Privacy Policy


PRIVACY POLICY (the “Website”) is published and maintained by Fresh Cosmetics Ltd.

Fresh Cosmetics Limited is based in the United Kingdom with its registered office located at 6th Floor, UK House, 180 Oxford Street, London W1D 1AB.

Fresh, Inc. and Fresh Cosmetics Limited together comprise Fresh (“we”, “us” and/or “our”).


Why should you read this Privacy Policy?


This privacy policy (“Policy”) lets you know how we may collect, use and disclose your personal information.  By using the Website and/or any of the services offered by Fresh, you signify your agreement to the terms of this Policy.

This Policy is incorporated into and forms part of our Terms of Use, which governs the use of the Website. You can read our Terms of Use by clicking here

Your Personal Information


We collect various types of information about you (your “Personal Information”) which may include:


•Address (including home, work, billing and/or shipping address)

•Email address

•Telephone number (including mobile number)

•Credit card and other payment information



Information detailed in the Website Usage Information section below; and/or

Any other information that identifies you or facilitates our online/offline communication with you as an individual.


How Fresh Collects your Personal Information

Depending on how you use our services, we may collect your Personal Information in a number of different ways including when you:

  • Complete a customer information card in one of our retail stores, by providing us with information such as your name, email address, address, telephone number, date of birth and/or gender;
  • Sign up to receive our email blasts, by providing us with information such as your email address;
  • Become a registered user of our Website by providing us with information such as your email address;
  • Sign up for our birthday gift program, by providing us with information such as your name, address, telephone number, email address and birthday;
  • Make a purchase via our Website, by providing us with information such as your name, billing address, telephone number, shipping address and credit card information;
  • Information which you provide when you enter a competition or contest, or answer a survey; and/or
  • Use our Website, as detailed in the Website Usage Information section below.

Fresh does not knowingly collect or use any Personal Information from individuals under the age of 13.  If we become aware that any such information has been provided or submitted to us, we will delete the information as soon as possible.

By making a purchase, you become a registered user of the Website. You can choose to store information needed to make a purchase, such as your shipping and billing addresses in the “My Account” section. You can access this section using your registration login and password.

Website Usage Information


“Cookies” are small data files that are stored on your computer’s hard drive, which enable us to improve the functionality and overall user experience of our Website.  We may use Cookies to keep, and sometimes track, information about how you use our Website, the pages you look at and the items you purchase. 

We may use cookies for purposes including:

  • Store information in your shopping cart;
  • Store your username and/or password on our registered user login page.

You can control how your browser handles Cookies received from websites. You can choose to refuse all Cookies, or to be prompted before a Cookie is saved to your hard drive, or to only accept Cookies from certain websites that you designate.  By refusing to accept Cookies from the Fresh Website, you may not be able to use some of the features and functionality available on the Website.

Clear GIFs

We may use “clear GIFs” (aka “Web beacons” or “pixel tags”) or similar technologies, in the Website and/or in our communications with you to enable us to know whether you have visited a web page or received a message.  A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a web page or in an email that communicates to us whether you viewed an email that we sent you or visited a certain page on our Website.  A clear GIF may enable us to relate your viewing or receipt of a web page or message to other information about you, including your Personal Information.

IP Address and Clickstream Data

Our server automatically collects data about your server’s Internet address when you visit us.  This information, known as an Internet Protocol address (“IP Address”) is a number that is automatically assigned to your computer by your Internet service provider whenever you are on the Internet.  When you request pages from our Website, our servers may log your IP Address and sometimes your domain name.  Our server may also record: the referring page that linked you to us (e.g. another website or a search engine); the pages you visit on our Website; the website you visit after our Website; the advertisements you see and/or click on; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on our Website or a referral site; and other web usage activity and data logged by our web servers.  We use this information for internal system administration, to help diagnose problems with our server, and to administer our Website.  Such information may also be used to gather broad demographic information, such as country of origin and Internet service provider.

Any or all of these processes regarding our Website usage information may be performed on our behalf by our service providers.

How Fresh Uses your Personal Information

We will use your Personal Information in a number of different ways, including to:

  • Respond to your requests;
  • Process your orders; and
  • Provide you with information about our product and service offerings;
  • Maintain our internal record keeping;
  • Anonymise and/or aggregate your Personal Information by combining it with other information;
  • Analyse user behaviour as a measure of interest in and use of our Website, retail stores, products, services and communications, both on an individual basis and in combination with other information for analysis purposes; and/or share it with our affiliates for internal marketing purposes. 

We may also send you communications about products, services, companies and events, sponsored by us and others, that we think might be of interest to you.  We will send you such communications by methods such as email, phone, mail.  Before we do this, we will obtain your consent where we are required to do so in accordance with applicable law.  You may opt out of receiving such communications from us by following the instructions in the Your Right to Opt In and Opt Out section below.


