1.    OVERVIEW

Oh Mdame, LLC (“Oh Madame,” “we,” “us,” or “our”) is committed to respecting and protecting your privacy. We act in accordance with the requirements of the various privacy and data protection laws.

This Privacy Notice explains how we collect, use and share Personal Data pertaining to our customers and Website visitors (collectively, “you” and “your”) and explains the rights you have regarding our use of your Personal Data. Please take into account that not all sections may be equally relevant or applicable to you depending on the circumstances.

Please ensure you read this Privacy Notice carefully before using our Website and/or providing us with your Personal Data.

2.    PERSONAL DATA

Personal Data is any information that relates directly or indirectly to an identified or identifiable living individual or, where applicable, legal entity. Personal Data may include a name, an (email) address, a telephone number, an IP address, credit card information, preferences, age, gender, occupation, etc.

The Personal Data that we collect, and how we collect it, depends on how you interact with us. For instance, if you are one of our customers, we may collect different types of data compared to when you are a visitor. We have included a generic outline of our data collection and processing activities below.

A.  PERSONAL DATA WE COLLECT FROM YOU AND WHY

We collect Personal Data directly from you as as a Website visitor:

–          When you visit our Website we automatically collect, store and use technical information about your interaction with our Website. This General Information is sent from your computer or personal device to us using a variety of cookies and other technical means.
General categories of Personal Data that we collect are the following:

–          Contact information: such as name, title, address, email address and telephone number;

–          Biographical information: such as gender, birthdate, nationality, photograph or videos containing your image, occupation and information about family life (excluding special categories of data) including family, children, hobbies and interests;

–          Registration data: such as newsletter requests, event/incentive trips registrations, subscriptions and related information such as feedback and survey responses;

–          Other data: any other Personal Data you voluntarily provide to us. For instance, when you choose to provide us with Personal Data of your family members when completing our online form that contains a dedicated field for this purpose, or when you contact our customer service.

It is not mandatory for you to provide your Personal Data to us. However, we may not be able to carry out the purposes described above if you choose not to provide us with your personal data.

B.             CHILDREN

We do not knowingly collect or otherwise process any Personal Data from children under the age of 13 and do not direct our services, Website or Apps to children under the age of 16. If you think that a child for which you are responsible provided Personal Data to us, we strongly encourage you to contact us immediately and we will work with you to find a solution to remediate this.

We encourage you to participate in your child’s experience on the Internet and to review important safety tips with each child before he or she explores the Internet.

3.  YOUR PERSONAL DATA PROTECTION

We protect your Personal Data and implement technical and organizational security measures to protect it against any unauthorized or unlawful processing and against any accidental loss, destruction, or damage.

In particular, we operates data networks protected by industry standard firewall and password protection systems. Access to this information will be provided only to authorized individuals for legitimate business purpose.

In addition, access to your Personal Data is restricted to staff and service providers on a need-to-know basis.

While we endeavor to always protect our systems, sites, operations and information against unauthorized access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.

Please contact the Privacy Team if you have any questions about how we protect your Personal Data.\

4.    RETAINING YOUR PERSONAL DATA

We hold on to your Personal Data for as long as necessary to achieve the processing purposes listed above under “Personal Data we collect from you and why”. This means, for instance, that we no longer store your Personal Data when our (contractual) relationship with you comes to an end, unless further storage is permitted or required under applicable law.

5.  YOUR RIGHTS

You have certain rights regarding how we use and keep your Personal Data. These are:

–          Rectification. You have the right to require that any incomplete or inaccurate Personal Data that we process about you is amended;

–          Deletion. You have the right to request that we delete Personal Data that we process about you under specific conditions;

–          Withdrawing Consent. If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time. This does not affect the lawfulness of the processing that was based on your consent prior to withdrawal. This includes cases where you wish to opt out from marketing messages that you receive from us;

–          Access. Subject to certain exceptions, you have the right to access and request a copy of the Personal Data we are processing about you, which we will provide to you in electronic form and/or in writing, or verbally where allowed by applicable laws. Where permissible under applicable laws, we may charge you a reasonable fee for this access request;

Where we process your Personal Data for direct marketing purposes, you have the right to object at any time to such processing, including for profiling purposes to the extent that it is related to direct marketing. If you object to processing for direct marketing purposes, we will no longer process your Personal Data for such purposes.

You can exercise the above rights, where applicable by contacting the Privacy Team or by using our online tool in the markets where such tool is available. We will respond to any of your requests to exercise these above data subject rights within the period prescribed by applicable laws. At our discretion, we may require you to prove your identity before providing the requested information. This is to ensure that your Personal Data is disclosed only to you. We may not be able to appropriately handle your request if you decide not to provide us with the Personal Data that we need to handle your request. If you are not satisfied with the way we handled your request, or for violations of applicable data protection laws, you may lodge a complaint or file a claim with a competent Supervisory Authority.

6.      YOUR OBLIGATIONS

We expect that you only communicate Personal Data about yourself to us. If you also communicate Personal Data about other people to us, then you must ensure that you comply with any legal obligations that may apply to your provision of the information to us, and to allow us, where necessary, to use, process and transfer that information. In particular, and subject to local applicable laws, if you use a credit card not issued to you, you confirm that the credit cardholder has consented to the use of his/her credit card in relation to your purchase and has agreed that Nu Skin may collect, use and disclose his/her Personal Data for the purpose of processing your purchase.

We also expect that the Personal Data that you communicate to us are correct and that, if your Personal Data requires updating, you will promptly inform us.

7.           YOUR MARKETING CHOICES

You can control whether to receive direct marketing from us (e.g., which we may send through electronic means, such as promotional emails). In certain markets, you will need to provide us with your consent before receiving marketing. For instance, we may ask you to tick a box indicating to “receive promotional emails” when you sign up as a new customer or Brand Affiliate. In all markets, you can choose not to receive such communications at any time. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed, or receive any other marketing communication, please follow the unsubscribe link in the relevant communication or contact the Privacy Team.

8.    CHANGES TO THE PRIVACY NOTICE

We may update this Privacy Notice from time to time. We will notify you of any significant changes by posting those changes here or by notifying you through other appropriate communication channels we generally use with you. Any changes to this Privacy Notice will be considered effective immediately after the changes are posted on this Website unless otherwise indicated.

9.   THIRD PARTY WEBSITES

Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. OH MADAME WEBSITE COOKIE POLICY

Oh Madame uses cookies and other data collection technologies for certain areas of our website.

A cookie is a small piece of data sent from our website and stored on your computer that helps to personalize your web experience. It helps our website remember information about your visit, such as your preferred language, so that you do not have to enter this information again the next time you visit the same website. Some cookies ensure that the graphics on a website appear correctly, while others make sure a website application works properly.

Cookies vary in their purpose and duration. For instance, cookies may be required for the website to work or to provide functionality and performance, while some provide us with information about your browsing history or how long you stay on a page.

A. Managing Cookies in Your Browser

You may configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. For example, in the Google Chrome browser, under the Tools menu, you can use the option “Clear Browsing Data” to delete cookies and other site and plug-in data.

The Privacy Notice was last revised on November 10, 2019.


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