Privacy policy

Alfred Franks and Bartlett PLC operates the authorised website for Eulah, eulahskin.com, and is licensed to manufacture and sell Eulah products. Alfred Franks and Bartlett PLC ("we", "us" or "our") is committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals' rights.

The statement applies to personal data provided to us, both by individuals themselves and by others on behalf of individuals. We may use personal data provided to us for the purposes described in this privacy statement or as made clear in another form before collecting personal data.

Alfred Franks and Bartlett PLC's registered office is Ground Floor Cooper House, 316 Regents Park Road, London, N3 2JX. Eulah's trading address is AFB House, Alban Park, Hatfield Road, Hertfordshire, AL4 0JJ.

The Eulah website is eulahskin.com and is owned and operated by Alfred Franks and Bartlett PLC.

PERSONAL DATA

Under the UK GDPR and the Data Protection Act 2018 ("the Act"), personal data is defined as 'any information relating to an identified or identifiable natural person ('data subject'), by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person'.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure and retention periods for each purpose differ and are set out in the relevant sections below.

The personal data that is provided to us comes either directly from the individual concerned, from a third party acting on behalf of an individual or from publicly available sources (such as internet searches and Companies House).

Where we receive personal data from a third party that relates to an individual, we request that the third party informs the individual of the necessary information regarding the use of their data and we check the third party in accordance with the Data Processing Agreement. In addition, at the very first communication with the individual, we inform them where we collected the data from.

THE DATA CONTROLLER

A data controller is the individual or legal person who controls and is responsible for keeping and using personal data in paper or electronic files. Alfred Franks and Bartlett PLC, trading as Eulah, is the data controller as defined by relevant data protection laws and regulation.

LAWFUL PROCESSING

The lawful bases for processing are set out in Article 6 of the UK GDPR. At least one of these must apply whenever personal data is to be processed:

(a) Consent: you have given Alfred Franks and Bartlett PLC freely given, specific, informed and unambiguous consent for your personal data to be processed for a specific purpose.

(b) Contract performance: the processing is necessary for the performance of a contract you have with Alfred Franks and Bartlett PLC, or because you have asked us to take specific steps before entering into a contract.

(c) Compliance with a legal obligation: the processing is necessary for Alfred Franks and Bartlett PLC to comply with the law (for example tax or consumer protection obligations, not including contractual obligations).

(f) Legitimate interests: the processing is necessary for Alfred Franks and Bartlett PLC's legitimate interests, or the legitimate interests of a third party, unless there is a good reason to protect the individual's personal data that overrides those legitimate interests.

DATA RIGHTS

Your data subject rights are listed below:

• the right of access

• the right to rectification

• the right to erasure or right to be forgotten

• the right to restriction of processing

• the right to be informed

• the right to data portability

• the right to object

• the right not to be subject to a decision based solely on automated processing

Under the UK GDPR and the Act, you may ask for a copy of the information we hold about you and you may request that corrections be made to this information if it is inaccurate or not up to date.

To exercise any of the above rights, please write to:

Head of Data Privacy

Ground Floor Cooper House, 316 Regents Park Road, London, N3 2JX

Email: data@afb.co.uk

Phone: 01727 833877

DATA THAT WE HOLD

Customers

We sell Eulah skincare products directly to individuals through our website. The exact data held will depend on the products and services provided.

Where we engage with customers, we may collect and process personal data in order to satisfy a contractual obligation. We request that customers only provide the personal data that is required for us to fulfil that obligation.

Why do we process data?

Where data is collected from customers, it is used for a number of purposes, such as:

• Providing products and services to customers: data is processed in order to take payment, fulfil and deliver your order and handle returns and refunds;

• Customer management: when communicating with and assessing the needs of customers, personal data may be processed in order to ensure that their needs are appropriately met;

• Administration: in order to manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing customer relationships, administering customer facing applications and maintaining internal operating processes.

What data is processed?

The data that is processed depends on the products and services being provided.

• Personal data may include name, contact details, delivery and billing address, order history, payment data and any other specifically relevant data.

Business Contacts

Personal data from our contacts, which covers both potential and prior customers, is held in our Customer Relationship Management and email marketing systems.

This information is entered into these systems as part of the process of providing products and services to you, or when you sign up to hear from Eulah.

