Privacy Notice
1. 
Table of Content
1. Table of Content
2. Overview
3. Who we are and how to contact us
4. What Personal Data do we collect?
5. How we use your Personal Data
6. Sharing and transferring your Personal Data
a. We do not sell your Personal Data
b. We do not disclose your Personal Data to third parties for their own direct marketing purposes
c. If you are a Brand Affiliate or Customer, we may share your Personal Data with other Brand Affiliates
d. We may share your Personal Data within the Nu Skin group
e. We may share your Personal Data to our trusted third-party suppliers who may process it on our behalf
f. We may also disclose your Personal Data to other third parties
7. International Transfers
a. International data transfers
b. EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
8. How we protect your Personal Data
9. How long do we keep your Personal Data
10. What are your rights regarding your Personal Data
11. Your marketing choices
12. Your obligations
13. Children
14. Changes to the Privacy Notice
Annex 1 – List of Nu Skin entities responsible for processing your Personal Data
Annex 2 - List of personal data processing activities
2. Overview
At Nu Skin, we want to set the standard for the industry in data protection. To that end, Nu Skin is committed to respecting and protecting your privacy rights and your choices and to treating your Personal Data with the utmost care in all circumstances.
Our Privacy Notice is designed to provide transparency into our privacy practices and principles in a format that is easily understandable and readable.
This Privacy Notice explains how we process the Personal Data we collect about you
- when you buy and/or use our products, services and mobile applications,
- when you browse our Websites and social media content,
- when you participate in events organized by us,
- when you visit our premises, or
- when you apply for a job at Nu Skin.
Please ensure you read this Privacy Notice carefully before using our Websites or mobile applications and/or providing us with your Personal Data.
3. Who we are and how to contact us
Nu Skin Enterprises Inc. and its affiliates and subsidiaries (“Nu Skin”, “we”, “us” and “our”) are an international group of companies offering personal care products, nutritional supplements, devices and other goods or services through (i) the Nu Skin websites (whether local or global) (each a “Website”), (ii) Nu Skin mobile applications and tools (the “Apps”) and (iii) a network of independent distributors or sales people (“Brand Affiliates1”).
Depending on who you are or how you interact with us, your Personal Data are processed by different entities of Nu Skin and/or for different purposes. You will find here (Annex 1) the list of the Nu Skin entities acting as data controllers responsible for processing your Personal Data. Please contact the Privacy Team or our Data Protection Officer [DPOoffice@nuskin.com] if you have questions or concerns, want to update your Personal Data, or to exercise your rights as described below.
1 Referred to as “Business Partners” in Mainland China and “Brand Member” in Japan.
4. What Personal Data do we collect?
Personal Data, or Personal Information, means any information or pieces of information that could identify you directly (e.g. your name) or indirectly (e.g. through your email address or telephone number).Personal Data may include a name, an (email) address, a telephone number, credit card information, preferences, age, gender, or occupation, among other things.
The Personal Data that we collect, and how we collect it, depends on how you interact with us. For a complete overview of the Personal Data we process about you, as well as our interaction-specific data processing activities, and our processing purposes, please refer to our “List of Personal Data Processing Activities”, here.
We might collect or receive Personal Data from you via our Website, Apps, social media channels, call center or when you otherwise transfer Personal Data to us. Sometimes you give this Personal Data to us directly (e.g. when you create an account, when you contact us, when you purchase from our Website), and sometimes we collect it (e.g. using cookies to understand how you use our Website and Apps, or through our smart devices).
In some circumstances we may also receive Personal Data about you from:
- Brand Affiliates;
- individuals who provide us with your Personal Data (e.g. your family members);
- regulatory bodies;
- other companies providing services to us (e.g. social listening companies; past employers; recruitment agencies).
Some of these third-party sources may include publicly available sources of information. In particular, we may receive Personal Data from social networks when you engage with our content, reference our Website, or grant us permission to access information from these social networks.
In addition, where permitted by law, we may collect, either directly or through third party service providers, information that is publicly available on the Internet (e.g. from websites, blogs, social media).
