Privacy Policy
Last updated: June 2026
1. Introduction
This Privacy Policy explains how TGM Company LLC, operating the ELEMENTUM brand and the e-commerce website available at www.elementumskin.com (the "Website"), collects, uses, stores, and protects your personal data when you visit, browse, or purchase from our Website.
TGM Company LLC ("ELEMENTUM", "we", "us", "our") is a limited liability company registered in the Shams Free Zone, Sharjah, United Arab Emirates, holding UAE VAT Registration Number 104237674700003. TGM Company LLC is the trademark owner, producer, and distributor of ELEMENTUM products.
We are committed to protecting your privacy and handling your personal data with transparency, care, and full compliance with applicable data protection laws worldwide, including but not limited to:
– The UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL);
– The EU General Data Protection Regulation (GDPR) — Regulation (EU) 2016/679 — for customers located in the European Economic Area;
– The UK General Data Protection Regulation (UK GDPR) for customers located in the United Kingdom;
– The Saudi Arabia Personal Data Protection Law (PDPL) for customers located in the Kingdom of Saudi Arabia;
– Other applicable national data protection laws in jurisdictions where we operate or where our customers are located.
By accessing or using our Website, creating an account, placing an order, or subscribing to our communications, you acknowledge that you have read and understood this Privacy Policy.
2. Data Controller
The data controller responsible for your personal data is:
Legal Entity: TGM Company LLC
Trading As: ELEMENTUM
Registered Address: Shams Free Zone, Sharjah Media City, Sharjah, United Arab Emirates
VAT Registration Number: 104237674700003
Contact: +971 50 269 5192
Privacy Contact Email: hello@elementumskin.com
Website: www.elementumskin.com
For all privacy-related queries, requests, or complaints, please contact us at hello@elementumskin.com.
3. Personal Data We Collect
We collect personal data in the following categories, depending on how you interact with us:
3.1 Data You Provide Directly
– Identity Data: full name, username or display name;
– Contact Data: email address, postal address, telephone number;
– Account Data: login credentials, order history, preferences;
– Transaction Data: details of purchases, products ordered, payment method type (we do not store full card numbers);
– Communication Data: messages, enquiries, feedback, and correspondence you send to us;
– Skin Profile Data: skin type, skin concerns, and related responses you submit through our skin assessment quiz. This data may be treated as health-adjacent or sensitive data under applicable law and is handled with an elevated standard of care.
3.2 Data Collected Automatically
– Usage Data: pages visited, time spent on the Website, links clicked, and other browsing behaviour;
– Device and Technical Data: IP address, browser type and version, operating system, device identifiers;
– Commerce Data: cart contents, checkout behaviour, abandoned carts;
– Location Data: country or region inferred from IP address for pricing, compliance, and language purposes.
3.3 Data from Third Parties
We may receive personal data from third-party service providers who assist us in operating our Website and fulfilling orders (such as payment processors, logistics providers, and marketing platforms), as well as from publicly available sources where legally permitted.
4. How We Use Your Personal Data
We use your personal data for the following purposes and on the following legal bases:
4.1 Fulfilment of Your Order (Contractual Necessity)
– Processing and confirming your purchase;
– Arranging payment, delivery, and returns;
– Sending order confirmations, shipping updates, and invoices;
– Managing your customer account and subscription, if applicable.
4.2 Legitimate Business Operations (Legitimate Interest)
– Improving our Website, products, and services;
– Analysing usage patterns and customer behaviour to enhance the shopping experience;
– Fraud detection, security monitoring, and abuse prevention;
– Internal reporting and business analytics.
4.3 Marketing and Communications (Consent)
– Sending you promotional emails, product launches, and brand content where you have provided explicit consent;
– Personalising marketing communications based on your skin profile, preferences, and purchase history;
– Sending post-purchase email sequences including product recommendations and replenishment reminders;
– You may withdraw your consent at any time by clicking "unsubscribe" in any of our emails or by contacting us at hello@elementumskin.com.
4.4 Legal and Regulatory Compliance
– Complying with applicable laws, regulations, and court orders;
– Fulfilling our UAE VAT obligations and other fiscal requirements;
– Responding to lawful requests from public authorities.
4.5 Skin Assessment Quiz Data
Skin type and concern data collected through our quiz is used solely for the purpose of providing personalised product recommendations. It is not sold, licensed, or otherwise shared with third parties for their own commercial purposes. Where such data may be classified as health-adjacent data under applicable law, we process it only with your explicit consent.
5. Sharing Your Personal Data
We do not sell your personal data. We may share your data with trusted third-party service providers acting as data processors on our behalf, strictly to enable the operation of our Website and fulfilment of your orders. These categories of providers include:
– E-commerce platform and hosting providers;
– Payment processing providers (for secure transaction handling);
– Buy-now-pay-later and instalment payment providers;
– Logistics, shipping, and fulfilment partners;
– Email marketing and customer relationship management platforms;
– Subscription management providers;
– Customer review and ratings platforms;
– Analytics and website performance tools;
– Customer support software providers.
All third-party processors are bound by contractual data processing agreements and are required to process your data solely in accordance with our instructions and applicable law. We do not permit them to use your data for their own independent purposes.
We may also disclose your data to: (i) regulatory authorities or law enforcement when required by law; (ii) professional advisors including lawyers and accountants under duties of confidentiality; or (iii) a buyer or prospective buyer in the event of a business sale or transfer, subject to equivalent confidentiality obligations.
6. International Data Transfers
ELEMENTUM operates globally and your personal data may be transferred to, and processed in, countries outside your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction.
Where we transfer personal data from the European Economic Area (EEA) or the United Kingdom to third countries, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission, adequacy decisions, or other legally recognised transfer mechanisms.
Where we transfer data from or to the UAE, Saudi Arabia, or any other jurisdiction in which we operate, we comply with the applicable data transfer requirements of those jurisdictions.
By using our Website and providing your personal data, you acknowledge that your data may be transferred and processed as described above.
7. Data Retention
We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including:
– Order and transaction records: retained for a minimum of five (5) years to comply with UAE commercial and tax regulations;
– Account data: retained for as long as your account remains active, plus a reasonable period thereafter;
– Marketing consent records: retained for as long as necessary to demonstrate compliance;
– Skin profile data: retained for the duration of your customer relationship, unless you request deletion sooner.
After the applicable retention period, we securely delete or anonymise your personal data.
8. Your Data Protection Rights
Depending on your country of residence, you may have the following rights regarding your personal data:
8.1 Rights Available to All Customers
– Right of Access: to request a copy of the personal data we hold about you;
– Right to Rectification: to request correction of inaccurate or incomplete data;
– Right to Erasure: to request deletion of your personal data, subject to certain legal exceptions;
– Right to Restriction: to request that we limit the processing of your data in certain circumstances;
– Right to Object: to object to processing based on legitimate interests or for direct marketing purposes;
– Right to Data Portability: to receive your data in a structured, machine-readable format (where applicable);
– Right to Withdraw Consent: where processing is based on consent, to withdraw that consent at any time.
8.2 Additional Rights for EU/EEA Customers (GDPR)
If you are located in the European Economic Area, you have the right to lodge a complaint with your local data protection supervisory authority. You also have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal or similarly significant effects.
8.3 Additional Rights for UAE Customers
If you are located in the UAE, you have the right to file a complaint with the UAE Data Office where you believe your personal data rights have been infringed.
8.4 Additional Rights for Saudi Arabia Customers
If you are located in the Kingdom of Saudi Arabia, you have the right to lodge a complaint with the National Data Management Office (NDMO) in accordance with the Saudi Arabia Personal Data Protection Law.
To exercise any of your rights, please contact us at hello@elementumskin.com. We will respond within the timeframe required by applicable law (typically within 30 days). We may need to verify your identity before processing your request.
9. Data Security
We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to, encrypted data transmission (SSL/TLS), access controls, and secure payment processing through PCI-DSS compliant payment providers.
While we take every reasonable precaution, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant authorities and affected individuals in accordance with applicable law.
10. Payment Processing
All payment transactions are processed by third-party payment providers. We do not store, transmit, or process your full payment card details on our servers. Payment data is processed directly by our payment partners who operate under PCI-DSS compliance standards. We may retain limited transaction reference data (such as transaction IDs, amounts, and payment method type) for order management and compliance purposes.
11. Children's Privacy
Our Website and products are intended for adults aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have inadvertently collected data from a minor, we will promptly delete it. If you believe a minor has provided us with personal data, please contact us at hello@elementumskin.com.
12. Third-Party Links and Platforms
Our Website may contain links to third-party websites, social media platforms, or other external services. This Privacy Policy applies solely to data collected through www.elementumskin.com. We are not responsible for the privacy practices of third-party websites and encourage you to review their respective privacy policies before providing any personal data.
13. Cookies and Tracking Technologies
Our Website uses cookies and similar tracking technologies to enhance your browsing experience, analyse Website performance, and support our marketing activities. The use of cookies is governed by our separate Cookie Policy, available at www.elementumskin.com/cookies, which we encourage you to review. By continuing to use our Website, you consent to our use of cookies in accordance with our Cookie Policy.
14. Changes to This Privacy Policy
We reserve the right to update or modify this Privacy Policy at any time. Where changes are material, we will notify you by posting an updated version on our Website with a revised "Last Updated" date, and where appropriate, by sending a notification to the email address associated with your account. Continued use of our Website following the publication of changes constitutes your acceptance of the updated Privacy Policy.
15. Contact Us
For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact us:
Brand: ELEMENTUM by TGM Company LLC
Email: hello@elementumskin.com
Website: www.elementumskin.com
Address: Shams Free Zone, Sharjah Media City, Sharjah, United Arab Emirates
We will endeavour to respond to all legitimate requests within 30 days. Where a request is particularly complex, we may extend this period and will notify you accordingly.