Privacy policy
This Privacy Policy explains how CLOWNHAUS (PTY) LTD, registration number 2020/479322/07 / K2020479322, trading as CLOWNHAUS®, collects, uses, stores, discloses, and protects personal information when you access or use www.clownhaus.com, communicate with CLOWNHAUS®, subscribe to communications, submit an enquiry, request services, or otherwise interact with CLOWNHAUS®.
For purposes of this Privacy Policy, “CLOWNHAUS®”, “we”, “us” or “our” refers to CLOWNHAUS (PTY) LTD. “You” or “your” refers to any website visitor, prospective client, client, subscriber, requester, supplier, service provider, or other person whose personal information may be processed by CLOWNHAUS®.
CLOWNHAUS® operates as a South African cosmetic consulting and advisory services business. As of the effective date of this Privacy Policy, CLOWNHAUS® provides services only and does not sell, dispatch, deliver, or ship physical or digital products through the website. If CLOWNHAUS® introduces digital products, downloadable resources, paid templates, training materials, or other online products in future, this Privacy Policy and the applicable website policies may be updated before or at the time those products are made available.
This Privacy Policy must be read together with our Website Terms of Service, Service Terms / Terms of Engagement, Refund, Cancellation and Rescheduling Policy, No Physical Goods / No Shipping Currently Policy, Legal Notice, and PAIA Manual and Access to Records provisions.
1. Responsible Party
The responsible party for the processing of personal information under this Privacy Policy is:
Responsible party: CLOWNHAUS (PTY) LTD
Company registration number: 2020/479322/07 / K2020479322
Trading name: CLOWNHAUS®
Website: www.clownhaus.com
Public contact email: info@clownhaus.com
Registered Information Officer: Ridwaan Ismail
Information Regulator registration number: 2026-045994
CLOWNHAUS® uses an email-only public contact route for general privacy, PAIA, POPIA, and website enquiries.
2. Scope of this Privacy Policy
This Privacy Policy applies to personal information processed through or in connection with:
1. the CLOWNHAUS® website;
2. website enquiries and contact forms;
3. email correspondence;
4. newsletter and marketing subscriptions;
5. consultation requests;
6. service enquiries;
7. invoices, proof of payment, and payment administration;
8. client onboarding and project communications;
9. cosmetic advisory, formulation, documentation, regulatory, claims, training, or related service engagements;
10. website analytics and cookies;
11. PAIA and POPIA requests; and
12. any other lawful interaction with CLOWNHAUS®.
This Privacy Policy does not apply to third-party websites, platforms, applications, payment systems, analytics providers, or service providers that are not owned or controlled by CLOWNHAUS®, except to the extent that CLOWNHAUS® determines the purposes and means of processing personal information in relation to those third parties.
3. Personal Information We Collect
CLOWNHAUS® collects only the personal information reasonably required for lawful business, advisory, administrative, contractual, legal, security, marketing, and recordkeeping purposes.
Depending on how you interact with CLOWNHAUS®, we may collect the following categories of personal information:
3.1 Identity and contact information
This may include:
1. name and surname;
2. business name;
3. job title or role;
4. email address;
5. telephone number;
6. country, province, or city;
7. communication preferences; and
8. any contact details voluntarily submitted by you.
3.2 Enquiry and communication information
This may include:
1. information submitted through website contact forms;
2. email correspondence;
3. consultation requests;
4. meeting notes;
5. information contained in messages, attachments, briefs, or supporting documents;
6. records of requests, instructions, queries, complaints, or follow-ups; and
7. information required to respond to or assess your enquiry.
3.3 Client and service-related information
Where you request or engage CLOWNHAUS® for services, we may process information relating to:
1. your business, brand, product concept, formulation brief, technical question, regulatory query, or service request;
2. cosmetic product information supplied by you;
3. ingredient lists, claims, labels, packaging details, supplier documents, manufacturer information, or technical documents supplied by you;
4. commercial or strategic information voluntarily supplied as part of a service engagement;
5. project scope, deliverables, proposals, quotations, invoices, and service records; and
6. information required to provide cosmetic consulting, advisory, documentation, formulation support, regulatory support, claims support, GMP/ISO 22716 readiness support, training, or related services.
