Privacy and Cookie Policy

Effective date: 09/09/2025
Last updated: 28/01/2026

This Privacy Policy and Cookie Policy (the “Policy”) explains how STELLAR CARE SERVICES LTD (company number 13656611) of Dept 6400a 126 East Ferry Road, Canary Wharf, London, United Kingdom, E14 9FP (“CliniqueMode”, “we”, “us”, “our”) collects, uses, discloses, stores, and protects personal data when you access or use our website at cliniquemode.com and any related services, features, tools, and content (collectively, the “Website” and “Services”). For the purposes of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, we are the data controller in respect of the processing described in this Policy.

We are committed to processing personal data lawfully, fairly, and transparently in accordance with the laws of England and Wales and applicable UK data protection law, including UK GDPR and the Data Protection Act 2018. This Policy applies only to information collected through our Website and Services. It does not apply to third-party websites, platforms, or services that may be linked to or integrated with the Website; those third parties have their own policies and we are not responsible for their practices.

1. Key terms and definitions
   In this Policy:

• Personal data means any information that relates to an identified or identifiable individual.
• Processing means any operation performed on personal data, whether automated or not, including collection, recording, organisation, structuring, storage, use, disclosure, or deletion.
• Controller means the entity that determines the purposes and means of processing personal data.
• Processor means a third party that processes personal data on behalf of the controller.
• User means any individual who accesses or uses the Website or Services.
• Cookies means small text files placed on your device that enable the Website to function and/or provide analytics and other features. Similar technologies include pixels, SDKs, local storage, and tags.
• Account means a user profile created on the Website (where available).
  Wallet Balance means any internal stored-value balance feature offered on the Website for advance payment of Services (where applicable).

1. Who we are and how to contact us
   Controller: STELLAR CARE SERVICES LTD (company number 13656611)
   Address: Dept 6400a 126 East Ferry Road, Canary Wharf, London, United Kingdom, E14 9FP
   Website: cliniquemode.com
   Email (privacy enquiries and rights requests): info@cliniquemode.com
2. Summary of what we do
   CliniqueMode provides AI-generated, digital skincare guidance and educational outputs such as ingredient analysis, safety insights, compatibility checks, and personalised routine suggestions based on information provided by users. The Services are delivered digitally. We do not sell or ship physical goods through the Website. Some inputs you provide may relate to your skin preferences or sensitivities. You should not submit information about pregnancy, breastfeeding, or children, and the Services are not intended for such use.
3. The personal data we collect
   We collect personal data in the following categories:
   1. Data you provide directly
      1. Account and contact data: name (if provided), email address, login credentials (in hashed form), and other profile information you choose to provide.
      2. Support and communications: contents of messages you send to us (for example, emails, support tickets, feedback).
      3. Transaction and billing data: records of purchases, payment status, currency, timestamps, and billing descriptors. We do not typically store full payment card numbers; these are handled by payment processors.
      4. User inputs for Services: product names, ingredient lists, routine preferences, and other information you submit for analysis or routine generation.
      5. Preferences: marketing preferences, cookie preferences, and consent records (where applicable).
   2. Data collected automatically
      1. Device and technical data: IP address, device identifiers, browser type and version, operating system, language settings, and similar technical identifiers.
      2. Usage data: pages viewed, features used, clickstream data, timestamps, approximate location derived from IP (country/city level), and error logs.
      3. Security data: authentication logs, fraud and abuse indicators, and audit records needed to protect the Website and users.
   3. Cookies and similar technologies
      We use cookies and similar technologies to operate the Website, remember preferences, improve performance, and understand how users interact with our Services. See Section 10 for details.
   4. Special category data
      Special category data under UK GDPR includes information about health. We do not intentionally request or require special category data. However, some user inputs (for example, allergies, sensitivities, or skin-related details) could, depending on context, be treated as health-related information. If you choose to submit such information, we process it only to provide the Services you request and to maintain and improve service quality and security, as described in this Policy. You should not submit data relating to pregnancy, breastfeeding, or minors.

1. How we use your personal data and why
   We use personal data for the following purposes:
   1. Providing and operating the Website and Services
      To create and manage accounts, authenticate users, provide access to paid and unpaid features, generate Deliverables, and deliver digital content to your device or account.
   2. Processing payments and administering purchases
      To process one-off purchases and/or Wallet Balance top-ups (where offered), prevent fraud, maintain accounting records, handle chargebacks and disputes, and provide transaction confirmations.
   3. Customer support and communications
      To respond to enquiries, provide technical support, send service messages (such as confirmations, security notices, and important changes), and manage complaints.
   4. Personalisation and service improvement
      To tailor outputs to user-provided preferences and to improve the accuracy, usability, and security of the Website and Services, including troubleshooting, analytics, testing, and quality assurance.
   5. Security, fraud prevention, and misuse detection
      To protect the Website, our systems, and users; to detect and prevent unauthorised access, abuse, and attacks; and to enforce our Terms and related policies.
   6. Legal and regulatory compliance
      To comply with legal obligations, respond to lawful requests from authorities, and establish, exercise, or defend legal claims.
   7. Marketing (where permitted)
      If you opt in (or where otherwise permitted by law), to send updates, product news, and offers. You can opt out at any time using the unsubscribe link in emails or by contacting us at info@cliniquemode.com.

