et al Privacy Notice

The International Institute for Active Ageing (“iiaa”) Limited, is a UK-based company that manufactures and sells scientifically proven, planet-positive skin health brands across multiple countries. Our mission is to deliver transformative, life-changing skin results for clients and unparalleled business benefits to our professional salon community.

Our brands and divisions are ‘Advanced Nutrition Programme’, ‘et al’; and ‘eventis Technologies’. We are also the official UK and Republic of Ireland distributor of ‘Environ® Skin Care’ products.

This Privacy Notice addresses the processing of personal data by the et al brand from iiaa, collected from the et al website (https://etalbeautycollective.co.uk/about-us/) or as part of et al’s broader operations. For information on the processing of personal data by iiaa and its other brands and websites, please see the separate iiaa and brand-specific Privacy Notices. If you have a data privacy question or concern regarding et al or this Privacy Notice, please contact iiaa by emailing Privacy@iiaa.eu

Who is responsible for et al’s processing of personal data?

Which personal data is processed and where does it come from?

What is the personal data used for and why?

Purposes of processing

Lawful bases

If you fail to provide your personal data

Change of purpose

Marketing

Cookies

Sharing & Disclosing

Transfers

Retention or your personal data

Security of your personal data

Links to external websites

Your personal data rights

Changes to our privacy practices or to your personal data

Contact Us

Date last updated


Who is responsible for et al’s processing of personal data?

iiaa is the ‘Data Controller’, responsible for how personal data is processed (e.g. how it is collected, used, stored and protected, etc.) by its et al brand.

iiaa is incorporated in the UK with company number 02810868 and registered address of Riverside House, 2A Southwark Bridge Road, London SE1 9HA. Its ICO (the UK’s Information Commissioner’s Office) registration number is Z695067X.

When “we“, us” or “our” is used below it refers to iiaa.

Which personal data is processed and where does it come from?

The personal data relates to the individuals who interact with et al via its website and broader operating processes. Each individual (legally known as the ‘data subject’) is referred to as “the Client”, “I”, “you”, “your”, “user” or “data subject” below.

You provide us with your personal data by filling in forms on our et al website. For instance, when you register to use our website, contact us, subscribe to one of our services, request further services or report a problem with our website; or when you email or call us with your et al questions and enquiries or should you ever need to report an adverse reaction to an et al product.

We collect your personal data when you purchase our products and services; register for one of our et al training sessions; enter one of our et al competitions; and, visit our premises. We also collect details of your visits to our website and the resources that you access. When you register to take part in our clinical trials we collect your personal data.

If you interact with us via social media we collect your personal data; for instance, when you log in to our website via a social media account, or post content from a social media account onto our website (when using the Instagram feed feature for example). Please refer to the privacy policy / notice for each social media account to find out how that platform processes your personal data.

We may also collect or receive your personal data indirectly and from other sources and third parties, for instance:-

  • - For our et al end-user consumer customers – from retailers, department stores, salons and skin healthcare professionals; marketing and loyalty partners (which may include Data Brokers or third-party marketing agencies enlisted to run targeted promotional campaigns); digital platforms and social media; and beauty tech and app providers;
  • - For our et al stockists / trade / B2B customers and distributors – from credit reference agencies; industry directories; events, exhibitions and trade show organisers; parent companies, franchises, or subsidiaries where part of a corporate group;
  • - For those in our et al supply chain and operations – from regulatory bodies and cosmetocovigilance services; and logistics & courier providers;
  • - For our employees and contractors recruited specifically for the et al brand – from recruitment agencies; payroll and benefits providers; previous employers and professional references
  • - For the data subjects who visit our premises – from our building management company.
  • - For the delegates who attend our et al training courses – from the salons or other companies who employ or register the delegates.
  • - For participants for et al clinical trials – from referring medical professionals and dermatologists; Clinical Research Organisations (CROs); Patient Recruitment Agencies; and, Healthcare Booking and Telehealth Platforms.
  • - For Healthcare Professionals (HCPs) and Key Opinion Leaders (KOLs) supporting our et al brand – from medical associations and regulatory bodies; medical marketing and PR agencies; scientific publishers and research databases; and, Continuing Medical Education (CME) providers;
  • - Where et al adverse reactions / product safety concerns are reported on your behalf or for you – from medical professionals and hospitals; National Health Authorities / Regulatory Bodies; legal representatives or family members; and, retailers and distributors;
  • - For our et al shareholders, investors, and corporate advisors where applicable – from company registrars and corporate databases; investment banks, Venture Capital firms, or brokerages; and,
  • - For et al website visitors and digital app users - indirect / automated collection; as well as from cookie and tracking tech providers; and, Consent Management Platforms (CMPs).

