Datenschutzerklärung

This Privacy Policy describes how nayaglow.com (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

Collecting Personal Information

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

Device information

  • Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
  • Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
  • Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels .
  • Disclosure for a business purpose: shared with our processor Shopify .

Order information

  • Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit / debit card numbers, email address, and phone number.
  • Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
  • Source of collection: collected from you.
  • Disclosure for a business purpose: shared with our processor Shopify for processing the order.

Customer support information

  • Examples of Personal Information collected: 
  • Purpose of collection: to provide customer support.
  • Source of collection: collected from you.
  • Disclosure for a business purpose: 



Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:

  • We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
  • We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
  • Voucher and advertising system of VCHFY GmbH: On the basis of Art. 6 (1) lit. b DSGVO, we use the voucher and advertising system of the company VCHFY GmbH, Tornquiststraße 51, 20259 Hamburg, Germany, to fulfil a contract or to carry out pre-contractual measures for the sale of our products. When this programme is called up, personal data (IP address, order number and article and order values) are forwarded to VCHFY for order processing. The voucher and advertising system uses cookies for this purpose. These are necessary for the fulfilment of the contract or for pre-contractual measures and are also based on Art. 6 para. 1 lit. b DSGVO.
  • Details on the handling of user data can be found in the VCHFY GmbH privacy policy at: http://www.vchfy.com/de/datenschutz/.

Behavioural Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

  • We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
  • We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Using Personal Information

We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.

Lawful basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

  • Your consent;
  • The performance of the contract between you and the Site;
  • Compliance with our legal obligations;
  • To protect your vital interests;
  • To perform a task carried out in the public interest;
  • For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

Automatic decision-making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We do not  engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

  • Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
  • Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.

 

Advertising by e-mail

Email newsletter with registration

If you register for our newsletter, we will use the data required for this purpose or separately provided by you to send you our e-mail newsletter on a regular basis based on your consent pursuant to Art. 6 (1) p. 1 lit. a DSGVO. Unsubscribing from the newsletter is possible at any time and can be done either by sending a message to the contact option described below or via a link provided for this purpose in the newsletter. After unsubscribing, we will delete your e-mail address from the list of recipients, unless you have expressly consented to further use of your data pursuant to Art. 6 (1) p. 1 lit. a DSGVO or we reserve the right to use data beyond this, which is permitted by law and about which we inform you in this statement.

Newsletter dispatch

The newsletter may also be sent by our service providers as part of processing on our behalf. If you have any questions about our service providers and the basis of our cooperation with them, please use the contact option described in this privacy statement.

Our service providers, Omnisend ( https://www.omnisend.com/legal) are located in these countries: UK. There is no European Commission adequacy decision for these countries. Our cooperation with you is based on these guarantees: standard data protection clauses of the European Commission.

HOW DO I UNSUBSCRIBE FROM MARKETING EMAILS?

You can choose to stop receiving marketing messages from us at any time.

This can be done:

  • Clicking the "Unsubscribe" link in your email
  • Contacting us directly (via hello@nayaglow.com) and clearly state that you like to unsubscribe from the marketing emails. 

We will process the update to your preferences when you tell us about the change. However, please note that it can take a few days-weeks for some of our systems to update, so you may receive some marketing messages during this process.

This change to your contact preferences will not stop communications regarding any orders you place, such as order confirmation and shipping emails.

Review Collection

If you order any products from this Site, you will be invited to complete a customer review with Loox, the verified customer service company. You can provide a review in your own name or anonymously, and there is no obligation to leave a review. 

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

 

How do we use your personal information?

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
- Communicate with you;
- Screen our orders for potential risk or fraud; and
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

 

    Your rights

    GDPR

    If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.

    Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.

    Cookies

    A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

    We use the following cookies to optimize your experience on our Site and to provide our services.

    Cookies Necessary for the Functioning of the Store

    Name Function
    _ab Used in connection with access to admin.
    _secure_session_id Used in connection with navigation through a storefront.
    cart Used in connection with shopping cart.
    cart_sig Used in connection with checkout.
    cart_ts Used in connection with checkout.
    checkout_token Used in connection with checkout.
    secret Used in connection with checkout.
    secure_customer_sig Used in connection with customer login.
    storefront_digest Used in connection with customer login.
    _shopify_u Used to facilitate updating customer account information.

    Reporting and Analytics

    Name Function
    _tracking_consent Tracking preferences.
    _landing_page Track landing pages
    _orig_referrer Track landing pages
    _s Shopify analytics.
    _shopify_fs Shopify analytics.
    _shopify_s Shopify analytics.
    _shopify_sa_p Shopify analytics relating to marketing & referrals.
    _shopify_sa_t Shopify analytics relating to marketing & referrals.
    _shopify_y Shopify analytics.
    _y Shopify analytics.

     

    The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

    You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

    Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

    Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

    Third Parties and Social Media 

    We cannot be responsible for the privacy policies and practices of other third party sites (including but not limited to Facebook, YouTube, Twitter), or for advertisers on our site, even if you access them using links from our website and we recommend that you check the policy of each site you visit. If you linked to our Site from a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and we recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions. Unless expressly stated, we are not agents for these third party sites or for any third party advertisers on our Site, nor are we authorised to make representations on their behalf.

    Do I control my data? 

    Under the General Data Protection Regulation, you have several important rights available to you. In summary, those include rights to:

    • Be informed about how your personal information is being used (hopefully this privacy notice explains it all)
    • Access the personal information we hold about you
    • Request that we transfer elements of your data to another service provider
    • Request us to correct any mistakes in your information which we hold
    • Request the erasure of personal information concerning you in certain situations
    • Receive the personal information concerning you which you have provided to us, in a structured format or to ask us to transfer that information to another service provider
    • Stop any direct marketing
    • Object to processing of your personal data
    • You can ask us to restrict or suspend processing of your personal data under certain circumstances, for example if you want us to restrict processing while the accuracy of personal data is being established
    • Right not to be subjected to automated decision-making that significantly affects you, however, we will only use automated decision making in limited circumstances
    • Right to withdraw your consent, where processing of your personal data is based on consent, you can remove it at any time

    For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

    If you would like to exercise any of these rights, please:

    • Email us hello@nayaglow.com
    • Let us have enough information to identify you;
    • Let us know the information to which your request relates

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made many requests or your request is not clear we might need to seek further information from you. In this case, we will notify you and keep you updated.

    Keeping your personal data safe 

    We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

    We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

    If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

     

    Do Not Track

    Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

    Changes

    We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

    Consent

    By using our website, you hereby consent to our Privacy Policy and agree to its Terms and Conditions.

    Contact

    For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at hello@nayaglow.com or by mail using the details provided below:

    NAYA Skincare Ltd., Kemp House, 152-160, City Road, London EC1V 2NX, United Kingdom

    Last updated: [01/07/2021]

    We hope that we can resolve any query or concern you raise about our use of your information. If you are not happy with how NAYA Skincare manages your personal data, you have the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/.