Privacy policy

Last updated: April 2025

Introduction

eyekandy Limited (“Company”, “we,” “our,” or “us”), a company registered in England with registered address; 4 Emmanuel Court, Reddicroft, Sutton Coldfield, West Midlands, BE3 CAZ, United Kingdom, believes in protecting the personal data it collects from individuals (“users”) that access or use this website (the “website”) or third party websites that utilise eyekandy tools and “services” (including but not limited to the eyekandy WebAR Player, the eyekandy 3D Player and the eyekandy Sales Ambassador) and takes seriously its obligation to comply with its obligations under applicable data privacy laws including, without limitation, the UK General Data Protection Regulation (“UK GDPR”). The Company is a controller as defined in the UK GDPR as it pertains to usage of www.eyekandy.com and processor or sub-processor as it pertains to delivery of the eyekandy services on third party websites (for example brand websites or retailer websites).

This notice (“notice”) sets out how the Company uses, discloses, transfers and otherwise processes users’ personal data collected by communicating with eyekandy electronically (e.g. email), through their use of the eyekandy website or a third party website and how we use cookies in the operation of the website and services.

Personal data we process and how we collect your data

For purposes of this policy, “personal data” means any information relating to you or that can enable us to identify you. Whilst using our services, accessing our website or a third party website, we may process the following types of personal data:

Name
Email Address
Telephone Number
Company / Organisation that you are contacting eyekandy from
Your product preferences and requirements
IP Address if interacting with eyekandy services on a third party website
User content data such as audio and video samples you provide when interacting with our AI Personal Shopper and Sales Ambassador services

For clarity, the specific personal data we process in the act of delivering eyekandy services to third party websites are as follows;

3DHi, AR, Virtual Experience and “Badge” Services

IP Address

AI-Personal Shopper and Sales Ambassador Services

IP Address
User content data such as audio and video samples you provide when interacting with our services
We do not process sensitive personal data and so please ensure you do not volunteer any such information (e.g. information relating to your health) at any time you interact with us or our products. If you do volunteer sensitive personal data when interacting with our AI Personal Shopper or Sales Ambassador, our policy is addressed in the Transparency Statements associated with that individual service
The eyekandy services are not intended for use by anyone under 18 years of age. If you are a parent of guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us and if necessary, we will comply with all applicable legal requirements and make best endeavours to delete the information
We use OpenAI’s language processing services as part of delivering these services. For more details, see https://openai.com/en-GB/policies/row-privacy-policy/

We collect your personal data using both “active” and “passive” means.

Active means:

We will process any personal data you upload / volunteer when you engage with a third party website via a Personal Shopper tool powered by us.
The eyekandy website actively collects personal data from users by asking specific questions and permitting users to communicate directly with us, for example via e-mail or feedback forms. Some areas of the website may also require a user to submit information, including personal data, to register for certain services or benefits, such as syndication services

Passive means:

We passively collect (i.e., without the user actively providing the information) personal data about a user as the user accesses and navigates through the website using various technologies and means, such as navigational data collection and cookies. Our cookie policy is outlined below.
We may also collect your personal data from publicly available sources and from organisations such as analytics providers (e.g. Google)

We process your personal data on several different legal bases, as follows:

Our legitimate interests – if you are visiting our website or contacting us electronically, you are most likely an employee or representative of a partner, client or customer of our international brand and retail services business. If you are visiting a third party website, you are most likely a customer or potential customer of that third party.

Examples of the way in which we process your personal data as necessary for our legitimate interests include:

To facilitate commercial interactions between our company and your employer;
For the security and safety of the website, our technology connected to the website and the users of the website;
To detect and prevent fraud;
To protect and defend the rights or property of others, or our own rights and interests;
To manage and administer the website, including troubleshooting, testing, maintenance and support, analysing web traffic and utilizing web analytics solutions;
To administer our business in the context of a business reorganisation or restructuring exercise;
To monitor communications and interactions via our website and third party website tools for self regulatory practices and to protect the security of our communications systems and procedures, to check for obscene or profane content and quality control and training purposes;
For use in marketing our products and services to your employer or affiliated entities and to understand and measure the effectiveness of any marketing we undertake;
For the improvement and optimisation of our products and services and
To provide content to the third party’s website to enhance your shopping experience.
Our legal obligations – we may need to process your personal data to comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders and legal process
Your prior consent – Where we are required to do so by applicable data protection law, for placing cookies on your device (subject to certain exceptions) or sending marketing communications to you. As required by law, we provide you certain details on our use of cookies and marketing communications below

We are not responsible for any privacy statement displayed by a third party, nor do we control the way your data is processed by a third party when you visit a third party website. Therefore, when engaging with eyekandy services or products via a third party website, we encourage you to read that third party’s privacy policy.

