PRIVACY POLICY

Updated April 2019

At Nuaroma SKINCARE, we take the protection for your Personal Information (such as name; address; phone number; date of birth; e-mail address; credit card number; gender; language preference; and merchandise category preferences) very seriously.

We collect Personal Information that you provide to us voluntarily and process it for the following purposes ("Purposes"):

To complete transactions with you and manage your membership of our customer loyalty scheme where applicable;
to direct market to you, with your permission;
to understand and analyze our sales, and your needs and preferences;
to develop, enhance, market and provide products and services to meet your needs;
to enable you to participate in promotions and contests;
to enable you to participate in customer research or focus groups;
to process exchanges or product returns;
to improve our shops; and,
to respond to requests or complaints.

We may hold or process such Personal Information securely anywhere in the world, for as long as is necessary for the Purposes and we may only share it with franchisees, subsidiaries and subcontractors of Nuaroma SKINCARE. We use Secure Sockets Layer (SSL) technology to protect your credit card information online.

Subject to your consent we may communicate with you through a variety of channels, including through our stores, our customer loyalty schemes, and through the internet, and through a variety of means such as post, email, phone, fax, or text message, subject to your preference. You may unsubscribe at any time by writing to us in the manner explained in our communications or by contacting us as set out in section 14.1 below.

We have a designated Information Officer in our global headquarters, responsible for compliance with this policy and with all applicable laws.

Our web sites make use of cookies as well as beacons to help us provide a better user experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of our web site and your ability to access certain features of the site or to engage in transactions.

1. OUR APPROACH TO PRIVACY

1.1. At Nuaroma SKINCARE, we recognize that the protection of your Personal Information is a very important principle in building trust and maintaining a good relationship with you. In this Privacy Policy the first person ("we", "our", "us", "ours") denotes Nuaroma SKINCARE(002846618-U) or any of its affiliates and subsidiaries all connected to Nuaroma SKINCARE® brand responsible for the collection of the Personal Information and bound by this Privacy Policy. The second person ("you", "your", "yours") denotes you as the customer, or generally the individual providing Personal Information or any other information, being the subject matter of this Privacy Policy.

1.2. This Privacy Policy details our commitments and your rights regarding the Processing of your Personal Information in line with applicable legislation.

1.3. We are responsible for the Personal Information under our control, including Personal Information disclosed by us to a Vendor (often referred to as the data processor). "Vendor" in this Privacy Policy means in relation to Personal Information any person or entity (other than an employee of Nuaroma SKINCARE who Processes the Personal Information on behalf of Nuaroma SKINCARE "Processing", in relation to Personal Information, means for example obtaining, recording, holding or using the Personal Information anywhere in the world or carrying out any operation or set of operations on the Personal Information, including (a) organisation, adaptation or alteration of the Personal Information, (b) retrieval, consultation or use of the Personal Information, (c) disclosure of the Personal Information by transmission, dissemination or otherwise making available, or (d) alignment, combination, blocking, erasure or destruction of the information or data; As a global business we wish to be able to communicate with our customers worldwide, and may have to process customer personal data anywhere in the world. This policy complies with the highest legal standards around the world, and in particular, among others, with European data protection legislation, which generally sets some of the highest standards worldwide for the protection of personal data. We may disclose Personal Information outside of the jurisdiction from which it was collected. In the conduct of our business, we transfer to, hold or access Personal information from various countries including Australia and the European Economic Area. The data protection laws of those countries may not provide an equivalent level of protection to those in which the Personal Information was collected. However, this does not change our commitments to safeguard your privacy and we will arrange for appropriate security measures to be in place to ensure a comparable level of protection for your Personal Information. In particular we will abide by this Privacy Policy when transferring your Personal Information outside of the jurisdiction in which it was collected and will make sure that recipients of data disclosures outside of the of the jurisdiction in which it was collected are aware of this Privacy Policy and comply with it and all applicable laws relating to cross-border data disclosure.

1.4. In certain specific instances, this Privacy Policy may also be supplemented by additional policies and terms, or by short Privacy Statements used in connection with particular purpose(s) or on various forms, which we may identify to be applicable.

1.5. We designate one or more persons ("Information Officer") in our headquarters (at Selangor, Malaysia). We also have local contact details for any Privacy Policy related matters as set out in Sungai Buloh(Contacting Us) below.

1.6. We take every measure to provide a comparable level of protection for Personal Information should the information be Processed by a Vendor.

1.7. By providing your Personal Information, you consent to the collection and use or otherwise Processing (including disclosure) of your Personal Information in the manner and for the Purposes described in this Privacy Policy.

