Don’t Forget the Bubbles Limited (“DFTB”, “us” or “we”) is the Data Controller over any Personal Data we process about you for the purposes set out in this Privacy Notice. DFTB complies with the General Data Protection Regulation (“GDPR”) and Data Protection Act 2018 when processing your Personal Data. This privacy notice outlines the personal data DFTB collects from you through your interaction with the website www.dontforgetthebubbles.com and the Skin Deep project website www.dftbskindeep.com. If you have any concerns about DFTB’s processing of your Personal Data, or you have a general enquiry in relation to data protection, please contact us at firstname.lastname@example.org
What is Personal Data?
Personal Data: means any information relating to an identified or identifiable person, known as a ‘Data Subject’. An ‘identifiable’ natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier or to one or more factors specific to that person.
Special Category Data: means Personal Data concerning health; a person’s sex life or sexual orientation; data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; and genetic data, biometric data which identifies a natural person.
When we use the term ‘Personal Data’ we mean both Personal Data and Special Category Data.
What Personal Data is DFTB processing?
We may collect, use, store and transfer different kinds of Personal Data about you including the following:
Identity Data includes first name, last name, title, profession or speciality, job title, employer and gender.
Contact Data includes 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 images, films, and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, operating system and browser type. This data provides us with information about user’s browsing actions and patterns. It is used to inform improvements to the website and for internal system administration.
Usage Data includes information about how you use our website, products and services including the date and time of visits, the pages viewed, time spent at our website and the websites visited just before and after our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Special Category Data includes health information provided by you, which may include the following:
Images of medical condition and symptoms
Medication currently being or having been provided;
Health services currently being or having been provided;
Race and ethnicity information.
If you are submitting an image or film which shows an identifiable individual to our Skin Deep Project, the individual (or their parent. guardian or attorney) must consent using our consent form which can be found at https://dftbskindeep.com/consent-process/
Where did DFTB obtain my Personal Data from?
DFTB obtained your data from the following sources:
Direct interactions. You may give us your Identity, Contact, Financial and Special Category Data by filling in forms on our website or by corresponding with us email or otherwise. This includes Personal Data you provide when you
submit images, films, and forms on our website;
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;
give us feedback or contact us.
Third parties. We may receive Special Category Data about you from various third parties, including healthcare providers, hospitals and the National Health Service. This will namely be through submission of images or films on our website for our Skin Deep Project and information given alongside these images and/or films.
Cookies and Google Analytics. Cookies are small text files that are stored on your computer or mobile device when you visit DFTB’s website. They do not cause your computer any harm nor do they identify you personally. They only identify the computer being used to access the website. The cookies obtain Usage Data in relation to your use of the website. DFTB uses this information to help us monitor the use of our website and to provide you with a better user experience.
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data to provide our goods and services to you, including:
Enabling you to register your information on our database or subscribe to our monthly newsletter;
To correctly classify conditions on our image library;
Enabling you to purchase images from us, or submit images to us
Responding to requests, enquiries, complaints and other customer care related activities;
For administrative purposes such as creating orders, transaction records, receipts and invoices;
Subject to you providing your consent (in accordance with GDPR) sending you messages to promote and market our goods and services, including special offers and events which might interest you; and
Any other purposes required by law
We will process your Special Category Data on the basis that you give us your explicit consent to do so.
For what purposes will we process your Personal Data?
We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing
To provide you with services
(a) Identity (b) Contact (c) Financial
(a) Performance of a contract with you (b) Consent (where we process Special Category Data)
To publish video footage on our website or on our YouTube page together with related information about skin conditions
(a) Special Category Data
Consent (where we process Special Category Data)
To publish images on our website, classify skin conditions on our image library and provide information about skin conditions on our topic pages (for our Skin Deep Project)
(a) Special Category Data
Consent (where we process Special Category Data)
Responding to requests, enquiries, complaints and other customer care related activities
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
(a) Identity (b) Contact (c) Marketing and Communications
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our operations 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
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
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. We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase or Personal Data supplied by you
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.
Will my Personal Data be shared with any other organisation/third parties and if so, why?
We may disclose your Personal Data to:
Our suppliers in order to provide you with any goods you purchase;
Any service providers that are providing a service to your or us in relation to our goods or services (such as third party payment providers or IT service providers); and
Any other third party (i) where disclosure is necessary in order for use to meet your request for goods or services or (ii) with your explicit consent.
Where will DFTB keep my Personal Data?
Your Personal Data will be stored in a secure environment, located in the United Kingdom.
Will my Personal Data be shared outside of the UK?
Personal Data provided to us may be transferred, processed, used or stored by us or by our third party service providers in countries other than the UK, including the European Economic Area (“EEA”) and the United States of America. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
Personal Data which is shared with third parties may be processed by that third party outside of the UK and EEA.
We may share de-identified, aggregate and/or anonymous data with third parties in the UK and overseas, including in Australia, the USA and Canada, for research, development, statistical or other business related purposes.
Application of overseas privacy laws
If you are located in a European Union Member State, to the extent that we are subject to GDPR, we will comply with our obligations under the GDPR in relation to the processing of any personal data that we hold about you.
Is my Personal Data safe?
DFTB works hard to protect your Personal Data and have adopted appropriate technical and organisational measures to keep it safe from unauthorised disclosure, alteration or destruction. 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 will take reasonable steps to ensure that the Personal Data we hold is accurate, complete, up-to-date, secure and protected from unauthorised access, modification or disclosure. However, we will not be held responsible for events arising from unauthorised access to your Personal Data.
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.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to DFTB via the internet. Any transmission is at your own risk.
How long will DFTB retain my Personal Data?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for or until such time that you withdraw your consent and exercise your right to request that DFTB stops processing your Personal Data. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Does DFTB make any automated decisions about me or profile my Personal Data?
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this information by using cookies, server logs, Google Analytics and other similar technologies.
What are my rights in relation to the Personal Data DFTB holds about me?
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. Please contact us at email@example.com if you would like to exercise any of your rights or you have any queries. The rights you can have over your data are as follows:
Right to be informed about the collection and use of your Personal Data.
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 information we hold about you corrected.
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 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. 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 the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
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.
Right to make a complaint to the Information Commissioners Office (“ICO”) if you think we have infringed your rights. You can find more information about reporting a matter to the ICO at the following link: www.ico.org.uk.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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 and keep you updated.
Third Party links
DFTB’s website may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy notices and that we do not accept any responsibility or liability for these notices or for any Personal Data that may be collected through these websites or services, such as contact and location data. Please check these notices before you submit any Personal Data to these websites or use these services.
Changes to this Privacy Notice
We reserve the right to amend or change this Privacy Notice. Any changes we may make to this Privacy Notice in the future will be communicated to you in some manner.
Complaints and queries
Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to Tessa Davis at firstname.lastname@example.org