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Privacy
policy
1. Introduction
1.1 We
are committed to safeguarding the privacy of [our website visitors and service
users].
1.2 This
policy applies where we are acting as a data controller with respect to the
personal data of [our website visitors and service users]; in other words,
where we determine the purposes and means of the processing of that personal
data.
1.3 We
use cookies on our website. Insofar as those cookies are not strictly necessary
for the provision of [our website and services], we will ask you to consent to
our use of cookies when you first visit our website.
1.4 Our
website incorporates privacy controls which affect how we will process your
personal data. By using the privacy controls, you can [specify whether you
would like to receive direct marketing communications and limit the publication
of your information]. You can access the privacy controls via https://www.nuciya.com/index.php?route=extension/module/isenselabs_gdpr/personal_data_request
1.5 In
this policy, "we", "us" and "our" refer to Nuciya
Natural Beauty Incorporated .[ For more information about us, see Section 13.]
2. Credit
2.1 This
document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In
this Section 3 we have set out:
(a) the
general categories of personal data that we may process;
(b) [in
the case of personal data that we did not obtain directly from you, the source
and specific categories of that data];
(c) the
purposes for which we may process personal data; and
(d) the
legal bases of the processing.
3.2 We
may process [data about your use of our website and services] ("usage
data"). The usage data may include [your IP address, geographical
location, browser type and version, operating system, referral source, length
of visit, page views and website navigation paths, as well as information about
the timing, frequency and pattern of your service use]. The source of the usage
data is [Google, Facebook, Addroll and other Analytics systems]. This usage
data may be processed [for the purposes of analysing the use of the website and
services]. The legal basis for this processing is [consent] OR [our legitimate
interests, namely [monitoring and improving our website and services]].
3.3 We
may process [your account data] ("account data").[ The account
data may [include your name and email address].][ The source of the account
data is [you or your employer].] The account data may be processed [for the
purposes of operating our website, providing our services, ensuring the
security of our website and services, maintaining back-ups of our databases and
communicating with you.] The legal basis for this processing is [consent] OR
[our legitimate interests, namely [the proper administration of our website and
business]] OR [the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract].
3.4 We
may process [your information included in your personal profile on our website]
("profile data").[ The profile data may include [your name,
address, telephone number, email address, profile pictures, gender, date of
birth, relationship status, interests and hobbies, educational details and
employment details].] The profile data may be processed for [the purposes of
enabling and monitoring your use of our website and services]. The legal basis
for this processing is [consent] OR [our legitimate interests, namely [the
proper administration of our website and business]] OR [the performance of a
contract between you and us and/or taking steps, at you request, to enter into
such a contract].
3.5 We
may process [your personal data that are provided in the course of the use of
our services] ("service data").[ The service data may include shopping
interests and demographic data].][ The source of the service data is [you
or your employer].] The service data may be processed [for the purposes of
operating our website, providing our services, ensuring the security of our
website and services, maintaining back-ups of our databases and communicating
with you]. The legal basis for this processing is [consent] OR [our legitimate
interests, namely [the proper administration of our website and business]] OR
[the performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract].
3.6 We
may process [information that you post for publication on our website or
through our services] ("publication data"). The publication
data may be processed [for the purposes of enabling such publication and
administering our website and services]. The legal basis for this processing is
[consent] OR [our legitimate interests, namely [the proper administration of
our website and business]] OR [the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract] OR [[specify
basis]].
3.7 We
may process [information contained in any enquiry you submit to us regarding
goods and/or services] ("enquiry data"). The enquiry data may
be processed [for the purposes of offering, marketing and selling relevant
goods and/or services to you]. The legal basis for this processing is [consent].
3.8 We
may process [information relating to our customer relationships, including
customer contact information] ("customer relationship data").[
The customer relationship data may include [your name, your employer, your job
title or role, your contact details, and information contained in
communications between us and you or your employer].][ The source of the
customer relationship data is [you or your employer].] The customer
relationship data may be processed [for the purposes of managing our
relationships with customers, communicating with customers, keeping records of
those communications and promoting our products and services to customers]. The
legal basis for this processing is [consent] OR [our legitimate interests,
namely [the proper management of our customer relationships]].
3.9 We
may process [information relating to transactions, including purchases of goods
and services, that you enter into with us and/or through our website] ("transaction
data").[ The transaction data may include [your contact details, your
card details and the transaction details].] The transaction data may be
processed [for the purpose of supplying the purchased goods and services and
keeping proper records of those transactions]. The legal basis for this
processing is [the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract and our legitimate
interests, namely [the proper administration of our website and business]].
3.10 We
may process [information that you provide to us for the purpose of subscribing
to our email notifications and/or newsletters] ("notification data").
The notification data may be processed [for the purposes of sending you the
relevant notifications and/or newsletters]. The legal basis for this processing
is [consent] OR [the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract].
3.11 We
may process [information contained in or relating to any communication that you
send to us] ("correspondence data"). The correspondence data
may include [the communication content and metadata associated with the
communication].[ Our website will generate the metadata associated with
communications made using the website contact forms.] The correspondence data
may be processed [for the purposes of communicating with you and
record-keeping]. The legal basis for this processing is [our legitimate
interests, namely [the proper administration of our website and business and
communications with users]].
3.12 We
may process shopping interests data.[ This data may include items
viewed, bought and demographic details. The source of this data is data
provided by the user by the use and activity on our website.] This data may
be processed for the improvement of our sales and marketing policies. The legal
basis for this processing is [consent] OR [our legitimate interests, namely [specify
legitimate interests]] OR [the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract].
3.13 We
may process [any of your personal data identified in this policy] where
necessary for [the establishment, exercise or defence of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure]. The
legal basis for this processing is our legitimate interests, namely [the
protection and assertion of our legal rights, your legal rights and the legal
rights of others].
3.14 We
may process [any of your personal data identified in this policy] where
necessary for [the purposes of obtaining or maintaining insurance coverage,
managing risks, or obtaining professional advice]. The legal basis for this
processing is our legitimate interests, namely [the proper protection of our
business against risks].
3.15 In
addition to the specific purposes for which we may process your personal data
set out in this Section 3, we may also process [any of your personal data]
where such processing is necessary [ for compliance with a legal obligation to
which we are subject, or] in order to protect your vital interests or the vital
interests of another natural person.
3.16 Please
do not supply any other person's personal data to us, unless we prompt you to
do so.
4. Providing your personal data to others
4.1 We
may disclose [your personal data] to any member of our group of companies (this
means our subsidiaries, our ultimate holding company and all its subsidiaries)
insofar as reasonably necessary for the purposes, and on the legal bases, set
out in this policy.[ Information about our group of companies can be found at /about-us.]
4.2 We
may disclose [your personal data] to [our insurers and/or professional
advisers] insofar as reasonably necessary for the purposes of [obtaining or
maintaining insurance coverage, managing risks, obtaining professional advice,
or the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure].
4.3 We
may disclose [specify personal data category or categories] to [our
suppliers or subcontractors][ identified at /about-us insofar as reasonably
necessary for the improvement of our services.
4.4 Financial
transactions relating to [our website and services] [are] OR [may be] handled
by our payment services providers, Paypal, Coinpayments.net. We will share
transaction data with our payment services providers only to the extent
necessary for the purposes of [processing your payments, refunding such
payments and dealing with complaints and queries relating to such payments and
refunds]. You can find information about the payment services providers'
privacy policies and practices at https://www.paypal.com/ca/webapps/mpp/ua/privacy-full
and https://www.coinpayments.net/help-privacy
4.5 We
may disclose [your enquiry data] to [one or more of those selected third party
suppliers of goods and services identified on our website] for the purpose of
[enabling them to contact you so that they can offer, market and sell to you
relevant goods and/or services].[ Each such third party will act as a data controller
in relation to the enquiry data that we supply to it; and upon contacting you,
each such third party will supply to you a copy of its own privacy policy,
which will govern that third party's use of your personal data.]
4.6 In
addition to the specific disclosures of personal data set out in this Section
4, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.[
We may also disclose your personal data where such disclosure is necessary for
the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.]
5. International transfers of your personal
data
5.1 In
this Section 5, we provide information about the circumstances in which your
personal data may be transferred to [countries outside the European Economic
Area (EEA)].
5.2 We[
and our other group companies] have [offices and facilities] in Canada.[
The European Commission has made an "adequacy decision" with respect
to [the data protection laws of each of these countries].][ Transfers to [each
of these countries] will be protected by appropriate safeguards, namely [the
use of standard data protection clauses adopted or approved by the European
Commission, a copy of which can be obtained from [https://ec.europa.eu/info/law/law-topic/data-protection_en]]
OR [the use of binding corporate rules, a copy of which you can obtain from [https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/binding-corporate-rules_en]].
5.3 The
hosting facilities for our website are situated in United States of America.
