1. Introduction

This Privacy Policy details how PICO Academy (PICO London Ltd, company registration number 11546368 at registered office Cameo House, 11 Bear Street, London, WC2H 7AS, UK, collect, use and process personal data provided to us. If you have any questions on this Privacy Policy or otherwise relating to how we process your personal data you can contact us at academy@picoclinics.com.

This Privacy Policy affects your legal rights and obligations so please read it carefully. If you do not agree to be bound by this Privacy Policy, please do not provide your personal data to us. This means that you will be unable to use many of the services offered on our website.

We may update this Privacy Policy from time to time at our discretion and in particular to reflect any changes in applicable laws. If we do so, and the changes substantially affect your rights or obligations, we shall notify you of the updates if we have your email address. Otherwise, you are responsible for regularly reviewing this Privacy Policy so that you are aware of any updates.

We are the controller of the personal data provided to us for the purposes of applicable data protection legislation.


2. Whose personal data do we collect?

By personal data we mean identifiable information about you, such as your name, email address, gender, age, mobile and home telephone number and your IP address.

If you provide it to us, we will also collect special categories of personal data about you such as information about your health.

We do not knowingly collect personal data about any individual under the age of 18.


Information you provide to us

From time to time you may provide to us personal data. This may be because you wish to:

use our website or any associated mobile application; create an account with us on our website or any associated mobile application; register and/or attend one of our training courses; have an aesthetic procedure, including as a model at one of our training courses, and in doing so, you must complete our consent; provide feedback or reviews to us; provide services to us; or otherwise contact us including with queries, comments or complaints.

We shall process all such personal data in accordance with this Privacy Policy. Certain personal data is mandatory to be provided to us in order that we can fulfill your request, for example to attend on one of our training courses, and we shall make this clear to you at the point of collection of the personal data.

If you provide to us personal data about any other individual, for example, if you wish to register someone else on one of our courses, you must have their consent to do so.

All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this and we may also report this to the appropriate authorities. In particular, if you provide false information to try to attend one of our courses, you may not be entitled to attend the course. At our request, you shall promptly provide evidence of your identity.

When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.


Information we automatically collect about you

When you use our website, we automatically collect and store information about your device and your activities. This information could include: technical information about your device such as type of device, web browser or operating system; your preferences and settings such as time zone and language;
how long you used the website and which services and features you used.

Some of this information is collected using cookies and similar tracking technologies.


Information we receive from others

We may receive personal data about you from our payment providers, and from other individuals who chose to provide it to us for any reason. For example, one of our trainees may provide personal information about you if you are a model at a training course.

If we reasonably believe that any of the personal data you have provided to us is inaccurate, we may receive further personal data from third parties, confirming or otherwise, your identity.


Lawful use of your personal data

We will only use your personal data where we have a lawful basis to do so. The lawful purposes that we rely on under this Privacy Policy are: consent (where you choose to provide it); performance of our contract with you; compliance with legal requirements; and legitimate interests.

When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.

If you wish to register and attend a training course at PICO Academy, we shall collect your personal data to allow you to do so in accordance with our Training Terms and Conditions and we will contact you with prompts and reminders about your course.

If you wish to have an aesthetic procedure at PICO Academy, including as a model at a training course, we shall collect your personal data to allow you to do so in accordance with our Clinic Terms and Conditions and we will contact you with prompts and reminders about your participation. You must complete a consent form, and within that form, acknowledge and agree that we may take photographs of your procedures for our internal records and, if you model consent, for various marketing purposes as more specifically set out on the consent form.

We may from time to time need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety.

We may also use your personal data for our legitimate interests including:

  • to improve our website and services;
  • in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
  • to deal with any customer services you require;
  • for audit purposes;
  • and to contact you about changes to this Privacy Policy as set out above.


Who do we share your data with?

If you have an aesthetic procedure at PICO Academy, we shall share your personal data, including your health related data with any of our advisers, and if you are a model on one of our courses, our trainees so that they can best determine the procedure that is most suitable for you. As a trainee, you agree only to use a model’s personal data to determine the procedure that is most suitable for them and to administer that procedure. Trainees should not retain a copy of any personal data of a model.

For our legitimate interests, we may share your personal data with our service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including IT service providers, payment providers, accountants, auditors and lawyers.

We shall provide our service providers, sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, in particular we shall not share your health related personal data with any service providers, sub-contractors and agents. In any event, we shall request that they delete your personal data or make it anonymous within their systems.


Where we hold and process your personal data

Some or all of your personal data may be stored or transferred outside of the United Kingdom and the European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the United Kingdom or the EEA or if any of our service providers are based outside of the United Kingdom or the EEA.

Where your personal data is transferred outside the United Kingdom or the EEA, it will only be transferred to countries that have been identified as providing adequate protection for personal data or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).



We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. In particular, access is restricted to employees who need to know your personal data, and we use appropriate password protection and appropriate strong encryption electronic measures within our electronic data management systems.

However, unfortunately, because of the nature of electronic storage, we cannot promise that your personal data or any other data you provide to us will always remain secure.  If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimise the loss of any data.



You may consent to receive marketing email messages from us about the services we offer. You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe from a marketing email. Please note that it may take us a few days to update our records to reflect your request.

If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information. We will still contact you as necessary about your account and any appointments you have booked.


Your rights

You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below.

  • Right of access: You have the right to obtain from us a copy of the personal data that we hold for you.
  • Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date.
  • Right to portability: You can request that we transfer your personal data to another service provider.
  • Right to restriction of processing: In certain circumstances, you have the right to require that we restrict the processing of your personal information.
  • Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws.
  • Right to stop receiving marketing information: You can ask us to stop sending you information about our services, but please note we shall continue to contact you in relation to any matters relating to your account, if you have one.


You may be able to exercise some of these rights within your account on the website.

We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.

If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time. You can also contact the Information Commissioner, see www.ico.org.uk or if you are based outside of the United Kingdom, please contact your local regulatory authority


Retention of personal data

Subject to the provisions of this Privacy Policy, we will retain personal data in accordance with applicable laws.
In particular, we shall retain your personal data for as long as you have an account on our website and for sufficient time in order to deal with any issues that might arise on your account after it has been closed. However, we may also be required to retain personal data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements of HMRC in respect of financial documents.



If any provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.

This Privacy Policy shall be governed by and construed in accordance with English law and you agree to submit to the exclusive jurisdiction of the English Courts.

Last updated: 16th September 2022