Genaura Limited

This privacy policy sets out how Genaura Limited ("Genaura", "we", "us" or "our") collects, uses and protects your personal data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. We are committed to safeguarding your privacy and complying with UK GDPR and the Data Protection Act 2018.

Contents

1. Important information and who we are

2. Types of personal 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. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Contact details

11. Complaints

12. Changes to the privacy policy and your duty to inform us of changes

13. Third-party links

1. Important information and who we are

Privacy policy

This privacy policy gives you information about how Genaura collects and uses your personal data through your use of this website, including any data you may provide when you register with us, sign up to our newsletter, purchase a product or service, or take part in a competition.

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

Controller

Genaura Limited (company number 15456338), a company registered in England and Wales, is the controller and is responsible for this website and for your personal data. Where we refer to "Genaura", "we", "us" or "our" in this privacy policy, we mean Genaura Limited.

Genaura Limited's registered address and contact details are set out in paragraph 10 (Contact details) below.

2. Types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store, and transfer various types of personal data about you, grouped as follows:

Identity Data includes first name, last name, any previous names, 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 of payments to and from you, as well as other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, login data, browser type and version, pages visited, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID, and other technology on the devices you use to access this website.

Profile Data includes your username and password, purchases or orders you have made, your interests, preferences, feedback, and survey responses.

Usage Data includes information about how you interact with and use our website, products, and services.

Marketing and Communications Data includes your preferences for receiving marketing from us and our third parties, and your communication preferences.

We also collect, use, and share aggregated data, such as statistical or demographic data, which is not personal data because it does not directly or indirectly reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature, to analyse general trends in how users interact with our website, and to help improve the website and our service offering.

Special category data

Special category data is more sensitive personal data that requires extra protection under data protection law. It includes health data (for example, information about skin or scalp conditions, sensitivities, or allergies).

If you use a skin or scalp assessment, quiz, or similar tool on our website, or otherwise provide us with information about your skin or scalp condition, sensitivities, or allergies to receive personalized product recommendations, we will process this as special category health data. We will only collect and use this data:

• with your explicit consent, given at the time you provide the information; or
• where necessary for reasons of substantial public interest, or another condition permitted under Article 9 of the UK GDPR and the Data Protection Act 2018,

and, in either case, only for the purpose of providing you with personalized product recommendations and improving our product formulations and range. You can withdraw your consent to this processing at any time by contacting us at contact@genaura.com, though this may mean we are no longer able to provide personalized recommendations to you. We do not use special category data for any automated decision-making that produces legal or similarly significant effects on you (see paragraph 4 below).

3. How is your personal data collected?

We use different methods to collect data from and about you, including through:

Your interactions with us.

You may give us your personal data by filling in online 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;

•  complete a skin or scalp assessment or similar tool; or

• Give us feedback or contact us.

Automated technologies or interactions.

As you interact with our website, we automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy for further details: https://genaura.com/cookie-policy-uk/

Third parties or publicly available sources.

We will receive personal data about you from various third parties and public sources as set out below:

• Technical Data is collected from analytics providers such as Google Analytics (based outside the UK); visitor-tracking providers such as Sourcebuster JS; advertising networks such as Meta (Facebook/Instagram Ads) or Google Ads (based both inside and outside the UK); and search information providers such as Bing or Google Search Console (based inside or outside the UK).
• Contact, Financial, and Transaction Data is collected from providers of technical, payment, and delivery services such as Stripe (outside the UK), PayPal (outside the UK), Complianz (inside the UK), and Royal Mail (inside the UK).
•  Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register, both based inside the UK.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: we may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests, and we do not do so where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: we may use your personal data where necessary for compliance with a legal obligation we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: we rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example, if you subscribe to an email newsletter, or where you provide special category health data as described in paragraph 2 above.

Providing your personal data

When we ask you to provide personal data to enter into a contract with us (for example, to place an order), or when we are required by law to collect personal data, we will make this clear at the point of collection. If you do not provide the requested data when asked, we may not be able to perform the contract we have or are trying to enter into with you (for example, we may be unable to process or deliver your order), and we will tell you if this is the case.

Purposes for which we will use your personal data

We have set out below, in table format, a description of all the ways we plan to use the various categories of your personal data and the legal bases we rely on to do so. We have also identified our legitimate interests where appropriate.

