Privacy Policy

The protection of your personal data is our highest priority, which is why we only use your data in strict compliance with the applicable data protection principles. From May 25, 2018, the provisions of the EU General Data Protection Regulation (hereinafter referred to as GDPR) will apply throughout Europe. As of today, we would like to inform you in detail about how NinaperfectSkin processes personal data in accordance with this new Regulation (cf. Article 13 and following of the GDPR). Please read our Privacy Policy carefully. If you have any questions or comments about our Privacy Policy, you can contact us at any time at the email address below.

 

  1. Overview

The following data protection provisions inform you about the type and scope of the processing of personal data by NinaperfectSkin, owned by MG DIGITAL GROUP LLC, 120 Madeira Drive Northeast STE 220, Albuquerque, NM 87108, UNITED-STATES, registered in ALBUQUERQUE, NEW Mexico, under EIN number: 35-2719181

 (hereinafter “NinaperfectSkin”, “we”, “us” or “our”). Personal data is information that can directly or indirectly identify you. Use of our apps, products, services, technologies or features and any related pages, apps and services (collectively, the “Offering”) is subject to this Privacy Policy.

 

As part of a new registration and/or through an appropriate explanation to existing customers, you confirm your agreement to this Privacy Policy and you expressly agree to the processing, use and disclosure of your personal data of the way described here.

 

Data processing by NinaperfectSkin may be divided into two categories :

All the data necessary for theexecution of a contract with NinaperfectSkin will be processed for the execution of the contract and/or the preparation of the contract. If external service providers are also involved in the processing of the contract, e.g. payment service providers, optimization services, hosting providers, etc., your data will be passed on to them to the extent required.

  • When you use our offer, various information is exchanged between your terminal and our server or the server of the services we use. This may also include personal data. The information thus collected is used in particular to further optimize our offer.

According to GDPR requirements, you have different rights that you can assert with us. This includes the right to withdraw your consent at any time regarding the processing of selected data, in particular the processing of data for advertising purposes. The possibility of withdraw your consent is always highlighted typographically. Further information on your rights can be found below in an additional paragraph and in the individual descriptions of the respective data processing.

 

Our offer is only accessible to people who have reached the age of 16. If you have not yet reached the said minimum age requirement, you may use our Offers only if and insofar as your parents have expressly consented thereto and if you have provided us with sufficient proof of such consent.

 

If you have any questions regarding our Privacy Policy, you may at any time contact: hello@ninaperfectskin.com.

  1. Name and contact details of the controller and the company's data protection officer

This Privacy Policy applies to the processing of data by The Company, as responsible under the GDPR for the following offers: www.ninaperfectskin.eu. The company has been designated responsible within the EU in accordance with articles 3 Para.2 and 27 Para. 1, 3 GDPR.

  1. Purposes of data processing, legal bases and legitimate interests pursued by us or by a third party and categories of recipients.

3.1. USE OF OUR OFFER

When you use our Offer, in particular our website or our application, the information is automatically sent to our servers by the application or the browser used on your terminal and stored temporarily in a log file. The following information are recorded without your intervention and stored in the log file until they are automatically or manually cleared:

  • the IP address of the device used,
  • the date and time of access,
  • the name and URL of the accessed file, the website/application from which the access took place (referrer URL),
  • the unique identifier of the browser you are using,
  • the name of your internet service provider.

Le processing of the aforementioned data is carried out in accordance with Article 6, paragraph 1, point f) of the GDPR. Our legitimate interest stems from the purposes of data collection listed below. At this point, we would like to point out that the data collected does not allow us to identify you personally or to draw any conclusions about it. We use the IP address of your terminal and the other data listed above for the following purposes:

  • guarantee the correct establishment of a connection,
  • guarantee comfortable use of our Offer,
  • assess the security and stability of the system and,
  • perform other administrative tasks.

The data is stored in accordance with the retention periods provided for by law and is then automatically deleted. In addition, we use cookies, tracking tools, targeting procedures and interfaces to other services as part of our Offer, e.g. to social media platforms, payment services or service providers. app store. The exact procedures and how your data is used for such purposes are explained in more detail in section 4 below.

3.2. CONCLUSION, EXECUTION OR TERMINATION OF A CONTRACT

Data processing when concluding the contract

 

We define our services as personalized health tracking technology: our technology provides an array of information about your health and well-being based on your metrics and data.

 

 In such a context, we process the data necessary to the conclusion, performance or termination of a contract. Said data includes in particular:

  • email-address,
  • first and last name, if applicable,
  • billing and payment data,
  • data entered by you and generated by the use of our Offer, such as gender, age and height, weight, etc.

