Privacy Notice

Last updated: 11 September 2026

1. Who we are

Rin Lab Ltd ('RIN', 'our', 'us' or 'we') is a company registered in England and Wales (company number 16944047) at 66 Paul Street, London, England, EC2A 4NA and ICO registration number xxxx.

This privacy notice informs you as to how we collect and use your personal data, what your privacy rights are and how the law protects you in respect of when we are collecting and using your personal data.

We are a data controller and responsible for your personal data. RIN respects your privacy and is committed to protecting your personal data. We strive to ensure that we are clear about how we will use the personal data that we collect. We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, Privacy and Electronic Communications Regulations 2003 and other applicable laws that regulate protection and privacy of your personal data, each as amended from time to time (the 'data protection laws').

2. Purpose of this privacy notice

It is important that you read this privacy notice together with any other privacy notices or fair processing notices 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 personal data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

3. How to contact us

If you have any questions about this privacy notice or our privacy practices or would like to exercise your data protection rights (referred to below), please contact us via email at hello@rinskin.com.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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. We may provide you with a complaint form so that you can provide details about the circumstances of your complaint. This will also enable us to investigate as efficiently as possible.

When we receive your complaint, we will:

• acknowledge receipt within 30 days of receiving it;
• without undue delay, take appropriate steps to investigate your complaint, including making appropriate enquiries with you or any other persons involved to properly understand the issue;
• keep you informed of the progress of your complaint; and
• without undue delay, tell you the outcome of your complaint once we have considered it.

If we respond to your complaint and you are still not satisfied with the outcome, you may still complain to the ICO or exercise any right you have to take legal action.

4. Change to this privacy notice

We keep our privacy notice under regular review, and it may be updated from time to time so please make sure that you have seen the latest version.

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.

5. What we use your personal data for

We collect personal data about you through your relationship and communications with us, including for the following purposes:

1. to manage your interest in hearing about our product launches and to market our products to you;
2. to manage our relationship with you and provide our products to you;
3. to contact you regarding any order for our products;
4. to provide, operate, administer and manage our business;
5. to improve our website or services or to customise the website according to your interests;
6. to deal with any queries or feedback you provide to us from time to time;
7. to enforce and/or defend any of our legal claims or rights; and/or
8. for any other purpose required by applicable law, regulation, the order of any court or regulatory authority.

6. 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 as follows:

• Identity Data includes your name, title and date of birth.
• Contact Data includes your email address, postal address and any telephone number.
• Profile Data includes data in relation to your orders, interests, preferences and feedback.
• Communications Data includes your preferences in respect of communications from us, including marketing communications.
• Technical Data includes information collected from you in the use of our website or our social media sites, including your IP address. We may also collect this information via cookies; please refer to our Cookie Policy at Appendix 1 for more information.

We do not collect any Special Categories of Personal Data about you (this includes details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health, race and ethnicity, trade union memberships and genetic and biometric data). We do not collect any information about criminal convictions and offences.

Please note that where we need to collect personal data from you (either as required by law or to enable us to provide a service to you) and you fail to provide such data when requested, we may not be able to provide the relevant products or services to you, but we will always notify you first if this is the case.

7. How we use your personal data

We will only use your personal data when the applicable data protection laws allow us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to use data to perform the contract we are about to enter or have entered into with you;
• where it is necessary in connection with our legitimate interests (or those of a third party) such as managing our business and those interests do not unjustifiably override your fundamental rights or freedoms;
• where you have given your consent for us to use your personal data for a particular purpose (such as to hear about our product launches); and
• where we need to comply with a legal or regulatory obligation.

We may send you marketing communications where you have consented to such contact, or in the case of our products, where these are similar to those we have already provided to you. You can ask us to stop sending you marketing messages at any time by: (i) by following the opt-out links on any marketing message sent to you; or (ii) by contacting us at any time using the contact details in section 3 above.

8. Change of purpose of use of your personal data

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.

9. Disclosures of your personal data

Other than as expressly set out in this privacy notice or as otherwise permitted under data protection laws, we will not share or distribute any of the personal data you provide to us without your consent.

We may share your personal data with third parties under this privacy notice, for the purposes set out above, in the following circumstances:

• to our service providers, who handle that data on our behalf and in accordance with our instructions under contract (called 'data processors'). These include IT suppliers, data hosting providers, warehouse fulfilment providers and external agencies we may use; or
• where disclosure is necessary to enable us to establish, defend or enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be required by law.

We or the third parties mentioned above occasionally also share personal data with:

• our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations; and/or
• our and their professional advisors (such as lawyers), in which case the recipient of the information will be bound by confidentiality obligations; and
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations as noted above.

10. International data transfers

We may transfer your personal data to certain parties who are located overseas. This may involve transferring your personal data outside the UK to certain countries whose laws are not regarded under the GDPR as providing the same level of protection for your personal data as you enjoy in the UK. These transfers are often referred to as 'restricted transfers'.