Automated decision-making

We do not carry out any processing based solely on automated decision-making (including profiling) which produces legal effects concerning you, or similarly significantly affects you, without human involvement. If this changes, we will update this policy and, where required by law, obtain your consent.

Direct marketing

During the registration process on our website, when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Genaura via email, SMS, telephone and post. Alternatively, 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 marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view on which products, services and offers may be of interest to you, so that we can send you relevant marketing communications.

Third-party marketing

We will obtain your express consent before we share your personal data with any third party for their direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by logging in to the website and checking or unchecking the relevant boxes to adjust your marketing preferences, by following the opt-out links in any marketing communication sent to you, or by contacting us at contact@genaura.com.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example, order confirmations, delivery updates, updates to our Terms and Conditions, or checks that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy: https://genaura.com/cookie-policy-uk/

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below, for the purposes set out in the table under paragraph 4 (How we use your personal data) above.

• Internal Third Parties – other companies within the Genaura corporate group (if any), acting as joint controllers or processors, based in the UK, who provide IT, system administration, fulfilment or other support services.
• External Third Parties – service providers acting as processors who provide IT and system administration services; payment processors (such as Stripe and PayPal); delivery and logistics companies (such as Royal Mail and courier services); professional advisers (including lawyers, bankers, auditors and insurers); and HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
• Specific third parties – for example, Google Analytics (analytics provider based outside the UK), Meta (advertising network based outside the UK), and other providers identified in paragraph 3 above.
• Business transfers – third parties to whom we may choose to sell, transfer or merge parts of our business or our assets, or who we may acquire or merge with. If our business changes, the new owners may use your personal data in the same way as set out in this privacy policy.

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 it for specified purposes and in accordance with our instructions.

6. International transfers

We may share your personal data within Genaura and/or with third-party service providers, some of which are located outside the UK.

Whenever we transfer your personal data out of the UK to countries whose laws do not provide the same level of data protection as UK law, we ensure that a similar degree of protection is afforded to it by putting in place appropriate safeguards, such as:

• The International Data Transfer Agreement (IDTA) issued by the UK Information Commissioner's Office; or
• The International Data Transfer Addendum to the European Commission's Standard Contractual Clauses, or any other data transfer mechanism approved for use in the UK.

To obtain a copy of these safeguards, please contact us at contact@genaura.com.

7. 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 address any suspected personal data breach and will notify you and any applicable regulator if we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 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 of 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, regulatory, tax, accounting or other requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for 6 years after they cease to be customers for tax purposes.

In some circumstances, you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have a number of rights under data protection law in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "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 in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it, 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. We may not always be able to comply with a request for erasure for specific legal reasons, which we will notify 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) as the legal basis for that particular use of your data, including profiling based on our legitimate interests. In some cases we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• Object at any time, on an absolute basis, to the processing of your personal data for direct marketing purposes (see "Opting out of marketing" in paragraph 4 above for details of how to object to receiving direct marketing communications).
• 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. 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 (see paragraph 4 above for details of when we rely on consent). 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, and we will tell you if this is the case.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data where: you want us to establish the data's accuracy; our use of the data is unlawful but you do not want us to erase it; you need us to hold the data even though we no longer require it, because you need it to establish, exercise or defend legal claims; or you have objected to our use of your data and we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us at contact@genaura.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or we could 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 anyone who does not have the right to receive it. We may also contact you to request further information regarding 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.

10. Contact details

Genaura Limited is the controller of your personal data. We have not appointed a formal Data Protection Officer, as this is not currently a legal requirement for our business; instead, all privacy queries and requests to exercise your rights should be sent to the contact below, where they will be handled by a member of our team responsible for data protection.

If you have any questions about this privacy policy, about how we use your personal data, or if you want to exercise your privacy rights, please contact us:

• Email address: contact@genaura.com
• Postal address: Genaura Limited, 16 Great Queen Street, Covent Garden, London, WC2B 5AH, United Kingdom
• Company number: 15456338 (registered in England and Wales)

11. Complaints

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 opportunity to address your concerns before you approach the ICO, so please contact us at contact@genaura.com in the first instance at contact@genaura.com.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 7 July 2026.

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, for example, a new address or email address.

13. 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.