This “Privacy Policy” describes the privacy practices of The Inkey List, a brand owned by Brand Evangelists for Beauty Limited, and its affiliates and subsidiaries  (the “Company”, “our”, “we”, or “us”),  in connection with the www.theinkeylist.com website, and any other website that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their information.

Table of Contents

• Personal Information We Collect
• How We Use Your Personal Information
• How We Share your Personal Information
• Your Choices
• Other sites, mobile applications and services
• Security practices
• International data transfers
• Children
• Changes to this Privacy Policy
• How to Contact Us
• Your California Privacy Rights
• Acne Analyzer Pro

Personal Information We Collect

Information you provide to us.  Personal information you provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
• Demographic Information, such as your city, state, country of residence, postal code, and age.

• Content you choose to upload to the Service, such as text, images, audio, and video, along with the metadata associated with the files you upload.
• Profile information, such as your username and password that you may set to establish an online account with us, date of birth, biographical details, photograph, interests, preferences, information about your participation in our surveys, and any other information that you add to your account profile.

• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
• Transaction information, such as information about payments to and from you and other details of products or services you have purchased from us.
• Usage information, such as information about how you use the Service and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Service.
• Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications

• Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from social media platforms. We may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

Information we obtain from other third parties.  We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.

Cookies and Other Information Collected by Automated Means 

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service, including but not limited,  your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information.  Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons.

A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites.

Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. Please see the “Targeted online advertising” section for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Service.  We use your personal information to:

• provide, operate and improve the Service
• provide information about our products and services
• establish and maintain your user profile on the Service
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in
• facilitate social features of the Service, such as by providing chat or messaging functionality
• communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages
• communicate with you about events or promotions in which you participate
• understand your needs and interests, and personalize your experience with the Service and our communications
• provide support and maintenance for the Service
• to respond to your requests, questions and feedback

For research and development.  We analyze use of the Service to analyze and improve the Service and to develop new products and services, including by studying user demographics and use of the Service.

To send you marketing and promotional communications.  We may send you Company-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.

To display advertisements. We work with advertising partners to display advertisements on the Service or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Service or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent.  In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. 

To create anonymous, aggregated or de-identified data.  We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. 

How We Share your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Affiliates.  We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers.  We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Other Users of the Service and the Public. We may provide functionality that enables you to disclose personal information to other users of the Service or the public. For instance, you may be able to submit content to the Service (such as comments, reviews, surveys, blogs, photos, and videos), and we will display your name or username along with the content you submit. We do not control how other users or third parties use any personal information that you make available to such users or the public.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.  

Business transfers.  We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Your Choices

In this section, we describe the rights and choices available to all users.

Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications.  You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at help@theinkeylist.com.  You may continue to receive service-related and other non-marketing emails.  If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message. You may also text STOP to +1 (855) 761-9214.

Cookies & Browser Web Storage.  We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third party websites. Most browsers let you remove or reject cookies.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  Please note that if you set your browser to disable cookies, the Sites may not work properly.  Similarly, your browser settings may allow you to clear your browser web storage.  

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

Other sites, mobile applications and services

The Service may contain links to other websites, mobile applications, and other online services operated by third parties.  These links are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions.  Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information.  We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security practices

The security of your personal information is important to us.  We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfers

We are headquartered in the United Kingdom and have service providers in other countries, and your personal information may be transferred to the United Kingdom or other locations outside of your country where privacy laws may not be as protective as those in your country. 

Children  

As a general rule, children are not allowed to use the Service, and we do not collect personal information from them. We define "children" as anyone under 13 years old. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it.  We encourage parents with concerns to contact us.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to help@theinkeylist.com. You may also write to us via postal mail at:

            The Inkey List

            Attn: Legal – Privacy

            Be For Beauty

           6th Floor, The Hub, 40 Friar Lane, Nottingham, NG1 6DQ

            United Kingdom

Your California Privacy Rights

Under California Civil Code section 1798.83, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at help@theinkeylist.com. You must put the statement "Your California Privacy Rights" in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Acne Analyzer Pro & Biometric Data

Our Acne Analyzer Pro (US) & Breakout Analyzer Pro (Global) (both referred to as a digital tool) tool uses a combination of machine learning tools and statistical algorithms to perform personalised skin analysis based on the facial scans you provide to us. Both these tool work by analysing these facial scans to provide you with personalised skincare insights and recommended skincare products designed to target any skin concerns that have been identified in our skin analysis.

If you choose to use our Acne Analyzer Pro or Breakout Analyzer Pro, your image will be used to provide the functionality of the tool. In some cases, you may choose to either allow access to your camera or upload a photo in order for the tool to complete a “face scan,” which occurs entirely on your own device and browser. The output of the analysis is used to visually display the results of the analysis and related services to you. The above may include the processing of your biometric data outside of your browser or device, such as where we partner with a third party that collects your biometric data for purposes of providing you with or facilitating the digital tool you are interacting with.

If you choose to save your image, facial scan, skin analysis data and any other information relating to your skincare profile to your myINKEY account, we will keep this information for the purposes of quality control and the development and improvement of our digital tool as well as providing personalised product recommendations to you. This information will be deleted upon request

If you are a user of our digital tools and are signed into a myINKEY account, if you elect to save your and / or if you elect to email yourself your score, your individual skin analysis score will be connected to your name and email address and retained according to the retention schedule set forth below and consistent with the purposes set forth in this policy.

HOW YOUR BIOMETRIC DATA IS DISCLOSED

We do not share or facilitate the sharing of your biometric data with third parties unless you have consented to the disclosure, or where the disclosure is otherwise permitted or required by law. We never sell, lease, trade, or otherwise profit from your biometric data.

Som biometric data may be shared with or directly collected by third parties (such as our service providers) for purposes of providing you with or facilitating the specific product or service that you are interacting with. To the extent that we collect and subsequently disclose any biometric information to third party service providers in order to facilitate the service, we restrict how such partners may use and share your biometric data.

HOW WE PROTECT YOUR BIOMETRIC DATA

Where we collect or otherwise possess your biometric data, we use a reasonable standard of care to store it, transmit it, and protect it from disclosure. Our practices for protecting your biometric data are, at a minimum, just as robust as those we use to store, transmit, and protect other confidential and sensitive information that we possess.

Your biometric data is stored securely in Be For Beauty’s (The INKEY list’s) internally managed database and / or with secure cloud service providers. Your image and/or biometric data will be deleted the earlier of (a) when the initial purpose for collecting or obtaining the image and such biometric data has been satisfied, (b) two (2) years of your last interaction with the tool or (c) upon your request for us to delete your data from our database if you are a registered user.

RETENTION AND DELETION OF YOUR BIOMETRIC DATA

If we are ever in possession of your biometric data, we will only keep it until the following occurs, at which point we will permanently destroy it, and direct any third party service providers involved to do the same.

We will permanently destroy your biometric data once the initial purpose for collecting your biometric data has been satisfied

We may deviate from the retention schedule described in this section where reasonably necessary to comply with a valid warrant or a subpoena issued by a court of competent jurisdiction, or if otherwise required to do so by law.

If you are using Acne Analyzer Pro as a guest user and are not signed into the website, your image will be retained for a period of 12 months and will then be permanently deleted. The biometric data derived from your image will be stored in a de-identified manner, uncoupled from your deleted image and not connected to your name or email address unless you are signed into a myINKEY account.

If you have any questions regarding how we store and manage your data please contact help@theinkeylist.com