We are committed to protecting your privacy, and will ensure that any information you provide is stored and used in accordance with the General Data Protection Regulation and the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003. We will not share your data with any third party except for administrative purposes relating to the services we provide and where we may be required to do so by law.
This privacy notice will inform you about how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you.
This privacy notice is divided into the following sections.
1. IMPORTANT INFORMATION - WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. DATA SECURITY
7. DATA RETENTION
8. YOUR LEGAL RIGHTS
1. Important Information - Who We Are
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a service or take part in a competition.
This website is not intended for children and we do not knowingly collect data through it relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
Eudelo is the controller and responsible for your personal data (collectively referred to as Eudelo, “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Our full details are:
Full name of legal entities: Eudelo Enhance Limited trading as ‘Eudelo’
Phone Number: 020 8088 2800
Email address for our DPO: firstname.lastname@example.org
Postal address: Eudelo, 63 Bondway, London, SW8 1SJ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated in Sep 2021 and historic versions can be obtained by contacting us.
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.
This 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 notice of every website you visit.
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 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.
Treatment Data includes information about the treatment you wish to receive from us. This information could include ‘health data’ which is a special category of personal data and therefore requires us to take extra steps to ensure it is adequately protected.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
With the exception of Treatment Data, we do not collect any other 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.
The DeloRx website logs IP addresses and browser types to provide you with the best possible user experience and allow us insight into consumer behaviour. You can browse our site without entering any personal information, and therefore remain anonymous during your visit. However, the enquiry form asks for personal information such as name, postal address, email address and telephone number to enable us to send out the requested information, and make any future visits to our site easier.
3. Hows 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 some feedback.
Automated technologies or interactions. As you interact with our website, we may 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.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers such as Google based inside OR outside the EU;
- advertising networks based inside OR outside the EU
- search information providers such as Google or Bing based inside OR outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Worldpay based inside the EU.
- Identity and Contact Data from data brokers or aggregators Experian based inside the EU.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
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.
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 or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending 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.
USING YOUR HEALTH DATA
In light of the services which we provide to our customers, it will often be necessary for us to use information about your health. Even in the broadest sense of the word, ‘health’ information is a special category of personal data which requires us to have an additional lawful basis for using this information. Where we use information about your health for the purpose of providing our services to you (or in preparation for us to provide services to you), the additional lawful basis on which we shall rely will be that such use is necessary in order for us to provide you with health care or treatment.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Below is 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.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest
| To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you
| To process and deliver our services to you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Health information | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Necessary for us to provide health care or treatment
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (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) Identity (b) Contact (c) Technical | (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 | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | 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 | (a) Technical (b) Usage | 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 | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | 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 good or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time following the opt-out links on any marketing message sent to you or by contacting us at any time using the details given above.
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.
Cookies & Webtracking
I. WHAT ARE COOKIES?
II. COOKIE UPDATE
We will only read or write cookies for the preference level set, cookies set prior to you changing your settings will still be on your computer and you can remove them using your browser settings.
We use a cookie to remember your cookie preferences this has a couple of consequences
If you delete all your cookies you will have to update your preferences with us again.
If you use a different device, computer profile or browser you will have to tell us your preferences again.
As web tracking offers more chances to market to website visitors across the Internet, you as a visitor to the website, may be targeted with adverts on other websites. Google and third party vendors might show targeted adverts with the ability to opt out. First and third party cookies are used to provide information and offer improvements to optimise quality of adverts served. You can change the cookie management settings in your web browser to stop these adverts. If you are a registered Facebook user, you may also receive targeted adverts. You can read about how Facebook works by following this link https://en-gb.facebook.com/policies/cookies/
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.
5. Disclosures Of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. Such third parties consist of:
IT: Service providers acting as processors who provide IT and system administration services.
Advisors: Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
Authorities: HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
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.
6. Data Security
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.
7. Data Retention
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us.
8. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click here to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us.
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 may 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 may 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Necessary for us to provide health care or treatment means processing your special categories of personal data (i.e. health data) where it is necessary for the purposes of preventive or occupational medicine, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or UK law or pursuant to contract with a health professional (subject to required conditions and safeguards).
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
Terms & Conditions
These Terms and Conditions are applicable every time you access our website and/or order goods from our website. Please note that these Terms and Conditions also incorporate the following sections which we advise that you read:
Before proceeding with an order you will be required to show that you have read and understood the following terms and conditions. We recommend that you print a copy of these Terms and Conditions for your future reference.
1.1 This site is owned and operated by Eudelo Enhance Limited. Our registered office is 63 Bondway, London, SW8 1SJ.
1.2 All rights in this website are owned by us. Any unauthorised use, copying or modification is prohibited.
2. Ordering Goods
2.1 All orders placed through our website will be subject to our acceptance of the order.
2.2 When you submit an order to us on our website you will receive a confirmatory email of this order saying that we are processing your order. You should check this email for accuracy and let us know immediately if there are any errors. This email does not constitute acceptance of the order by us. Your order will be accepted by us (and a contract will then be formed between us) when we despatch the goods to you. Title to the goods will pass to you on delivery.
2.3 Promotional codes are codes that enable customers to obtain benefits such as discounts, free delivery and free gifts. These codes are non-transferable so may only be used by the person to whom they are issued and must only be used in accordance with their terms and conditions of use. If you use a promotional code to claim a promotional benefit, you must first check that it was issued to you and that you are eligible to use it. By using it to claim a promotional benefit you will be confirming that:-
(i) you are entitled to use the code;
(ii) you meet all the conditions that apply to its use;
(iii) you agree to the terms set out below.
