Privacy notice

Every Face Counts is a research project run ahead of the launch of a new Irish beauty brand. It is for people in Ireland and the United Kingdom. This notice explains what we collect, why, where it goes and what your rights are. It is written to meet the EU General Data Protection Regulation (GDPR), the Irish Data Protection Act 2018, the UK GDPR and the UK Data Protection Act 2018.

Who is responsible. The data controller is Senne & Co. Ltd, a company registered in England and Wales, acting through its founder Mark Sweeney. Contact: hello@everyfacecounts.ie. When the Irish company behind the brand is set up, it will become the controller and this page will be updated.

What we collect. If you take the survey, we collect your answers, including your age band, where you live (country and county or city) and your skin tone range. We do not ask for your name, and adding your email at the end is optional. If you came through a community group, we ask which group, so we can make the donation. If you sign up to be kept posted, we collect your email address. We do not collect names unless you give one.

Why we collect it, and the legal basis. Survey answers: to understand what people want from their makeup and design the product around real answers. Our legal basis is legitimate interest, in running a research project for a new business, and we do not ask for your name. Email addresses and contact: to tell people who have asked about the project, the product and events. Our legal basis is your consent, given when you tick the box or sign up, and you can withdraw it at any time. Group donations: to pay the right amount to the right group. Our legal basis is legitimate interest.

Where it is kept and who can see it. Survey answers are stored in Tally. Email sign ups are stored in Squarespace. Both providers act as our processors under written data processing terms, and where they move data outside the EU or UK they rely on the EU Standard Contractual Clauses, the UK International Data Transfer Addendum or an adequacy decision, as applicable. Data moves between Ireland and the UK under the EU adequacy decision for the UK and the UK adequacy regulations for the EU. Only the small project team sees your data. We do not sell it and we do not share it with other companies.

How long we keep it. Survey answers for up to two years, or until the brand launches, whichever comes first. After that we keep only summary findings with nothing that identifies you. Email addresses until you ask us to remove them or until the project closes. Group donation records for six years, as required for accounts.

Your rights. Under GDPR and the UK GDPR you can ask to see the data we hold about you, to correct it, to have it deleted, to restrict or object to how we use it, to receive a copy in a usable format, and to withdraw consent at any time. Email hello@everyfacecounts.ie and we will reply within one month. You can also complain to a regulator: the Data Protection Commission in Ireland (dataprotection.ie) or the Information Commissioner's Office in the UK (ico.org.uk).

Age. You must be 18 or over to take part. We do not knowingly collect data from anyone under 18, and if we find we have, we delete it.

Cookies. This site uses only the cookies it needs to work, plus Squarespace analytics if you accept them in the banner. You can change your choice at any time using the cookie preferences link at the bottom of the page.

Group donations. For every completed survey from a member of a participating community group, we donate 10 euro to that group, up to 500 euro per group, paid by bank transfer in December 2026. This is a goodwill arrangement at our discretion.

Changes. If this notice changes we will update the date below and, where the change matters, tell people who have given us their email.

Last updated October 2026.