Cookies and web analytics used on this website and eyekandy-hosted landing pages

The eyekandy website and eyekandy-hosted landing pages make use of cookies. Cookies are small text files downloaded by your internet browser and stored on the device you use to access the website (e.g., your desktop computer, laptop, tablet or smartphone). Depending on their purpose, cookies log specific user-related information such as your user preferences, authentication information, security parameters, data concerning the devices you use to access the website, and statistical information regarding your use of the website. Where necessary during your visit to the website or when revisiting the website, your internet browser transmits the cookies including the contained information back to the servers they were initially downloaded from. The analysis and processing of such information allows us to ensure the functionality of the website and landing pages, improve your online experience, and optimize the structure and content of the service.

The cookies we use can be categorized as follows:

Strictly Necessary Cookies – These are cookies that are required for the operation of the website or of certain parts thereof. They either serve the sole purpose of carrying out network transmissions or are strictly necessary in order for us to provide an online service explicitly requested by you.

Analytical/Performance Cookies – These cookies allow us to carry out web analytics or other forms of audience measuring such as recognizing and counting the number of visitors and seeing how visitors move around the website. This helps us to improve the way the website works, for example, by ensuring that users can easily find what they are looking for.

Functionality Cookies – These cookies are used to recognize you when you return to the website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). Loss of the information in these cookies may make our services less functional but would not prevent the website from working.

Targeting/Profiling Cookies – These cookies record your visit to the website and/or your use of the services, the pages you have visited and the links you have followed. We will use this information to make the website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that on partner websites (brands and retailers that use the eyekandy service platform) eyekandy utilises the “storage” areas of your web browser to store the following pieces of information:

Cookie Name/Location	Who Places the Cookie	Cookie Category	Expiry	Purpose
__EK__WOTW__USER__ID__ localStorage	eyekandy	Analytical / Performance	Persistent for 1 year	Monitors the current user’s ID. A randomly generated v4 UUID value
__EK__WOTW__SESSION__ID__ sessionStorage	eyekandy	Analytical / Performance	Persistent for the current session	Monitors the current user’s session ID. A randomly generated v4 UUID value
eky-ab-v2 cookies	eyekandy	Analytical / Performance	Persistent for 1 year	Stores information on the user’s group for AB testing (where applied)
eky-ai-shopper-state localStorage	eyekandy	Strictly Necessary Cookies	Persistent for 1 hour	Maintaining the session state and conversation history

The following cookies are used on some pages of the eyekandy website:

The following web analytics are used on third party websites:

You may influence the scope and extent to which we use cookies when you visit a website. In particular, you may prevent cookies from being stored on your device by adjusting the respective settings on your internet browser. However, please be aware that this might render certain functions of the website inoperable or more difficult to use. Depending on the internet browser you use, you might also be able to specifically reject cookies.

Marketing Communications

You may be receiving electronic communications as a result of being on our B2B marketing database. To provide newsletters or similar, we log and store your name, title, email address and company name. You can unsubscribe from these newsletters at any time by clicking the ‘unsubscribe from this list’ link at the bottom of the email or by sending an email to dpo@eyekandy.com.

We do not send marketing communications to consumers.

Recipients of your personal data

For the following purposes, we may disclose your personal data to the third party service providers and suppliers listed in the table below.

We may also share your personal data with third party retailers where we are providing a personal shopper assistant on the retailer website. All data sharing is completed as required or permitted by applicable law.

Personal Data Potentially Disclosed to 3rd party suppliers and service providers listed below;	Purposes Underlying the Potential Disclosure	Sub Processor Privacy Statement
AWS	To manage B2B documents such as contracts, project plans	https://aws.amazon.com/privacy
ChatGPT	To provide AI shopping experiences	https://openai.com/en-GB/policies/row-privacy-policy/
GSuite	To communicate with users of the eyekandy website contact form	https://policies.google.com/privacy
GCP	To manage product and service related cases	https://cloud.google.com/terms/cloud-privacy-notice
Tavus	Facilitating visual interaction	https://www.tavus.io/privacy-policy
SiSense	To provide eyekandy customers access to operational syndication and reporting systems	https://www.sisense.com/about/legal/privacy-and-data-protection-center/
Vimeo	Facilitating video streaming	https://vimeo.com/privacy
Intercom	Facilitates web chat from our website	https://www.intercom.com/legal/privacy
Calendly	Enables meeting co-ordination	https://calendly.com/legal/privacy-notice
Cartesia	Facilitating Text to Speech Services for eyekandy platform	https://cartesia.ai/legal/privacy.html

Where necessary, additional recipients of your personal data could include legal and professional advisors, law enforcement bodies, government bodies and/or regulators.

Data transfers to recipients outside of the UK

We may transfer your data to affiliated companies or third party service providers located outside the UK. If so, we will ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data; or
We will comply, and require the compliance of our third party providers, with one of the approved transfer mechanisms, such as the International Data Transfer Agreement or the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers
You can ask for a copy of such appropriate safeguards by contacting the eyekandy Data Protection Officer at dpo@eyekandy.com.

