Privacy and cookies policy

Facesoft Ltd (company number 10579464) (Facesoft / we / our / us) takes your privacy very seriously and is committed to protecting and respecting your privacy.

If you wish to contact us regarding this privacy and cookies policy, please contact us using the contact details set out here. Facesoft is the data controller. Our registered office is at 20-22 Wenlock Road, London, England, N1 7GU and trading office is at 80 Wood Lane, Shepherd's Bush, London, W12 OBZ.

This privacy and cookies policy (together with our Terms and Conditions) sets out the basis on which any personal data we collect from you when you interact with us, that is provided by you through your use of our website (https://www.facesoft.io/) (the Website) or the Facesoft platform via the Website (the Facesoft Platform), or that is provided to us by an Organisation or user of the Facesoft Platform, will be processed by us.

This privacy and cookies policy does not apply to websites that you may be able to access via links on the Website or the Facesoft Platform and/or activities offered by third parties. Please ensure you review any relevant policies on any third party websites before proceeding. We are not responsible for the collection or use of your personal data from third party websites.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Topics covered

Our terms and conditions

In order to use the Facesoft Platform, the organisation you represent (the Organisation) or you on behalf of the Organisation will have entered into our Terms and Conditions for the use of the Facesoft Platform. As mentioned above, your personal data will be governed by this privacy and cookie policy, but also our Terms and Conditions. You may also wish to check your Organisation's privacy policy. If you are not a user of the Facesoft Platform then these Terms and Conditions will not apply, however, this privacy and cookie policy will still explain how we process your personal data.

Data we collect from you or about you and our sources of that data

We will collect the following data about you:

Data you give us. You may give us data about you:

  • when you fill out a form on the Website or via the Facesoft Platform;
  • when you create a Facesoft Platform account;
  • when you use the Facesoft Platform;
  • when you transmit or upload content including, but not limited to CCTV footage, images, photographs and data files to the Facesoft Platform; this data are only processed and not stored, unless you give us explicit consent
  • if you sign up to receive marketing communications about us, the Facesoft Platform and other products or services we offer;
  • if you complete a survey, for example, about the Facesoft Platform or the Website;
  • when you report a problem with the Facesoft Platform or the Website;
  • when you provide us with feedback, opinions and / or comments regarding the Facesoft Platform or Website; and
  • if you contact or correspond with us (for example, by phone, e-mail or otherwise) for any other reason (for example, to request further services from us).

Data we collect about you. We will automatically collect the following:

  • when you use the Facesoft Platform or the Website, details of your usage (including the date, time, location or duration of the usage);
  • if you visit the Facesoft Platform or Website certain technical information, for example, the type of device (and its unique device identifier) you use to access the Facesoft Platform or Website, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform; and
  • information about your visit to the Facesoft Platform or Website including the full Uniform Resource Locators (URL), clickstream to, through and from the Facesoft Platform or Website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Data we collect or are provided with from third parties. We may be given or collect personal data about you by or from third parties:

  • by your Organisation to enable you (as an end user) to use the Facesoft Platform;
  • when an Organisation or user of the Facesoft Platform uploads content which contains your personal data including, but not limited to CCTV footage, images, photographs and data files to the Facesoft Platform and we use such content to train the Facesoft Platform. We require the Organisation to confirm that they have obtained appropriate consents from you or provided you with appropriate notices about this sharing and processing of your personal data.

Purpose and legal basis for processing your data

We will process the personal data held about you for the purposes stated below:

Purpose of processing Type of personal data Legal basis for processing
To enable us to provide you with access to the Facesoft Platform and for you to use the Facesoft Platform Your name, a username, your Organisation details (if applicable) and email address Legitimate interest - to perform our contract with your Organisation if you are using the Facesoft Platform on their behalf Performance of our contract with you if you are using the Facesoft Platform for your own purposes
To enable us to provide support services to you Your name, username, your Organisation details (if applicable) and email address Legitimate interest - to perform our contract with your Organisation if you are using the Facesoft Platform on their behalf Performance of our contract with you if you are using the Facesoft Platform for your own purposes
To enable us to identify you and any accounts you hold with us Your name, username, your Organisation details (if applicable) and email address Legitimate interest - to perform our contract with your Organisation if you are using the Facesoft Platform on their behalf Performance of our contract with you if you are using the Facesoft Platform for your own purposes
To allow us to notify you about changes to any element of the Facesoft Platform or Website Your name, username, Organisation details (if applicable) and email address Legitimate interest - to perform our contract with your Organisation if you are using the Facesoft Platform on their behalf Performance of our contract with you if you are using the Facesoft Platform for your own purposes
To monitor your use of the Facesoft Platform Your name, your Organisation details, username and email address and login details (as applicable) Legitimate Interest - to allow us to ensure that the Facesoft Platform is used in accordance with the Terms and Conditions
To deal with any enquiries, correspondence, concerns or complaints you have raised Your name, information about the issue raised, customer details (if applicable), phone number and email address Legitimate Interest - to allow us to improve the Facesoft Platform
To allow us to make improvements to the algorithms underlying the Facesoft Platform Your image Consent (if we are processing special category data) or legitimate interest - to allow us to improve the Facesoft Platform (if we are processing any other personal data)
To ensure that the Facesoft Platform is presented in the most effective manner for you and for your device The technical information as mentioned above Legitimate Interest - to allow us to present the Facesoft Platform better
For our internal operations, including data analysis, testing, research, statistical purposes and troubleshooting The technical information as mentioned above Legitimate Interest - to better understand customers, end users and continuously improve the Facesoft Platform
As part of our efforts to keep the Facesoft Platform safe and secure The technical information as mentioned above Legitimate Interest - to improve and ensure the safety of the Facesoft Platform
To provide you with information, products or services that you request from us or which we feel may interest you Your name, customer details, username and email address Consent
To notify you about changes to any element of the Terms and Conditions, Facesoft Platform, for example, an update or upgrade, or this privacy and cookies policy Your name, customer details, username and email address Legitimate interest - to allow us to perform our contract with our customer Performance of our contract with you if you are using the Facesoft Platform for your own purposes

