Model Secrets is committed to protecting our customer's privacy. Please take the time to review this notice which explains what information we collect about you, how we use it, and your rights. Branding Partnerships Limited (“MODEL SECRETS”, “we” or “us”) is the data controller of the personal data collected via or in connection with modelsecrets.com and any associated App (the “Site”).
What personal data do we collect about you?
We collect personal data from you when you provide it to us directly and through your use of the Site. This information may include:
• Information you provide to us when you use our Site (e.g. your name, contact details, gender, product reviews, and any information which you add to your account profile);
• Transaction and billing information, if you make any purchases from us or using our Site (e.g. credit/debit card details and delivery information);
• Records of your interactions with us (e.g. if you contact our customer service team, interact with us on social media);
• Information you provide us when you enter a competition or participate in a survey;
• Information collected automatically, using cookies and other tracking technologies (e.g. which pages you viewed and whether you clicked on a link in one of our email updates). We may also collect information about the device you use to access our Site; and
• Other information necessary to provide the Site, for example we may access your location if you give us your consent.
What do we use this personal data for?
Depending on how you use our Site, your interactions with us, and the permissions you give us, the purposes for which we use your personal data include:
• To fulfil your order and maintain your online account.
• To manage and respond to any queries or complaints to our customer service team.
• To personalise the Site to you and show you content we think you will be most interested in, based on your account information, your purchase history and your browsing activity.
• To improve and maintain the Site, and monitor its usage.
• For market research, e.g. we may contact you for feedback about our products.
• To send you marketing messages and show you targeted advertising, where we have your consent or are otherwise permitted to do so.
• For security purposes, to investigate fraud and where necessary to protect ourselves and third parties.
• To comply with our legal and regulatory obligations.
We rely on the following legal basis, under data protection law, to process your personal data:
• Because the processing is necessary to perform a contract with you, or take steps prior to entering into a contract with you (e.g. where you have made a purchase with us, we use your personal data to process the payment and fulfil your order).
• Because we have obtained your consent (e.g. where you contact us with a query, where you add optional information to your account profile, or if you consent to receive marketing from us).
• Because it is in our legitimate interests as an e-commerce provider to maintain and promote our services. We are always seeking to understand more about our customers in order to offer the best products and customer experience. We use information about you to tailor your view of the Site, to make it more interesting and relevant in respect of the products and offers on view.
Our Site may allow you the option of adding additional information to your account profile, such as information about your body type, skin type, hair type, hair condition, training regime, performance goals, height and weight. We treat this information with particular sensitivity, as we understand it can reveal information about your health or ethnicity, for example. You do not have to provide this information to us, and can delete it or update it at any time.
If you no longer want to receive marketing communications from us (or would like to opt back in!), you can change your preferences at any time by contacting us (details below), clicking on the ‘unsubscribe’ link in any email, or updating your settings in your account. If you unsubscribe from marketing, please note we may still contact you with service messages from time to time (e.g. order and delivery confirmations, and information about your legal rights).
You may also see ads for our Site on third party websites, including on social media. These ads may be tailored to you using cookies (which track your web activity, so enable us to serve ads to customers who have visited our Site). Where you see an ad on social media, this may because we have engaged the social network to show ads to our customers, or users who match the demographic profile of our customers. In some cases, this may involve sharing your email address with the social network.
If you no longer want to see tailored ads you can change your cookie and privacy settings on your browser and these third party websites.
Who do we share this personal data with?
We share customers’ personal data with third parties in the following circumstances:
• With our suppliers and service providers working for us, e.g. payment processors and delivery companies.
• With our professional and legal advisors.
• With third parties engaged in fraud prevention and detection.
• With law enforcement or other governmental authorities, e.g. to report a fraud or in response to a lawful request.
• Otherwise where we have your consent or are otherwise legally permitted to do so.
Storage and retention
We use service providers based around the world. Consequently, your personal data may be processed in countries outside of Europe, including in countries where you may have fewer legal rights in respect of your data than you do under local law. If we transfer personal data outside the European Economic Area we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate safeguards, in particular the EU’s standard contractual clauses. Please contact us if you would like more information about these safeguards.
We will keep your personal data for as long as we need it for the purposes set out above, and so this period will vary depending on your interactions with us.
For example, where you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing, tax and warranty purposes. We may also keep a record of correspondence with you (for example if you have made a complaint about a product) for as long as is necessary to protect us from a legal claim. Where we no longer have a need to keep your information, we will delete it.
Please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
This Site ensures that data is encrypted when leaving the Site. This process involves the converting of information or data into a code to prevent unauthorised access. This Site follows this process and employs secure methods to ensure the protection of all credit and debit card transactions. Encryption methods such as SSL are utilised to protect customer data when in transit to and from this Site over a secure communications channel.
Whilst we do everything within our power to ensure that personal data is protected at all times from our Site, we cannot guarantee the security and integrity of the information that has been transmitted to our Site.
Our Site is not intended for, and should not be used by, children under the age of 18. We do not knowingly collect personal data from children under 18.
You have certain rights in respect of your personal data, including the right to access and correct your personal data, and, in specific circumstances, to transfer your personal data to another entity in a commonly-used format.
You have the right to object to your personal data being used for certain purposes, including to send you marketing. See ‘Marketing’ above, for more details of how to opt-out of marketing.
You also have the right to request erasure of your personal data, for example; where our purposes for processing your personal data have come to an end; where you object to our processing of your personal data based on legitimate interests and we have no overriding legitimate grounds to continue to process your personal data; and where our processing was based on your consent which you have withdrawn.
We will comply with any requests to exercise your rights in accordance with applicable law. Please be aware, however, that there are a number of limitations to these rights, and there may be circumstances where we are not able to comply with your request. To make any requests regarding your personal data, or if you have any questions or concerns regarding your personal data, you should contact us using the details below. You are also entitled to contact your local supervisory authority for data protection.
Address: Customer Services, Branding Partnerships Limited, Puerorum House (1st Floor), 26 Great Queen Street, London. WC2B 5BL.
Last updated 04/04/2022