janeiredale.co.uk / janeiredale.ie
(Pharma-E Limited, Trading as Clever Beauty)
Last updated: June 2026
Pharma-E Limited t/a Clever Beauty (“janeiredale.co.uk”) (“We”, “Us”, “Our”) Privacy Statement.
This is Our Privacy Statement which details how We use your personal data (“Personal Data”) when you use Our Website www.janeiredale.co.uk. We take Our data protection responsibilities seriously.
1.1 This Website is owned by Pharma-E Limited t/a Clever Beauty (“janeiredale.co.uk”) a company registered in Albert House, South Esplanade, St Peter Port, Guernsey, GY1 1AJ with company number 36207. Pharma-E Limited t/a Clever Beauty’s registration number with the Office of the Data Protection Authority (ODPA) in Guernsey is DPA3739.
1.2 The Data Protection (Bailiwick of Guernsey) Law 2017 and the European and UK General Data Protection Regulation (the “Regulations”) set out the responsibilities We have to protect your data.
1.3 This Privacy Statement sets out the way We will obtain and hold your Personal Data. This is known as “Processing”. When read together with Our Terms and Conditions of Use and Cookie Policy, this Privacy Statement covers Our relationship with you in relation to this Website.
1.4 Any questions, comments and requests regarding this Privacy Statement should be addressed to: Data Protection Officer, Pharma-E Limited, Albert House, South Esplanade, St Peter Port, Guernsey, GY1 1AJ or email: DPO@janeiredale.co.uk.
2.1 For the purposes of this Privacy Statement:
3.1 We may collect and process the following data and information that you give Us if you register an account, place an order for Goods, or if you submit content on Our Website or otherwise by corresponding with Us by phone, email or otherwise:
3.2 We understand that the data collected at 3.1 is Personal Data.
3.3 We will collect and process the following data automatically from your visit to Our Website:
3.4 Some of the Personal Data We collect and process is necessary to enter into and perform Our contract with you or for Us to meet Our legal obligations.
4.1 We use cookies on this Website to distinguish you from other users and to improve your experience. Non-essential cookies (including analytics cookies) will only be placed on your device after you have given your prior, informed consent using the Cookiebot consent tool (accessible via the privacy trigger icon at the bottom of the screen). Essential cookies, which are strictly necessary for the Website to function, do not require your consent. The use of cookies does not give Us access to your computer or any Personal Data beyond what you choose to share with Us.
4.2 You may choose to accept or decline cookies by using the Cookie Settings tool (accessible via the Cookiebot Privacy Trigger icon) or by modifying your own browser’s settings.
4.3 Further information about the cookies We use and how they work is available in Our Cookie Policy.
5.1 The Website may, from time to time, contain links to and from the websites of our partner networks and affiliates. Please note that these websites and any services accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites or services. Please check these policies before you submit any Personal Data to these websites or use these services.
6.1 We shall use the data and information you give to Us:
6.2 We reserve the right to add to the list of uses in clause 6.1. We shall not use pre-collected data and information for any new uses of your data without consulting you and obtaining your express consent if We are required to do so under the Regulations.
6.3 Where you provide Us with information for the purposes of account registration and orders, We may use such information to verify the information provided, process your application and order, and transfer the data to our Data Processors in order to fulfil or analyse your order.
6.4 We reserve the right to anonymise your data to obtain analysis while retaining your privacy.
7.1 We will only use your Personal Data when the law allows Us to do so. Most commonly We will use your Personal Data in one of the following circumstances:
7.2 The table below sets out the specific lawful basis We rely on for each processing activity:
| Processing Activity | Lawful Basis (Article 6) | Notes |
|---|---|---|
| Creating and managing your account | Contract - Art. 6(1)(b) | Necessary to perform Our contract with you |
| Processing and fulfilling your order | Contract - Art. 6(1)(b) | Necessary to perform Our contract with you |
| Maintaining internal business records | Legitimate interests - Art. 6(1)(f) | LIA held on file with the DPO |
| Customer service and enquiry handling | Contract - Art. 6(1)(b) / Legitimate interests - Art. 6(1)(f) | Depends on whether query relates to an existing order |
| Direct marketing communications | Consent - Art. 6(1)(a) | You may withdraw consent at any time |
| Website analytics (Google Analytics) | Consent - Art. 6(1)(a) | Obtained via Cookiebot prior to any analytics cookies being set |
| CRM service messages (Klaviyo) | Legitimate interests - Art. 6(1)(f) | Service-related messages about your order or account. LIA held on file |
| CRM marketing messages (Klaviyo) | Consent - Art. 6(1)(a) | Only where you have given express consent to marketing |
| Reviews, loyalty and behavioural analytics (Yotpo, which uses Snowplow) | Consent - Art. 6(1)(a) | Obtained via Cookiebot |
| Fraud prevention and site security | Legitimate interests - Art. 6(1)(f) | LIA held on file with the DPO |
| Compliance with legal obligations | Legal obligation - Art. 6(1)(c) | e.g. tax and regulatory requirements |
| Business sale or transfer | Legitimate interests - Art. 6(1)(f) | Disclosure to prospective buyers as part of due diligence |
7.3 Where We rely on legitimate interests as Our lawful basis, We have carried out a Legitimate Interests Assessment (LIA) to confirm that Our interests do not override your rights and interests. A copy of any relevant LIA is available on request from the DPO at DPO@janeiredale.co.uk.