Where we need to collect personal data by law or as part of a contract we have with you and you fail to provide that data when requested, we may not be able to provide you with the Facesoft Platform. Where we have a legal basis to use your personal data without consent (as we have described above), this policy fulfils our duty to process personal data fairly and lawfully and in a manner that you would expect given the nature of our relationship with you, by giving you appropriate notice and explanation of the way in which your personal data will be used.

Where consent is required for our use of your personal data as described above, we will request your consent. Typically, we would collect your consent by you performing an action such as ticking the appropriate consent box or otherwise communicating your consent to us (for example, by email or by you providing us with non mandatory information), you consent to our use of that personal data as set out in this policy. For example, we will only process your personal data for marketing purposes if we have your consent to do so. In certain circumstances, you may not be giving the consent to us directly, but to our customer who is collecting your consent on our behalf.

Children

The Facesoft Platform is not intended for and may not be used by anyone under the age of 18. If you are under the age of 18, you must stop using the Facesoft Platform immediately.

Organisations and end users may be uploading data of children under the age of 18 to Facesoft. We require them to confirm that they have either obtained the child's consent if they are over the age of 16 or the child's legal guardian's consent or provided the child or its legal guardian with appropriate notices of the sharing and process of the child's personal data for this reason.

Marketing

We would like to provide you with information by email about us, the Facesoft Platform and other products and services which may be of interest to you. We will only provide you with marketing communications if you would like us to. You can tell us by ticking the relevant boxes when you first access the Facesoft Platform or by updating your account settings.

If you no longer wish to receive marketing communications from us, please contact us using the contact details set out below.

You can also manage your preferences by updating / changing the privacy settings of your account.

Disclosure of your personal data

We may share your personal data with selected third parties in accordance with this policy including:

  • any member of our group of companies, including our subsidiaries and ultimate holding company;
  • service providers (for example, IT services), business partners, suppliers and sub-contractors for the performance of any contract we enter into with you, but also when providing you with marketing communications;
  • analytics and search engine providers that assist us in the improvement and optimisation of the Facesoft Platform;
  • government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information);
  • in the event that we sell any business or assets or receive investment into our business, in which case we may disclose your personal data to the prospective buyer or investor;
  • professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
  • if Facesoft's or substantially all of its assets are acquired by a third party, in which case personal data held by us, including your personal data, will be one of the transferred assets; and
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the Terms and Conditions for the Facesoft Platform or any other contract between you and us; or to protect the rights, property or safety of us, our customers and others.

Where we store your personal data

Your personal data will be transferred to, processed and stored at destinations inside the European Economic Area (EEA).

Should we decide to transfer personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. To find out which countries are covered by this, please see here.
  • Where there is no adequacy decision by the European Commission in respect of these countries (to the extent that they are outside the EEA), which means they are not deemed to provide an adequate level of protection to your personal data, we ensure that your personal data receives an adequate level of protection. We have therefore put in place the following measures to ensure that your personal data is treated by those third parties in a way that is consistent with EU and UK laws on data protection:
    • EU-US Privacy Shield; and/or
    • EU standard contractual clauses.

If you would like to find out more about these safeguards in respect of processing of your personal data, please contact us using the contact details below.

The Facesoft Platform can be accessed and used worldwide, which means your data may be processed outside the EEA. Please note that the country from which you are accessing personal data may not provide an adequate level of protection for your personal data.

Security

All information you provide to us is stored on secure severs. We will use appropriate technical and organisational measures to safeguard your personal data.

If you are an end user and we have given you (or you have chosen) a password which enables you to access the Facesoft Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We maintain, and ensure that anyone we share your personal data with maintains, appropriate technical and organisational measures to ensure that an appropriate level of security in respect of all personal data we process. Unfortunately the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the Facesoft Platform; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access or inadvertent disclosure.

