We are committed to protecting your privacy and any personal information you share with us. As part of this effort, we process personal information in accordance with the EU’s General Data Protection Regulation (GDPR) and other data protection regulations applicable to us. Accordingly, we have developed this privacy policy in order for you to understand how we collect, use, communicate, disclose and otherwise make use of personal information. We have outlined our privacy policy below. It is recommended that you read this privacy policy carefully. If you have additional questions or would like further information on this topic, please feel free to contact us at

1. Who are we and how can you contact us?

The party responsible for the processing of your personal data is Shoppar LTD, a private company established in 2016 and existing under the laws of the United Kingdom, having its registered office in Shenfield.

Shoppar LTD
43 Shenfield Road, Shenfield, Essex, CM15 8EN, UK

If you have any questions or wishes in connection with your personal data, you may also contact our Data Protection

officer: Kris Milne +44 (0)203 966 0012
2. How do we use your personal data?

We use multiple sensors to gain an understanding of any audience within a physical space. Through the camera we gather real-time insights into the reactions and behaviour of our shopping audience in real-time, by estimating the following features:

Facial expressions / emotion recognition Head position / head gaze
Facial landmarks
Attention span

The thermal component enables the tracking of audience count and audience location. The mmWave radar allows us to understand details such as gestures and posture.

Plexal, 14 East Bay Lane,
The Press Centre, Here East, Queen Elizabeth Olympic Park, Stratford, London, E20 3BS, UK

43 Shenfield Road, registered with the Companies House. Telephone number: +44 (0)203 966 0012

The analysis also includes information about your shopping experiences. Based on the estimated features above, we capture facial expressions, such as happiness, surprise and fear.

All data collected is stored and used anonymously for statistical and analytical purposes and/or to display optimized advertising based on the collected anonymous features. No images are recorded or stored, therefore no uniquely identifiable data can be extracted. Images from the camera sensors undergo real-time conversion into data within a few tenths of a second, without any storage of your facial images.

The processing of your personal data for this short period of time is necessary for the purposes of the legitimate interests pursued by us, namely to create anonymous statistical and analytical data get insight in our shopping audience and/or optimized advertising.

3. How long do we retain your personal data?

We shall retain personally identifiable information only as long as reasonably necessary to translate them into anonymous statistical and analytical data. As mentioned above, no images are recorded or stored, therefore no uniquely identifiable data can be extracted. Images from the camera sensors undergo real-time conversion into statistical data within a few tenths of a second. The image is then discarded immediately without any storage of your facial images.

4. Do we share your personal data with third parties?

The technology described above is provided to us by Shoppar LTD. Shoppar LTD processes your personal data on our behalf. The processing by Shoppar is governed by a so called data processing agreement in which we have ensured that that Shoppar shall only process the personal data on our instructions.

5. What are your rights?

Under the GDPR, you have a number of rights with regard to your personal data and the processing thereof. Since the data processed by us, is stored and used anonymously and no images are recorded or stored, we will not be able to identify you should you invoke your rights under the GDPR. Because of that, we are not able to the rights below do not apply to us (article 11 GDPR):

you have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and additional information about the processing of your personal data;

you have the right to request the rectification of inaccurate personal data concerning you; you have to right to ask us to erase your personal data (right to be forgotten);

you have the right to obtain restriction of processing of your personal data, for example when you have contested the accuracy of your personal data;

you have the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, where the processing is based on your consent or on a contract;

you have the right to object to processing of personal data which is based on our legitimate interests. We shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims;

where personal data are processed for direct marketing purposes, you always have the right to object to the processing of personal data for such marketing. In that case, we shall no longer process your personal data for such purposes;

6. How do we protect your personal data?

We take appropriate technical and organizational measures to protect your (personal) information against loss or any form of unlawful use.

7. Can this privacy statement be amended?

It is possible for the privacy statement to be amended in the future. It is therefore recommended to regularly visit the section on the website in which we outline the privacy policy.

8. Questions or complaints?

If you have any questions, please do not hesitate to contact us via In case you suspect a breach of data protection legislation and the matter is not solved amicably between us in negotiations, you also have the right to lodge a complaint with a supervisory authority.