Privacy Policy

FETTLE AESTHETICS Privacy Policy DRAFT — for solicitor review prior to publication. Not yet legally reviewed.

1. Who we are

This Privacy Policy explains how Fettle Aesthetics Ltd, a company registered in England and Wales under company number 17325745, with registered office at South Lodge, Whitbarrow Lodge, Witherslack, Cumbria, LA11 6SJ ("Fettle Aesthetics", "we", "us", "our"), collects, uses, and protects personal data when you use fettleaesthetics.co.uk (the "Site") and related services. We are the data controller for the personal data described in this policy. If you have questions, contact us at info@fettleaesthetics.co.uk

2. What personal data we collect

We collect the following categories of personal data:

Account data: name, email address, password (stored encrypted), phone number
Listing data: business/clinic name, listing content, photos, and any information you choose to include in a listing
Verification data: business/company registration details submitted for seller verification
Payment data: processed directly by Stripe; we do not store full card details ourselves. We may retain limited payment metadata (e.g. amount, date, listing fee band) for accounting purposes
Communications: messages sent through the Site's inbox, and any correspondence you send us directly
Technical data: IP address, browser type, device information, and usage data collected automatically, including via cookies (see our Cookie Policy)

3. How we use your data

We use personal data for the following purposes, and on the following legal bases under UK GDPR:

To create and manage your account (performance of a contract)
To publish and display listings (performance of a contract)
To process listing fee payments via Stripe (performance of a contract)
To verify seller identity and business details (legitimate interests — maintaining marketplace trust and safety)
To communicate with you about your account, listings, or enquiries (performance of a contract / legitimate interests)
To send you service-related notifications, such as launch updates if you signed up for these (consent, where required)
To detect and prevent fraud, misuse, or breaches of our Terms (legitimate interests / legal obligation)
To comply with legal and regulatory obligations, including tax and accounting requirements (legal obligation)

4. Who we share data with

We share personal data with:

Stripe, Inc. — for payment processing. Stripe acts as an independent data controller for payment data; see Stripe's own privacy policy.
Sharetribe Ltd — our marketplace platform provider, which hosts listing and account data on our behalf as a data processor.
Porkbun LLC — our domain registrar and website hosting provider for the Site's landing page.
Google LLC — for Search Console and any analytics tools we may enable.
Other users, where necessary — for example, a Buyer and Seller may see limited contact or listing details of one another in order to complete a transaction.
Professional advisers (e.g. our solicitors or accountants), regulators, or law enforcement, where required by law. We do not sell personal data to third parties.

5. International transfers

Some of our service providers (including Stripe and Google) may process data outside the UK. Where this occurs, we rely on appropriate safeguards such as Standard Contractual Clauses or an adequacy decision, as required under UK GDPR. [Napthens to confirm specific safeguards per current provider terms.]

6. How long we keep data

We retain personal data for as long as necessary to provide the Service and to comply with legal obligations (for example, UK tax law generally requires financial records to be kept for at least 6 years). Listing data is generally retained for the duration of the listing plus a reasonable period thereafter for record-keeping, then deleted or anonymised. [Exact retention periods to be confirmed and formalised with Napthens.]

7. Your rights

Under UK GDPR, you have the right to:

Access the personal data we hold about you
Request correction of inaccurate data
Request deletion of your data, in certain circumstances
Object to or restrict certain processing
Request a copy of your data in a portable format
Withdraw consent, where processing is based on consent
Lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk To exercise any of these rights, contact us at info@fetleaesthetics.co.uk

8. Security

We take reasonable technical and organisational measures to protect personal data, including relying on Stripe's PCI-DSS compliant infrastructure for payment data and encrypted password storage via Sharetribe. No method of transmission or storage is entirely secure, and we cannot guarantee absolute security.

9. Children

The Site is not directed at, and we do not knowingly collect data from, individuals under 18.

10. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be notified via the Site or by email where appropriate.

11. Contact us

For any privacy-related questions or to exercise your rights, contact info@fettleaesthetics.co.uk or by post to South Lodge, Whitbarrow Lodge, Witherslack, Cumbria, LA11 6SJ.