Privacy Notice

At Soul Paint (“Soul Paint”, “we”, “us”, “our”) we are committed to respecting your privacy and protecting the personal data that we obtain and hold about you and others.

This privacy and data notice (“Privacy Notice”) explains how we will process the personal data relating to you that you provide to us when you sign up to and access the Soul Paint experience, (the “Services”), any query or communication that you may send to us, or that we may collect from others about you when you use our Services. 

Where we decide the purpose and means for which personal data you supply through the use of our Services is processed, we are the “controller” for the purposes of the General Data Protection Regulation 2016/679 (“EU GDPR”), the GDPR as it forms part of the laws of England, Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR” and together with the EU GDPR, the “GDPR”)and the UK Data Protection Act 2018 (“UKDPA”).

Please read this Privacy Notice carefully as it contains important information about the following:

▪       What information we may collect about you;

▪       How we will use information we collect about you;

▪       Whether we will disclose your details to anyone else; and

▪       Your choices and rights regarding the personal data we hold about you.

Our Services may sometimes be operated by third parties. These third party services may have their own privacy notices and we recommend that you review them. They will govern the use of personal data that you submit whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Notice in the future, which will be made available at www.soulpaint.co. You should check here from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email or through the Soul Paint website.

Our legal name is Hatsumi Ltd and our registered office is Flat 6 19 Brunswick Place, Hove, England, BN3 1ND.

If you have any questions or comments about this Privacy Notice, please contact us at hello@soulpaint.co

Information We May Collect About You

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We may collect and process the following personal data from you (together referred to as “Your Information”) when you use the Services provided by us:

Information that may be provided by you when you use our Services (“Submitted Information”)

o  Your name;

o  Your email address;

o  Your demographic;

o Hardware device information.

Sensitive Information that may be provided by you when you use our Services (“Sensitive Information”)

We may collect and process special category data, such as biometric data, where necessary for provision of the Services. Our lawful basis for processing this data is for our legitimate business interests and the condition under Article 9 is that we only collect and process this data once you provide us with you explicit consent to do so. Where required, we maintain an appropriate policy document in accordance with the Data Protection Act 2018. We apply strict security measures to protect this data and retain it only for as long as necessary. You have rights over your data, including the right to withdraw consent and to complain to the Information Commissioner’s Office.

Information that may be provided by you when you contact us for support

o  Your name;

o  Your email address;

Your telephone number (if you choose to provide this).

Analytics Information

o  Your user interface usage (e.g. buttons clicked, screens viewed);

o  Hardware device information;

o  Your location.


Why We Collect Information About You

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To provide our Services

We may process Your Information and Sensitive Information so that we can properly provide our Services to you, as well as to improve the Services, in line with the legitimate interest we have in promoting our business and providing you with information about the services we offer.

Additionally, if consented to by you, Your Information may be shared with third parties for academic research purposes, in which appropriate safeguards including encryption and limited access to the data are put in place.

To respond to your enquiries and requests for support

We may process Your Information so that we are able to properly respond to your enquiries and support requests.

For the above purpose, we rely upon the legal basis of performance of a contract and our legitimate interests, being our commercial interests to respond to your queries and requests for support and to maintain good commercial practice in customer service.

To provide our website and information about our Services

We may process information about you (being Your Information or any part thereof) so that we can provide you with information (such as through email marketing communications) about the Soul Paint experience, in line with the legitimate interest we have in promoting our business and providing you with information about the Services we offer.

You are under no obligation to provide us with any details, but if you choose to not provide us with relevant information, we may not be able to respond and/or provide the assistance that you request.

To add you to our mailing list

We may process Your Information where you have subscribed to our mailing list.

In line with the legitimate interest we have in promoting our business, we will, with your permission, use the email address you give us to provide you with news and updates about our Services via email. If you would like to be removed from our mailing list, please let us know byclicking unsubscribe at the bottom of any marketing email that you receive from us.

Analytics

Our website uses mechanisms to collect and log analytical information to help compile statistical reports on website activity. This process is crucial to the running of our business.

We use the following third party analytics providers when conducting our analysis, which will contain a full list of details collected:

https://www.squarespace.com/privacy


Data Sharing

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We will share your information with third parties only in the ways that are described in this Privacy Policy

Academic research purposes: If consented to by you, we may share your information with our third party partners for the extraction and analysis of data for academic research purposes. However, this is on the basis that all data is encrypted to the highest standard.

Group members, personnel, suppliers or subcontractors: We keep your information confidential, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Notice. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition, transfer or sale of all or a portion of our assets, you will be notified (for example, via email, account message and/or a prominent notice on our website) of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Required by law: We may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement:We may also disclose your personal data to third parties (e.g. our licensors, website or app operators, stores or networks) in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect our rights, property or safety, or those of our customers or others.


Your Rights In Relation To Personal Data Which We Process Relating To You

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You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply with requests without undue delay and within one month at the latest.

To make a request, please let us know by email to hello@soulpaint.co.

Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected.

We will use reasonable efforts, to the extent required by law, to supply, correct or delete personal data held about you on our files (and with any third parties to whom it has been disclosed to).