5. How we use your Personal Data
We process your Personal Data based on the following legal grounds, as permitted by applicable law:
- to fulfill our obligations under a contract with you, or to take steps prior to entering into a contract with you (e.g. you ask us to create a customer account for you or you wish to purchase a product from us);
- to comply with a legal obligation (e.g. when you make a purchase we need to keep your transaction information to comply with our tax, financial reporting, and consumer protection obligations);
- when it is in our legitimate business interest to use your Personal Data (e.g. to operate, evaluate and improve our organization; to prevent and protect us and others against fraud, unauthorized transactions, claims and other liabilities; to ensure compliance with company policies and industry standards);
- based on your consent (e.g. when you opt-in to subscribe to our marketing newsletters).
Our use of your Personal Data depends on who you are and how you interact with us. Click here for a list of the ways that we use your Personal Data, and which of the reasons we rely on to do so.
We will only process special categories of Personal Data (e.g., race or ethnicity; health-related data) when you request us to do so (i.e. when we have your explicit consent) or in exceptional circumstances and where we have a legal basis to do so (e.g., to protect your vital interests).
Please contact the Privacy Team if you have any questions about how we collect and use your Personal Data.
6. Sharing and transferring your Personal Data
When we share your Personal Data as described below, we will take the necessary steps to ensure that any third-party recipients have implemented reasonable security mechanisms to protect your Personal Data.
a. We do not sell your Personal Data
First, we want to be clear that we do not and will not sell your Personal Data to third parties; and in the past 12 months, we have not sold your Personal Data to any third party.
b. We do not disclose your Personal Data to third parties for their own direct marketing purposes
Also, we do not disclose your Personal Data to third parties for their own direct marketing purposes. However, if you direct us to share your Personal Data with third-party sites or platforms, such as social networking sites, these third-party sites or platforms could potentially use your data for marketing reasons.
c. If you are a Brand Affiliate, we may share your Personal Data with other Brand Affiliates2 and customers
With your Downlines – If you are a Brand Affiliate, we may transfer your Personal Data to your personally sponsored customers and Brand Affiliates (“Downlines”) in order to enable them to reach out to you for support, training and product recommendations. The Personal Data we make available to your Downlines may include your name, profile picture, and contact details. If you do not want your Downlines to have access to your Personal Data, you can edit your privacy settings in V&G, your account or by contacting customer care.
With your Uplines – We may also transfer your Personal Data to your sponsor, upline Brand Affiliates and upline Brand Representative (“Uplines”) so that they can reach out to you and provide you with business and/or product support and training, . The Personal Data we make available to your Uplines may include your account information (name, photo, birthday, contact details), business information (market, overall purchase volume and volume generated by your ADR contract (auto-ship) and date it is scheduled to ship, pin title, activity dates) and your order information including your purchases (product name, quantity, volume, price, order tracking, ship to details), as well as auto-ship contract details (product name, quantity, price, ship to details). You can manage what Personal Data is shared with which Uplines by editing your privacy settings in V&G, your account, or by contacting customer care. In addition, we may inform your Uplines about your qualification to our incentive trips.
d. If you are a customer, we may share your Personal Data with certain Brand Affiliates
We may transfer your Personal Data to your sponsor, upline Brand Affiliates and upline Brand Representative (“Uplines”) so that they can reach out to you and provide you with product support and recommendations. The Personal Data we make available may include your account information (name, photo, birthday, contact details), and your order information including your purchases (product name, quantity, volume, price, order tracking, ship to details), as well as auto-ship contract details (product name, quantity, price, ship to details). You can manage what Personal Data is shared with your sponsor by editing your privacy settings in your account, or by contacting customer care.
e. We may share your Personal Data within the Nu Skin group
Your Personal Data may be accessed within Nu Skin. This means that we may share your Personal Data across the Nu Skin group of companies, which includes our ultimate parent company and its affiliates and subsidiaries. Access will always be controlled on a need-to-know basis, and only provided where it is necessary to provide you with requested services or to allow us to perform any necessary or legitimate functions (including for operational, management, administrative, supervisory or evaluative or educational purposes). You may consult the list of Nu Skin entities that may receive your data here (Annex 1) and a list of data processing purposes and categories here (Annex 2).
