Privacy & Cookie Statement
Introduction
At Curlsmith we respect the privacy of our customers, visitors to our website and competition entrants.
Data Controller Details
Curlsmith is a trading name of HOT UK Ltd with registered office address at 280 Bishopsgate, London, United Kingdom, EC2M 4RB if you are based in the UK or KAZ Europe SARL, Route de la Chaux 4 1030 Bussigny, Switzerland if you are based outside the UK in Europe, the Middle East or Africa; together the “EMEA region”. Curlsmith may be referred to as “we,” “us” or “our”.
If you have additional questions or require more information about our Privacy and Cookie Statement, do not hesitate to contact Volker Schleiff via vschleiff@helenoftroy.com.
Curlsmith is a data controller, it determines the processes to be used when using your personal data. References to “you” or “your” are to users of our site in the UK or the EMEA region our other services, and entrants of our competitions.
This statement explains, in line with GDPR, our privacy and data protection practices in connection with:
- Our websites and social media pages
- Emails and text messages which we send to our customers and recipients of our newsletters
- Entrants in our competitions
- What information we collect, how we use that information, how long we keep it for and what controls you have
We need to collect and use personal information to fulfil the expectations and requirements of our users and customers, e.g. by communicating with you and providing an interactive service.
Clear User’s Consent
By using curlsmith.com, by submitting personal data to Curlsmith or by clicking “I Agree”, depending on the website, service, or application you are using, you express your consent and agreement to the processing of your personal data in the manner provided in this Policy. If you do not agree with this Policy, please do not use the website, or provide Curlsmith with your personal data, or do not grant your consent otherwise.
What information do we collect?
We collect the following kinds of information about our website and app users:
- Non-personal information such as pages accessed and files downloaded. This tells us information like how many people use our site, how many people visit on a regular basis, which pages are most popular and which pages are least popular. This information doesn’t tell us anything about who you are or where you live, it simply allows us to monitor and improve our service.
- Personal information such as name, postal address, telephone number, email address and payment card details. We collect this information only in connection with specific activities, such as newsletter subscriptions, curl quiz personalised recommendations, live chat queries, product purchases, competition entries etc. The information is either needed to fulfil your request or to enable us to provide you with a more personalised service. You don’t have to disclose any of this information to browse our site. However, if you choose to withhold requested information, we may not be able to provide you with certain services.
- User-Generated Content. We may also collect other information that you submit or disclose in connection with our services, such as product interests, reviews, feedback, testimonials, ideas, postings, submissions, photographs, diagrams, drawings, plans, notes, suggestions, inventions, creative materials, videos, designs, and other information. Where applicable we will ask permission before using your content on our website or social media platforms
- Device information such as information about the device (for example, iPhone or iPad), including, where available: the device’s or computer’s unique device identifiers, operating system, browser type and, if applicable, mobile network information, in order to provide the best user experience for our visitors.
- Location information when you use one of our location-enabled services, we may collect and process information about your actual location. Some of these services may require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by changing the app settings on your device.
How is your information used?
We use the information you provide to:
- Process sales transactions
- Fulfil website visitor requests, e.g. competition entries, provision of newsletters and general customer service communication.
- Record any contact we have with you. Communicate with our customers and newsletter subscribers.
- Provide a personalised service to you when you visit our website e.g. by customising the content and/or layout of our pages for each individual user.
- Prevent or detect fraud or abuses of our website and enable third parties to carry out technical, logistical or other functions on our behalf.
- Provide you with information which we think may be of interest to you (see below).
- Profile the use of our website and carry out research on our users’ demographics, interests and behaviour to help us gain a better understanding of how our users navigate and use our website (here information is used in aggregate and therefore anonymously).
- Improve our service to our users.
We use personal information to communicate with our customers/subscribers about:
- Our activities and promotions and about updates to our product range, retail partners and website.
Use of cookies
Cookies are small text files that are placed on your computer or device by websites and apps that you visit. Almost all websites and apps use cookies to make them work as intended, or to make them work more efficiently.
Which cookies does Curlsmith use?
- Session cookies: These are temporary and only stored in your computer/device’s memory for the time that you’re browsing our site. They’re deleted as soon as you end your session.
- Permanent or stored cookies: These remain on your computer/device even after you’ve finished your session. Strictly necessary cookies– These are required for the operation of our site or app, e.g. cookies to enable you to log into our website.
- Analytical/performance cookies: These allow us to recognise and count the number of visitors to our site, and see how our visitors move around our site, so we can improve the way our site works, e.g. by ensuring that users can find what they’re looking for easily.
- Functionality cookies: These are used to recognise you when you return to our site, so we can personalise our content for you and remember your preferences, e.g. your choice of text size or colour choice.
- Targeting cookies: These record your visit to our site, the pages you’ve visited and the links you’ve followed. We’ll use this information to make our site more relevant to your interests.
The table below explains the cookies we use and why.
Do you have to accept cookies?
Most web browsers automatically accept cookies. If you prefer, you should be able to change your browser to notify you when you receive a cookie (read the information that came with your browser software), giving you the opportunity to decide whether to accept a cookie. If you refuse cookies, you may not be able to take full advantage of our website.
Why we use cookies.
Cookies help us to improve our site to deliver a better and more personalised service. They enable us to:
- Estimate our audience size and usage pattern
- Store information about your preferences, and so allow us to customise our site according to your individual interests.
- Recognise you when you return to our site so as to avoid lengthy registration on each visit Identify who you are and to access your account information
- Control how often visitors see similar ads
- Track the progress and number of entries in our promotions and competitions Any information gathered by the use of cookies on our site is compiled on an aggregate, anonymous basis.