1. Legal bases for processing
   Under UK GDPR, we rely on the following legal bases (as applicable):
   1. Contract: processing is necessary to perform the contract with you (for example, providing paid Services, delivering digital outputs, managing your account).
   2. Legitimate interests: processing is necessary for our legitimate interests (such as improving the Website, preventing fraud, securing systems, and understanding usage), provided those interests are not overridden by your rights.
   3. Consent: where required (for example, certain cookies, marketing communications in some cases). You can withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.
   4. Legal obligation: where processing is necessary to comply with UK legal obligations (for example, accounting, tax, regulatory compliance).
   5. Legal claims: where processing is necessary to establish, exercise, or defend legal claims.

1. AI processing and user inputs
   Our Services generate outputs using automated systems, including artificial intelligence. When you submit inputs (such as ingredient lists or preferences), those inputs are processed to produce Deliverables and improve the operation and security of the Services. You remain responsible for the accuracy and appropriateness of the information you submit. You should avoid submitting unnecessary personal data in free-text fields.

We may use aggregated and/or de-identified data (where reasonably possible) for analytics and service improvement. Where we use data for these purposes, we apply safeguards designed to reduce privacy risks.

1. How we share personal data
   We do not sell your personal data. We may share personal data with the following categories of recipients, to the extent necessary for the purposes in this Policy:
   1. Payment processors and financial service providers: to process card payments, handle disputes, and prevent fraud.
   2. Hosting and infrastructure providers: to host the Website, databases, and systems.
   3. Analytics and performance providers: to measure website performance and understand usage patterns (subject to cookie choices where required).
   4. Customer support and communications tools: to manage support requests and send transactional communications.
   5. Professional advisers: legal, accounting, audit, and insurance advisers, where necessary and subject to confidentiality.
   6. Authorities: regulators, courts, law enforcement, or other public authorities where we are legally required or permitted to do so.

Where third parties process personal data on our behalf, they act as processors (where applicable) and are required by contract to process personal data only on our instructions and to implement appropriate security measures.

1. International transfers
   We may transfer personal data outside the UK and/or the European Economic Area where our suppliers or systems operate internationally. Where this occurs, we implement appropriate safeguards as required by UK data protection law, such as the UK International Data Transfer Agreement (IDTA), the UK Addendum to EU Standard Contractual Clauses, adequacy regulations, or other lawful transfer mechanisms, together with supplementary measures where appropriate.
2. Cookies and similar technologies.
   1. Types of cookies we use:
      1. Strictly necessary cookies: required for core functionality such as security, authentication, and session management. These cannot usually be disabled via our website controls.
      2. Functional cookies: remember choices and preferences to improve user experience.
      3. Analytics cookies: help us understand how the Website is used and improve performance.
      4. Marketing cookies: used to measure the effectiveness of marketing campaigns and, where applicable, to deliver relevant advertising. We use these only where permitted and, where required, with consent.
   2. Managing cookies. You can control cookies through:
      1. Our cookie banner or preference centre (where available).
      2. Your browser settings (blocking or deleting cookies).
      3. Opt-out tools provided by some third-party analytics/advertising providers.

If you disable cookies, parts of the Website may not function properly.

1. Data retention
   1. We retain personal data only as long as necessary for the purposes described in this Policy, including to comply with legal, accounting, or reporting requirements. Retention periods vary depending on the type of data and the reason we hold it. For example:
   2. Account data is generally retained while your account remains active and for a reasonable period thereafter to handle disputes, enforce Terms, or comply with legal obligations.
   3. Transaction records may be retained for the period required by applicable tax and accounting rules.
   4. Support communications may be retained for a reasonable period to manage and improve support quality and to handle complaints.
   5. Security logs may be retained for a limited period necessary for security and fraud prevention.
   6. Where we retain data for analytics, we aim to use aggregated or de-identified data where feasible.
2. Security measures
   We implement reasonable technical and organisational measures designed to protect personal data, including access controls, encryption in transit (and where appropriate at rest), logging, and secure development and operational practices. No website or system can be guaranteed 100% secure, and you acknowledge that transmitting information over the internet carries inherent risks.
3. Your rights. Subject to applicable law and certain exemptions, you may have the right to:
   1. Request access to your personal data (subject access).
   2. Request correction of inaccurate or incomplete data (rectification).
   3. Request deletion of personal data (erasure), in certain circumstances.
   4. Request restriction of processing, in certain circumstances.
   5. Object to processing, in certain circumstances (including direct marketing).
   6. Request data portability, where processing is based on consent or contract and is carried out by automated means.
   7. Withdraw consent at any time, where we rely on consent.
   8. Lodge a complaint with the UK Information Commissioner’s Office (ICO).

To exercise your rights, contact us at info@cliniquemode.com. We may need to verify your identity and may request additional information necessary to process your request. We aim to respond within the timeframes required by law.

1. Children and age restriction
   The Website and Services are intended for individuals aged 18 or older. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a minor, we will take steps to delete it promptly.
2. Third-party links and integrations
   The Website may contain links to third-party websites or use third-party services (for example, payment providers or analytics). We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy notices before providing personal data.
3. Changes to this Policy
   We may update this Policy from time to time. The updated version will be posted on the Website with a revised “Last updated” date. Where required by law, we will provide additional notice and/or obtain consent for material changes (for example, where changes affect cookie consent requirements).
4. Contact
   If you have questions about this Policy, how we process personal data, or you wish to exercise your rights, contact:
   STELLAR CARE SERVICES LTD (company number 13656611)
   Dept 6400a 126 East Ferry Road, Canary Wharf, London, United Kingdom, E14 9FP
   Email: info@cliniquemode.com
   Website: https://cliniquemode.com