f. We may share your Personal Data to our trusted third-party suppliers who may process it on our behalf
We rely on trusted third parties to perform a range of business operations on our behalf. We always use our best efforts to ensure that all third parties we work with will keep your Personal Data secure. We only provide them with the information they need to perform the service, and we require that they do not use your Personal Data for any other purpose. For example, we may entrust services that require the processing of your Personal Data to:
- Third parties that assist and help us in providing digital and e-commerce services such as social listening, store locator, loyalty programs, identity management, ratings and reviews, CRM, web analytics and search engine, user generated content curation tools;
- Advertising, marketing, digital and social media agencies to help us deliver advertising, marketing, and campaigns, to analyze their effectiveness, and to manage your contact, questions and our relationship;
- Third parties required to deliver a product to you (e.g. postal/delivery services);
- Third parties that assist and help us in providing IT services, such as platform providers, hosting services, maintenance and support on our databases as well as on our software and applications;
- Third parties that assist in maintaining the security of our systems, Websites and Apps;
- Third parties that provide us with consulting services in the field of market research and analytics, collect feedback and conduct market surveys on our products, services and otherwise for customer relationship management purposes;
- Payment service providers and credit reference agencies for the purpose of assessing your credit score and verifying your details where this is a condition of entering into a contract with you;
- Third parties that assist us for customer care and cosmetovigilance and pharmacovigilance purposes;
- Third parties that assist us for the organization of events, incentive trips, meetings, etc. in which you may participate;
- Lawyers, auditors, financial advisors, and other third party service providers in connection with their services to Nu Skin.
g. We may also disclose your Personal Data to other third parties
If Nu Skin or a part of its assets are acquired by a third party, Personal Data we hold relating to those assets will be one of the transferred assets. In such cases, your Personal Data will be processed by the buyer acting as the new controller and its privacy policy will govern the processing of your Personal Data.
We may also disclose your Personal Data to any regulatory, statutory, governmental or other relevant authorities, agencies or bodies and industry regulators, and any other person to whom Nu Skin is compelled, required or permitted to do so by law, rules or regulations, legal process or litigation, or to any person pursuant to any order of a court of competent jurisdiction or comparable legal process.
In other circumstances if we have your consent or we are permitted to do so by law.
2 Does not apply to Mainland China.
7. International Transfers
a. International data transfers
You understand and agree that we may transfer Personal Data to other jurisdictions as necessary for the purposes described in this Privacy Notice, including to jurisdictions that may not provide the same level of data protection as the jurisdiction in which your Personal Data was originally collected. For instance, we may transfer your data to the U.S. because our parent companies are located there.
When we transfer your Personal Data to other countries or jurisdictions, we will protect that data as described in this Privacy Notice and in accordance with applicable law. Where required under applicable law, we will put in place binding contractual obligations with the data recipient to safeguard your data protection rights. Furthermore, we will notify any data transfer and/or data transfer mechanisms to the competent Supervisory Authority where required under applicable law.
With respect to transfers originating from the European Economic Area ("EEA") to the United States and other non-EEA jurisdictions, we implement standard contractual clauses approved by the European Commission, and other appropriate solutions to address cross-border transfers as required or permitted by Articles 46 and 49 of the General Data Protection Regulation. Please contact the Privacy Team, if you have any questions with respect to the safeguards we have put in place to protect your Personal Data when we transfer this (including how to obtain a copy of or consult these safeguards).
b. EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Nu Skin International Inc. (NSI) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Prior to July 16, 2020, Nu Skin relied on its EU-US Privacy Shield certification as one means of demonstrating adequacy and safeguarding transfers of data from the EU. In addition to Privacy Shield, Nu Skin also executed Standard Contractual Clauses with entities involved in such data transfers. As of July 16, 2020, Nu Skin has primarily relied on Standard Contractual Clauses for EU and UK transfers. For transfers occurring prior to July 16, 2020, Nu Skin will continue to be responsible for the processing of EU and UK Personal Information under the EU Privacy Shield Framework and will maintain full compliance with the requirements of that framework until further notice. Subsequent transfers of EU or UK Personal Information to any third-party acting as an agent on our behalf occurring after July 16, 2020, will be under the terms of the EU Commission’s Standard Contractual Clauses. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.
