Privacy Notice
The privacy and security of your personal information is extremely important to us. This privacy notice explains how and why we use your personal data, to make sure you stay informed and to ensure you're confident about giving us your information.
We'll keep this page updated to show you all the things we do with your personal data. This notice only applies if you interact with The Inkey List in any way (customer or employee) visit our website - desktop or mobile, email, call or write to us. In certain circumstances we may also provide an extra privacy notice, which will always refer to this page.
To be clear, we'll never sell your personal data and will only share it with organisations we work with when it's necessary and the privacy and security of your data is assured.nbsp;
Who are 'we'?
In this notice, whenever you see the words 'we', 'us', 'our', 'inkey', 'inkey list' all refers to The Inkey List. The Inkey List is a brand owned by Brand Evangelists for Beauty.
Brand Evangelists For Beauty (Reg. Co. number 10787576) is a beauty brand and a beauty product development house. We carry out commercial trading activities via our website www.beforbeauty.co.uk where we promote and sell our current brands and products and share details of our new and upcoming brands.
If you have any questions in relation to this privacy notice or how we use your personal data they should be sent to dpo@beforbeauty.co.uk or addressed to the Data Protection Officer, 6th Floor, The Hub, 40 Friar Lane, Nottingham, NG1 6DQ, United Kingdom.
What personal data do we collect?
Your personal data (any information which identifies you, or which can be identified as relating to you personally for example, name, address, phone number, email address) will be collected and used by us.
We'll only collect the personal data that we need.
We collect personal data in connection with specific activities such as placing an order, conducting research, employment etc.
You can give us your personal data by filling in forms on our website, making a purchase via our website, participating in discussion boards, subscribing to take part in research on our website or other social media functions on our website, entering a competition, promotion or survey or by corresponding with us (by phone, email) or in the future by creating a The Inkey List account.
This personal data may include name, title, address, date of birth, age, gender, employment status, email address, telephone numbers, personal description, photographs, usernames and passwords.
Personal data provided by you
This includes information you give when interacting with us; when your placing an order or communicating with us. For example:
- Personal details (name, date of birth, email, address, telephone, etc)
- Financial information (payment information such as credit, debit card or PayPal details)
Information from third parties
We may in the future, buy anonymous external data (e.g. census data, Experian MOSAIC, etc) and combine it with your personal data at an aggregated level to build profiles which may help us work out what you're most likely to want to hear from us about and how.
Our website may use a pixel operated by Teads, after obtaining your consent, in order to optimize our advertising campaigns. This pixel only collects information regarding the URL address, the types of device, browser and operating system information you currently use. For more information, feel free to read Teads privacy policy.
Please also note that you have the right to access personal data Teads hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that Teads restrict, certain processing, by addressing your request at dpo@teads.com.
How we use your personal data
We'll only use your personal data on relevant lawful grounds as permitted by the EU General Data Protection Regulation (from 25 May 2018)/UK Data Protection Act and Privacy of Electronic Communication Regulation.
Personal data provided to us will be used for the purpose or purposes outlined in any fair processing notice in a transparent manner at the time of collection or registration where appropriate, in accordance with any preferences you express. If asked by the police, or any other regulatory or government authority investigating suspected illegal activities, we may need to provide your personal data.
Your personal data may be collected and used to help us complete your order or request. Below are the main uses of your data:
Marketing communications
Your privacy is important to us, so we'll always keep your details secure. We'd like to use your details to keep in touch about things that you may be interested in, but we will not do this without your specific consent.
If you choose to hear from us we may send you information based on what is most relevant to you or things you've told us you like. We may also show you relevant content online. This might be about products or competitions we think you might want to hear about.
We'll only send these to you if you agree to receive them and we will never share your information with companies outside The Inkey List for inclusion in marketing. (We may however share cookie data with third parties to help with our own advertising targeting). If you agree to receive marketing information from us, you can change your mind at a later date.
Personal data provided to us may also be profiled to help us with advertising targeting. Or we may use your personal data to find online users with a similar profile to yourself who may be interested in our products or services.
We may sometimes use third parties to capture some of our data on our behalf, but only where we are confident that the third party will treat your data securely, in accordance with our terms and in-line with the requirements set out in the GDPR.
The www.uk.theinkeylist.com uses cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS.” “The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third partiesHow you can change your contact preferences.
We'd love to keep in touch, but we understand that you might change your mind in the future. If you want to stop hearing from us we ensure it's as east to opt out as opt in. All of our email marketing contains an unsubscribe link which will remove you from our email list immediately. Alternatively you can email us directly at hey@beforbeauty.co.uk and we'll ensure that you are removed from all mailing lists.
You may opt-out of the SMS Service at any time. Text the single keyword command STOP to +1 (855) 462-0309 or click the unsubscribe link (where available) in any text message to cancel. You'll receive a one-time opt-out confirmation text message.
Please note that you will still continue to receive contact from us when required to provide relevant information in relation to services provided by us to you, for example order confirmation, order and delivery updates or feedback on our services.
We'll always act upon your choice of how you want to receive communications (for example, by email, post or phone).
Please note that you will still receive information from us
Recipients of data (third-party processing)
We may at times, pass your personal data on to third-party service providers contracted to us in the course of dealing with you. These may include for example but not limited to, couriers, fulfilment houses, credit card processing companies or other services required in the fulfilment of your order. In addition, this may also include marketing and advertising services.
Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the legal purpose of our business. When they no longer need your data to fulfil this service, they will dispose of the details securely. We only use sub-contracted processors who have demonstrated sufficient guarantees of compliance.
If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent unless we are legally required to do otherwise.
Retention period
We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. We are required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices.
We will generally process personal data for a period of six years. After this period, the data will be anonymised and used for reference purposes only.
Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
The right to be informed
- We will inform you of what personal information we collect and how this is used. This privacy notice is how we inform you of this information.
- We will inform you of any changes to the way we process your data.
The right of access
- You have the right to request a copy of the information that we hold about you.
The right of rectification
- You have a right to correct data that we hold about you that is inaccurate or incomplete.
The right to erasure
- In certain circumstances you can ask for the data we hold about you to be erased from our records.
The right to restrict processing
- Where certain conditions apply to have a right to restrict the processing.
The right to data portability
- You have the right to have the data we hold about you transferred to another organisation.
The right to object
- You have the right to object to certain types of processing such as direct marketing.
Rights in relation to automated decision making and profiling
- You also have the right not to be subject to automated processing or profiling.
Profiling
We know it's important to our customers that we use our resources appropriately. So, we use automated profiling and targeting to help us understand our customers and make sure that:
- our communications (e.g. emails) and services (e.g. our website) are relevant, personalised and interesting to you
- our services meet the needs of our customers
- we use our resources responsibly and keep our costs down
We use specific tools to profile how you interact with us online, for example, Adobe Analytics, Google Analytics and Shopify CMS. Much of the information we collect is aggregated, however we may also collect some personal data for the use of personalising your experience, optimising our marketing campaigns, and to ensure the site is functioning as intended.
The personal information that is collected includes transactional information (i.e. order number) We will also collect data on individual user activity when they create or log into a The Inkey List account. This information takes the form of an encrypted string. If you've agreed that we can contact you for marketing purposes, we may also gather additional information about you from external sources, for example: updates to address and contact information, or publicly available information regarding your wealth, earnings and employment at an aggregate level. This analysis may be carried out by us or by third party organisations working for us. We may also host encrypted personal data on third party websites (e.g. social media platforms) to ensure that you only see relevant, personalised and interesting content from those organisations.
Opting Out of Interest Based Advertising
Please click the following link to opt out of Interest based advertising - http://optout.networkadvertising.org
Recruitment and employment
In order to comply with our contractual, statutory, and management obligations and responsibilities, we process personal data, including Special Category Personal data, from job applicants and employees.
Such data can include, but isn't limited to, information relating to health, racial or ethnic origin, and criminal convictions. In certain circumstances, we may process personal data or sensitive personal data, without explicit consent. Further information on what data is collected and why it's processed is given below.
Contractual responsibilities: Our contractual responsibilities include those arising from the contract of employment. The data processed to meet contractual responsibilities includes, but is not limited to, data relating to: payroll, bank account, postal address, sick pay; leave, maternity pay, pension and emergency contacts.
Statutory responsibilities: Our statutory responsibilities are those imposed through law on the organisation as an employer. The data processed to meet statutory responsibilities includes, but is not limited to, data relating to: tax, national insurance, statutory sick pay, statutory maternity pay, family leave, work permits, equal opportunities monitoring.
Management responsibilities: Our management responsibilities are those necessary for the organisational functioning of the organisation. The data processed to meet management responsibilities includes, but is not limited to, data relating to: recruitment and employment, training and development, absence, disciplinary matters, e-mail address and telephone number.
Special Category personal data
The Act defines Special Category personal data as information about racial or ethnic origin, political opinions, religious beliefs or other similar beliefs, trade union membership, physical or mental health, sexual life, and criminal allegations, proceedings or convictions.
In certain limited circumstances, we may legally collect and process sensitive personal data without requiring the explicit consent of an employee.
(a) We will process data about an employee's health where it is necessary, for example, to record absence from work due to sickness, to pay statutory sick pay, to make appropriate referrals to the Occupational Health Service, and to make any necessary arrangements or adjustments to the workplace in the case of disability. This processing will not normally happen without the employee's knowledge and, where necessary, consent.
(b) We will process data about, but not limited to, an employee's racial and ethnic origin, their sexual orientation or their religious beliefs only where they have volunteered such data and only for the purpose of monitoring and upholding our equal opportunities policies and related provisions.
(c) Data about an employee's criminal convictions will be held as necessary.
Disclosure of personal data to other bodies
In order to carry out our contractual and management responsibilities, we may, from time to time, need to share an employee's personal data with one or more third party supplier.
To meet the employment contract, we are required to transfer an employee's personal data to third parties, for example, to pension providers and HM Revenue & Customs.
In order to fulfil our statutory responsibilities, we're required to give some of an employee's personal data to government departments or agencies e.g. provision of salary and tax data to HM Revenue & Customs.
Updating your data and marketing preferences
We want you to remain in control of your personal data. If, at any time, you want to update or amend your personal data or marketing preferences please contact us via hey@beforbeauty.co.uk
You may opt-out of the SMS Service at any time. Text the single keyword command STOP to INKEY List or click the unsubscribe link (where available) in any text message to cancel. You'll receive a one-time opt-out confirmation text message.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by us, you have the right to lodge a complaint directly with our data protection representative: dpo@beforbeauty.co.uk
In the event you wish to make a compliant on how your initial complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority. The contact details are:
Information Commissioner's Office
Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
UK Calls - 0303 123 1113
Outside UK - +44 1625 545 700
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
