Privacy policy
Last updated: 26 October 2026
This Privacy Policy explains how Penrose Skin collects, uses and shares your personal information when you use penroseskin.com (the "Site"), buy from us, join our emails or texts, or contact us. It does not cover purchases from another seller or marketplace, whose own privacy notice applies. "We", "us" and "our" mean Penrose Skin Inc (section 1). Words such as Order, Subscription and Guarantee mean the same as in our Terms of Service.
1. Who we are
Penrose Skin is run by Penrose Skin Inc, 312 W 2nd St, Unit #A2299, Casper, WY 82601, USA. It is the "controller" responsible for your personal information, wherever you live and whether or not you buy from us.
2. What we collect
- Contact and Order details: your name, email address, phone number, billing and delivery addresses, what you buy and your Subscription details.
- Payment details: our payment providers take your card or wallet details. We see only limited details, such as the card type and last four digits.
- Messages and photos: what you send us, such as photos of jars for a Guarantee or damage claim.
- Skin reaction reports (section 7).
- Marketing choices: whether you have agreed to emails or texts.
- Survey answers, if you choose to answer.
- Collected automatically: when you use the Site or open our emails, we and our partners use cookies, pixels and similar tools to collect your device and browser type, IP address, approximate location, what you view, add to your cart and buy, the ad or link that brought you to us, and whether you open and click our emails (section 4).
- From other companies: payment and fraud check results, Subscription details and portal changes from our e-commerce platform and payment providers, the ads you saw or clicked from advertising partners, and tracking updates from delivery partners.
3. How we use your information
Our legal basis under UK and EU law for each purpose is shown in bold.
- Contract: to take payment for, pack and deliver your Orders, run your Subscription, and handle your messages, refunds, returns, Guarantee claims and delivery problems.
- Legitimate interests, where these do not override your rights: to prevent fraud and keep the Site and payments secure, check that offers and the Guarantee are used only once per household, deal with disputes and chargebacks, enforce our Terms, keep a record of customers we no longer take Orders from because of fraud or misuse, and run and improve our business and the Site.
- Consent: to send marketing emails and texts (section 6), and to use non-essential cookies and share information with advertising partners to show and measure our ads (sections 4 and 5).
- Legal obligation: to keep tax and accounting records, and to meet our product safety and consumer law duties.
Some of our replies may be written by AI, or with its help, using your message and Order details. We make no decisions about you by computer alone that have legal or similarly significant effects.
4. Cookies and tracking
We use essential cookies to run the Site, cart and checkout, analytics tools (including heatmaps) to see how the Site is used, and marketing pixels from our advertising, email and text partners to show and measure our ads and emails.
UK, EU and Swiss visitors: we use only essential cookies unless you accept others on our cookie banner. You can change your choice at any time with "Cookie settings" at the bottom of every page.
Everyone else: analytics and marketing cookies are on by default, and you can opt out of their use for advertising as section 5 explains. We do not respond to "Do Not Track" signals.
5. Who we share it with
Service providers handle your information only to do work for us, under contract: our e-commerce platform (store, checkout, Subscriptions and accounts), email and text providers, customer support and AI tools, fulfilment, delivery and customs partners, analytics and survey tools, professional advisers, banks and IT providers.
Payment providers, including any wallet or pay later service you use, process your payment for us and also handle your details under their own privacy policies.
Advertising partners, such as social media and search platforms, collect what you view, add to your cart and buy on the Site through their pixels, with cookie IDs. When you buy, we may also send them your email address and phone number in coded (hashed) form so they can match you to their users. They use this to show and measure our ads, including to people like you, and under their own privacy policies.
Under some US state laws, this may count as a "sale" of personal information or "sharing" it for targeted advertising. You can opt out at any time with "Your privacy choices" at the bottom of every page, and we treat a Global Privacy Control signal as an opt-out for that browser. In the UK, the EU and Switzerland, we share this information with advertising partners only if you accept marketing cookies.
Others: we share information when the law requires it, and to protect our rights or prevent fraud, for example by sending our records to your bank if you dispute a charge. If we sell, merge or restructure all or part of our business, the new owner receives the information it needs and must protect it as this policy says. Websites we link to have their own privacy policies, and we are not responsible for them.