How long we keep your personal data

We have implemented appropriate retention periods for your personal data collected or otherwise processed on or through the website as set forth in our data retention policy. Where our processing of your personal data is based on legitimate interests or compliance with legal obligations, it will be deleted as soon as the underlying purpose has expired. We may retain your personal information for longer periods if it is subject to legal requirements such as government reporting or fraud prevention which we are required to observe. Personal data processed based on your consent, which is intended to be processed for the duration of your association or relationship with the company will be deleted in accordance with the above principles, or earlier if and when you withdraw your consent to continued processing.

Your rights regarding the processing of your personal data under the UK GDPR

You have the following rights under UK GDPR:

inquire whether and what kind of personal data we hold about you and how it is processed, and to access or request copies of such personal data;
request the correction or supplementation of personal data about you that is inaccurate, incomplete or out-of-date in light of the purposes underlying the processing; or to
request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

In addition, you have, subject to the conditions set out in the applicable law and without limitation, the rights to:

request us to restrict the processing of personal data in certain situations;
object, in certain circumstances, to the processing of personal data where we are relying on a legitimate interest, and to
request portability of personal data that you have actively or passively provided to us (which does not include data derived or inferred from the collected data), where the processing of such personal data is based on consent or a contract with you and is carried out by automated means.

If you wish to exercise any of the rights indicated above, please contact us via email at DPO@eyekandy.com.

There is no fee to access your personal data or to exercise any other right listed above, however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Your provision of personal data to us

Your use of the eyekandy website, third party websites that use eyekandy services and electronic communication methods and your provision of personal data to us in the process is purely voluntary on your part. Subject to your sole discretion, you can, at any point, stop using the website or, where applicable, opt out of certain data processing operations while on the website or in electronic communications as described in this policy. An exception applies if and to the extent that you want to enter into or perform a contract with us through electronic communications. In this event, providing us with your related personal data is necessary for us to be able to enter into the contract with, or provide any contractual services to you.

How we protect your personal data

We are committed to ensuring the security of your personal data. We take appropriate commercially reasonable technical, physical and organizational measures to prevent unauthorized or unlawful processing of your personal data or accidental loss or destruction of your personal data.

Changes to this notice

eyekandy reserves the right in its sole discretion to amend this policy from time to time. In this event, we will post the revised policy on the website. We encourage you to periodically view this policy so that you remain informed as to how we are protecting users’ personal data and about what cookies are used on the website. We may, where necessary, notify users of any modified version of this policy that might materially affect the way we use, disclose or otherwise process users’ personal data or otherwise affect their privacy rights. We may do this by posting an update on the website which users will see at their next visit.

Special notice pertaining to the AMD “AI Personal Shopper” UK Pilot 2025

Eyekandy is a processor as it pertains to delivery of the eyekandy service on third party websites (for example brand websites or retailer websites)
We will process IP Address when interacting with eyekandy services on a third party website (this includes when you make use of eyekandy’s AI driven Personal Shopper assistant or other interactions on third party websites). We do not process sensitive personal data, so please ensure you do not volunteer any such information (such as but not limited to e.g. information relating to your health, racial or ethnic origins, sexual orientation, political opinions, religious beliefs, trade union membership etc.) at any time you interact with us or our products
We will restrict cookies to “analytical\performance” for the purpose of the AMD pilot
We will not engage in any marketing communications with service users
We will engage the below 3rd party service providers in providing the service for the AMD pilot;

AWS (https://aws.amazon.com/)	To manage B2B documents such as contracts, project plans
OpenAI\ChatGPT	To provide AI shopping experiences
Google Analytics	Monitoring of the service delivery for subsequent pilot analysis

With the exception of Google Analytics, we do not transfer your PII to affiliated companies or to third party service providers located outside the UK (this includes your IP address) however if a data subject voluntarily enters PII into the tool, it could potentially be processed outside the UK by our partner OpenAI. This eventuality is addressed in our Transparency Policy

Contact us or our Data Protection Officer

If you have any questions, concerns or complaints with respect to this privacy policy or the way we handle your privacy, please contact our Data Protection Officer:

eyekandy Ltd, 4 Emmanuel Court, Reddicroft, Sutton Coldfield, West Midlands, BE3 CAZ, UK

eyekandy Data Protection Office

+44 (0) 203 757 0730

Whilst we would appreciate the chance to respond to any concerns you may have as to our processing of your personal data, you also have the right to complain to the UK regulator for data protection issues, the ICO, the contact details are:

The Information Commissioner’s Office Water Lane, Wycliffe House Wilmslow – Cheshire SK9 5AF Tel. +44 1625 545 745 e-mail: international.team@ico.org.uk Website: https://ico.org.uk