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Privacy Policy

How Hutton Medical collects, uses and protects your personal information

1. INTRODUCTION

Wellness on Route (Pty) Ltd, trading as Hutton Medical (“Hutton Medical”, “we”, “us” or “our”), respects your privacy and is committed to protecting your personal information in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”) and any other applicable Law.  This Privacy Policy explains how Hutton Medical collects, uses, stores, discloses and otherwise processes personal information when you use or interact with SkinDrop, including when you visit the Website, create or use an Account, purchase Products or use the Subscribe & Save or loyalty programmes. This Policy applies to personal information processed by Hutton Medical through SkinDrop. 

2. WHO WE ARE (RESPONSIBLE PARTY)

The responsible party for purposes of POPIA is Wellness on Route (Pty) Ltd, trading as Hutton Medical, registration number 2018/510982/07, with its physical address at 4 Longships Drive, Plettenberg Bay, 6600, South Africa, email [email protected] and telephone +27 (0)44 533 0518. Hutton Medical’s Information Officer is Denel Joles and is responsible for overseeing POPIA compliance and dealing with requests relating to personal information.

3. PERSONAL INFORMATION WE COLLECT

  1. Identity and contact details: name, email address, telephone number, delivery and billing address.
  2. Account information: login details, order history, subscription and Skindrops loyalty activity.
  3. Payment information: processed securely by our payment provider; we do not store your full card details.
  4. Health and skin information: for example details you share in a skin assessment, consultation, or when we advise on product suitability (see section 4).
  5. Communications: messages, enquiries, reviews and correspondence with us.
  6. Website and device data: IP address, browser, and cookie data (see section 13).

4. SPECIAL PERSONAL INFORMATION (HEALTH)

Some information we process – such as skin conditions, medical or health details relevant to product or treatment suitability – constitutes “special personal information” under POPIA.

Hutton Medical will process health information only where permitted by POPIA, including where the data subject has consented to the processing or where the processing is otherwise authorised by sections 27 and 32 of POPIA. Where health information is processed for the purposes of providing appropriate skincare, treatment, care or advice, such processing will be limited to what is necessary for those purposes.

Health information will be treated as confidential and access will be restricted to persons who require access for legitimate and authorised purposes, subject to appropriate technical and organisational safeguards. Hutton Medical will not use health information obtained through a consultation or skin assessment for unrelated marketing purposes merely because it is in its possession.

5. HOW WE COLLECT INFORMATION

We collect information directly from you (when you create an account, place an order, complete a skin assessment, subscribe, join Skindrops, contact us, or visit our practice), and automatically through cookies and similar technologies when you use the Website.

6. WHY WE PROCESS YOUR INFORMATION

  1. To create and administer your Account 
  2. To process and deliver your orders, subscriptions and downloads.
  3. To operate your account and the Skindrops loyalty programme.
  4. To provide skincare advice and care, and to respond to enquiries.
  5. To send service communications (order and subscription updates).
  6. To send marketing communications, where lawfully permitted (see section 8).
  7. To meet legal, regulatory, accounting and tax obligations, and to prevent fraud.

7. LAWFUL BASIS FOR PROCESSING

Hutton Medical will process personal information only where a lawful basis exists under POPIA or other Applicable Law, including where you have provided consent, processing is necessary to perform a contract, comply with a legal obligation, protect your legitimate interests or those of another person, or pursue Hutton Medical’s legitimate interests where permitted and not overridden by your rights. Where processing is based on consent, you may withdraw your consent, subject to any legal or contractual consequences and without affecting the lawfulness of processing carried out before withdrawal.

8. MARKETING AND CONSENT

We only send marketing communications where you have opted in, and you can unsubscribe at any time using the link in our emails or by contacting us. Withdrawing marketing consent does not affect service communications relating to your orders or subscriptions.

9. WHO WE SHARE YOUR INFORMATION WITH (OPERATORS)

We share personal information only as needed, with service providers (“operators”) who process it on our behalf under confidentiality obligations, including:

  1. Our payment provider, to process payments.
  2. Our courier/delivery partner, to deliver orders.
  3. Our website hosting, IT, email and loyalty-programme service providers.
  4. Third-party suppliers (for example MedWave) where you enquire about or purchase a device they fulfil.
  5. Professional advisers or regulators, where required by law.

We do not sell your personal information.

10. CROSS-BORDER TRANSFERS

Some of our service providers, including hosting, IT, email or other technology providers, may process or store personal information outside the Republic of South Africa. By accepting this Privacy Policy and providing your personal information, you consent to the transfer of your personal information to third parties in foreign countries where this is necessary for the purposes described in this Privacy Policy, subject to the requirements of POPIA. Where personal information is transferred outside the Republic, Hutton Medical will take appropriate steps to ensure that the transfer is conducted in accordance with section 72 of POPIA and that the personal information receives an adequate level of protection.

11. SECURITY

We apply reasonable technical and organisational measures to protect personal information against loss, unauthorised access and misuse. While we work to safeguard your information, no online transmission or storage is completely secure.

12. RETENTION

We keep personal information only for as long as necessary for the purposes described here, or as required by law (for example tax, accounting or medical record-keeping obligations), after which it is securely deleted or de-identified.

13. COOKIES

The Website uses cookies and similar technologies to make it work, remember your preferences, support the Skindrops programme, and understand how the site is used. You can control cookies through your browser settings; disabling some cookies may affect how the Website functions.

14. YOUR RIGHTS

Subject to POPIA, you have the right to request confirmation of and access to personal information we hold about you; request correction or deletion; object to certain processing, including direct marketing; withdraw consent where applicable; request restriction of processing where permitted by law; and lodge a complaint with the Information Regulator. To exercise these rights, contact our Information Officer at the details above. We may need to verify your identity before processing your request. 

15. COMPLAINTS

If you are not satisfied with how we handle your information, please contact us first. You also have the right to lodge a complaint with the Information Regulator (South Africa): enquiries: [email protected]; complaints: [email protected].

16. CHILDREN

The Website is primarily intended for persons aged 18 years and older. Where Products are intended for children, purchases must be made or managed by a parent or lawful guardian, who is responsible for any information provided about the child. Hutton Medical will not knowingly process a child’s personal information except where permitted by POPIA or other Applicable Law and, where required, will obtain any prior authorisation from the Information Regulator.

17. THIRD-PARTY WEBSITES

SkinDrop may contain links to third-party websites or services. Hutton Medical is not responsible for the privacy practices of third-party websites that are not operated by us. You should review the privacy policy of any third-party website before providing personal information to it.

18. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. The current version is always available on the Website, with the date it was last updated.

19. CONTACT

[email protected], 4 Longships Drive, Plettenberg Bay, 6600, +27 (0)44 533 0518.

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