If, before accepting your order, we find that you are not entitled to use the code or do not meet all the terms and conditions of its use, we may reject your order or alternatively process it without the promotional benefit being applied. If, after accepting your order, we find that you were not entitled to use the code or did not meet all the terms and conditions of its use, we may reverse the benefit that you obtained. If you transacted on a cash basis e.g. by debit or credit card, we may take a further payment, equivalent to the value of the benefit obtained, from the card used. If you transacted on a credit basis, the value of the benefit obtained may be charged to your credit account.
2.4 Should you wish to cancel your order or return any goods, please go to the Delivery & Returns section for further information.
3. Processing your orders and payment
3.1 Whilst it is our intention to keep our website up to date and error free, product description or pricing errors may occur. If we discover such an error after you have submitted an order to us, we will contact you prior to accepting your order with the correct details. You may then either cancel your order or re-confirm it based on the correct information. If we are unable to contact you, we will treat your order as cancelled.
3.2 All prices shown on our website are inclusive of VAT. Delivery charges are clearly highlighted throughout the site. For further information on delivery charges see the Delivery & Returns section.
4.1 Some postal addresses in Northern Ireland, some offshore islands and some remote areas of Great Britain may not be covered by our delivery services and we may not be able to arrange delivery of some items to such addresses. You will be notified of this when you place your order.
4.2 Whilst we make every effort to deliver goods on the day we specify, we cannot guarantee delivery on that day or accept liability for deliveries made outside this timescale. This also applies to products sent direct from our manufacturers. We cannot accept liability for out of pocket expenses or other costs incurred due to failed or delayed deliveries.
4.3 All items are subject to stock availability.
4.4 When we deliver your items to you, you may be asked to sign for the goods to acknowledge that you have received them.
4.5 Please note that if you wish to return goods under our Approval guarantee, you have 14 days from receipt of the goods to return them to us. For further information on returns and exceptions to our home approval guarantee please see the Delivery & Returns section.
4.6 If an item is faulty please contact us and we will arrange an appropriate remedy.
6.1 The use of our site and any contracts formed are governed by English law.
6.2 All products are sold on the basis that they are for personal, domestic use only.
6.3 We shall not be responsible to you whether in contract, tort (including negligence) or otherwise for incidental, special, indirect or consequential loss or damage, any loss of profit (direct or indirect), loss of sales, loss of goodwill or reputation, loss of business, third party claims, pure economic loss arising out of or in connection of the performance or non performance of our obligations under these terms and conditions including such damage as may be reasonably foreseeable at the date you order the goods.
6.4 Nothing in these terms and conditions shall exclude or restrict our liability for death or personal injury caused by our negligence.
6.5 Our liability for any claim for loss or damage shall be limited to the sum paid by you for the goods.
6.6 A person who is not a party to these terms and conditions shall have no right to enforce any term under the Contracts (Rights of Third Parties) Act 1999.
6.7 If any provision of these terms and conditions is found to be invalid or unenforceable by a court the invalidity or unenforceability of such provision shall not affect the other provisions of these terms and conditions.
6.8 We may assign or transfer any of our rights or sub contract any of our obligations under these terms and conditions to any third party.
6.9 You may not assign or transfer any of your rights or sub contract any of your obligations under these terms and conditions except with our specific permission in writing.
6.10 We reserve the right to change these terms and conditions from time to time and any such changes will be communicated on our website.
6.11 There may be links on our website to third party websites which we believe may be of interest to you. We do not have any control over the content of these websites nor can we be liable in respect of anything contained on these websites.
6.12 These terms and conditions govern the entire trading relationship between you and ourselves and will remain in force for the duration of our trading relationship.
6.13 All intellectual property rights (including use of trade marks) shall be solely owned by us. You are permitted only to use material on this website as expressly authorised by us or our licensors.
6.14 Any unauthorised use of material on this site is strictly prohibited.
6.15 We will use reasonable endeavours to verify the accuracy of any product or pricing information which we place on the site but we make no warranties (whether express or implied) in relation to the accuracy of such information).
6.16 We may close your account or terminate our trading relationship by giving you notice of at least seven (7) days. This does not affect your obligation to repay any amounts you owe to us.
7.1 We are the operators of this website, and the contents of it are either our property (or that of our affiliated companies) or are used under licence from our suppliers. We are the owners of the compilation of information in this website.
7.2 Our rights, and those of our affiliates and suppliers, are protected by UK, European, and International intellectual property laws, including those for the protection of copyrights, trademarks, and database rights. Misuse of this website may incur civil liability or attract criminal sanctions.
7.3 We grant you a limited, non-exclusive and revocable licence to access our website for the purposes of browsing our (or our affiliates) product offer(s), ordering goods or services from us (or our affiliates), or obtaining contact information for us (or our affiliates).
7.4 Your licence to access our website does not extend to any commercial use of our website, or to any use of our website whatsoever which is for the benefit of any commercial entity other than us (or our affiliates).
7.5 You are expressly not permitted to download any part of our site (other than by reason of automatic page caching), to amend or modify it or any part of it, to reproduce or copy, sell (including any resale), or otherwise exploit our website (or any part of it) for any purpose other than as set out above, nor are you permitted to frame our website or to link to any element of it other than the homepage without our permission.
7.6 You are permitted to link to our homepage, provided that the link is not misleading, false, derogatory, or otherwise prejudicial to our (or our affiliates) suppliers interests, but you are expressly not permitted to use any of our logos or graphics either as or in connection with such a link.
8. Medical Information
8.1 The information on the Eudelo Boutique website is for educational purposes only. This website does not intend to provide any medical advice and should not be considered medical advice or counsel. If you have questions about your general or skin health, please consult your doctor.
8.2 This website should not be used as a substitute for off-line dermatology or medical help provided by a medical professional. Opinions provided here are Dr. Williams’ and do not represent the opinions of her employers or the medical societies of which she is a member.