The legal basis used is Art. 6 Para. 1 point a), point b) of the GDPR and Article 9 paragraph 2 point a) of the GDPR. Insofar as we do not use your contact details for customer support (see in detail section 3.3.), we keep the data collected for the processing of the contract until the end of the said contract or until the expiration of any contractual warranty and warranty rights. After the expiry of the said period, we will retain the personal data required by law for the prescribed legal duration. During such a period (usually six to ten years from the conclusion of the contract), the data will only be reprocessed in the event of control by the tax authorities.

3.3. DATA PROCESSING FOR CUSTOMER SUPPORT OR CUSTOMER SERVICE

3.3.1. Informational purposes

 

Insofar as you have registered for our Offer, we guide you as an existing customer. In such a case, we process your contact details in order to send you information, for example about new, extended or improved functions, products and services.

3.3.2. TARGETED ADVERTISING

To ensure that you only receive information that is intended to be of interest to you, we categorize and complete your customer profile with other information. We use statistical information as well as information about you (for example, referral data or basic data from your customer profile). The objective is to optimize our Offer according to your real or supposed centers of interest and/or personal needs and to provide you with appropriate recommendations so that you are not bored with useless promotions.

 

The legal basis for the aforementioned processing is Article 6(1)(b) and (f) GDPR as well as Article 9(2)(a) GDPR. The processing of existing customer data for advertising purposes is considered a recognized legitimate interest in accordance with recital 47 of the GDPR.

 

3.3.3. Customer Support

 

gorgias

 

We use the ticketing system of Gorgias, 768 Harrison St, San Francisco, CA 94107, USA (“Gorgias”) to process service, support and other user requests based on Article 6(1)(b) GDPR. If you submit a support request through one of our channels (e.g. our contact form, live chat, email, etc.), the following data (depending on content and selected contact channel ) will be processed through the Gorgias servers:

  • the data you have entered,
  • your name,
  • Your email address,
  • information about your browser,
  • your IP address.

You will find more information on the processing of data by Gorgias in the Gorgias privacy policy available at: https://www.gorgias.io/privacy/gdpr. If you have any questions, you can also contact Gorgias' data protection officers directly at the following address: support@gorgias.io.

 

3.3.4. Sending the Newsletter

 

We offer interested customers the opportunity to subscribe to our Newsletter . In order to ensure that the e-mail address entered is actually associated with the interested customer, we use the double opt-in procedure: once you have entered your e-mail address in the registration field, we will send you a confirmation link. It is only when you click on this confirmation link that your e-mail address will be added to our mailing list. We retain data collected through this process for documentation and verification purposes only. Said data includes in particular:

  • the e-mail address transmitted,
  • the IP address of the device used,
  • the date and time of the recording,
  • how to address,
  • the date, content and time of the confirmation email,
  • the IP address of the device used for confirmation,
  • and the date and time of your confirmation.

The legal basis used is Article 6(1)(a) GDPR. We keep this data until the end of the contractual relationship because we can thus prove the legality of sending the Newsletter. After the expiry of the said period, we will retain the personal data required by law for the prescribed legal duration. During such a period (usually ten years from the conclusion of the contract), the data will only be processed again in the event of an audit by the tax authorities. You can withdraw your consent at any time with effect for the future. To do this, simply click on the unsubscribe button in the corresponding e-mail or send a short notification by e-mail. To do this, please use the contact details of our Data Protection Officer.

 

3.3.5. Right of objection

 

You can withdraw your consent to the processing of data for the aforementioned purposes at any time free of charge, separately for the respective communication channel and with effect for the future. All you need to do is send an e-mail or a letter to the contact details given in point 1.

 

In the event of a dispute, we will block the relevant contact address for further processing of promotional data. We will process your objection as soon as possible and implement the corresponding blocking measures immediately after verification. We draw your attention to the fact that, in exceptional cases, information or product recommendations may still be sent even after receipt of your objection. This is only done for technical reasons and does not mean that we will not implement your dispute. Thank you for your understanding.