The personal data we collect and process includes your names; contact details; billing and address/es; profile data including username or similar identifier and password; payment information, transaction data and product purchase history; data related to the administration of your training; treatment plan and recommended products; marketing communications / direct marketing and cookie preferences; and, device, usage and content data including unique device identifiers, mobile network information, traffic and communication data, and, CCTV footage.

In certain instances, the personal data we may process to provide you with our skin healthcare products and services may be recognised by data privacy laws as ‘special category’. For instance, information relating to your skin health and conditions, your overall health including any allergies, medical conditions or reactions to makeup, or skin analysis images which may identify you and reveal your racial and ethnic origin. In addition, if you have chosen to register for one of our clinical trials we collect specific data – including special category data - such as your demographic information including your age, sex and ethnic background and your health data. What is the personal data used for and why?

Our et al products are not intended to be used for children under the age of 16 years and we do not knowingly collect or use or store personal data relating to children.

Purposes of processing

If you are aged 16 years or above process (use) your personal data for different purposes including, to:-

Present the content from our et al website and digital apps in the most effective manner to you and to your computer or device, and, allow you to participate in the interactive features of our et al service(s), when you choose to do so;

Respond to your questions and enquiries and provide you with the et al information, products or services, support and assistance that you request from us;

Provide you with consultations to identify suitable et al product options and combinations;

Carry out our obligations arising from any contracts entered into between you and us (for instance, fulfilling your et al purchases);

When you visit our premises, to manage your visit and ensure health, safety, and security.

Deliver and manage the et al training course(s) you have registered or have been registered for;

Notify you about material changes to our et al products and services;

Facilitate our et al clinical trials: if you have chosen to register for one, to screen your eligibility to take part, administer the trial, analyse the findings and publish the results after we have anonymised your personal data;

Identify, engage, and manage our relationships with Healthcare Professionals (HCPs) and Key Opinion Leaders (KOLs) supporting our et al brand; this includes conducting credential verification, administering service contracts, collaborating on clinical research and skincare product development, and managing medical education, marketing, and public relations initiatives;

Manage investor relations and administer shareholdings in the et al brand, including processing financial distributions, distributing regulatory corporate communications, and maintaining legally mandated company share registers;

Aggregate the personal data and other information for research;

Investigate any adverse reaction(s) to any et al products you or others may have reported; and,

Recruit and manage the payroll, benefits and employee relations for our dedicated et al contractors or employees (more information is available in our separate ‘iiaa Applicants Privacy Notice (Policy)’ and ‘iiaa Employee Privacy Notice (Policy)’).

Lawful bases

We rely on the following legal justifications (lawful bases) - depending on the context - for the processing of your personal data:

‘Consent’, for instance, when you of register for or subscribe to use our et al website and services, or post material on our et al website.

‘Explicit consent’ - for instance, when we are processing your special category data.

‘Performance of a contract’ in order to provide you with the ANP products and services you have requested, subscribed to or purchased (for instance, skin analysis, consultations, treatment plan, etc.); and,

‘To fulfil our legal obligations’ - where it is necessary for compliance with a legal obligation that we are subject to (for instance, fulfilling our product safety management obligations).

‘Vital interests’ - in rare, life-or-death emergencies where it is absolutely necessary to protect your life or someone else's, and you are physically unable to give us your permission.

We may also rely on the ‘legitimate interests’ lawful basis as outlined below, if the processing is necessary to run our business and improve our et al products and services and we have already assessed and determined that it does not unduly affect your interests or fundamental rights and freedoms – we always seek to maintain a balance between our legitimate interests and your privacy.

The commercialisation of et al’s products and services, for instance, to improve the website, and to notify of material changes to the website, etc.

Direct marketing to the trade, for instance, ‘Customer Relationship Management (CRM) and outreach communications, typically using a CRM platform.

To notify you about material changes to our et al products and services.

Administering our Subscribe & Save service for et al products, for instance, informing subscribers of the special offers and promotions for the product(s) they have ordered and subscribed to.

To manage your visit to our premises and ensure health, safety, and security.

If you fail to provide your personal data

We need certain personal data to comply with the law and fulfil our contract(s) with you. If you choose not to provide it, we may be unable to deliver your goods or services and may need to cancel your order. We will always notify you first.