8.1 The data and information We collect from you will be transferred to and securely stored on servers hosted by our third-party e-commerce platform, Shopify Inc., and other approved Data Processors as described in section 9 below.
8.2 We are committed to ensuring that your data and information is secure. In order to prevent unauthorised access or disclosure, We have put in place suitable physical, electronic and operational procedures to safeguard and secure the information We collect online, including:
8.3 Any Personal Data that We collect as described at clause 3.1 shall be processed in accordance with the Regulations, and only to permit Us to process your request or enquiry.
9.1 In providing Us with data and information, you agree that We may disclose such information, where necessary for the purposes and uses listed in clause 6, to:
9.2 We will only disclose your Personal Data to parties who bear sufficient legal responsibility for its protection and who have sufficient privacy and security measures in place to reasonably ensure that it will be protected and handled appropriately.
9.3 We may disclose your Personal Data to third parties:
10.1 Some of Our third-party service providers are based outside the UK and the European Economic Area (EEA). Their processing of your Personal Data will therefore involve a transfer of data outside these areas.
10.2 Whenever We transfer your Personal Data outside the UK or EEA, We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
10.3 Please contact the DPO at DPO@janeiredale.co.uk if you want further information on the specific mechanism used by Us when transferring your Personal Data out of the UK or EEA.
11.1 We will only retain your Personal Data for as long as necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
11.2 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, the purposes for which We process the Personal Data and whether We can achieve those purposes through other means, and the applicable legal requirements.
11.3 In some circumstances We will 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.
You have the following rights in relation to your Personal Data:
Where We process your Personal Data on the basis of Our legitimate interests under Article 6(1)(f), you have the right to object to that processing at any time. If you object, We will cease processing your data unless We can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or where processing is necessary for the establishment, exercise, or defence of legal claims.
Processing activities We currently carry out on the basis of legitimate interests include: maintaining internal business records, certain customer service activities, fraud prevention, service-related CRM communications, and business sale or transfer (see Section 7.2). To exercise your right to object, please contact the DPO at DPO@janeiredale.co.uk, setting out the specific processing activity you object to and the grounds for your objection. We will respond within one calendar month.
Where We rely on consent as the lawful basis for processing your Personal Data (such as for direct marketing or non-essential cookies), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
To withdraw marketing consent, please contact Us at DPO@janeiredale.co.uk or use the unsubscribe link in any marketing communication. To withdraw cookie consent, please use the Cookie Settings tool on the Website.
To exercise any of the rights listed above, please contact:
Data Protection Officer, Pharma-E Limited, Albert House, South Esplanade, St Peter Port, Guernsey, GY1 1AJ
Email: DPO@janeiredale.co.uk
There is normally no charge for making a request. We will respond within one calendar month. We may ask you to verify your identity before We act on a request.
13.1 We reserve the right to make changes to this Policy from time to time by updating this page. Every time you wish to use Our Website, please check the statement to ensure you understand the terms that apply at that time.
13.2 This version is effective as of June 2026.
14.1 Pharma-E Limited is established in Guernsey and is not established in the United Kingdom or the European Union. As required by Article 27 of the UK GDPR and Article 27 of the EU GDPR, Pharma-E has designated representatives in the UK and EU who may be contacted by UK and EU data subjects and by the relevant supervisory authorities.
14.2 UK Representative (Article 27 UK GDPR):
Healthxchange Pharmacy UK Limited, 1st Floor Sackville House, 143-149 Fenchurch Street, London, England, EC3M 6BL
The UK Representative may be contacted by data subjects located in the United Kingdom who wish to exercise their rights under the UK GDPR in relation to Pharma-E’s processing of their personal data, or by the Information Commissioner’s Office. The UK Representative acts in a representative capacity only; Pharma-E remains solely responsible for its own compliance with the UK GDPR.
14.3 EU Representative (Article 27 EU GDPR):
Healthxchange Ireland Limited, Unit 16 The Exchange, Calmount Business Park, Ballymount, Dublin, D12 RF43, Ireland
The EU Representative may be contacted by data subjects located in the European Union who wish to exercise their rights under the EU GDPR in relation to Pharma-E’s processing of their personal data, or by EU supervisory authorities. The EU Representative acts in a representative capacity only; Pharma-E remains solely responsible for its own compliance with the EU GDPR.
15.1 If you believe that your information held by Us is not being handled properly, you have the right to complain to the competent data protection authority: