Privacy notice

Controller

The controller's contact details will be added here before the service opens to the public. Until then, the site is a demo.

What we collect

The site logs anonymous usage events: which page was viewed, which product was opened, what was searched for, which filters were used, which product was saved or added to a comparison, and which store link was clicked. Each event stores:

• the event type and a timestamp
• the page path, and the product, store, or category identifier when the event concerns one of them
• the search term, if the event is a search
• a campaign tag, if you arrived through a campaign link, and the traffic source, meaning the domain of the site you came from
• a session identifier: a random value created in your browser that disappears when you close the tab

From the product finder we log the skin type, the skin concern, the product types chosen, and the number of results, without a session identifier.

We do not store IP addresses. The server reads the address from the request to limit how many events one visitor can send, but the address never reaches the event log. We do not collect your name, your email address, or anything else that could identify you.

Visitor statistics

To count visitors we use Fathom Analytics, a statistics service from the Canadian company Fathom that does not use cookies. Your browser loads Fathom's script and sends Fathom a record of the page view: the page address and the site you came from. Like any web request, it also carries your IP address and your browser's user-agent string, from which Fathom works out your browser, device type, and country. According to Fathom, requests from the European Union are handled on its EU servers, where the IP address is deleted before the anonymized data is stored on Fathom's servers in the United States. We see only totals in Fathom, never individual visitors. The legal basis is the same legitimate interest as for our own usage events.

What is stored in your browser

There are no cookies. The site uses your browser's own storage for two things:

• Session storage (sessionStorage): the session identifier, the campaign tag, and the traffic source. The identifier is a random string that says nothing about you, and all three disappear when you close the tab. They are sent with usage events to our own server.
• Local storage (localStorage): the products you save and your comparison list. They stay on your device until you delete them. When you open your saved products or a comparison, your browser fetches their details from our server by product identifier. Saving and comparing are logged as usage events, but the list itself exists only in your browser.

When you click Buy, the first eight characters of the session identifier travel to the affiliate network in the tracking link, as described below. Apart from that, nothing in your browser's storage is shared with a third party or used for advertising.

Why

We collect usage events to improve the service: which searches find nothing, which guides are read to the end, whether the store links work. The legal basis is legitimate interest (GDPR Article 6(1)(f)): monitoring and improving how the service works. Because the data is not linked to a person and is not used for profiling or advertising, that interest does not override your privacy.

Going to a store

When you click Buy, you go to the store's site through an affiliate network's tracking link. From that point on, the store's and the network's own privacy policies apply to you, not this one. The link carries a reference to the network made of the page language, the campaign tag, the product identifier, and the first eight characters of the session identifier, so that we can tell where a click and any purchase came from. The network reports clicks and purchases to us by that reference; we never receive your name, contact details, or payment details. The affiliate disclosure explains this in more detail.

Retention and location

Events are kept for at most 24 months and then deleted. Our own event log is stored on servers in the EU. We use three processors: the platform that hosts the website, the database service, and Fathom Analytics (visitor statistics, see above). All three process data only on our behalf. Fathom's anonymized visitor statistics are stored in the United States, as described above.

Your rights

You have the right to know what has been stored about you, to ask for it to be corrected or deleted, and to object to its processing. You can also lodge a complaint with a data protection supervisory authority, in particular in the country where you live or work, or where you think the infringement took place (GDPR Article 77).

There is one limit we should be clear about: because the events contain nothing that identifies you, we usually cannot find “your” rows in the log. We will not create an identifier just to find them, because that would create exactly the kind of data we deliberately do not collect. Your saved products and comparisons are in your own browser's storage, so you can delete them yourself by clearing this site's data in your browser.

Changes

If we ever collect anything beyond what is described above, this page will be updated before the change takes effect, and the date at the top will show when.