Retaining personal data

We will retain the personal data we receive or collect about you for the period reasonably required for us to use it in accordance with this privacy and cookies policy or in accordance with our legal rights and obligations. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Unless we inform you otherwise (or you request that we erase your personal data), we will retain your personal data on record for the duration of your use of the Facesoft Platform. If our customers have allowed us to use their data to train the Facesoft Platform then we will retain the data for as long as we need to in order to accomplish this purpose.

Even if you request that we erase your data, we may still need to keep it (please see below) or may keep it in a form that does not identify you.

Your rights

You have the following rights with regard to your personal data:

  • Access. You have the right to access data we hold about you. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Rectification or erasure.You have the right to request that we rectify or delete any personal data that we hold about you (unless we have the legal right to retain it). If you request that we erase any personal data that we require in order to provide the Facesoft Platform to you, you may no longer be able to use it. This right does not extend to non-personal data. It is likely to be necessary for us to retain your personal data to enable us to carry out our contract with you and your rights under applicable law to request erasure may be limited accordingly.
  • Data portability. You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller if the legal basis for processing such personal data is consent or performance of a contract.
  • Restriction. You also have the right to restrict us from processing your personal data if the data is inaccurate, the processing is unlawful or we no longer need to your personal data for the purposes for which we hold it.
  • Object / Change of preferences. You have a right to request that we stop processing your personal data where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal data for direct marketing purposes. For example, if you have given your consent to receive updates from us, but have changed your mind, you have the ability to opt out from receiving such communications going forward by contacting us using the details provided below or clicking the relevant link in any communications you receive.
  • Complaints. If for any reason you are not happy with the way that we have handled your personal data, please contact us. If you are still not happy, you have the right to make a complaint to the Information Commissioner's Office.
  • Automated decision making. We carry out the following profiling and automated decision making: the Facesoft Platform analyses images to detect facial expressions, gender, age and ethnicity. If you have any questions in respect of our profiling or automated decision making processes or the accuracy of them, please let us know using the contact details here.

Please note that if you ask us to stop processing your personal data in a certain way or erase your personal data, and this type of processing or data is needed to facilitate your use of any of the Facesoft Platform you may not be able to use the Facesoft Platform as you did before, or at all. This does not include your right to object to direct marketing, which can be exercised at any time without restriction. Please allow at least 10 working days for your request to be actioned.

Please note that the rights mentioned above do not extend to non-personal data. Please also note that it is likely to be necessary to retain your personal data for the purposes of assessing and verifying data that is submitted and/or held on the Facesoft Platform and to manage the Facesoft Platform, so therefore your rights under applicable law to request erasure may be limited accordingly.

If you would like to exercise any of the rights mentioned above, please contact us at using the details set out below.

Cookies

We use cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer or mobile device if you agree. Cookies contain information that is transferred to your computer's or mobile device's hard drive.

We use the following cookies:

  • Strictly necessary cookies. Y These are cookies that are required for the operation of the Facesoft Platform. They include, for example, cookies that enable you to log into the Facesoft Platform.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Facesoft Platform when they are using it. They also enable us to see how users use the Facesoft Platform. This helps us to improve the way the Facesoft Platform works.
  • Functionality cookies. These are used to recognise you when you return to the Facesoft Platform. 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 the Facesoft Platform, the pages you have visited and the links you have followed. We will use this information to make the website and the advertising displayed on it more relevant to your interests.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Purpose
authentication cookie an authentication and authorization mechanism to keep visitors logged in to our platform
cookie consent cookie a cookie to store the visitors consent regarding the use of cookies
google analytics cookies cookies as described here to help us monitor the usage of our platform
image storage consent cookie if the visitor opts to let us use images stored for research purposes, this cookie stores this preference

By clicking ["agree"] on the cookie consent box when you first access the Facesoft Platform and by continuing to access and use the Facesoft Platform you accept our use of the cookies. You can 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 the Facesoft Platform. For more detailed information about cookies and how they can be managed and deleted, please visit www.allaboutcookies.org.

Changes to the privacy and cookies policy

Any changes we make to our privacy and cookies policy in the future will be posted on www.facesoft.io/privacy and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this privacy and cookies policy. Continued use of the Facesoft Platform will signify that you agree to such changes.

How to contact us

We have appointed a data protection officer to oversee compliance with this privacy policy. Questions, comments and requests regarding the privacy and cookies policy are welcomed and should be addressed to Data Protection Officer at Facesoft Ltd at 80 Wood Lane, Shepherd's Bush, London, W12 OBZ or by email at privacy@facesoft.io.

Please also contact us if you would like to know more about our data processing activities, to update or amend any of your personal data which you have provided to us or if you believe our records relating to your personal data are incorrect.

This privacy and cookies policy was last updated on 28/11/2018.

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