  1. Data processing for the provision of our services

In the following, we would like to inform you about the processing of data necessary for the provision of our Offer:

4.1. ONLINE PRESENCE AND WEBSITE OPTIMIZATION

We do not sell or rent your data to third parties for marketing purposes without your express consent. In order to provide our customers with the best possible product, to improve the quality of our Offering from time to time and to protect the interests of our customers, we will, under certain circumstances, disclose certain data to third parties; however, such disclosure will always be subject to strict restrictions, which are further described below:

 

4.1.1. Cookies – General information

 

We use cookies on our website on the basis of Article 6(1)(f) GDPR. Our interest in optimizing our Offers must be considered justified within the meaning of the aforementioned regulation. Cookies are small files that your browser creates automatically and which are stored on your device (laptop, tablet, smartphone, etc.) when you use our Offers. Cookies do not damage your terminal, do not contain viruses, Trojan horses or other malicious software. Cookies make it possible to save information which is in each case specific to the terminal used. However, this does not mean that we can immediately identify you. The use of cookies serves in particular to make the use of our Offer more pleasant for you. We use session cookies to detect that you have already visited certain pages of our website. If you use our Offer again later, the cookie automatically recognizes you. Additionally, we also use temporary cookies for the purpose of user-friendliness, which are stored on your terminal for a certain defined period of time. These are automatically cleared when you exit.

 

On the other hand, we use cookies to record statistically the use of our Offers and evaluate them with the aim of optimizing them for you and displaying information specifically tailored to your needs. These cookies allow us to automatically recognize you when you return to our site. These cookies are automatically deleted after a defined period of time. Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or that a message always appears before a new cookie is created. However, the complete deactivation of cookies prevents you from accessing all the functions of our Offers. How long cookies are stored depends on their intended use and is not the same for everyone.

 

4.1.3. Facebook Pixel

 

In order to use, further optimize and evaluate the conversion of our Facebook campaigns as needed, we use an individual behavior pixel from Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“ Facebook”) in accordance with Article 6, paragraph 1, point f of the GDPR. This pixel is embedded in the code of our website. This allows us to verify that the Facebook ads we initiate are only displayed on the page of users who have shown an interest in our services. In doing so, we ensure that our Facebook advertisements arouse the potential interest of the user and do not disturb him. We also track the actions of Facebook users after they have seen or clicked on one of our Facebook advertisements. This allows us to evaluate the conversion of the respective campaign for statistical, market research and billing purposes. The following information is processed:

  • timestamp,
  • the URL,
  • campaign information (including print specification, form field, activated button).

The data collected in this way is anonymous and does not allow us to draw any conclusions as to the identity of the user. Processing for the purposes of behavioral and interest-based advertising is considered a recognized legitimate interest in accordance with recital 47 of the GDPR. The data is stored in accordance with the retention periods provided for by law and is then automatically deleted.

 

If you log into your Facebook account after placing the pixel or if you visit our website while logged in, it is possible that this data will be stored and processed by Facebook, about which we hereby inform you. Facebook may connect this data to your Facebook account and use it for advertising purposes, in accordance with Facebook's Data Use Policy: https://www.facebook.com/about/privacy/. You will find more information on the Facebook pixel here. You can allow Facebook and its partners to serve ads on Facebook and other sites. You can withdraw your consent at any time regarding special data processing by changing your Facebook settings or by simply telling us that you no longer wish to do so in the future. To do this, please use the contact details of our Data Protection Officer. Please note that the dispute declared only applies to the device used. For more information, please refer to the Privacy Policy and Privacy Information From Facebook.

 

4.1.4. Facebook Lookalike Audiences Campaigns

 

In order to use, further optimize and evaluate the conversion of our Facebook campaigns as needed, we use an individual behavior pixel from Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“ Facebook”) in accordance with Article 6, paragraph 1, point f of the GDPR. You can find more information about Facebook's Lookalike Audiences campaigns at: https://www.facebook.com/business/help/365463786964246

 

Such processing for the purposes of behavioral and interest-based advertising is considered a legitimate interest recognized in accordance with recital 47 of the GDPR. If you are a Facebook lookalike audience, we will pass your email address and device ID to Facebook. You can withdraw your consent at any time regarding special data processing by changing your Facebook settings: https://www.facebook.com/settings/?tab=ads or by simply telling us that you no longer wish to do so in the future. To do this, please use the contact details of our Data Protection Officer.

 

4.1.5. Pinterest Tag

 

In order to use, further optimize and evaluate the conversion of our Pinterest campaigns as needed, we use a Pinterest tag, an individual code snippet, from Pinterest Inc., 635 High Street, Palo Alto, CA, States United States, (“Pinterest”) which is integrated into the content of our website, in accordance with Article 6, paragraph 1, point f of the GDPR. This allows us to verify that the Pinterest ads we initiate only appear on the page of users who have shown an interest in our services. In doing so, we ensure that our Pinterest advertisements engage the user's potential interest and do not disturb them. We also track the actions of Pinterest users after they have seen or clicked on one of our Pinterest advertisements. This allows us to evaluate the conversion of the respective campaign for statistical, market research and billing purposes. The following information is processed:

  • device information (e.g. type, brand),
  • the operating system used (for example, iOS 11),
  • the IP address of the device used,
  • the time of use of our Offer,
  • The type and content of the campaign and
  • the reaction to the respective campaign (e.g. button click).

The data collected in this way is anonymous and does not allow us to draw any conclusions as to the identity of the user. Such processing for behavioral and interest-based advertising purposes is considered a recognized legitimate interest in accordance with recital 47 of the GDPR. The data is stored in accordance with the retention periods provided for by law and is then automatically deleted.

 

If you log into your Pinterest account after visiting our website or if you visit our website while logged in, it is possible that this data will be stored and processed by Pinterest, about which we hereby inform you. It is possible that Pinterest can connect this data to your account and also use it for advertising purposes. You can find more information in Pinterest's Privacy Policy: https://policy.pinterest.com/de/privacy-policy. You can withdraw your consent at any time regarding special data processing by disabling all relevant settings under “Personalization” in your Pinterest account https://help.pinterest.com/de/articles/edit-your-settings#Web or by activating the “Do Not Track” setting of your browser.

 

4.1.6.Google Analytics

 

To design our Offer as needed and to continuously optimize it, we use the Google Analytics service of Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, (“Google”) in accordance with Article 6 , paragraph 1, point f of the GDPR. Through the use of cookies, Google creates pseudonymised usage profiles. The information generated by the cookie about your use of this website such as

  • browser type/version,
  • the operating system used,
  • the referring URL (the previously visited page),
  • the host name of the accessing computer (IP address),
  • the time of the server request.

are transmitted to a Google server in the USA and stored there. The information is used to evaluate the use of the Offerings, compile reports on activities and provide other services related to the use of the Offering for the purposes of market research and needs-based design. This information may also be passed on to third parties if required by law or if third parties are commissioned to process this data. Your IP address will never be merged with other Google data. IP addresses are anonymized, so that a allocation is not possible (so called IP masking).

 

You can prevent the use of cookies upstream by modifying the parameters of your navigation software or withdraw your consent regarding further processing via the cookie by clicking on this link and choosing to no longer participate; please note, however, that in such a case not all functions of our offers can be used to their full extent. In addition, you can prevent any creation of data generated by a cookie and related to your use of our Offer (in particular your IP address) as well as the processing of said data by Google by downloading and installing the browser add-on. We recommend using Private mode on mobile devices. You can find more information on data protection in connection with Google Analytics on the web page of Google Analytics.

 

4.1.7. Google Tag Manager

 

Google Tag Manager allows us to manage our website tags (website code). These facilitate the management and development of our Offer and reduce the loading time. Google Tag Manager implements website code only. Google Tag Manager does not set cookies and does not collect any personal information. The tool only embeds website code that we have stored elsewhere that can be used to collect data. The tool serves only to facilitate the modulation of the code but does not access the data processed by the code. We will notify you of any tags incorporated into this Privacy Policy. You can find more information about Google Tag Manager and the terms of service on Google's pages.

 

4.1.8. Stripe payment processing service

 

For the purpose of contract execution and above all payment processing, we transmit your name and e-mail address to our payment service Stripe Payments Europe Ltd., block 4, Harcourt Center, Harcourt Road, Dublin 2, Ireland ( “Stripe”) in accordance with Article 6, paragraph 1, point a) and b) of the GDPR. Through the use of the Stripe library, we will not process the information entered during the ordering process (address, account number, bank code, possibly credit card number, invoice amount, currency and transaction number ) but will pass them directly to Stripe from your browser. The data is used exclusively by Stripe for the execution and completion of the payment process and transmitted securely via the “SSL” encryption method. Stripe is certified PCI DSS. Stripe may transfer, process and store personal information outside of the European Union. You can find more information about Stripe's Privacy Policy by clicking on this link.

 

We use a text messaging platform, which is subject to the following terms and conditions. By opting in to our text marketing and notifications, you agree to these terms and conditions.
By entering your phone number during checkout and initiating a purchase, subscribing via our subscription form or a keyword, you agree that we may send you SMS notifications (for your order, including reminders abandoned cart service) and SMS marketing offers. You acknowledge that consent is not a condition of any purchase.
Your phone number, name and purchase information will be shared with our SMS platform "SMSBump Inc, a European Union company with an office in Sofia, Bulgaria, EU. This data will be used to send you Targeted marketing messages and notifications.When sending the text messages, your phone number will be passed to a text messaging operator to complete their delivery.
If you wish to unsubscribe from receiving text messages and notifications, reply STOP to any mobile message we send to you or use the unsubscribe link we have provided to you in one of our messages. You understand and agree that other opt-out methods, such as using alternative words or requests, will not be considered a reasonable way to unsubscribe. Message and data charges may apply.
For any questions, send "HELP" to the number from which you received the messages. You can also contact us for more information. If you wish to opt out, please follow the procedures above.