Whenever we undertake such a restricted transfer of your personal data, we will do so in a manner that complies with applicable data protection law.

For occasional restricted transfers we may rely on an exemption under applicable data protection law that permits such a transfer to take place subject to certain conditions, based on one or more of the following:

• the transfer of your personal data is necessary for the establishment, exercise or defence of legal claims;
• we have explicit consent from you to make the restricted transfer;
• the restricted transfer is necessary for the conclusion or performance of a contract entered into in your interests that RIN is a party to; or
• the transfer is necessary in order to perform a contract between you and RIN, or to take certain pre-contractual measures at your request.

Alternatively, where we are transferring personal data on a regular basis, we may use specific standard contractual terms and/or other measures approved for use by the ICO which are deemed to give the transferred personal data the same legal protection it has under data protection law in the UK.

11. Data security

We employ appropriate technological and operational security measures to protect personal data we hold against any unauthorised access, any unlawful processing or loss. We have procedures in place to deal with any suspected personal data breach, and we will notify you, the ICO or other applicable data privacy regulator of a personal data breach where we are required to do so under the data protection laws.

However, data transmission over the internet is not 100% secure and we cannot guarantee the security of any data you send to us over the internet or when using public Wi-Fi or other public communications services. We therefore strongly recommend that you take appropriate precautions, such as using a secure virtual private network, where you wish to send any personal data to us that you consider to be particularly sensitive.

12. Data retention

We will only retain your personal data for as long as is reasonably necessary to fulfil the purposes we collected it for. This includes for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements or where we need to retain information in order to deal with possible future legal claims in line with legal limitation periods.

The criteria that we use for retaining your personal data will generally be determined by reference to the data protection laws and relevant guidance issued by the ICO from time to time.

Personal data that we no longer need to hold is securely disposed of and/or anonymised, so you can no longer be identified from it.

13. Your legal rights

Under certain circumstances, you have rights under applicable data protection laws in relation to your personal data. If you wish to exercise any of these rights please contact us, using the contact details provided above in section 3.

You will not normally 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 (or refuse to comply with your request) if your request is clearly unfounded, repetitive or excessive.

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.

Subject to the above, data protection law requires us to respond to all legitimate requests within one month. If, however, your request is particularly complex this period may be extended by an additional two months, although we will let you know if this is the case.

Data subject rights:

• 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.
• 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. 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 if: (i) you want us to establish the accuracy of personal data; (ii) where our use of your personal data is unlawful but you do not want us to erase it; (iii) 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 (iv) you have objected to our use of your personal 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 in certain circumstances. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

Appendix 1
Cookie Policy

1. 'Cookies' on rinskin.com

1.1 rinskin.com uses 'cookies'. Some of these are essential or functional, while others help us to improve your experience by providing insights into how the site is being used. We may also use 'cookies' for advertising. Some 'cookies' and similar technologies, particularly those that track browsing behaviour across the web are perceived by data protection regulators as privacy-intrusive. We are, therefore, presenting the below information to rinskin.com visitors in order to explain why and how we use this technology. 'Cookies' work with the help of certain online identifiers and typically involve the processing of the following information that is considered personal data:

1. Internet Protocol (IP) addresses;
2. device or mobile IDs and/or device model and type;
3. browser information, operating system information, and/or language preferences;
4. the location and the preceding and succeeding websites you have visited, including which pages/part/icons on rinskin.com you interacted with;
5. applications you click on and how often; and/or
6. the pages of rinskin.com you visit, and how long you spend on each page.

1.2 Lawful grounds for processing

For the purposes of data protection law, we use the following justifications to process your online identifiers derived from 'cookies':

1. we use 'cookies' for the correct, efficient and viable delivery of online content. The processing is necessary for our legitimate interest (that are to ensure the availability of rinskin.com);
2. we use 'cookies' for the analysis and optimisation of rinskin.com's performance and engagement. The processing is necessary for the purpose of improving our services and is subject to your permission (consent); and
3. we use 'cookies' for the delivery (including via third parties) of targeted advertising tailored to your interests. The processing is necessary for the purpose of promoting our services and is subject to your permission (consent).

1.3 Details of the processing

The following 'cookies' are automatically downloaded on any device used to access rinskin.com.

1.4 Exercising control ¹

1. Please exercise your choice with respect to accepting or rejecting 'cookies' via the pop-up on rinskin.com);
2. In addition to the controls provided on rinskin.com via the pop-up, you can choose to block 'cookies' by activating the settings on your browser that allow you to refuse the setting of all or some 'cookies'. However, if you use your browser settings to block all 'cookies' (including essential 'cookies') you may not be able to access parts of rinskin.com. Your browser settings also allow you to delete all 'cookies' stored on your device whenever you wish.
   

Note to Rin: again, this can be tailored or removed depending on the nature of the cookies you end up using.