6. Marketing emails and texts
We send marketing emails and texts only if you have agreed. Agreeing is never a condition of buying. If we offer a discount for joining, we give any notice the law requires. Every marketing email has an unsubscribe link. For texts, reply STOP to stop them or HELP for help. Message frequency varies. Message and data rates may apply.
We never share the mobile number you give us to join our texts, or your consent, with any third party for their own marketing. A phone number you give at checkout may be sent to advertising partners in coded form (section 5).
If you unsubscribe, we still send the messages you need about your Orders and Subscription, such as shipping updates and reminders before each charge.
7. Skin reaction reports
If you report a skin reaction, we collect what happened, which product you used and its batch code. We use this health information only to help you and to check the safety of our products, including any report the law requires. Only the people handling your report can see it, and we never sell it or use it for marketing or ads. Apart from any report the law requires, we share it only with service providers that help us handle it, such as our email, help desk and AI tools. Washington residents can ask to see it, with a list of who received it, ask us to delete it, or withdraw consent. Under UK and EU law, we also rely on the conditions the law allows for product safety and legal claims.
8. Your rights
US residents can ask to access and get a copy of their personal information, ask us to correct or delete it, and opt out of its sale or sharing and of targeted advertising (section 5). We will not treat you worse for using these rights.
UK, EU and Swiss residents have the right to access their personal information and get a copy, have it corrected or deleted, restrict or object to our use of it, stop direct marketing at any time, receive it in a common format to move it to another company, and withdraw consent at any time without affecting what we did before.
Residents of other countries, such as Canada or Australia, can ask to access, correct or delete their information in the same way, and we will answer under the law where they live.
How to use your rights. Email contact@penroseskin.com with "Privacy" in the subject line and the email address you use with us. It is free in most cases. We check it is you first (not needed for a request to opt out of sale or sharing), usually by matching your email address and a detail from your Order. Someone else can make a request for you with your signed permission. We reply within 5 business days and complete your request within 45 days in the US, or within one month in the UK and Europe (three months if it is complex), or tell you if we need longer. Some rights have limits, for example we must keep tax records, and we will tell you if one applies.
Appeals and complaints. If you are unhappy, please tell us first. In the US, if we turn down your request, reply with "Appeal" in the subject line and a person who did not make the first decision will look at it again; if you are still unhappy, you can contact your state attorney general. In the UK, you can complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint. Elsewhere, you can complain to the data protection or privacy regulator in your country.
9. International transfers
We are in the US, and we and our providers handle your information there and in other countries, including the details our fulfilment partners need to send your Order. These countries may not protect your information in the same way as the law where you live.
When UK, EU or Swiss customers' information leaves the UK or Europe, we use a safeguard the law allows: a country officially recognised as protecting data properly, a US company signed up to the relevant Data Privacy Framework (EU-US, Swiss-US or the UK Extension), or standard contractual clauses (with the UK Addendum, or the UK International Data Transfer Agreement, for UK information). You can ask us for a copy of these safeguards.
10. How long we keep it
We keep your information only as long as we need it, then delete it or remove anything that identifies you. As a guide:
- Order, payment, refund and tax records: 7 years after the Order;
- customer service messages and claim photos: up to 3 years after your last contact;
- skin reaction reports: 6 years after the report;
- marketing information: until you unsubscribe, or after 3 years with no activity. After you unsubscribe we keep a short record so we do not contact you again.
We may keep information for longer if the law requires it, or to deal with a dispute or legal claim.
11. Children
You must be 18 or over to buy from us. We do not knowingly collect information from anyone under 18, or sell or share the information of anyone under 16. If you think a child has given us their information, email us and we will delete it.
12. Security
We take reasonable steps to protect your information, but no system is completely secure, so please never send us your card number by email.
13. Changes to this policy
We may update this policy and will change the date at the top. If we make an important change, we will tell you by email or with a notice on the Site.
14. Contact us
For privacy questions, email contact@penroseskin.com with "Privacy" in the subject line, or write to us, or to our UK or EU representative, at the addresses in section 1. Our Contact information page lists all the ways to reach us.