Third party services
- Curlsmith uses a variety of services hosted by third parties to help us provide and manage our services. When you use our website or apps these third parties may collect information sent by your browser as part of a web page or app request, such as cookies or your IP address.
- Third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies
Curlsmith.com uses third party services including the following:
Google: https://policies.google.com/privacy
- To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
- We use Hotjar in order to better understand our users’ needs and to optimise the website service and user-experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and where users may struggle to use the website, etc.). This enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (in particular device’s IP address (captured and stored only in an anonymised form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymised user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user.
- The Facebook Pixel stores anonymous data which allows us to serve adverts on the Facebook social platform that are relevant to the products and pages you have visited on ucurlsmith.com. Information collected only includes: pages viewed. Curlsmith Europe does not have access to any personal details during this process. Facebook anonymously handles the connection of “Page View” data to Facebook profiles allowing for the distribution of personalised adverts.
- Shopify is a complete commerce platform that lets anyone start, grow, manage, and scale a business. It enables businesses to build an online store, market to customers, and accept payments across multiple sales channels and locations—all in one place
When might we provide personal information to others?
When we use other companies to provide services on our behalf, e.g. processing, mailing or delivering orders, answering customers’ questions about products or services, sending mail and emails, analysing data or processing credit card payments.
If we receive a complaint about any content you have posted or transmitted to or from our site, if required to do so by law, to enforce or apply our Terms & Conditions or if we believe that we need to do so to protect and defend the rights, property or personal safety of Curlsmith, our website or our visitors and for other lawful purposes.
If we merge with another organisation to form a new entity, information may be transferred to the new entity.
We may disclose aggregate statistics about our site visitors, customers and sales to describe our services and operations to prospective partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics won’t include any personally identifying information
Security
We have security measures in place to attempt to protect against the loss, misuse and alteration of personal data under our control. Whilst we can’t ensure or guarantee that loss, misuse or alteration of data won’t occur, we’ll do our best to try to prevent this.
Unfortunately, the transmission of data across the internet isn’t completely secure and whilst we do our best to try to protect the security of your information we can’t ensure or guarantee that loss, misuse or alteration of data won’t occur whilst you or we are transferring this data.
Where you or we have provided a password enabling you to access parts of our websites, use our apps or use our services, it’s your responsibility to keep this password confidential. Please don’t share your password with anyone.
The addition of password requirements has been added to the website as a form of risk mitigation.
Links
Our website may contain links to other sites and our website can also be accessed from links on third party sites. We can’t be responsible for the privacy policies and practices of other websites even if you access those sites using links from our website or if you linked to our website from those sites. We recommend that you check the privacy statement of each site you visit and contact the website owner or operator if you have any concerns or questions.
Using our social media pages
(i.e. Curlsmith pages on websites like Facebook, Instagram, Twitter, YouTube or Pinterest)
Whilst this statement covers our privacy practices and how we will use any data collected from our website and social media pages, it doesn’t cover how providers of social media websites will use your information. You should read the social media site’s privacy policies before adding any content to our social media pages. Make use of the social media site privacy settings and reporting mechanisms to control the way that your information is handled.
Posting content on our website and social media pages
Remember that the internet provides instant worldwide access. Any information that you provide will be just that – worldwide instantly!
We do not moderate our website. So, if you post comments about other people it’s not only your privacy that is at stake. Protect your friends’ privacy and reputations. Be careful about uploading any content that may show you or your friends in compromising situations and be aware that other users may abuse the content you have provided.
Please don’t provide information about yourself or other people unless you’re sure you and they are happy to have it made public. In particular, don’t provide any information about others without their consent where that information might identify them, such as:
- Names
- Tagged photos
- Location
Under no circumstances make public other peoples’ home address, email addresses or contact numbers.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it. Such analytical tools as Google Analytics that store anonymised data will be kept indefinitely so that we can use historical data to make informed decisions about website developments based on our users’ interactions.
Minors
Children Under the Age of 13
We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not send us any information about yourself including your name, address, telephone number, or e-mail address. In the event we learn that we have collected personal information from a child under 13 without parental consent, we will delete this information as quickly as possible. If you believe that we may have received information from or about a child under the age of 13 please contact us.
Minors Over the Age of 13
We recommend that minors over the age of 13 ask a parent or guardian for permission before sending any information about themselves to anyone, including us, over the internet.
Your rights
If you would like to review or revise information you have previously provided to us online you can do so by sending an email to vschleiff@helenoftroy.com.
You may request details of personal information which we hold about you under General Data Protection Regulation. If you would like a copy of the information held on you or if you have any questions relating to this statement or how we use the personal information we have about you, please email vschleiff@helenoftroy.com.
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
- The right to be informed: This means that we must tell you how we use your data, and this is the purpose of this privacy notice.
- The right of access: You have the right to access the data that we hold on you. To do so, you should make a subject access request.
- The right for any inaccuracies to be corrected: If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it.
- The right to have information deleted: If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
- The right to restrict the processing of the data: For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
- The right to portability: You may transfer the data that we hold on you for your own purposes.
- The right to object to the inclusion of any information: You have the right to object to the way we use your data where we are using it for our legitimate interests.
- The right to regulate any automated decision-making and profiling of personal data: You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
Changes
We may make changes to this statement from time to time. If we make changes we will post the changes on this page.
Your acceptance of this statement
By using our sites, social media pages, or by entering a competition or prize draw or registering to receive our newsletters, you consent to our collection and use of information in accordance with this statement. If you don’t agree to this statement, please don’t use our site, social media pages or apps or enter our competitions or register for our newsletters.
This Privacy and Cookie Statement was last updated: February 2024