Who is responsible
Daniel Harvey, trading as Brand Face, is the data controller responsible for the personal information described in this policy.
Daniel Harvey, trading as Brand Face
Chausseestraße 37, Mitte
10115 Berlin
Germany
Business email: [email protected].
Support and privacy requests: [email protected].
This policy covers brand-face.com and the UGC Starter Kit.
Text messages
We send text messages to people who have given us their mobile number and ticked the consent box in the chat widget on our website. We keep a timestamped record of every opt-in.
What we send. Marketing messages about offers, discounts and course updates. We also reply to you if you message us.
Opting out. Reply STOP to any message to cancel. We will send one confirmation and then stop. You can opt back in at any time by giving consent again in the chat widget.
Help. Reply HELP for assistance, or email [email protected].
Frequency and cost. Message frequency varies. Message and data rates may apply. Carriers are not liable for delayed or undelivered messages. Our programme works with all major US carriers, including AT&T, T-Mobile and Verizon.
Age. You must be 18 or older to receive our text messages.
Consent to receive text messages is never a condition of purchase.
Information we handle
When you register or order, we collect your name, email address and phone number. If you give consent in the chat widget on our website, we also record that consent and the time you gave it. Purchases also create order and billing records, with payment collected by our payment processor. Support messages, course participation and anything you choose to share in the community are handled too, and website visits may produce device, connection and cookie-preference information.
Information you post in community areas may be visible to other members. Avoid sharing information you want to keep private.
Why we use it
We use information to provide course access, administer orders, answer questions and operate the community. We also use relevant records to meet legal obligations, protect the service and handle complaints.
Where the law requires a legal basis, we rely on performing our contract with you, our legitimate interests in running and promoting the service, consent where we ask for it, and compliance with legal obligations. If you do not provide the details needed to create your account or process an order, we may not be able to provide the service.
Who receives information
No mobile information will be shared with third parties for marketing or promotional purposes. Information sharing with subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
We use providers for website hosting, payment processing, customer records, email delivery and course/community hosting. Each receives information relevant to its role.
Where a sales team helps run enrolment calls for Brand Face, they receive the contact details and call outcomes needed for that work.
We advertise on Meta platforms such as Facebook and Instagram. Where tracking technologies are used for advertising or measurement, we ask for your consent where the law requires it.
We may disclose relevant information where the law requires it.
Emails and calls
Service messages cover matters such as access, orders and support. Marketing messages and sales calls are handled according to the applicable permission and contact rules, and if a call is recorded, we will tell you.
You can opt out of text messages at any time by replying STOP. You can object to direct marketing at any time. Use the unsubscribe link in marketing emails or contact [email protected] to update your preferences. Where we rely on consent, you can withdraw it without affecting the lawfulness of earlier processing.
Cookies and similar technologies
We use cookies and similar technologies to run the website, remember your preferences and, with your consent where required, to measure our marketing and show relevant advertising. You can control cookies through your browser settings and any preference control we provide.
Retention and international transfers
We keep member and access records while your access continues, financial records for as long as tax and accounting law requires, and other records only as long as they are needed for the purpose we collected them.
We may need to retain some information for legal obligations or to honour a request not to contact you.
Some of our providers, including our customer-records, payment and community platforms, are based in or store information in the United States. Where information leaves your country, we rely on the safeguards recognised by applicable law, such as approved contractual clauses. Contact us for more information about them.
Security
We limit access to personal information to the people who need it to run the service, use established providers, and protect information with encryption in transit. No online service can promise perfect security, but we take reasonable steps to protect your information.
Your rights
Depending on the law that applies, you may request access, correction, deletion, restriction or a portable copy of your information, and object to certain uses.
Contact [email protected] to make a request. We may need information to verify your identity. You can also complain to the relevant data protection authority.
Eligibility and updates
The UGC Starter Kit is intended for adults aged 18 or over. The service is not directed at children, and we do not knowingly collect their information. We do not make solely automated decisions about you that have legal or similarly significant effects.
We will update this policy when our practices change, show the revision date and provide further notice where required.