1. Purpose of the Privacy Policy

The goal of our Privacy Policy is to provide all necessary information about processing your personal data in a concise, transparent, intelligible and easily accessible form, using clear and plain language, and assist the Data subjects in exercising their rights under Section 4.

The legal basis of our duty to communicate information is the relevant data protection regulations of the United Kingdom (hereinafter: UK).

In the Privacy Policy, we may define you as “data subject”, or “contact person of our business partners” in the following.

You may find further definitions concerning your personal data within the Appendix of the current Privacy Policy.

 

2. Data of the controller

Name	FaceTill Ltd.
Registry number	13833436
Registered seat	Littlehampton
E-mail	legal@facetill.co.uk
Tax number	94283 25372

 

3. Data processing concerning contacting and communication

It is possible to connect us through our availabilities located on the website. 

Also, by communicating with our business partners, we process the personal data of their contact person. The details of these processing are described hereunder.

 

3.1.1. Processed personal data and purpose of processing

Personal data	Purpose of processing
name	identification of the Data subject, or the contact person of our business partner
phone number	contacting and communication with the Data subject, or the contact person of our business partner
e-mail address	contacting and communication with the Data subject, or the contact person of our business partner

 

3.1.2. Legal basis of processing

If you contact us through our website, we process your personal data on your freely given consent that you provide in the moment of your connection by phone or email.

If you, as the representative of our business partners provide your personal data to communicate with us, the legal basis of processing personal data is the legitimate interest of us and our business partners. It is each Party’s legitimate interest to maintain an effective business communication and to perform the contract. Since it is the part of your scope of duty (representation of our business partners), in our view, processing your name and contact data doesn’t restrict disproportionately your privacy and freedom of self-determination.

 

3.1.3. Duration of the processing

If you contact us through our website, we process your personal data until the withdrawal of your consent. You have the right to withdraw your consent at any time via email. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

In relation to the processing of the personal data of our business partners’ contact persons, we process their personal data until the personal data are no longer necessary in relation to the purposes for which they were collected or as long as it is possible according to the relevant acts.

 

3.1.4. Mode of processing

Your personal data are collected manually, in electronic form.

 

3.1.5. Data protection contractual clause

Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing concerning communicating with our business partners, we, as data controllers, while performing the contracts concluded with our business partners, both at the time of the determination of the means for processing, and at the time of the processing itself, implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of the data protection law regime of the UK.

 

3.2. Processing concerning newsletter

In order to provide relevant information to you, it is possible to subscribe our newsletter both in the registration form and on our website’s specific surface serving for this purpose. The details of such processing are described hereunder.

 

3.2.1. Processed personal data and purpose of processing

Personal data	Purpose of processing
name	to address the user
e-mail address	connecting the user by newsletter
phone number	sending text messages to you on your request

 

3.2.2. Legal basis of processing

Your consent.

 

3.2.3. Duration of processing

We process the personal data until the withdrawal of your consent. You can anytime unsubscribe our newsletter by clicking the “Unsubscribe” box.

 

3.2.4. Mode of processing

Personal data are collected automatically and manually, in electronic form.

 

3.3. Processing concerning customer service

In order to answer your questions or to inspect the circumstances you requested a complaint for, we operate customer service.

 

3.3.1. Processed personal data and purpose of processing

Personal data	Purpose of processing
name	identification of the user
e-mail address	connecting with the user and providing information
phone number	connecting with the user and providing information

 

3.3.2. Legal basis of processing

We process the personal data we collect from you by legal obligations.

 

3.3.3. Duration of processing

We process your personal data as long as the relevant consumer protection acts determine it.

 

3.3.4. Mode of processing

Personal data are collected automatically and manually, in electronic and paper form.

 

3.4. Processing concerning payments

When purchasing goods on our site payments are done through us towards the seller, in this process your personal data is processed by us, our payment processor and the seller. The details of our such processing is described hereunder, the data processing of the payment processor is linked in the section about data recipients.

 

3.4.1. Processed personal data and purpose of processing

Personal data	Purpose of processing
name	confirmation of the accounting
address	confirmation of the accounting
Type, name, and nature of goods	confirmation of the accounting
Price of the goods you purchased	confirmation of the accounting

 

3.4.2. Legal basis of processing

Processing is necessary for compliance with a legal obligation related to invoicing.

 

3.4.3. Duration of the processing

8 years after accounting.

 

3.4.4. Mode of processing

Personal data are collected manually, in electronic form.

 

3.4.5. Provision of processing

Since we cannot perform our accounting obligations without knowing any information about you, the processing is a statutory requirement.

 

3.5. Processing concerning ordering

In order to fulfill your orders, we and our sellers process your data in certain ways, the details of such processing are described hereunder.