Nu Skin is responsible for both the processing of Personal Data it has received, under each Privacy Shield Framework, and the subsequent transfers to a third party acting as an agent on its behalf. Nu Skin complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to Personal Data received or transferred pursuant to the Privacy Shield Frameworks, Nu Skin is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
8. How we protect your Personal Data
We protect your Personal Data and implement reasonable security measures including physical (e.g. secured filing cabinets), technical and organizational security measures appropriate to protect your Personal Data against unauthorized or unlawful processing and against any accidental loss, destruction, or damage.
In particular, we operate data networks protected by industry standard firewall and password protection systems. We also use transport layer security (TLS) to protect the transmission of your Personal Data. 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.
9. How long do we keep your Personal Data
We hold on to your Personal Data for as long as necessary to achieve the processing purposes described in our “List of Personal Data Processing Activities”.
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.
Generally, and while this will depend on several factors as outlined below, we do not keep your data for longer than 10 years. To determine the retention period of your Personal Data, we consider several criteria, including:
- The purpose for which we hold your Personal Data;
- Our legal and regulatory obligations in relation to that Personal Data, for example any financial reporting obligations;
- Whether our relationship with you is ongoing, for example, you have an active account, you continue to receive marketing communications, or you regularly browse or purchase off our Website or Apps);
- Any specific requests from you in relation to the deletion of your Personal Data; and
- Our legitimate interests in relation to managing our own rights, for example the defense of any claims.
When we no longer need to use your Personal Data, it is removed from our systems and records, or anonymized so that you can no longer be identified from it.
10. What are your rights regarding your Personal Data
Nu Skin values your privacy rights and is committed to providing you control over your Personal Data. If you exercise any of these rights explained in this section of the Privacy Notice, we will not disadvantage you. You will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services.
Generally, you have the following rights:
- Information. You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Data, and your rights. This is why we are providing you with the information in this Privacy Notice;
- 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, subject to certain exceptions, for instance, where we need to keep your Personal Data to comply with a legal obligation;
- 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;
In addition, if you are in the EEA or in Thailand you have the following rights:
- Restriction. You have the right to request that we restrict our processing of your Personal Data under specific conditions (also applicable if you are in Macau; in Korea, this right is known as the right to request the suspension of the processing of your Personal Data);
- Portability. You have the right to request that we transmit the Personal Data we hold in respect of you to you or to another data controller under specific conditions;
- Objection. Where the legal justification for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
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. California residents can also call the following toll-free number: 800-487-1000. 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 a resident of the European Economic Area and 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 (for example, with the Supervisory Authority in your country or market of residence).
11. 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 or remain on a mailing list to which you previously subscribed, please follow the unsubscribe link in the relevant communication or contact the Privacy Team.
12. 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 as well as Nu Skin Policies & Procedures, if you use a credit card not issued to you, you confirm that the credit card holder has consented to the use of their credit card in relation to your purchase and has agreed that Nu Skin may collect, use and disclose their 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.
13. Children
Nu Skin does not direct the sale of its products or services to children, nor does it allow its Brand Affiliates to be underage (under 18 in most markets; under 20 in Japan and under 19 in Korea).Nu Skin children’s products can only be purchased by an adult. If you are a minor, you may use the Website only with the involvement of a parent or guardian.
Except in very limited circumstances (e.g. as part of our Corporate Social Responsibility activities), 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 18. 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 they explore the Internet.
If you register your child to a Nu Skin event or incentive trip, we process your child’s Personal Data for the purposes of attending the event or incentive trip. If the event requires processing of your child’s special category data, we will request your explicit consent.
14. 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.
The Privacy Notice was last revised on February 24, 2023.
Annex 1 – List of Nu Skin entities responsible for processing your Personal Data
The table below lists the relevant Nu Skin legal entities responsible for the processing of your Personal Data. Depending on your interactions with us and/or your location, one or more different Nu Skin entities might be responsible for such processing.
Please note that when fields include a “/”, this means that we do not collect or otherwise process Personal Data for that data subject category in a given country/market.
Where a field includes more than one data controller, this means that we have more than one Nu Skin entity in that country/market and the controller responsible will be the entity that you have a relationship with (e.g. because you visited or applied with that specific Nu Skin office).