2. ABOUT INFORMATION COLLECTION

2.1. We communicate with you through a variety of means and channels, including through our stores, our customer loyalty schemes, through the internet (via our information or selling web sites) or through our direct selling business and whether by post, email, phone, fax, or text messaging on your mobile phone, although we do generally note that our preferred means of communication is email which has the least impact on the environment. Such communications may involve giving to you, as well as receiving information from you. Some of the information that we receive is personally identifiable information (as defined in section 3 below), while some information (particularly information collected through your access of our web sites) is non-personally identifiable information (as described in section 4 below). This Privacy Policy is primarily concerned with the Processing of Personal Information

2.2. We provide you with information that explains why the Personal Information is needed and how the Personal Information will be processed.

2.3. We usually collect personal information through:

2.3.1 our websites;

2.3.2 use of social media;

2.3.3 orders for products or services;

2.3.4 third party service providers;

2.3.5 requests for brochures, to join a mailing list or to be contacted for further information about our products or services;

2.3.6 warranty claims;

2.3.7 provision of customer service and support;

2.3.8 responses to surveys or research conducted by us or on our behalf;

2.3.9 entries into competitions or trade promotions conducted by us or on our behalf;

3.PERSONAL INFORMATION

3.1. We at Nuaroma SKINCARE limit the amount and type of information that we collect to that which is necessary for the identified purposes and do not collect your Personal Information unless you (directly or indirectly) provide it to us voluntarily.

3.2. Although the precise details of the Personal Information collected will vary according to the specific purpose, we may typically collect the following Personal Information from or in relation to you:

3.2.1. name;

3.2.2. address;

3.2.3. phone number(s);

3.2.4. date of birth;

3.2.5. email address;

3.2.6. credit card number;

3.2.7. gender;

3.2.8. language preference; and merchandise category preferences

3.2.9. identity card number or national insurance number (only in markets where this is appropriate pursuant to local law or custom)

4. NON-PERSONALLY IDENTIFIABLE INFORMATION

4.1. Where we collect information through our web sites, as is the case with many other web sites, we automatically collect certain non-personal information regarding web site use that does not identify you. Examples include the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access the web site, the internet address of the web site from which you linked directly to our web site, the operating system you are using, the sections of the web site you visit, the web site pages read and images viewed, and the content you download from our web site.

4.2. We may use non-personal information to compile tracking information reports regarding site user demographics, site traffic patterns, and site purchases. None of the tracking information in the reports can or will be connected to the identities or other Personal Information of individual users.

4.3. In this way, your visit to our web site will be logged; however, you will remain anonymous to us unless you specifically choose to share information with us. We use this information about the way in which our customers use our website to better understand which features are most popular and best meet the needs of our visitors.

5. WHEN IS PERSONAL INFORMATION COLLECTED AND HOW IS IT USED?

5.1. We at Nuaroma SKINCARE collect Personal Information for the following purposes ("Purposes"):

5.1.1. to complete transactions with you and to administer sales and to manage your membership with our customer loyalty scheme (if you become a member);

5.1.2. to direct market to you, with your permission;

5.1.3. to understand and analyze our sales, and your needs and preferences;

5.1.4. to develop, enhance, market and provide products and services to meet your needs;

5.1.5. to enable you to participate in promotions and contests;

5.1.6. to enable you to participate in customer research or focus groups;

5.1.7. to process exchanges or product returns;

5.1.8. to improve our Shops; and,

5.1.9. to respond to requests or complaints

5.1.10. to enable you to participate in our customer loyalty schemes and manage your membership thereof

5.2. We only keep Personal Information for as long as is necessary to satisfy the specified purposes, for which it was collected. We retain Personal Information in accordance with our own guidelines, procedures and principles and in line with applicable law

5.3. We may disclose your Personal Information to a Vendor as explained in section 1.3 above. These subsidiaries will treat your Personal Information as confidential, in accordance with this Privacy Policy and with all applicable Data Protection legislation and will process such Personal Information only for the purposes and within the terms set out herein.

5.4. We may disclose your Personal Information if we are required to do so by law or requirement of a competent authority.

5.5. In addition to the above, we may from time to time work on specific initiatives with carefully selected third party companies/organisations (outside of Nuaroma SKINCARE) to share opportunities with you. If we do this, we will inform you at the time of such initiatives that, if you decide to submit any Personal Information it will be shared with those selected companies/organisation and will only do so with your prior consent.

5.6. You will always be given the opportunity to consent (opt in) to your information being shared pursuant to section 5.5, and the selected companies/organisation will be sufficiently identified to allow you to make an informed decision. If you do consent (opt in) and subsequently visit such companies'/organisations' websites we cannot control how they use or otherwise process any Personal Information you provide directly to them. We always encourage you to check their sites' terms and conditions and privacy policy before you give out any Personal Information.

5.7.If you do consent (opt in) to receive these communications you may unsubscribe at any point in the future by contacting us as provided at section 6.4 below.

5.8. We will only use your Personal Information for a purpose that has been specified prior to its use or where the Processing of your Personal Information is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract or Processing is necessary for other legal purposes.

5.9. As we develop our business, we might sell or buy Shops or assets. In such transactions, Personal Information may be one of the transferred business assets. Also, in the event that The Body Shop or substantially all of its assets are acquired, data files containing Personal Information will be one of the transferred assets.

6. CUSTOMER CONSENT (OPT IN - UNSUBSCRIBE)

6.1. Opt In: We at Nuaroma SKINCARE will not use your Personal Information for a purpose that has not previously been specified, unless we have previously obtained your consent or unless such purpose is required by law.

6.2. Consent to provide Personal Information is not a condition for our selling a product to you, unless the information requested is required to fulfill an explicitly specified and legitimate purpose.

6.3. In particular we will seek your explicit prior consent (opt in) before sending to you marketing communications (see section 5.1.2 above).

6.4. Unsubscribe: At any time, you can withdraw your consent to our collection, use or disclosure (generally Processing) of your Personal Information by (i) contacting us as set out in section 14.1 below, or (ii) writing to us in the prescribed manner (whether by email or post, or by text messaging etc), as specified in our communications to you, or in relevant forms that you might have signed (e.g. for our customer loyalty scheme). If you have any concerns whatsoever, with regard to the unsubscribe functionality that we make available to you, pursuant to this section, please contact us at the address or medium shown in section 14 below.

6.5. If you have previously opted into receiving commercial communications from us pursuant to 6.3 above, while also becoming a member of our loyalty scheme, should your membership to such scheme comes to an end for whatever reason, we will not take this to imply an automatic request to unsubscribe, and we will assume that we have your continued consent, unless you specifically unsubscribe, as is provided for in section 6.4.

7. ACCURACY OF INFORMATION

7.1. We at Nuaroma SKINCARE keep Personal Information as accurate, complete and up-to-date as necessary, taking into account its use and the interests of our customers.

8. ACCESSING AND UPDATING PERSONAL INFORMATION

8.1. Customers have a qualified right to access, rectify, delete, or object (to the processing of) your Personal Information held by us and to receive an account of its use and disclosure. We recommend that all customer requests for access to Personal Information held by Nuaroma SKINCARE(002846618-U) be made in writing, although we will not impose a formal requirement in this regard. However, we may require you to provide us with additional information reasonably necessary for us to satisfy your request.

8.2. Responding to a customer request (under section 14 below) for information will usually be done at no or minimal cost to the customer. However, a fee for reasonable costs incurred may be charged in responding in writing. The Personal Information requested is provided to the customer in a form that is generally understandable.

8.3. We amend the Personal Information contained in our database or elsewhere as required when an individual successfully demonstrates the inaccuracy or incompleteness of the Personal Information. An amendment may involve the correction, deletion or addition of information and notification to third party to whom the data have been disclosed. However, we may be unable to amend past purchase information or return transaction information.

9. EFFECTIVE DATE AND CHANGES TO THE PRIVACY POLICY

9.1. This Privacy Policy is effective as of December 2018.

9.2. We reserve the right to change our Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post those changes on our Homepage so our users are always aware of what information we collect from them, how we use it, and under what circumstances, if any, we disclose this information to third parties. Homepage in this Privacy Policy means the homepage of the corporate web site of Nuaroma SKINCARE web site.

9.3. If at any point we decide that we wish to use Personal Information for any purpose other than, or in addition to the Purpose(s) listed in this policy (section 5 above) or from that stated at the time this information was collected, we will notify you by way of an email, unless we do not have your email address, in which case we will use any other means of communication available to us depending on the contact details that you have provided to us. We will only proceed with such use, if we receive your consent with respect to such additional purposes (not previously communicated, or not previously included in this policy).

10. HOW DO WE KEEP YOUR INFORMATION SECURE?

10.1. We at The Body Shop protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Information, regardless of the format in which it is held.

10.2. We use various methods to safeguard Personal Information. They include:

10.2.1. physical measures: locked filing cabinets, restriction of access to offices, and company alarm systems.

10.2.2. technical tools: passwords and encryption, using generally industry best practices.

10.2.3. organizational controls: confidentiality agreements, limiting access on a need-to-know basis, staff training and security clearances.

10.3. Online security is also a priority. Nuaroma SKINCARE incorporates security measures such as encryption and authentication tools to protect your Personal Information from unauthorized use. Firewalls are utilized t protect our servers and network from unauthorized users accessing and tampering with files and other information that we store.