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.

e. Marketing Communications / Direct Marketing

From time to time we would also like to use our marketing communications / direct marketing platforms to send you marketing information (news and offers) for et al and / or the other brands from iiaa. The processing may include:-

Profiling and segmenting your personal data, and, combining it with other data collected or received indirectly from public sources or third parties (for instance, national census data) in order to send you only the marketing information that is relevant to your profile.

This processing is optional, and subject to you choosing to opt into (consent to) our marketing communications / direct marketing for et al and each of iiaa’s other brands separately and in advance. If the processing involves cross-border / international transfers of your personal data we will also collect your prior, informed, explicit consent or rely on approved transfer mechanisms such as Standard Contractual Clauses (SCCs).

You can opt out of our marketing communications at any time by using the unsubscribe link provided in each marketing communication.

Cookies

We use Google Analytics to analyse the use of our et al website. Google Analytics generates statistical and other information about our website use by means of cookies (small text files containing a random and unique identifier, which are stored on users' computers), which Google stores in reports. More information is available in the Google Analytics privacy policy: http://www.google.com/privacypolicy.html.

We use essential cookies on our et al website collecting your IP address for this purpose. These essential cookies enable core functionality such as page navigation and website performance, security, verification of identity and network management and they cannot be disabled. Our lawful bases for this processing of your data are 'contract fulfilment' and 'legitimate interests'.

We would also like to use the following cookies, but only if you give us your permission to do so by consenting. They are all disabled as the default. To consent click 'Accept '. Otherwise, you can reject them by keeping them disabled (or click 'Reject').

'Marketing cookies' track advertising effectiveness to provide a more relevant service and deliver better ads to suit your interests.

'Functional cookies' collect data to remember choices users make to improve and give a more personalised experience.

'Analytical cookies' help us to understand how visitors interact with our website, discover errors and provide a better overall analytics. We may also collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions and patterns and does not identify any individual.

Further information is available in our Cookie Policy.

Sharing & Disclosing

We use your personal data solely for the purposes outlined in this et al Privacy Notice and we do not sell, rent, share or otherwise make it commercially available to any third parties for marketing purposes, except with your prior permission.

We may share or disclose your personal data with authorised personnel or third parties, only if required for the stated uses and only as allowed by the law; for instance, with our service providers (such as payment services providers and delivery companies), and, with our research partners (aggregated data only). We may also disclose it to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of our customers, prospective customers, stockists or others.

We may disclose your personal data to public and government authorities, national security and/or law enforcement officials for many reasons. For instance, for fraud protection and credit risk reduction purposes, to ensure product safety and protect public health interests, and, to comply with any legal obligations and as otherwise required by law. This may include to respond to court orders, or similar legal processes, to establish or exercise our legal rights or, defend against legal claims, or if in such circumstances disclosure is required or appropriate. It may also include sharing with selected chemists or others in our supply chain should there ever be a need to investigate a recurring reaction.

To ensure the integrity of your personalised makeup plan we may share your et al product order history with your chosen Salon on Treatment Provider. Additionally, we may share your images with them for a specific use (for example, for their social media channels), but only after we have verified that you have explicitly consented to that specific use.

If in the future we re-organise or transfer all or part of our et al business, or substantially all of our et al assets are acquired by a third party we may need to transfer the information about our customers, prospective customers, stockists, employees or others to new et al entities or to third parties through which the business of et al will be carried out.

Transfers

If the sharing or disclosure of your personal data involves international data transfers to countries outside the UK we ensure that the transfers are to ‘adequate’ countries, i.e. those that have been deemed to provide an adequate level of protection in accordance with Data Protection Law. If the transfers are to ‘third countries’ not deemed as adequate, we rely on your explicit prior consent or we use standard contractual clauses or other mechanisms or instruments to mandate that the transfers are afforded the same degree of data protection and appropriate security measures as in the UK.

Retention of your personal data

We keep and store (retain) your personal data securely only for as long as we need to for the reasons described above, and for any additional term/s as required by applicable laws and/or to fulfil our legal obligations. For instance, we will retain your engagement and transactional information for as long as your et al customer account remains active and as needed to provide our et al services, and, where required to resolve disputes, and enforce our agreements.

Where you have given your explicit consent to use your special category personal for a specific marketing use or activity (for example, incorporation in iiaa’s training materials; publishing in internal company publications (e.g., newsletters, presentations, intranet posts), in external communications (e.g., website, promotional materials, press releases), or on social media platforms (e.g., Instagram); and, in corporate events coverage), this personal data may be retained for the specific use you have consented to, even after you have withdrawn your explicit consent, if removal from previously published materials is not feasible. Security of your personal data

We take appropriate physical and electronic safeguards and security measures to protect your personal data and keep it only as long as is necessary. We also use strict data security policies and procedures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised manner.  