Aggregate Statistics

We may disclose statistics, in the form of aggregate data, to third parties. This aggregate data may contain information regarding user behaviour as a measure of interest in, and use of, our Website and emails such as overall patterns or demographic reports.  The aggregate data will not describe or identify any individual user.


Legally Compelled Disclosures

We may disclose user information to government authorities and other third parties when compelled to do so by government authorities or otherwise as required or permitted by law, including but not limited to in response to court orders and subpoenas.  We also may disclose user information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the Website or anyone else that could be harmed by such activities.

Business Transfers

In the event that Fresh or its business or assets are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganisation, consolidation or liquidation, your Personal Information may be one of the transferred assets. 


How Fresh Secures your Personal Information


While Fresh will take reasonable precautions to protect the security and integrity of Personal Information provided to our Website, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that Personal Information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. 

We maintain various physical, electronic and procedural safeguards to protect your Personal Information, for example:

  • We use industry-standard Secure Sockets Layer ("SSL") authentication for online transactions made on our Website.  SSL authentication and encryption of the information that you send to us over the Internet helps protect your online transaction information from third party interception.
  • Your credit card information is never used except to issue refunds and charges for orders placed on our Website.  For security purposes, please don’t ever use email to send us your credit card information.
  • We never display your full credit card number once it has been entered. We will only reveal the last four digits of your credit card for verification purposes.
  • For additional security, we do not store your credit card number after processing your payment.

We encourage you to protect your own privacy. For example, we recommend that you do not share your password with anyone else.

Unfortunately, despite all of our efforts, there is always a risk that third parties may unlawfully intercept transmissions.  This reality is true of all Internet use.  As a result, we cannot ensure the security of any information you transmit, and you transmit all information at your own risk.

If you contact us by email or a “contact us” or similar feature on our Website, you should be aware that your transmission might not be secure.  A third party could view information you send by these methods in transit.

If you choose to become a registered user, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any access to or use of the Website by you or any person or entity using your password, whether or not such access or use has been authorised by or on behalf of you, and whether or not such person or entity is your employee or agent.  You agree to (a) immediately notify Fresh of any unauthorised use of your password or account or any other breach of security, and (b) ensure that you exit from your account at the end of each session.  It is your responsibility to control the dissemination and use of your password, control access to and use of your account, and notify Fresh when you desire to cancel your account on this Website. We are not responsible or liable for any loss or damage arising from your failure to comply with this provision.

We will not be liable for disclosure of your information due to errors or unauthorised acts of third parties during or after transmission.

In the unlikely event that we believe that the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development if appropriate. 


Where Fresh Stores your Personal Information

Your Personal Information that we collect from you may be transferred to, and stored at a destination outside the European Economic Area (“EEA”), including on a database owned by Fresh, Inc. and Demandware, Inc., both companies based in the US. Demandware, Inc provide IT services to the Fresh Group for the purpose of hosting and storage on US servers. Your Personal Information may also be processed by staff operating outside the EEA who work for one of our suppliers.  Such staff may be engaged in, amongst other things, the fulfilment of your order and the provision of support services.  Fresh Cosmetics Limited will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. 

By providing Personal Information to Fresh Cosmetics Limited, through this Website or otherwise, you agree to this transfer, storing or processing.

Your Right to Opt In and Opt Out

You may have the right to “opt in” and/or “opt out” of the use of your Personal Information for direct marketing purposes.  For example, at the time you are requested to provide Personal Information on this Website, you may have the opportunity to elect to, or not to: (1) receive information from us about our product and service offerings, or (2) have your Personal Information shared with other entities for their marketing purposes.  You are also able to edit your preferences in relation to our use of your Personal Information for direct marketing purposes, by visiting the “Your Account” of the Website.

Please note that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us. 

If you request for us to stop sharing your Personal Information with other entities for direct marketing purposes, your request will only apply as of the date it is made.  We will not be responsible for any communications that you may receive from entities that received your Personal Information prior to your opt out request.  In these cases, please contact that entity directly.


Changes to this Policy

As we update and expand our services, we may decide to change, edit, delete or revise the content of this Policy.  We will notify you of any changes by posting them on this page of our Website, so we recommend that you visit this page from time to time to check for any changes.  Any changes will be effective immediately upon us posting them to this page.  We may also notify you of changes to this Policy by other means, such as by sending you an email.


How To Amend and Access your Personal Information

If you:

  • Would like to amend/update any of the Personal Information we hold about you; and/or
  • Would like a copy of the Personal Information we hold about you,

    please contact us at

You can amend your Personal Information and unsubscribe directly in the “Your Account” of the Website


Contact Us

If you have any questions or comments regarding our privacy practices, you may contact us at