Terms of Use & Privacy Policy

Terms of Use & Privacy Policy

LAST UPDATED: July 2018

We are committed to protecting your personal data and to respecting your privacy. This Privacy Policy lets you know how we look after your personal data and tells you about your privacy rights and how the law protects you.

This Privacy Policy aims to give you information on how and why  E.T. Browne UK Limited processes your personal data, including when you use our website (regardless of where you visit it from), and any data you may provide through this website when take part in a competition, leave a product review or use one of our website tools.

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

Please read this Privacy Policy together with any other Privacy Policy 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 Policy supplements the other notices and is not intended to override them.

1. who we are

• 1.1.E.T. Browne UK Limited is the controller responsible for your personal data (referred to as “we”, “us” or “our” in this Privacy Policy).
• 1.2.We take our obligations very seriously. If you have any questions or concerns about this Privacy Policy, including any requests to exercise your legal rights, please contact us here [email protected].
• 1.3.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). However, we would really appreciate the chance to deal with your concerns first so we would be grateful if you would contact us here [email protected] before you approach the ICO.
• 1.4.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.

1. personal data we collect about you 

• 2.1.Personal data is information that relates to an identified or identifiable natural person, this means a human being. Anonymous data, where you cannot find out who the data relates to, is not personal data.
• 2.2.We may collect personal data from you, which can be split into the following different types:
  • (a)Identity Data, which includes your first name, last name, date of birth, gender and photographs of identifiable individuals.
  • (b)Contact Data, which includes your address, email address and telephone numbers.
  • (c)Technical Data, which includes your IP address, your login data, and your browser type.
  • (d)Profile Data, which includes details of your interests, preferences and feedback.
  • (e)Marketing and Communications Data, which includes your preferences in receiving marketing messages from us and our third parties and your communication preferences.
  • (f)Usage Data, which includes information about how you use our website, products and services.
• 2.3.We may collect aggregated details about your use of the website for the purpose of aggregate statistics or reporting purposes. Aggregated data (usage details combined from a number of people’s data) may come from your personal data but if it does not directly or indirectly reveal your identity, it is not considered personal data and falls outside the scope of this Privacy Policy. For example, we may combine and analyse your use of the website to work out the number of users accessing a specific website feature. However, to the extent that the aggregated information could still be considered personal data, we will continue to process it in accordance with this Privacy Policy.
• 2.4.We do not normally 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), except as set out in the next paragraph. Nor do we collect any information about criminal convictions and offences.
• 2.5.However, on occasion we may give you the opportunity to indicate whether you are pregnant or not, and this information would fall under the Special Categories of Personal Data. When using our Hair Consultation website app we will also collect information about your race or ethnicity, and this information would fall under the Special Categories of Personal Data. We will generally collect your explicit consent to our use of this information when you sign up to receive our special offers or our newsletters, or use our Hair Consultation website app. We will only collect this information with your explicit consent and you can withdraw consent at any time by contacting us here [email protected].

3. if you do not provide personal data

• 3.1.Where we need to collect personal data by law, or under the terms of the contract between us and you do not 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.

4. How do we collect your personal data?

• 4.1.We use different methods to collect data from and about you, including when you fill out a form or give us information via the phone, by post, online or by email or otherwise. Other instances where we may collect information are, when you:
  • (a)Visit our website, apps or social media (e.g. through cookies);Enter a competition or promotion;
  • (b)Enquire about products through our website or via phone, fax, email, post;
  • (c)Provide feedback;
  • (d)Fill in a form on our website to use one of our tools; and/or Otherwise contact us.
• 4.2.Personal data may be collected by us and by our third party service providers who assist us in operating the website. Including:
  • (a)Google Analytics:
    • (i)We use Google Analytics to help analyse how you use our website. Google Analytics generates statistical and other information about website use by means of cookies. Google will store this information.
    • (ii)If you do not want your website visit information reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.
  • (b)Click Stream Information:
    • (i)In common with many websites, when you read, browse or download information from our website, we or our internet service provider may also collect information such as the date and time of your visit to the website, the pages accessed and any information downloaded. This information is used for statistical, reporting and website administration, maintenance and improvement purposes only.
  • (c)Rhythm One (previously known as Radium One):
    • (i)We use Rhythm One (previously known as Radium One) to help analyse how you use our website. Rhythm One tracks cookies and builds profiles in order to serve targeted advertising. Rhythm One will store this information.
  • (d)DedicatedNow:
    • (i)We use DedicatedNow to host our website and databases, including information relating to your use of our website, such as the date and time of your visit to the website, the pages accessed and any information downloaded. This information is used for statistical, reporting and website administration, maintenance and improvement purposes only.
  • (e)EIP Concepts Inc:
    • (i)We use EIP Concepts Inc to develop or website and create new website features. EIP Concepts Inc may have access to information relating to your use of our website, such as the date and time of your visit to the website, the pages accessed and any information downloaded. This information is used for website development, website administration, maintenance and improvement purposes only.
  • (f)Mailchimp:
    • (i)We use Mailchimp to store your details, including email address, name and signup location. This allows us to manage how we get in touch with you, and helps us to plan and send out email newsletters. It also helps ensure that we have an accurate database of details from which to contact you.
    • (ii)If you no longer wish for your contact details to be stored using Mailchimp, please contact us and we will remove you from the system. You may also unsubscribe from our mailing list at any time using the “unsubscribe” links in our emails. Please note however that being removed from Mailchimp may result in you no longer receiving communications from us.