To find out which Nu Skin entity is the data controller responsible for your Personal Data, you need to determine:
1) In which category of data subject you fall:
2) Your country or market:
|
If you do not fall in one of the categories mentioned above, for instance because you do not have any, or no longer have a relationship with us, then Nu Skin International Inc. will be responsible for your Personal Data.
The last page of this Annex 1 contains the contact details of all entities listed herein. Please contact the Privacy Team if you have questions or concerns about this.
Country/market |
Customer |
Brand Affiliate/Business Partners |
Job Candidate |
Office visitor |
Argentina |
Nu Skin International Inc. and Nu Skin Argentina as joint controllers |
Nu Skin International Inc. and Nu Skin Argentina as joint controllers |
|
|
Australia |
Nu Skin International Inc. and Nu Skin Enterprises Australia, Inc as joint controllers |
Nu Skin International Inc. and Nu Skin Enterprises Australia, Inc as joint controllers |
Nu Skin Enterprises Australia, Inc. |
Nu Skin Enterprises Australia, Inc. |
Austria |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
Belgium |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin Belgium NV and NSE Products Europe BV as joint controllers |
Nu Skin Belgium NV or NSE Products Europe BV |
Nu Skin Belgium NV or NSE Products Europe BV |
Brunei |
Nu Skin International Inc. and NuSkin Pharmanex (B) Sdn Bhd as joint controllers |
Nu Skin International Inc. and NuSkin Pharmanex (B) Sdn Bhd as joint controllers |
NuSkin Pharmanex (B) Sdn Bhd |
NuSkin Pharmanex (B) Sdn Bhd |
Canada |
Nu Skin International Inc. and Nu Skin Canada |
Nu Skin International Inc. and Nu Skin Canada |
|
|
Chile |
Nu Skin International Inc. and Nu Skin Chile |
Nu Skin International Inc. and Nu Skin Chile |
|
|
Colombia |
Nu Skin International Inc. and Nu Skin Colombia |
Nu Skin International Inc. and Nu Skin Colombia |
|
|
Czech Rep |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
Denmark |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin Scandinavia A/S |
Nu Skin Scandinavia A/S |
Finland |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
France |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
French Polynesia |
Nu Skin International Inc., Nu Skin Enterprises New Zealand, Inc., as joint controllers |
Nu Skin International Inc. and Nu Skin Enterprises New Zealand, Inc., as joint controllers |
|
|
Germany |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin Germany GmbH |
Nu Skin Germany GmbH |
Hong Kong/Macau |
Nu Skin International Inc. and Nu Skin Enterprises Hong Kong, LLC as joint controllers |
Nu Skin International Inc. and Nu Skin Enterprises Hong Kong, LLC as joint controllers |
Nu Skin Enterprises Hong Kong, LLC |
Nu Skin Enterprises Hong Kong, LLC |
Hungary |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin Eastern Europe kft. |
Nu Skin Eastern Europe kft. |
Iceland |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
Indonesia |
Nu Skin International Inc. and PT Nusa Selaras Indonesia as joint controllers |
Nu Skin International Inc. and PT Nusa Selaras Indonesia as joint controllers |
PT Nusa Selaras Indonesia or PT Nu Skin Distribution Indonesia |
PT Nusa Selaras Indonesia or PT Nu Skin Distribution Indonesia |
Ireland |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
Israel |
Nu Skin International Inc. and Nu Skin Israel Inc. as joint controllers |
Nu Skin International Inc. and Nu Skin Israel Inc. as joint controllers |
|
|
Italy |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
Japan |
Nu Skin Enterprises Inc., Nu Skin International Inc. and Nu Skin Japan as joint controllers |
Nu Skin Enterprises Inc., Nu Skin International Inc. and Nu Skin Japan as joint controllers |
Nu Skin Japan |
Nu Skin Japan |
Luxembourg |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
Mainland China |
Nu Skin (China) Daily-Use & Health Products Co., Ltd |
Nu Skin (China) Daily-Use & Health Products Co., Ltd |
Nu Skin (China) Daily-Use & Health Products Co., Ltd; Shanghai Nu Skin Chuang Xing Daily-Use & Health Products Co Ltd; Nu Skin Beauty and Wellness Co. Ltd; Guangdong Xing Chuang Daily-Use & Health Products Co Ltd; Pharmanex (Huzhou) Health Products Co., Ltd. Pharmanex Electronic-Optical Technology (Shanghai) Co., Ltd. |
Nu Skin (China) Daily-Use & Health Products Co., Ltd; Shanghai Nu Skin Chuang Xing Daily-Use & Health Products Co Ltd; Nu Skin Beauty and Wellness Co. Ltd; Guangdong Xing Chuang Daily-Use & Health Products Co Ltd; Pharmanex (Huzhou) Health Products Co., Ltd. Pharmanex Electronic-Optical Technology (Shanghai) Co., Ltd. |
Malaysia |
Nu Skin International Inc. and Nu Skin (Malaysia) Sdn. Bhd as joint controllers |
Nu Skin International Inc. and Nu Skin (Malaysia) Sdn. Bhd as joint controllers |
Nu Skin (Malaysia) Sdn. Bhd |
Nu Skin (Malaysia) Sdn. Bhd |
Mexico |
Nu Skin International Inc. and Nu Skin Mexico as joint controllers |
Nu Skin International Inc. and Nu Skin Mexico as joint controllers |
Nu Skin Mexico |
Nu Skin Mexico |
Netherlands |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin Netherlands BV |
Nu Skin Netherlands BV |
New Caledonia |
Nu Skin International Inc. and Nu Skin Enterprises New Zealand, Inc., as joint controllers |
Nu Skin International Inc. and Nu Skin Enterprises New Zealand, Inc., as joint controllers |
|
|
New Zealand |
Nu Skin International Inc. and Nu Skin Enterprises New Zealand, Inc as joint controllers |
Nu Skin International Inc. and Nu Skin Enterprises New Zealand, Inc as joint controllers |
Nu Skin Enterprises New Zealand, Inc |
Nu Skin Enterprises New Zealand, Inc |
Norway |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
Peru |
Nu Skin International Inc. And Nu Skin Peru S.A.C. |
Nu Skin International Inc. and Nu Skin Peru S.A.C. |
Nu Skin Peru S.A.C. |
Nu Skin Peru S.A.C. |
Philippines |
Nu Skin International Inc. and Nu Skin Enterprises Philippines, LLC as joint controllers |
Nu Skin International Inc. and Nu Skin Enterprises Philippines, LLC as joint controllers |
Nu Skin Enterprises Philippines, LLC |
Nu Skin Enterprises Philippines, LLC |
Poland |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
Romania |
Nu Skin International Inc. and Nu Skin Enterprises SRL as joint controllers |
Nu Skin International Inc. and Nu Skin Enterprises SRL as joint controllers |
|
|
Singapore |
Nu Skin International Inc. and Nu Skin Enterprises Singapore Pte Ltd as joint controllers |
Nu Skin International Inc. and Nu Skin Enterprises Singapore Pte Ltd as joint controllers |
Nu Skin Enterprises Singapore Pte. Ltd or NSE Asia Products Pte Ltd |
Nu Skin Enterprises Singapore Pte. Ltd or NSE Asia Products Pte Ltd |
Slovakia |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
South Africa |
Nu Skin International Inc. and Nu Skin Enterprises South Africa (PTY) Ltd. as joint controllers |
Nu Skin International Inc. and Nu Skin Enterprises South Africa (PTY) Ltd. as joint controllers |
Nu Skin Enterprises South Africa (PTY) Ltd. |
Nu Skin Enterprises South Africa (PTY) Ltd. |
Spain |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
Sweden |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
Switzerland |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
Taiwan |
Nu Skin International Inc. and Nu Skin Taiwan, LLC, Taiwan Branch as joint controllers |
Nu Skin International Inc. and Nu Skin Taiwan, LLC, Taiwan Branch as joint controllers |
Nu Skin Taiwan, LLC, Taiwan Branch |
Nu Skin Taiwan, LLC, Taiwan Branch |
Thailand |
Nu Skin International Inc. and Nu Skin Enterprises (Thailand) Limited as joint controllers |
Nu Skin International Inc. and Nu Skin Enterprises (Thailand) Limited as joint controllers |
Nu Skin Enterprises (Thailand) Limited |
Nu Skin Enterprises (Thailand) Limited |
Ukraine |
Nu Skin Enterprises Ukraine LLC |
Nu Skin Enterprises Ukraine LLC |
Nu Skin Enterprises Ukraine LLC |
Nu Skin Enterprises Ukraine LLC |
United Kingdom |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
Nu Skin International Inc. and NSE Products Europe BV as joint controllers |
|
|
USA
|
Nu Skin International Inc.