Some client information may constitute confidential commercial information or intellectual property. CLOWNHAUS® treats such information separately from ordinary website visitor information and handles it in accordance with the applicable NDA, proposal, invoice, Service Terms / Terms of Engagement, or written scope of work.
3.4 Payment and invoicing information
CLOWNHAUS® currently issues invoices with banking details. We may process information necessary for invoicing, payment administration, accounting, reconciliation, and recordkeeping, including:
1. billing name;
2. business details;
3. email address;
4. invoice details;
5. payment reference;
6. proof of payment;
7. banking or account information visible on proof of payment; and
8. related accounting or tax records.
CLOWNHAUS® does not require you to submit unnecessary payment information. You should not send card numbers, banking passwords, PINs, or other sensitive financial access credentials to CLOWNHAUS®.
3.5 Marketing and subscription information
If you subscribe to CLOWNHAUS® communications, we may collect and process:
1. your email address;
2. subscription status;
3. consent or opt-in record;
4. unsubscribe or opt-out status;
5. email engagement information, including delivery, bounce, open, click, unsubscribe, or spam complaint data where available through Shopify Email; and
6. marketing preferences.
CLOWNHAUS® uses Shopify Email for email marketing and related subscriber management.
3.6 Website, device, cookie, and analytics information
When you use the website, certain information may be automatically collected by Shopify, Google Analytics, cookies, pixels, server logs, or similar technologies. This may include:
1. IP-related or approximate location information;
2. device and browser information;
3. pages viewed;
4. referral source;
5. session information;
6. interactions with website content;
7. cookie identifiers;
8. date and time of access;
9. analytics events; and
10. information used for website security, performance, diagnostics, and improvement.
CLOWNHAUS® uses Google Analytics to understand website traffic, improve website performance, and assess how visitors interact with the website.
4. Information We Do Not Intentionally Collect
CLOWNHAUS® does not intentionally collect special personal information, health information, medical information, skin photographs, allergy information, biometric information, religious information, criminal information, or information relating to children unless this is expressly requested, lawful, necessary for a defined purpose, and agreed in writing.
You must not submit unnecessary special personal information to CLOWNHAUS® through the website, contact forms, email, or consultation enquiries.
If you submit information that is unnecessary for the relevant enquiry or engagement, CLOWNHAUS® may delete, disregard, return, or restrict processing of that information where appropriate.
5. How We Collect Personal Information
CLOWNHAUS® may collect personal information directly from you when you:
1. visit the website;
2. submit a contact form;
3. subscribe to communications;
4. email CLOWNHAUS®;
5. request a consultation;
6. complete a questionnaire or onboarding form;
7. provide project documents or technical information;
8. request a quotation, proposal, or invoice;
9. make payment or submit proof of payment;
10. correspond with CLOWNHAUS®; or
11. exercise PAIA or POPIA rights.
CLOWNHAUS® may also collect limited personal information indirectly through Shopify, Shopify Email, Google Analytics, HostAfrica email hosting, iCloud storage, banking channels, or other lawful service providers used to operate the website, communicate with clients, store records, administer services, and manage business operations.
