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:
- processed lawfully, fairly and in a transparent manner,
- processed for specified, explicit and legitimate purposes,
- adequate, relevant and limited to what is necessary,
- accurate and kept up-to-date,
- kept for no longer than is necessary, and
- processed in a manner than ensures appropriate security.
Information you give to us
We may collect, use, store and transfer different kinds of information about you, including:
- Identity Data: such as your name, username or similar identifier, date of birth, gender;
- Identified Photographs: your photograph (associated with your other Personal Data and therefore identifying you as a private individual);
- Anonymous Photographs: photographs and associated Health Data that you upload on an anonymous basis to use our website;
- Contact Data: such as your address, email address and telephone numbers;
- Health Data: such as whether you smoke, your dietary preferences and how much you exercise;
- Social Media Data: such as your Apple ID and social media account details;
- Financial Data: such as bank account and payment card details;
- Transaction Data: including details about payments to and from you, and other details of products and services you purchase from us;
- Technical Data: including IP addresses, your log-in data, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website;
- Profile Data: such as your username, password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
- Usage Data: including information about how you use our website, products and services; and
- Marketing Data: such as your preferences in receiving marketing from us and our third parties, and your communication preferences.
“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:
- filling in a ‘Contact us’ form on our website,
- downloading our Apps or Software,
- uploading a facial photograph in our Apps, software or on our website,
- providing full details for collaboration projects,
- participating in discussions on social media outlets, or
- creating an account on our website,
- participating in discussion boards or other social media functions on our website,
- entering a competition, promotion or survey organised by us, or otherwise providing us with feedback,
- subscribing to our services or publications, or otherwise requesting marketing material to be sent to you, or
- corresponding with us by phone, email, letters or otherwise.
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:
- analytics providers (such as Google),
- advertising networks,
- search information providers
- providers of technical, payment and delivery services,
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:
- you have given us consent,
- we need to perform a contract we are about to enter into, or have entered into, with you,
- where it is necessary for our or a third party’s legitimate interests, and your interests and rights do not override those interests, or
- where we need to comply with a legal or regulatory obligation.
We will only use ‘special category’ information:
- provided we have your explicit consent to use it,
- where we believe that we need to use that data to protect your vital interests where you are not able to provide us with your explicit consent,
- where it is necessary for reasons of substantial public interest,
- where you have previously made that data public knowledge, or
- if we need to use that data to establish, exercise or defence legal claims.
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 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 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.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
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:
- providers of IT and system administration services to our business, including Dropbox, One Drive, Google Drive and other online cloud providers,
- our professional advisers (including solicitors, bankers, auditors and insurers),
- HM Revenue & Customs, the Information Commissioner’s Office, regulators and other authorities who require reporting of processing activities in certain circumstances,
- analytics and search engine providers that assist us in the improvement and optimisation of our website, and
- third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this policy.
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:
- Credit cards. We do not store any credit card details.
- Building entry controls. We require all staff to use security fobs to access the building.
- Methods of disposal. Paper documents are disposed of by shredding in a manner that ensures confidentiality.
- Overseas transfers. Whenever we transfer your personal information outside the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring that we apply appropriate safeguards (either by transferring data only to recipients in the European Union, to recipients in countries approved by the European Commission, to recipients that are party to the EU-US Privacy Shield, or by using specific contracts approved by the European Commission).
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.
You have various legal rights in relation to the information you give us, or which we collect about you, as follows:
- You have a right to access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
- You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
- You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
- You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
- You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
- Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.
- Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
- You have the right to object to us using/storing your information for direct marketing purposes.
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 email@example.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 firstname.lastname@example.org.
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 email@example.com.
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.
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 firstname.lastname@example.org.