5. Using your personal data

• 5.1.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:
  • (a)Where we need to perform the contract we are about to enter into or have entered into with you.
  • (b)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.
  • (c)Where we need to comply with a legal or regulatory obligation.
• 5.2.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.
• 5.3.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 here [email protected] 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.

• 5.4.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 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.
• 5.5.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.

6. MARKETING

• 6.1.Promotional offers from us: We may use your personal data to try to understand what you may want or need, or what may be of interest to you.
• 6.2.Third-party marketing: We will get your express opt-in consent before we share your personal data with any other company for marketing purposes, unless we are otherwise permitted to do so under applicable law.
• 6.3.Opting out: You can ask us or third parties to stop sending you marketing messages at any time by Contacting us here [email protected] at any time.

7. DISCLOSURES OF YOUR PERSONAL DATA

• 7.1.We do not disclose your personal data without your permission, unless the disclosure is:
  • (a)In accordance with this Privacy Policy or any agreement you enter into with us;
  • (b)To our related companies;
  • (c)To third parties to whom we may choose transfer, or merge parts of our business or our assets; or
  • (d)Required or authorised by law or for security reasons (including to prevent fraud).
• 7.2.We may disclose, or provide access to, your personal data to third parties, including our third party service providers, in connection with the purposes described in the table above.
• 7.3.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.

8.  INTERNATIONAL TRANSFERS

• 8.1.We share your personal data our parent company, E.T. Browne Drug Co., Inc., and our group companies controlled by E.T. Browne Drug Co., Inc. This will involve transferring your data outside the European Economic Area (EEA).
• 8.2.Some of our external third parties are also based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
• 8.3.Whenever we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
  • (a)We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
  • (b)Where we use certain service providers or transfer personal data to our Group companies located outside the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (“Model Form Agreements”). For a copy of the text of these Model Form Agreements, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
  • (c)Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
• 8.4.Please contact us here [email protected] if you want further information about the specific mechanism used by us when transferring your personal data out of the EEA.

9. DATA SECURITY

• 9.1.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.
• 9.2.While we take great care to protect your personal data on our website, unfortunately no information transmission over the Internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of protecting that information until it reaches us.
• 9.3.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.

10. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

• 10.1.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.
• 10.2.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.
• 10.3.Please contact us here [email protected] for more information about the data retention periods which we might apply to specific personal data we hold about you.

11. YOUR LEGAL RIGHTS

• 11.1.Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
  • (a)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.
  • (b)Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
  • (c)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 personal data 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.
  • (d)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 personal data which override your rights and freedoms.
  • (e)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 personal data’s accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal 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 personal data but we need to verify whether we have overriding legitimate grounds to use it.
  • (f)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 personal data which you initially provided consent for us to use or where we used the personal data to perform a contract with you.
  • (g)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, or where we are relying on a different legal basis for the processing. 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 here [email protected]

• 11.2.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.
• 11.3.Please contact us here [email protected] for more information about the data retention periods which we might apply to specific personal data we hold about you.

12. 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.

13. 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.

14. 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.

15. THIRD-PARTY LINKS

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 Policy of every website you visit.

16. CONTACT US

• 16.1.Please contact us using our details below:
  • Email address: [email protected]
  • Postal address:
  • E.T. Browne UK Ltd.
  • Unit 5, Loughton Business Centre
  • 5 Langston Rd
  • Loughton
  • ESSEX IG10 3FL, England
  • Tel: +44-208-418-9543
  • Fax: +44-208-508-4129

17. Cookies

• 17.1Like many websites, our website may use 'cookies' from time to time. For more information about the cookies we use, please see below. Cookies are small text files that we transfer to your computer's hard drive through your web browser to enable our systems to recognise your browser. If you access our website or click-through an email we send you, a cookie may be downloaded onto your computer's hard drive.
• 17.2Cookies may also be used to record non-personal information such as the date, time or duration of your visit, or the pages accessed, for website administration, statistical and maintenance purposes and to enhance the content and services offered on our website. Any such information will be aggregated and not linked to particular individuals.
• 17.3Cookies may also be used for other purposes on our website but in each case none of the information collected can be used to personally identify you. The default settings of browsers like Internet Explorer generally allow cookies, but users can easily erase cookies from their hard-drive, block all cookies, or receive a warning before a cookie is stored. Please note that some parts of the website may not function fully for users that disallow cookies.
• 17.4You 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, please note that some parts of this website may become inaccessible or not function properly.
• 17.5We use the following types of cookies:
  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
  • You can find more information about the individual cookies we use and the purposes for which we use them in the table below: