Introduction

We are committed to protecting and respecting your privacy.

Everyone has rights with regard to the way in which their personal information is handled. During the course of our activities we will collect, store and process personal information about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.

This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

For the purpose of UK data protection laws, the data controller is Change My Face Ltd of 2 Bath Mews, Bath Parade, Cheltenham, Gloucestershire, GL53 7HL (collectively referred to as "Change My Face", "we", "us" or "our" in this privacy notice).

Data protection principles

When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal information must be:

Information you give to us

We may collect, use, store and transfer different kinds of information about you, including:

‘Special category’ data and anonymous data

During the course of dealing with you, we may collect information about you relating to your racial or ethnic origin, religious or philosophical beliefs, health and lifestyle choices (specifically relating to smoking, drinking and diet), or certain types of genetic or biometric data (such information is known as ‘special category’ data).

This is most likely to occur, for example, if you upload a facial photograph using our Apps, software or website. This could either be by means of Identified Photographs (which would be special category data) or Anonymous Photographs (which would not be special category data).

We use the information you have given us to perform the service requested, namely to apply a variety of ‘lifestyle affects’ to your photo in order allow you to visualise what you might look like in the future.

How we collect your personal information

We may obtain personal information by directly interacting with you, such as:

We may obtain personal information via automated technology when you interact with our website by using cookies, server logs and other similar technologies.

We may also collect personal information about you from third parties or publicly-available sources, such as:

How we use your personal information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

We will only use ‘special category’ information:

Purposes for which we will use your personal information

We may use your personal information for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:

Purposes for which we will use the information you give to us Legal basis
To register you as a new customer, to create an account and process payments for Apps or Software downloaded. It will be necessary for the performance of the contract between you and us
To ensure compatibility of Apps or Software with the users device or computer. It will be necessary for our legitimate business interests, namely to ensure full operation and use of the App or Software downloaded.
To ensure Apps or Software designed accurately reflects the needs and intentions of the collaboration project. It will be necessary for the performance of the contract between you and us.
To perform the service requested, namely to modify facial photographs uploaded to allow users to visualise themselves in the future. We will only do this if you give us your consent by some specific, informed and unambiguous method.
To process your order and, if accepted, to deliver the products or services to you (including managing payments, fees and charges) It will be necessary for the performance of the contract between you and us
To collect and recover money owed to us It will be necessary for our legitimate business interests, namely to ensure we receive payment for products that you have ordered from us
To notify you about changes to our terms of sale or this privacy policy It will be necessary for our legitimate business interests, namely to ensure you are aware of our current terms and conditions
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to allow you to participate in interactive features of our service, when you choose to do so, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you and to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them It will be necessary for our legitimate business interests to ensure you receive the best experience possible when accessing and using our website. We will comply with our cookie policy when processing this information
To enable you to participate in a prize draw, competition or complete a survey It will be necessary for our legitimate business interests, namely to study how customers use our products, to develop them and help grow our business
To provide you with information about special offers and other products we sell that are similar to those that you have already received from us Where you have previously received marketing communications from us, then it will be necessary for our legitimate business interests, namely to ensure you continue to receive communications that you have previously agreed to receive

In all other cases, we will only do this if you give us your consent

We will only use your personal information for the purpose(s) for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

What if you cannot or will not provide us with your personal information

It is a contractual requirement for you to provide us with certain information, namely your name, address, email address and debit/credit card information. If you do not provide us with that information, we will be unable to accept and process your order and deliver the products or services to you.

Cookie policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Except for essential cookies, all cookies will expire two years.

Disclosure of your information

We may share your personal information with the parties set out below:

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Where we store your personal information

All information you provide to us is stored on our secure servers in the EU.

We will take all steps reasonably necessary to ensure that your data is treated securely, including taking the following safeguards:

If you are concerned about the levels of data security in any of those countries, please let us know and we will endeavour to advise what steps will be taken to protect your data when stored overseas.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

How long we will store your personal information

The length of time that we will store your data will depend on the ‘legal basis’ for why we are using that data, as follows:

Legal basis Length of time
Where we use/store your data because it is necessary for the performance of the contract between you and us We will use/store your data for as long as it is necessary for the performance of the contract between you and us
Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject We will use/store your data for as long as it is necessary for us to comply with our legal obligations
Where we use/store your data because it is necessary for our legitimate business interests We will use/store your data until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data)
Where we use/store your data because you have given us your specific, informed and unambiguous consent We will use/store your data until you ask us to stop

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitive of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your rights

You have various legal rights in relation to the information you give us, or which we collect about you, as follows:

If you wish to exercise any of your legal rights, please contact us by writing to the address at the top of this policy, or by emailing us at info@changemyface.com.

You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.

Identifying you as a customer

If you are a business client, we may identify you as a client of the firm in our marketing material or on our website, although we will never publicly disclose any confidential information about your legal matters without having obtained your prior consent. If you do not agree to us identifying you as a customer of the firm, please notify us by writing to the address at the top of this policy, or by emailing us at info@changemyface.com.

Opting out of receiving marketing communications

You can ask us to stop sending you marketing communications at any time by writing to the address at the top of this policy, or by emailing us at info@changemyface.com.

Automated decision-making

We do not use automated decision-making processes.

Third party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Changes to our policy

Any changes we make to our policy in the future will be posted on our website and, where appropriate, notified to you by email or via social media. Please check our website frequently to see any updates or changes to our policy.

Contact

Questions, comments and requests regarding this policy are welcomed and should be sent to the address at the top of this policy, or by emailing us at info@changemyface.com.