6. How We Use Personal Information
CLOWNHAUS® processes personal information for lawful, reasonable, and legitimate business purposes, including to:
1. operate, maintain, secure, and improve the website;
2. receive and respond to enquiries;
3. assess whether CLOWNHAUS® can assist with a requested service;
4. prepare quotations, proposals, invoices, and service communications;
5. provide consulting, advisory, technical, regulatory, documentation, formulation support, training, or related services;
6. administer consultations and service engagements;
7. manage client communications and records;
8. process invoices, proof of payment, and payment administration;
9. comply with tax, accounting, legal, regulatory, PAIA, POPIA, and recordkeeping obligations;
10. send newsletters, updates, insights, or marketing communications where permitted;
11. manage opt-ins, unsubscribe requests, and communication preferences;
12. conduct website analytics and performance monitoring;
13. protect the website, business systems, confidential information, and client information;
14. detect, prevent, or respond to fraud, misuse, unlawful conduct, unauthorised access, or security incidents;
15. enforce website terms, service terms, NDAs, invoices, proposals, or legal rights;
16. respond to lawful requests from regulators, courts, law enforcement, or competent authorities; and
17. maintain defensible business records.
CLOWNHAUS® will not use personal information for a purpose that is incompatible with the purpose for which it was collected unless permitted or required by law, authorised by you, or reasonably necessary in the circumstances.
7. Legal Basis and Justification for Processing
CLOWNHAUS® processes personal information where one or more lawful grounds or justifications apply, including where:
1. processing is necessary to conclude or perform a contract with you;
2. processing is necessary to respond to your enquiry or request;
3. processing is necessary for CLOWNHAUS® to comply with a legal obligation;
4. processing protects a legitimate interest of CLOWNHAUS®, a client, or another person;
5. processing is based on your consent, including for certain marketing communications; or
6. processing is otherwise permitted by POPIA or applicable law.
Where CLOWNHAUS® relies on consent, you may withdraw that consent, subject to legal, contractual, recordkeeping, and operational limitations.
8. Direct Marketing and Shopify Email
CLOWNHAUS® may send direct marketing communications, newsletters, business updates, cosmetic intelligence updates, service information, or related communications where you have subscribed, opted in, requested such communication, or where otherwise permitted by law.
CLOWNHAUS® uses Shopify Email for email marketing and subscriber management.
Each marketing email should identify CLOWNHAUS® as the sender and provide a functional unsubscribe or opt-out mechanism. You may unsubscribe from marketing communications at any time by using the unsubscribe link in the relevant email or by emailing info@clownhaus.com.
If you unsubscribe, CLOWNHAUS® may still send non-marketing communications where necessary, including communications relating to enquiries, consultations, invoices, service engagements, legal notices, PAIA/POPIA requests, security matters, or existing contractual obligations.
CLOWNHAUS® does not permit purchased email lists to be added to its marketing database without lawful grounds and appropriate consent records.
9. Cookies and Similar Technologies
The CLOWNHAUS® website uses cookies and similar technologies for website operation, functionality, analytics, security, performance, and user experience.
Cookies may be placed by Shopify, Google Analytics, or other service providers used to operate and improve the website.
Cookies may be used to:
1. operate the website;
2. remember preferences;
3. support website functionality;
4. measure website usage;
5. understand visitor behaviour;
6. improve content and performance;
7. detect technical issues;
8. support security; and
9. generate analytics reports.
You may control or disable cookies through your browser settings or, where applicable, through available cookie preference tools on the website. If you disable or block cookies, certain website functions may not operate correctly.
CLOWNHAUS® uses available privacy, cookie, analytics, and website configuration settings to support the lawful and proportionate use of cookies and similar technologies, where applicable.
10. How We Disclose Personal Information
CLOWNHAUS® does not sell personal information.
CLOWNHAUS® may disclose personal information only where lawful, necessary, and appropriate, including to:
1. Shopify, as the website platform provider;
2. Shopify Email, for email marketing and subscriber management;
3. Google Analytics, for website analytics;
4. HostAfrica, for email hosting;
5. iCloud or Apple services, for file storage and business records;
6. banking institutions, for payment and reconciliation purposes;
7. accountants, bookkeepers, legal advisors, compliance advisors, insurers, or other professional advisors;
8. service providers who assist with website, IT, email, storage, security, administration, or business operations;
9. laboratories, manufacturers, suppliers, consultants, or technical service providers only where relevant to a client engagement and subject to need-to-know access and client approval where applicable;
10. regulators, courts, law enforcement, public authorities, or competent bodies where required or permitted by law;
11. third parties involved in enforcing legal rights, preventing fraud, protecting confidential information, or responding to security incidents; and
12. any other person or entity where you have authorised the disclosure or where disclosure is required by law.