Objecting to us processing data about you

You can ask us to restrict, stop processing or delete your personal data if:

  • you consented to our processing the personal data and have withdrawn that consent;

  • we no longer need to process that personal data for the reason it was collected;

  • we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest, you don’t agree with that processing and there is no overriding legitimate interest for us to continue processing it;

  • the personal data was unlawfully processed;

  • you need the personal data to be deleted in order to comply with legal obligations; and/or

the personal data is processed in relation to the offer of a service to a child.

Obtain a machine-readable copy of your personal data, which you can use with another service provider

  • If (i) we are processing data in order to perform our obligations to you or because you consented and (ii) that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.

If you request, we will supply you with the relevant personal data in CSV format.  Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

Make a complaint to a Supervisory Authority

  • If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.

If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority. Contact information for the Information Commissioner’s Office, the UK’s independent authority setup to uphold information rights, is available here:https://ico.org.uk/.


Data Retention

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In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person to whom it relates for longer than is necessary.


Children

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Soul Paint takes the protection of the personal data of children very seriously. In accordance with the nature of our Services, we may process a limited amount of personal data about your child regarding their use of our services. We do so only for the purposes set out in this Privacy Notice.

Your prior consent would be required in order for us to collect any other personal data from your child or in order to disclose, use or otherwise process your child’s personal data in a way not set out in this Privacy Notice. In the event that we learn that we have collected personal data from a child other than as intended in accordance with this Privacy Notice, we will delete that information as quickly as possible.


Security

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Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through use of our Services; any transmission is at your own risk.


International Data Transfers

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The data we collect from you may be transferred to, and stored at, a destination outside the UK and/or European Economic Area (“EEA”). It may also be processed by staff that operate outside the UK and/or EEA and work for us or our suppliers. These staff may be engaged in the fulfilment of your orders, the processing of your payment details, the maintenance of our website and our services, and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where your personal data is transferred outside of the UK and/or EEA to a territory not subject to an adequacy decision by the UK Government and/or European Commission, we have agreements in place with the relevant parties which include either (i) standard data protection clauses adopted by the relevant data protection regulator and approved by the UK Government and/or European Commission or (ii) standard data protection clauses adopted by the UK Government and/or European Commission, to ensure that appropriate safeguards are used to protect your personal data together with other appropriate safeguards to protect your personal data. If you require more information about these safeguards, you can contact us at hello@soulpaint.co.


Contact Information

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All questions, comments or enquiries should be directed to hello@soulpaint.co.  We will endeavour to respond to any query or questions within a reasonable amount of time.


Information For Californian Residents

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Notice at Collection Depending on your use of our Services, the following categories of personal information may have been collected and disclosed in the preceding 12 months, as these categories are defined under the California Consumer Privacy Act ("CCPA"):

 

  • Identifiers; such as a real name, user name, account name, email, online identifiers, device identifiers, IP address, or mobile device identifiers;

  • Account login data; we collect and process the credentials necessary for you to access your Account; for any third-party connected accounts, following your authorization, we collect an access token that allows us to receive information from that third-party specific to your account with them;    

  • Characteristics of Protected Classifications under state or federal law; such as age or gender;

  • Internet or Electronic Network Activity information; such as, browsing history, search history, and information regarding interactions with our websites, applications, and/or advertisements;

  • Approximate (coarse) geolocation data; such as location data derived from IP address or device settings;

  • Inferences; such as consumer preferences drawn from the above.

 

Collection, use, and disclosure of this information is made for one or more of the business or commercial purposes listed in section 3.

The following categories of personal information may be "sold" or "shared," as those terms are defined under the CCPA, for purposes of targeted advertising:

  • Identifiers; such as a real name, user name, account name, email, online identifiers, device identifiers, IP address, or mobile device identifiers;

  • Characteristics of Protected Classifications under state or federal law; such as age or gender;

  • Internet or Electronic Network Activity information; such as, browsing history, search history, and information regarding interactions with our websites and/or advertisements;

  • Approximate (coarse) geolocation data; such as location data derived from IP address or device settings;

  • Inferences; such as consumer preferences drawn from the above.

 

This information may have been sold or shared with our advertising partners for the purposes described in the respective paragraph in section 4.

We do not "sell" or "share," as those terms are defined under the CCPA, personal information of consumers under 16 years of age. We also only use or disclose “sensitive personal information,” as defined under the CCPA, for the purposes specified in Section 7027(m) of the California Consumer Privacy Act Regulations. We retain the information we collect for as long as necessary to provide our Services, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons.

Supplemental California Privacy Notice Please see below for more details about how we process your personal information, incorporating the notice immediately above.

For each of the categories of personal information referenced above:

  • The categories of sources from which the personal information may have been collected are listed in section 2.

  • The categories of third-party recipients to which the personal information may be disclosed are listed in section 4.

 

Your Rights

Please see section 5 which we process relating to you for a summary of your California privacy rights and how to exercise them. This includes the right to opt-out of the sale or sharing of your personal information for cross-context behavioral advertising purposes (also known as targeted advertising).

© 2026 Hatsumi Ltd. All trade marks are the property of the relevant owners. All rights reserved.

Contact Information: hello@soulpaint.co