The European Commission has made an "adequacy decision" with respect
to [the data protection laws of each of these countries].][ Transfers to [each
of these countries] will be protected by appropriate safeguards, namely [the
use of standard data protection clauses adopted or approved by the European
Commission, a copy of which you can obtain from [https://ec.europa.eu/info/law/law-topic/data-protection_en]]
5.4 Manufacturers,
Supply Chain management companies [are] OR situated in Canada and the
United States.[ The European Commission has made an "adequacy
decision" with respect to [the data protection laws of each of these
countries].][ Transfers to [each of these countries] will be protected by
appropriate safeguards, namely [the use of standard data protection clauses
adopted or approved by the European Commission, a copy of which can be obtained
from [https://ec.europa.eu/info/law/law-topic/data-protection_en]] .
5.5 You
acknowledge that [personal data that you submit for publication through our
website or services] may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This
Section 6 sets out our data retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.
6.2 Personal
data that we process for any purpose or purposes shall not be kept for longer
than is necessary for that purpose or those purposes.
6.3 We
will retain your personal data as follows:
(a) [All
data entered into our customer forms as well as viewing and shopping data]
will be retained for a minimum period of [3 years] following [date of
last submission/update], and for a maximum period of [7 years]
following [date of late submission/update].
6.4 In
some cases it is not possible for us to specify in advance the periods for
which your personal data will be retained. In such cases, we will determine the
period of retention based on the following criteria:
(a) the
period of retention of [personal data] will be determined based on usefullness
6.5 Notwithstanding
the other provisions of this Section 6, we may retain your personal data where
such retention is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital interests
of another natural person.
7. Amendments
7.1 We
may update this policy from time to time by publishing a new version on our
website.
7.2 You
should check this page occasionally to ensure you are happy with any changes to
this policy.
7.3 We
[may] OR [will] notify you of [changes] OR [significant changes] to this policy
[by email or through the private messaging system on our website].
8. Your rights
8.1 In
this Section 8, we have summarised the rights that you have under data
protection law. Some of the rights are complex, and not all of the details have
been included in our summaries. Accordingly, you should read the relevant laws
and guidance from the regulatory authorities for a full explanation of these
rights.
8.2 Your
principal rights under data protection law are:
(a) the
right to access;
(b) the
right to rectification;
(c) the
right to erasure;
(d) the
right to restrict processing;
(e) the
right to object to processing;
(f) the
right to data portability;
(g) the
right to complain to a supervisory authority; and
(h) the
right to withdraw consent.
8.3 You
have the right to confirmation as to whether or not we process your personal
data and, where we do, access to the personal data, together with certain
additional information. That additional information includes details of the
purposes of the processing, the categories of personal data concerned and the
recipients of the personal data. Providing the rights and freedoms of others
are not affected, we will supply to you a copy of your personal data. The first
copy will be provided free of charge, but additional copies may be subject to a
reasonable fee.[ You can access [your personal data] by visiting [https://www.nuciya.com/index.php?route=extension/module/isenselabs_gdpr/personal_data_request]
when logged into our website.]
8.4 You
have the right to have any inaccurate personal data about you rectified and,
taking into account the purposes of the processing, to have any incomplete
personal data about you completed.
8.5 In
some circumstances you have the right to the erasure of your personal data
without undue delay. Those circumstances include: [the personal data are no
longer necessary in relation to the purposes for which they were collected or
otherwise processed; you withdraw consent to consent-based processing; you
object to the processing under certain rules of applicable data protection law;
the processing is for direct marketing purposes; and the personal data have
been unlawfully processed]. However, there are exclusions of the right to
erasure. The general exclusions include where processing is necessary: [for
exercising the right of freedom of expression and information; for compliance
with a legal obligation; or for the establishment, exercise or defence of legal
claims].
8.6 In
some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the
personal data; processing is unlawful but you oppose erasure; we no longer need
the personal data for the purposes of our processing, but you require personal
data for the establishment, exercise or defence of legal claims; and you have
objected to processing, pending the verification of that objection. Where
processing has been restricted on this basis, we may continue to store your
personal data. However, we will only otherwise process it: with your consent; for
the establishment, exercise or defence of legal claims; for the protection of
the rights of another natural or legal person; or for reasons of important
public interest.
8.7 You
have the right to object to our processing of your personal data on grounds relating
to your particular situation, but only to the extent that the legal basis for
the processing is that the processing is necessary for: the performance of a
task carried out in the public interest or in the exercise of any official
authority vested in us; or the purposes of the legitimate interests pursued by
us or by a third party. If you make such an objection, we will cease to process
the personal information unless we can demonstrate compelling legitimate
grounds for the processing which override your interests, rights and freedoms,
or the processing is for the establishment, exercise or defence of legal
claims.
8.8 You
have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you
make such an objection, we will cease to process your personal data for this
purpose.
8.9 You
have the right to object to our processing of your personal data for scientific
or historical research purposes or statistical purposes on grounds relating to
your particular situation, unless the processing is necessary for the
performance of a task carried out for reasons of public interest.