Where we have provided you (or you have chosen) a password to access certain parts of our et al website, you are responsible for keeping this password confidential and not share it with anyone. Data transmission over the Internet is not 100% secure. Consequently, we cannot guarantee or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we use reasonable efforts to ensure security on our systems.

We have procedures in place to handle any suspected personal data breach in accordance with the Data Protection Law. In the event of a personal data breach we will notify you and any applicable regulator when we are legally required to do so. We shall then fully investigate and implement corrective action to prevent recurrence. Links to external websites

Our et al 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 information about you. We do not control these third parties and are not responsible for their privacy practices, statements or notices. When you leave our et al website, we encourage you to read the privacy notice of every third party you visit or connect with. Your personal data rights

Under certain circumstances under Data Protection Law you have the following rights in relation to your personal data. To exercise your rights, please email privacy@iiaa.eu. We respond to you within one month. If your request is particularly complex we may take longer but we will notify you of the timeframe and keep you updated. You will not have to pay a fee exercise your rights, although we are allowed to charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, and we may refuse to comply with your request in certain circumstances. Please note that we may need to ask you for specific information first to confirm your identity, so that we are not disclosing your personal data to someone who has no right to receive it.

Request access – to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction – to have any incomplete or inaccurate personal data we hold corrected, though we may need to verify the accuracy of the new data you provide.

Request erasure – to ask us to delete or remove personal data where there is no good reason for continuing to process it, or we may be processing it unlawfully, or, are required to erase it to comply with local law. If we are not able to comply for other specific legal reasons - for example, we can lawfully deny deletion requests when data retention is required to ensure product safety, protect public health interests, or establish and defend legal claims - we will notify you at the time of your request. In addition, erasure from previously published materials may not be feasible.

Object to processing – where we are relying on a legitimate interest that you believe impacts on your fundamental rights and freedoms. We may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You may also object if we are processing your personal data for marketing communications / direct marketing purposes.

Request restriction of processing – to ask us to suspend the processing of your personal data 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 because you need it to establish, exercise or defend legal claims; or 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 (such as another Salon or Treatment Provider to continue to receive your et al treatments), in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided your explicit consent to use or where we have used the information to perform a contract with you.

Withdraw consent – where we are relying on your consent (e.g. to receive our et al marketing communications / direct marketing) you can opt out at any time by using the unsubscribe link provided in each marketing communication. Withdrawing your consent will not affect the lawfulness of any processing carried out beforehand. If you are withdrawing consent from our use of your personal data in our marketing materials and activities please note that your personal data may continue to be used on previously published materials where removal is not feasible, and will be removed from future materials where reasonably practicable.

Where we are relying on your explicit consent, for instance, for clinical trials, you may withdraw it, for instance, you may leave the trial at any time. Withdrawing your explicit consent will not affect the lawfulness of any processing carried out beforehand. However, in most instances your Salon or Treatment Provider may not be able to continue with or complete your treatment plan without your explicit consent. In addition, there are many instances in which we can lawfully deny deletion or consent withdrawal requests – for example, when investigating your reports of adverse reactions and data retention is required to ensure product safety, protect public health interests, or establish and defend legal claims.

You also have the right to make a complaint at any time to: the Information Commissioner’s Office (“ICO”), the UK regulator for data protection issues at http://www.ico.org.uk” if you are based in the UK; or, the Data Protection Commission (“DPC”), the Irish regulator for data protection issues at http://www.dataprotection.ie” if you are based in the Republic of Ireland; or any other regulatory authority for your territory (e.g. the member state where you reside at https://ec.europa.eu/info/index_en if you are based in the European Union). We would however, appreciate the chance to address your concerns first so please contact us in the first instance.

Changes to our privacy practices or to your personal data

We keep our privacy practices and this Privacy Notice under regular review to ensure that they meet legal requirements and industry standards. We may update them occasionally, with changes posted in this notice, and effective from the notice publication date. If the changes are material (significant modifications), we will notify you via email or place a prominent notice on the et al website.

It is important that the personal data we hold about you is always accurate and current and it is your responsibility to keep us informed if any of it changes during our relationship with you. Please contact us to inform us of any changes. Contact us

To exercise any of your data rights, or if you have a question or concern regarding et al or this notice, please contact iiaa by emailing Privacy@iiaa.eu If you have a data privacy complaint, please click here to complete and submit our ‘Data Privacy Complaints Form’. Date last updated

This et al Privacy Notice was last updated on 07/08/2026.