  

 

  1. Recipients outside the EU

As indicated in points 3.4 and 3.5 above, the data may also be transmitted to recipients located outside the European Union or the European Economic Area. This applies in particular to the processing of the mentioned analysis and targeting technologies, which may result in the transmission of data to the servers of the service providers. Affiliated service providers that we need to provide our services, such as hosting providers, CRM tools or analytics service providers may be other recipients. These servers may be located outside the European Union, in particular in the United States. We ensure that said service providers guarantee data protection standards equivalent to those of the GDPR and that the applicable directives are complied with. Thus, we only work with certified service providers. For said certification, the European Commission has established the adequacy of the level of data protection under the number C(2016) 4176) in accordance with Article 45 of the GDPR. The use of these certified service providers thus complies with the European standard for processing data in accordance with the law. In addition, service providers based outside the European Union have granted us adequate contractual guarantees guaranteeing compliance with these European standards and the adoption of the rights of data subjects, for example by relying on the standard contractual clauses of the European Commission.

  1. Your rights

6.1. OVERVIEW

Apart from the right of contestation to the consents you have given us, you can exercise the following rights if the respective legal conditions are met:

  • The right to information about your personal data stored with us according to Article 15 of the GDPR,
  • In the event of transmissions in accordance with Articles 46, 47 or 49, paragraph 1, point 2 of the GDPR, the right to information or reference to the appropriate or adequate guarantees and the possibility of obtaining a copy of the said guarantees or if the said guarantees are available,
  • Your personal data stored with us in accordance with Article 15 of the GDPR,
  • The right to correct inaccurate data or to complete the correct data in accordance with Article 16 of the GDPR,
  • The right to delete your data stored with us in accordance with Article 17 of the GDPR,
  • The right to limit the processing of your data in accordance with Article 18 of the GDPR,
  • The right to data portability in accordance with Article 20 of the GDPR.

6.2. RIGHT TO CONTEST

Under the conditions provided for in Article 21, paragraph 1 of the GDPR, it is possible to withdraw your consent to the processing of data for reasons relating to the particular situation of the data subject.

 

Le general right of objection above applies to all processing purposes described in this Privacy Policy based on Article 6, paragraph 1, point f) of the GDPR. Apart from the special right of objection regarding the processing of data for advertising purposes (see point 3.3 above), the GDPR requires us to implement a general right of objection only if you provide us with reasons which are of paramount importance. (for example, danger to life or health). In addition, you can also contact our competent supervisory authority: Commissioner for Data Protection and Freedom of Information Berlin, Friedrichstraße 219, 10969 Berlin, Germany.

  1. Data security

We use the highest standards of information security for our infrastructure and the processing of your data. For example, we use computer protection mechanisms, such as firewalls and data encryption. Our buildings and data are subject to physical access controls. Only employees who need access to our customers' personal data to carry out their activities can access it.

 

All data that you personally transmit to us, including your payment information, is transmitted via the general and secure standard SSL (Secure Socket Layer). SSL is a secure and proven standard, which is used in particular for online banking transactions. You will recognize an SSL connection in particular by noticing the s after http (https://…) in the address bar of your browser or at the lock symbol at the bottom of the browser.

 

For the rest, we use appropriate technical and organizational security measures to protect your personal data stored with us against manipulation, partial or complete loss and unauthorized access by third parties. Our security measures are constantly monitored against technological progress, regularly adapted to the respective risks and, if necessary, improved.

  1. Children's Privacy Policy.

Protecting the privacy of young children is particularly important. For this reason, we do not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow them to register. If you are under 16, please do not send us any information about yourself, including your name, address, telephone number or email address. No one under the age of 16 is permitted to provide any personal information to the Services. If we learn that we have collected personal information from a child under the age of 

 

16 years old without verification of parental consent, we will delete this information as soon as possible. If you believe we may have any information about or relating to a child under 16, please contact us at hello@ninaperfectskin.com

 

 

  1. Changes to our privacy policy.

If we change our privacy policy and procedures, we will post those changes on our website to let you know what information we collect, how we use it, and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on our website.

 

 

 

Last update 19/07/2022