CLOWNHAUS® limits third-party access to client information to what is reasonably necessary for the relevant purpose. Where client confidential information is involved, access may be further governed by an NDA, proposal, written scope of work, Service Terms / Terms of Engagement, or other written agreement.
11. Third-Party Websites and Platforms
The website may contain links to third-party websites, platforms, resources, documents, or services. CLOWNHAUS® is not responsible for the privacy practices, security measures, content, or legal terms of third-party websites or platforms not owned or controlled by CLOWNHAUS®.
You should review the privacy policy and terms of any third-party website or platform before submitting personal information to that third party.
12. Cross-Border Processing and Storage
CLOWNHAUS® is based in South Africa, but some service providers used by CLOWNHAUS®, including Shopify, Google Analytics, iCloud, and other technology providers, may process, transfer, access, or store information in jurisdictions outside South Africa.
Where personal information is transferred outside South Africa, CLOWNHAUS® will take reasonable steps to ensure that such transfer is lawful and subject to appropriate safeguards, contractual protections, operator obligations, or other lawful transfer mechanisms where required.
By using the website, communicating with CLOWNHAUS®, subscribing to communications, or engaging CLOWNHAUS® for services, you acknowledge that your personal information may be processed through technology systems and service providers that operate across jurisdictions.
13. Security Measures
CLOWNHAUS® takes reasonable technical and organisational measures to protect personal information against loss, misuse, unauthorised access, unauthorised disclosure, alteration, destruction, and unlawful processing.
These measures may include:
1. restricted access to client and business information;
2. need-to-know access controls;
3. password-protected accounts;
4. secure email and storage practices;
5. controlled third-party disclosure;
6. client approval for relevant third-party access where applicable;
7. use of reputable service providers;
8. retention controls;
9. review of access to client documents; and
10. appropriate response procedures for suspected security incidents.
No website, email system, cloud storage service, or internet transmission is completely secure. CLOWNHAUS® cannot guarantee absolute security, but will take reasonable steps to protect personal information in accordance with applicable law.
14. Security Compromises
If CLOWNHAUS® has reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, CLOWNHAUS® will take reasonable steps to investigate, contain, assess, and respond to the incident.
Where required by POPIA, CLOWNHAUS® will notify the Information Regulator and affected data subjects as soon as reasonably possible, unless the identity of the affected data subject cannot be established or notification is delayed as permitted by law.
Operators, service providers, or third parties who process personal information on behalf of CLOWNHAUS® must notify CLOWNHAUS® without undue delay where they become aware of an actual or suspected security compromise affecting personal information processed for or on behalf of CLOWNHAUS®.
15. Retention of Personal Information
CLOWNHAUS® retains personal information only for as long as reasonably necessary for the purpose for which it was collected, unless a longer retention period is required or permitted by law, contract, legitimate business interest, regulatory obligation, accounting requirement, tax requirement, dispute-resolution requirement, evidentiary purpose, or defensibility requirement.
Retention periods may differ depending on the nature of the information, including:
1. website and analytics information;
2. enquiry records;
3. subscriber records;
4. consultation records;
5. invoices and payment records;
6. client project documents;
7. NDA records;
8. proposals and scopes of work;
9. legal or regulatory correspondence; and
10. PAIA or POPIA request records.
CLOWNHAUS® may retain limited records where necessary to demonstrate compliance, resolve disputes, enforce agreements, defend claims, maintain audit trails, or comply with legal obligations.
Where information is no longer required, CLOWNHAUS® will take reasonable steps to delete, de-identify, archive, or restrict access to the information, subject to practical, technical, legal, and operational limitations.