10.4. We use Secure Sockets Layer (SSL) technology to protect your credit card information online. Upon entering the checkout page your computer will begin communicating with our server in secure mode. You will be able to tell that you are in secure mode because the "http" in the web address on your browser will change to "https".

10.5. In particular, with regard to credit card information, The Body Shop as a global retailer has signed up to and aims to comply - to the extent relevant to its type of business - with the Payment Card Industry Data Security Standard (PCI DSS) which is managed by the PCI Security Standards Council (which has been founded by American Express, Discover Financial Services, JCB, MasterCard Worldwide, and Visa International) and in order to improve credit card security for our customers. The PCI DSS is a multifaceted security standard that includes requirements for security management, policies, procedures, network architecture, software design and other critical protective measures with a view to achieving ongoing development, enhancement, storage, dissemination and implementation of high security standards for account data protection. For more details on PCI DSS please refer to:https://www.pcisecuritystandards.org/.

11. MATTERS SPECIFIC TO THE INTERNET

11.1. Links to Other Websites

11.1.1. The Web Site or any of Nuaroma SKINCARE various other web sites may contain links to other third party owned and operated web sites or internet resources. When you click on one of those links you are contacting another web site or internet resource. We have no responsibility or liability for or control over those other web sites or internet resources or their collection, use and disclosure (processing) of your Personal Information.

11.1.2. We encourage you to read the privacy policies of those other sites to learn how they collect and use information about you.

11.2. Cookies - Beacons

11.2.1. Our web sites make use of cookies as well as web beacons.

11.2.2. Cookies are small text files generated when you visit our web sites or use our online services that reside on your computer and can uniquely identify your browser. We use three types of Cookies: (a) a Session Cookie is used whilst you are viewing the web site and expire after you leave the web site. (b) a Registration Cookie is a small file that is generated when you register (log on) onto the web site and remains on the computer you registered from and is used to recognize you when you register (log on) again to the web site using the same computer. We use cookies on our web site to allow you to set your individual preferences and to help us provide a better user experience. (c) Third-party cookies of suppliers who set their own cookies on our website with our permission to enhance customer experience and functionality and to deliver the services that they are providing. For more information about this type of cookie and the possibilities to opt-out, refer to their individual privacy policies here.

11.2.3.Cookies also help us to study traffic patterns on our web site, store user preferences and track user trends on our web site, so that we can understand which parts of our web site are popular and make browsing an even more rewarding experience for our users. We may also use cookies when you register on line for services or information.

11.2.4. You may choose to decline cookies if your browser permits, but doing so may affect your use of our web site and your ability to access certain features of the site or to engage in transactions.

11.2.5. Tracking tags/Beacons: Each web page in our web sites contains tracking pixels that allow us to follow your progress through the various pages within the web site. This information is then aggregated (de personalised) before being analysed.

12. CHILDREN

12.1. We will never knowingly collect or solicit Personal Information from individuals under the age of sixteen (16) without first obtaining verifiable parental consent. If you are under the age of 16 you should not provide information to us. If we become aware that a person under 16 has provided Personal Information to us without verifiable parental consent (as may be the case where the information is provided via one of our web sites), we will remove such Personal Information from our files.

13. COMPLIANCE WITH THE LAW

13.1. Nuaroma SKINCARE has procedures in place in order to receive and respond to enquiries about Nuaroma SKINCARE policies and practices relating to its handling of Personal Information. Any complaint or enquiry should be made in writing and addressed as shown in section 14 below.

13.2. Nuaroma SKINCARE investigates all complaints and will use reasonable endeavours to respond to you in writing within 30 days of receiving the written complaint. Requests will be forwarded to the Information Officer. If the complaint is found to be justified, Nuaroma SKINCARE will take appropriate measures to resolve the matter, including, if necessary, amending its policies and practices. If we fail to respond to your complaint within 30 days of receiving it in writing or if you are dissatisfied with the response that you receive from us, you may have the right, depending on the jurisdiction, to make a complaint to the applicable regulator.

14. CONTACTING US

14.1. If there are any questions or concerns regarding this Privacy Policy or the data collection practices outlined herein, please contact us as follows:

By Email: e2nuaroma@gmail.com

By Phone:+6 017 673 4145(Monday to Friday between 9am - 5.30pm)

By Mail:
(Attn: Nuaroma SKINCARE)No 11, Jalan SU 16, Taman Selayang Utama, 68100, Batu Caves, Selangor, Malaysia.

14.2. You are reminded not to send via unencrypted means (such as email) sensitive information such as passwords, credit card information etc.