customers or others.

To enforce our legal rights:

If disclosure would mitigate our liability in an actual or threatened lawsuit;
As may be necessary to protect our legal rights and legal rights of our users, business partners or other interested parties;
To enforce our agreements with you; and
To investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

6. INTERNATIONAL TRANSFERS

In order to fulfil a contract with you, we may need to share your personal data with third parties such as payment processors located outside the UK, the EEA or other jurisdictions which have been deemed to provide equivalent protections for personal data. In such cases, we seek to ensure a similar degree of protection is afforded to your personal data by ensuring appropriate safeguards are implemented, which may protections such as standard contracts clauses when we transfer personal data to those jurisdictions.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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.

8. DATA RETENTION

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.

In some circumstances you can ask us to delete your data, as explained under Your legal rights below.

In some circumstances we may 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.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

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.

Right of rectification – You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Right to request erasure – You have the right to ask us to erase your personal data in certain circumstances.

Right to request restriction of processing – You have the right to ask us to restrict the processing of your personal data in certain circumstances.

Right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.

Right to data portability – You have the right to ask that we transfer your personal data to another organization, or to you, in certain circumstances.

Right to 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.

If you wish to exercise any of the rights set out above, please contact us at care@siobeauty.com or at the relevant address below:

UK GDPR Representative

Renita, LLC has designated DataRep as its GDPR representative pursuant to Article 27 of the UK GDPR. Enquiries to Renita, LLC under the UK GDPR may be made to:

datarequest@datarep.com
Renita, LLC c/o DataRep 107-111 Fleet Street, London, EC4A 2AB, United Kingdom

EU GDPR Representative

Renita, LLC has designated DataRep as its GDPR representative pursuant to Article 27 of the GDPR. Enquiries to Renita, LLC under the GDPR may be made to:

datarequest@datarep.com
Renita, LLC c/o DataRep 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

You also have the right to make a complaint at any time to your local data protection regulator. We would, however, appreciate the chance to deal with your concerns before you approach your local data protection regulator, so please contact us in the first instance.