8.10 To
the extent that the legal basis for our processing of your personal data is:
(a) consent;
or
(b) that
the processing is necessary for the performance of a contract to which you are
party or in order to take steps at your request prior to entering into a
contract,
and
such processing is carried out by automated means, you have the right to receive
your personal data from us in a structured, commonly used and machine-readable
format. However, this right does not apply where it would adversely affect the
rights and freedoms of others.
8.11 If
you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection. You may do so in the EU member state
of your habitual residence, your place of work or the place of the alleged
infringement.
8.12 To
the extent that the legal basis for our processing of your personal information
is consent, you have the right to withdraw that consent at any time. Withdrawal
will not affect the lawfulness of processing before the withdrawal.
8.13 You
may exercise any of your rights in relation to your personal data [by written
notice to us] [ in addition to the other methods specified in this Section 8].
9. About cookies
9.1 A
cookie is a file containing an identifier (a string of letters and numbers)
that is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.
9.2 Cookies
may be either "persistent" cookies or "session" cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user session,
when the web browser is closed.
9.3 Cookies
do not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information
stored in and obtained from cookies.
10. Cookies that we use
10.1 We
use cookies for the following purposes:
(a) [authentication
- we use cookies [to identify you when you visit our website and as you
navigate our website][ (cookies used for this purpose are: possibly all cookies)]];
(b) [status
- we use cookies [to help us to determine if you are logged into our website][
(cookies used for this purpose are: possibly all cookies)]];
(c) [personalisation
- we use cookies [to store information about your preferences and to
personalise the website for you ][ (cookies used for this purpose are: possibly
all cookies)]];
(d) [security
- we use cookies [as an element of the security measures used to protect user
accounts, including preventing fraudulent use of login credentials, and to
protect our website and services generally][ (cookies used for this purpose
are: possibly all cookies)]];
(e) [advertising
- we use cookies [to help us to display advertisements that will be relevant to
you][ (cookies used for this purpose are: possibly all cookies]]
(f) [analysis
- we use cookies [to help us to analyse the use and performance of our website
and services][ (cookies used for this purpose are: possibly all cookies])]];
and
(g) [cookie
consent - we use cookies [to store your preferences in relation to the use of
cookies more generally][ (cookies used for this purpose are: possibly all
cookies)]].
11. Cookies used by our service providers
11.1 Our
service providers use cookies and those cookies may be stored on your computer
when you visit our website.
11.2 We
use Google Analytics to analyse the use of our website. Google Analytics
gathers information about website use by means of cookies. The information
gathered relating to our website is used to create reports about the use of our
website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.[
The relevant cookies are: [all google cookies].]
11.3 [We
publish Google AdSense interest-based advertisements on our website. These are
tailored by Google to reflect your interests. To determine your interests,
Google will track your behaviour on our website and on other websites across
the web using cookies.] OR [We publish Google AdSense advertisements on our
website. To determine your interests, Google will track your behaviour on our
website and on other websites across the web using cookies. This behaviour
tracking allows Google to tailor the advertisements that you see on other
websites to reflect your interests (but we do not publish interest-based advertisements
on our website).] You can view, delete or add interest categories associated
with your browser by visiting: https://adssettings.google.com. You can also opt
out of the AdSense partner network cookie using those settings or using the
Network Advertising Initiative's multi-cookie opt-out mechanism at: http://optout.networkadvertising.org.
However, these opt-out mechanisms themselves use cookies, and if you clear the
cookies from your browser your opt-out will not be maintained. To ensure that
an opt-out is maintained in respect of a particular browser, you may wish to
consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.[
The relevant cookies are: [identify cookies].]
12. Managing cookies
12.1 Most
browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser, and from version to version.
You can however obtain up-to-date information about blocking and deleting
cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en
(Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/
(Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
(e) https://support.apple.com/kb/PH21411
(Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
12.2 Blocking
all cookies will have a negative impact upon the usability of many websites.
12.3 If
you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1 This
website is owned and operated by [Nuciya Natural Beauty Incorporated].
13.2 We
are registered in [Canada] under registration number [803443431 RT001], and our registered office is at [14803-29
ST Edmonton, Alberta].
13.3 Our
principal place of business is at [14803-29 ST Edmonton, Alberta].
13.4 You
can contact us:
(a) [by
post, to [the postal address given above]];
(b) [using
our website contact form];
(c) [by
telephone, on [the contact number published on our website from time to time]];
or
(d) [by
email, using [the email address published on our website from time to time]].
14. Data protection officer
14.1 Our
data protection officer's contact details are: Pavel Dolzhenko, [email protected]