 

3.5.1. Processed personal data and purpose of processing

Personal data	Purpose of processing
name (first name, surname, title)	identification of the purchaser or its representative
address	identification of the place of transportation
phone number	connecting the purchaser or its representative and giving information about the services
e-mail address	connecting the purchaser or its representative and giving information about the services

 

3.5.2. Legal basis of processing

If the legal person purchaser’s representative provides his or her personal data for these purposes, the legal basis of processing personal data – with regard to the relevant authorial practice – is the legitimate interest of us and the purchaser company. It is each party’s legitimate interest to maintain an effective business communication and to finalize the purchase. In our view – since it is the part of the representative’s scope of duty, and in case of the children’s and partner’s personal data, we need these pieces of information to make the gifts for the event – the processing of the mentioned personal data doesn’t restrict disproportionately the Data subject’s privacy and freedom of self-determination.

All the personal data you give us during the ordering of the available products are processed for the performance of the contract concluded between you and us and the sellers.

 

3.5.3. Duration of the processing

Until the personal data are no longer necessary in relation to the purposes for which they were collected or as long as it is possible according to the relevant acts (8 years after accounting or 5 years following performance).

 

3.5.4. Mode of processing

Personal data are collected automatically and manually, in electronic form.

 

3.5.5. Provision of processing

Since our sellers cannot perform the order without knowing any information about you, the processing is a requirement necessary to enter into a contract.

 

3.6. Processing concerning registration

Among others, the prerequisite of the use of the Website is the registration on the appropriate interface, during which the account may be created. You may also register by your Facebook profile, Google account, Apple profile, or e-mail address.  Registration for sellers is mandatory.

The details of data processing relating thereto is indicated below:

 

3.6.1. Processed personal data and purpose of processing

Personal data	Purpose of processing
name	identification of the user
e-mail address	connecting with the user
password	performing technical measures
name of the user in case of registration by social media profile (Facebook, Google, Linkedin, Apple)	identification of the user
Type of user (seller or not)	identification of the users’ purpose

 

3.6.2. Legal basis of processing

The data processing is required for the performance of the contract (general terms and conditions) between the Visitor or seller and us.

 

3.6.3. Duration of processing

We process the user’s personal data until the request for erasure. If the user does not use his/her account, then we shall anonymize the profile following the lapse of 5 years after the last order. We shall regularly review the scope of the collected data of the users in order for the principle of accuracy to apply in all cases.

 

3.6.4. Mode of processing

Personal data are collected in electronic form.

 

3.7. Advertisement

You have the possibility to place ads on the website through http://facetill.dev/advertisement/.

The details of data processing relating to advertisement and the use of the above link is indicated below:

 

3.7.1. Processed personal data and purpose of processing

Personal data	Purpose of processing
name	identification of the seller, making the advertisement available
e-mail address	identification of the seller, making the advertisement available
phone number	identification of the seller, making the advertisement available
billing address	identification of the seller, making the advertisement available
credit card transaction data	conducting the transaction/service

 

3.7.2. Legal basis of processing

The data processing is required for the performance of the contract (general terms and conditions) between the Seller and us.

Processing is also necessary for compliance with a legal obligation related to invoicing.

 

3.7.3. Duration of processing

Until the personal data are no longer necessary in relation to the purposes for which they were collected or as long as it is possible according to the relevant acts.

 

3.7.4. Mode of processing

Personal data are collected automatically and manually, in electronic form.

 

3.7.5. Provision of processing

Since we cannot perform our accounting obligations without knowing any information about the Seller, the processing is a statutory requirement.

 

4. What are your rights?

 

4.1. Right to access

You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the information featured in point 3.

You have the right to access to the following information concerning the processing of your personal data:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;
• the right to lodge a complaint with a supervisory authority;
• the existence of automated decision-making, including profiling, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

 

4.2. Right to rectification

You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

 

4.3. Right to erasure

You have the right to obtain from us the erasure of personal data concerning you without undue delay and we shall have the obligation to erase personal data without undue delay if it is mandatory according to the UK data protection law regime. The erasure of your personal data is obligatory for us in the following instances:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw consent on which the processing is based, and where there is no other legal ground for the processing;
• you object to the processing and there are no overriding legitimate grounds for the processing;
• the personal data have been unlawfully processed;
• the personal data have to be erased for compliance with a legal obligation in UK State law to which the controller is subject .

 

4.4. Right to be forgotten

If we made the personal data public and are obliged to erase your personal data, we inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

We do not make your personal data public.

 

4.5. Right to restriction of processing

You have the right to obtain from us restriction of processing if is obligatory according to the UK data protection law regime. Such instances are the following:

• the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead;
• we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;
• If you obtain restriction of processing in accordance with the above, we inform you before the restriction of processing is lifted.

 

4.6. Right to data portability

You have the right to receive the personal data concerning you, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us if is possible according to the UK data protection law regime. Where technically feasible, you have the right to have the personal data transmitted directly from us to another controller.