We use these systems to improve our services and to update our customers on additional products and services we provide. We rely on the lawful basis of contract, consent and legitimate interest, depending on the situation. Contacts can withdraw their consent or update their preferences at any time by visiting the website or using the unsubscribe link within one of our emails or replying STOP to an SMS.

Why do we process data?

Where personal data on business contacts is held, it is used for the following purposes:

• Updating the customer on products and services;

• Promotion and development of our offerings;

• Communication of updates;

• Feedback;

• Managing our relationships; and

• Administration and management.

What data do we hold?

Personal data that may be stored in these systems includes, but is not limited to, names, email addresses, mobile numbers, physical addresses and details of the initial interaction.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

Our people

We collect personal data for our people as part of the administration, management and promotion of our business activities.

Our Staff Handbook and consultancy agreements explain further how personal data is held for our staff, directors and consultants.

Applicants

Where an individual is applying to work for us, personal data is collected through the application process. Some data is collected through forms on the website, details of which can be found in the section describing people who use our website. Data collected on applicants via the website will be used for the purposes detailed below.

Why do we process data?

There are a number of purposes for which personal data for applicants is collected, such as:

• Employment: we process an applicant's personal data in order to assess their potential employment at Alfred Franks and Bartlett PLC; and

• Administration and management: we may also use this personal data in order to make informed management decisions and for administration purposes.

Suppliers

We collect and process personal data about our suppliers, subcontractors and the individuals associated with them. The data is held to manage our relationship, to contract and receive services from them and in some cases to provide products and services to our customers.

Why do we process data?

• Receiving goods and services: we process personal data in relation to our suppliers and their staff as necessary to receive the services;

• Providing services to our customers: where a supplier is helping us to deliver products or services to our customers, we process personal data about the individuals involved in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our customers;

• Administering, managing and developing our business and services: we process personal data in order to run our business, including:

– managing our relationship with suppliers;

– developing our business and services, such as identifying customer needs and improvements in service delivery;

– maintaining and using IT systems;

– hosting or facilitating the hosting of events; and

– administering and managing our website, systems and applications.

• Security, quality and risk management activities: we have security measures in place to protect our and our customers' personal information, which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake, for example automated scans to identify harmful emails. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers. We collect and hold personal data as part of our supplier contracting procedures. We monitor the services provided for quality purposes, which may involve processing of personal data.

• Promoting our services: we may use business contact details to provide information that we think will be of interest about us and our products and services.

• Complying with any requirement of law, regulation or a professional body of which we are a member: we are subject to legal, regulatory and professional obligations. We need to keep certain records to show we comply with those obligations and those records may contain personal data.

What data do we hold?

We hold the data that is necessary for the purposes listed above. As an example, we will typically hold supplier names, contact names and contact details of suppliers.

People who use our website and other means

When people visit our website, personal data is collected both through automated tracking and interactions with various forms on the website.

Personal data may also be collected when individuals contact us by phone, email or otherwise. This includes information provided when an individual registers to use our website, subscribes to our emails or SMS, makes an enquiry, leaves a review, enters a competition, promotion or survey, applies to work for Alfred Franks and Bartlett PLC or reports a problem with our website.

When individuals visit our website, certain personal data may be automatically collected.

We work closely with third parties who may collect data on our behalf (including, for example, subcontractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers).

Often, individuals who visit our website additionally fall into another category as listed in this privacy policy. For instance, users of our website may be current customers, business contacts or become customers in the future. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.

Why do we process data?

There are several reasons why we will process the personal data that an individual may provide to us when visiting our website. For example:

• Services: as part of the products you are purchasing;

• Administration: to administer our website and to improve internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. For example, we use this data to ensure that the website is presented well for individuals and is optimised appropriately;

• Functionality: in order to allow individuals to use some functionality of our website, certain personal data must be entered in order for features to work as intended;

• Security: in order to keep our website safe and secure, we may sometimes collect personal data, for instance login information and other data that can be used to verify an individual's identity;

• Promotion and development of our offerings: some personal data may be used in order to measure or understand the effectiveness of advertising we serve to individuals and to ensure that only relevant advertising appears.

What data do we hold?

The data that we hold depends on what data was entered and for what purpose.

Where data was entered in order to engage with functionality of our website, that personal data may include names, addresses, email addresses, phone numbers and payment information. Card details are processed by our payment provider and are not stored by us.

Where data is collected automatically, this includes technical information such as IP addresses used to connect an individual's device to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

We may also collect other data about an individual's visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), products viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.

