Fair Processing Notice for Users of the HoMedics Beauty App

Scope
All data subjects whose data is processed by FKA Brands Ltd

Responsibilities
All employees/staff of FKA Brands Ltd who interact with data subjects are responsible for ensuring that they draw this notice to the data subject’s attention and that, where relevant, they obtain the consent of the data subject to the processing of his/her data.

Fair Processing Notice
HoMedics is part of FKA Brands Ltd, Somerhill Business Park, Five Oak Green Rd, Tonbridge TN11 0GP. By creating a user account on this HoMedics Beauty app you have to enter some personal details. Our legal basis for the processing of your data is your consent. We will use the personal data that we collect from you for the following purposes:

User Name & Profile Picture
The user name and profile picture define how you wish to identify yourself on this app. You can use your real name, a nickname or any character name as you please. You can choose any photo or you can opt to have no photo personalisation.

Email address
We need your email address to uniquely identify your user account. If you change mobile device you will be able to access your user account using your email address. We require separately your consent to use your email address for marketing purposes. If you give us consent to send electronic marketing materials, you may unsubscribe at any time and your name will be withdrawn from our marketing list.

Date of Birth & Skin concerns
These are stored as a basis to help personalise your skin care plan within the app.

Your rights
Your rights according to the General Data Protection Regulation are as follows:
The right to be informed
The right to access
The right to rectification
The right to erasure (except where we are prohibited from doing so by law)
The right to restrict processing
The right to data portability
The right to object Rights in relation to automated decision making & profiling

Your rights under the GDPR will be fully supported by FKA Brands Ltd whilst complying with all legal obligations. Information about those rights can be found at www.ico.org.uk as well as a number of online resources. Specifically, your data is not subjected to any automated decision making.
If you have any concerns about the accuracy or use of the data you should in the first instance contact Customer Service to discuss and address your concerns. Contact details are on the website and order paperwork you might have received from us. If unsatisfied you are entitled to complain to the Information Commissioner’s Office via www.ico.org.uk.

Data Transfers Outside of the UK / EU
Your data may be held on servers which are physically located in the US. Your privacy is maintained by safeguards provided by the Privacy Shield agreement between the UK/EU and US Administrators.

FKA Brands Ltd processes personal data

What is Personal Data?
Personal Data is defined as ‘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”

Why does FKA Brands Ltd need to collect and store personal data?
In order for us to provide you with a beauty regime matched to your skin type and an excellent user experience, we need to collect some personal data. Where you specifically agree we will use it for correspondence purposes. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose and does not constitute an invasion of your privacy. A partner organisation is used to manage this app for us. Our contractors are obliged to keep your details securely, and use them only to fulfil the service they provide on our behalf. Once your service need has been satisfied, or you no longer wish to maintain your user account we will dispose of the details in line with FKA Brands Ltd.’s procedures.

How FKA Brands Ltd uses your information
FKA Brands Ltd will process - that means collect, store and use - the information you provide in a manner that is compatible with the EU’s General Data Protection Regulation (GDPR). We will hold your information securely and not keep it longer than is necessary. We don’t use this account data for automated profiling. Our aim is not to be intrusive and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Using your personal data
We will use the information you provide for the following purposes: To provide you with a beauty regime matched to your skin type. User access to the HoMedics Beauty app and for marketing if you have opted into our marketing list.

Contacting us
If you have any questions about privacy or data storage, please write to us at dpo@fkabrands.com