 

4.7. Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point 3.2. of the current policy. In such case, we no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

 

4.8. Right to lodge complaint

You have the right to appeal to UK courts and to make a complaint to the UK Supervisory Authority.

 

5. Measures and notification

 

5.1. Informing Data subjects

We communicate any rectification or erasure of personal data or restriction of processing carried out to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We also inform you about those recipients on the request of yours.

 

5.2. Mode and deadline of notification

We provide information on action taken on a request section 4 of the current policy to you without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. Where you make the request by electronic form means, we provided the information by electronic means where possible, unless you request it otherwise.

If we do not take action on your request, we inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy (see point 4.7.).

 

5.3. Monitoring

If we have reasonable doubts concerning the identity of the natural person making the request, we may request the provision of additional information necessary to confirm the identity of the data subject.

 

5.4. Costs of measures and notifications

We provide you information and take the necessary measures free of charge.

If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested or we refuse to act on your request.

 

6. Possible recipients

 

6.1. During the operation of our website

Our website’s hosting provider (data processor) can have access to the personal data you provide while using the website. The data processor’s data are the following:

Name: IBM Corp.

Connection: https://ibm.com

 

6.2. During Payment Processes

The following data processor, as our contracted service provider is responsible for processing payments.

Name: MANGOPAY S.A.

Connection: 2 Avenue Amélie, L-1125 Luxembourg, https://www.mangopay.com/contact/

 

6.3. Social media

Our website has several social media profile so that if you „like” us on Facebook or „follow” us on Instagram, we may learn all the personal data which is public on your profile.

 

7. Data security

We secure your personal information from unauthorized access, use or disclosure. We secure the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as connection data) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) or HTTPS protocol.

Our employees and the employees of the data processors have the right to get acquainted with the personal data of the User, to the extent necessary, for the performance of the tasks which belong to their job. We make all technical and organizational measures that guarantee the security of the data.

 

7.1. Organizational measures

We provide access to our IT systems with personalized rights. The “necessary and sufficient rights” principle applies to the allocation of accesses, consequently all employees may use our IT systems and services only to the extent necessary for the performance of their duties, with the appropriate rights and for the required time. Access to IT systems and services can only be granted to a person who is not restricted for security or other reasons (e.g. conflicts of interest) and who has the professional, business and information security knowledge required to use it securely.

We and the data processors undertake strict confidentiality rules in a written statement, and we are obliged to act in accordance with these confidentiality rules during the course of our activities.

 

7.2. Technical measures

The data is stored, with the exception of the data stored by our data processors, on our own devices, in a data center. The IT devices which store data are located in an isolated, separate closed server room, protected by a multi-stage access control system subject to authorization control.

We protect our internal network with multi-level firewall protection. In all cases, a hardware firewall (border protection device) is located at the entry points of the applied public networks. The data is stored redundantly, that is, in several places, so it is protected from destruction, loss, damage, or illegal destruction due to the failure of the IT device.

Our internal networks are protected from external attacks with a multi-level, active protection against complex malicious code (e.g. virus protection). The external access to the IT systems and databases is operated by us via an encrypted data connection (VPN).

We do steps to ensure that the IT tools and software continuously comply with the generally accepted technological solutions in the market.

We develop systems, during our development, in which logging can be used to control and monitor the operations performed, and to detect incidents, such as unauthorized access.

Our server is protected and closed, located on the dedicated servers of the hosting provider.

 

8. Other provisions

 

8.1. Processing for different purpose

If we intend to further process the personal data for a purpose other than that for which the personal data were collected, we provide the you prior to that further processing with information on that other purpose and with any relevant further information.

 

8.2. Data protection

We secure your personal information from unauthorized access, use or disclosure. We secure the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as connection data) is transmitted to other Web sites, it is protected through the use of encryption.

 

8.3. Record of processing

To comply with the relevant data protection laws of the UK, we maintain a record of processing activities under our responsibility.

 

8.4. Data breaches

Data breach is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed. In case of data breach, we act according to the relevant data protection laws of the UK. 

 

8.5. Changes to our Privacy Policy

We will occasionally update this Privacy Policy to reflect feedback. We encourage you to periodically review this Policy to be informed of how we are protecting your information.

Littlehampton, 01. 05. 2022.

FaceTill Ltd.

 

Appendix – Definitions

• ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
• ‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
• ‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;
• ‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;
• ‘filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis;
• ‘controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
• ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
• ‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
• ‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;
• ‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;
• ‘data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;
• ‘enterprise’ means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;
• group of undertakings’ means a controlling undertaking and its controlled undertakings;
• ‘supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article 51;
• ‘supervisory authority concerned’ means a supervisory authority which is concerned by the processing of personal data because:
• ‘relevant and reasoned objection’ means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the UK;