Our website uses cookies to distinguish individuals from one another. This helps us to provide a better experience when individuals browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

SHARING PERSONAL DATA

We use third party processors to process your personal data for the purposes of hosting our website and financial transactions (Shopify), email and SMS marketing (Klaviyo and Omnisend), website analytics (Google Analytics) and delivery (Parcelforce). For more information about how they process your data please click on the links above.

We may also share your personal data with third parties when we are legally permitted to do so. Before engaging with third parties, we conduct vendor risk assessments and regulation tests to verify the compliance level of those third parties. When we decide to share your data with those third parties, we put contractual arrangements and security mechanisms in place to protect your data in order to maintain compliance with our data protection, confidentiality and security standards.

Personal data held by us may be transferred to:

• Third party organisations that provide applications/functionality, data collection and processing or IT services to us: we use third parties to support us in providing our services, obtaining feedback from our customers and prospective customers and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud-based software as a service, identity management, website hosting and management, data analysis, data back-up, security and storage services;

• Third party organisations that otherwise assist us in providing goods, services or information, including our warehouse and delivery partners;

• Auditors and other professional advisers; and

• Law enforcement or regulatory agencies or those required by law or regulations.

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

THIRD PARTY WEBSITES

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

LOCATIONS OF PROCESSING

The data that we collect from you is processed in the UK. Where any of our third party processors store or process data outside the UK, the transfer is conducted in line with the requirements set out in Chapter 5 of the UK GDPR.

If personal data is transferred outside the UK to a country without a designated adequacy decision, Alfred Franks and Bartlett PLC will ensure appropriate safeguards are in place, such as the processor's Binding Corporate Rules, the UK International Data Transfer Agreement or Standard Contractual Clauses with the UK Addendum, so that the data is processed in accordance with the UK GDPR.

SECURITY OF YOUR INFORMATION

To help protect the privacy of data and personally identifiable information you transmit through use of our website, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide products or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

HOW LONG WE STORE YOUR PERSONAL DATA FOR

We store your personal data in accordance with our data retention policy, commonly known as the Record Retention and Destruction Policy (RR&D). This policy is reviewed and updated internally to ensure we do not store your data for longer than is necessary. We also review how and where we store any data to ensure that we meet our obligation to store data securely.

In addition, some of the data we hold may be subject to certain legal and regulatory obligations, which provide a minimum retention period for different types of data. The retention period varies depending on the data we hold.

Furthermore, as outlined in this policy we collect data for different purposes and from different groups, for which we retain the information in different ways:

Customers

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years). We may keep data for longer in order to establish, exercise or defend our legal rights and the legal rights of our customers.

Personal data we do not use is securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

Business Contacts

We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected. The personal data of business contacts shall not be retained where there is no evidence that a business contact is engaged with us or our communications.

Our People and applicants

Personal data collected for applicants is held for as long as necessary in order to fulfil the purpose for which it was collected, or for a maximum of two years where those purposes are no longer necessary.

Suppliers

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). Data may be held for longer periods where required by law or regulation and in order to establish, exercise or defend our legal rights.

People who use our website and other means

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

For more information about our data retention schedule, please email us at data@afb.co.uk.

CHANGES TO THIS PRIVACY POLICY

This privacy policy was last updated on 14 September 2026. Alfred Franks and Bartlett PLC reserves the right to vary this privacy policy from time to time. Such variations become effective on posting on this website. Your subsequent use of this website or submission of personal information to Alfred Franks and Bartlett PLC will be deemed to signify your acceptance of the variations.

COMPLAINTS

For further information on your rights and how to complain to the ICO, please refer to the ICO website ico.org.uk/concerns.

Contact details:

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Tel: 0303 123 1113 (local rate)

DATA CONTROLLER AND CONTACT INFORMATION

The data controller is Alfred Franks and Bartlett PLC, trading as Eulah, registered in England under company number 02937270. Registered office: Ground Floor Cooper House, 316 Regents Park Road, London, N3 2JX. VAT No: 646 2591 23.

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Head of Data Privacy

Ground Floor Cooper House, 316 Regents Park Road, London, N3 2JX

Email: data@afb.co.uk

Phone: 01727 833877

For general enquiries about Eulah:

Email: hello@eulahskin.com

Eulah, AFB House, Alban Park, Hatfield Road, Hertfordshire, AL4 0JJ