16. Children’s Personal Information
The website and services of CLOWNHAUS® are not directed at children.
CLOWNHAUS® does not knowingly collect personal information from children through the website. If CLOWNHAUS® becomes aware that personal information of a child has been submitted without appropriate authority or lawful basis, CLOWNHAUS® may delete or restrict processing of that information, unless retention is required or permitted by law.
17. Your POPIA Rights
Subject to applicable law, verification of identity, and any lawful limitations, you may have the right to:
1. request confirmation of whether CLOWNHAUS® holds personal information about you;
2. request access to your personal information;
3. request correction of inaccurate, irrelevant, excessive, outdated, incomplete, misleading, or unlawfully obtained personal information;
4. request deletion or destruction of personal information where lawful grounds exist;
5. object to the processing of personal information in certain circumstances;
6. withdraw consent where processing is based on consent;
7. object to direct marketing;
8. request that CLOWNHAUS® stop sending marketing communications;
9. lodge a complaint with CLOWNHAUS®;
10. lodge a complaint with the Information Regulator; and
11. exercise any other rights available under POPIA, PAIA, or applicable law.
Requests must be submitted in writing to info@clownhaus.com.
CLOWNHAUS® may require proof of identity, authority, or additional information before processing a request. CLOWNHAUS® may refuse, limit, or defer a request where permitted or required by law.
18. PAIA Manual and Access to Records
CLOWNHAUS (PTY) LTD has prepared a PAIA Manual in terms of section 51 of the Promotion of Access to Information Act 2 of 2000, as amended. The PAIA Manual describes the categories of records held by CLOWNHAUS®, the records that may be available without a formal PAIA request, and the procedure for requesting access to records.
Requests relating to access to records, access to personal information, correction, deletion, objection, or other PAIA/POPIA rights must be submitted in writing to the registered Information Officer at:
info@clownhaus.com
Registered Information Officer: Ridwaan Ismail
Information Regulator registration number: 2026-045994
Responsible party: CLOWNHAUS (PTY) LTD
Company registration number: 2020/479322/07 / K2020479322
A requester should use Form 2: Request for Access to Record when submitting a formal PAIA request. Where applicable, CLOWNHAUS® will respond using, or substantially in accordance with, Form 3: Outcome of Request and Fees Payable.
The official PAIA forms are available from the Information Regulator’s PAIA Forms page. The Information Regulator lists Form 02: Request for Access to Record [Regulation 7] and Form 03: Outcome of Request and Fees Payable [Regulation 8] on its PAIA Forms page.
A copy of the CLOWNHAUS® PAIA Manual may be requested by emailing info@clownhaus.com.
19. Complaints
If you have a complaint about how CLOWNHAUS® processes your personal information, you should first contact CLOWNHAUS® at:
info@clownhaus.com
CLOWNHAUS® will consider the complaint and respond within a reasonable period, subject to the nature of the complaint, the information available, and any legal or operational constraints.
You may also lodge a complaint with the Information Regulator of South Africa where you believe your rights under POPIA or PAIA have been infringed.
20. Updates to this Privacy Policy
CLOWNHAUS® may amend this Privacy Policy from time to time to reflect changes in law, regulatory guidance, Shopify functionality, website settings, service offerings, business operations, analytics tools, marketing practices, or internal compliance controls.
The updated version will be published on the website with an updated effective date. Continued use of the website or continued engagement with CLOWNHAUS® after publication of an updated Privacy Policy constitutes acknowledgement of the updated Privacy Policy, to the extent permitted by law.
21. Contact
For privacy, PAIA, POPIA, or personal-information requests, contact:
CLOWNHAUS (PTY) LTD
Trading as CLOWNHAUS®
Company registration number: 2020/479322/07 / K2020479322
Registered Information Officer: Ridwaan Ismail
Information Regulator registration number: 2026-045994
Email: info@clownhaus.com