|
Nu Skin International Inc.
|
Nu Skin International Inc.
|
Nu Skin International Inc.
|
Vietnam |
Nu Skin International Inc. and Nu Skin Enterprises Viet Nam Limited Liability Company as joint controllers |
Nu Skin International Inc. and Nu Skin Enterprises Viet Nam Limited Liability Company as joint controllers |
Nu Skin Enterprises Viet Nam Limited Liability Company |
Nu Skin Enterprises Viet Nam Limited Liability Company |
Annex 2 - List of personal data processing activities
| In which context is your personal data collected? | What personal data may we hold about you?* | How and why we may use it? | What is our legal basis for processing your personal data?* |
| *the following lists of data elements are intended to provide key examples and not necessarily be exhaustive in nature | *in those markets in which a "legitimate interest" is not a valid legal basis, we will rely on your consent to process your personal information as described herein | ||
| Customer account creation and management Personal Data collected during the creation or management of a customer or member account on Nu Skin Website/Apps (including Vera), through a social media login or in store. |
- Contact information: your name, title, address, email address or telephone number - Account information: your ID/username, password, login activity - Product information: your purchase history, details of products that we have sold to you, product returns, preferred products - Social media profile: where you use your social media login or share this personal data with us - Biographical information: your gender, birthdate, nationality, photograph, preferences, hobbies, interests |
To: - create and manage your account - allow you to manage your preferences |
The performance of a contract: so you can create and manage your account |
| - maintain our global databases - do research and development based on aggregate data, including but not limited to statistics about sales, market analysis, development of products and services |
Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools | ||
| - offer personalised services based on your characteristics | Your consent: so you can receive personalised services from us | ||
| Brand Affiliate account creation and management Personal Data collected during the creation or management of a Brand Affiliate account on Nu Skin Website/Apps (including Stela and Vera), through a social media login or in store. |
- Contact information: your name, title, address, email address or telephone number - Account information: your ID/username, password, login activity - Identification information: your passport number, permanent resident identification number, social security number, or any other identification details or documents or photocopies of the aforesaid identification documents, to the extent permissible under applicable laws - Billing or financial information: your bank account details, copy of bank account statement or any information or data required to verify and/or process payment transactions - Tax information: your tax ID number such as a VAT number, tax identification number or similar - Social media profile: where you use your social media login or share this personal data with us - Biographical information: your gender, birthdate, nationality, photograph, preferences, hobbies, interests |
To: - create and manage your account - process your commission and bonus payments - allow you to manage your preferences |
The performance of a contract: so you can create and manage your account To comply with a legal obligation: to request and keep information we are required to by law (for instance, we may be required by law to ask for an official identification number/document) |
| - do research and development based on aggregate data, including but not limited to statistics about sales, market analysis, development of products and services - maintain our global databases |
Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools | ||
| - give recognition to you as a Brand Affiliate, for instance by publishing your name, sales records, picture, pin title, charitable donations you made, etc., at Nu Skin events, in Business Support Materials, on our website and social media channels, via email, onsite at Nu Skin, etc. - promote our brand, for instance by using on the Website, in marketing materials or in other marketing tools, (i) testimonials given by you during Nu Skin’s events, or (ii) recordings or images of your appearances and/or performances at Nu Skin’s events - offer personalised services based on your characteristics, for instance, (i) sharing information in Nu Skin’s Business Support Materials, (ii) inviting you to events and sending reminders on events, venue, date and time, and (iii) organizing success trips and events |
Your consent: so we can give you recognition as a Brand Affiliate and/or offer you personalized services and promote our brand | ||
| Purchases and order management Personal Data collected during the purchase process made on Nu Skin Website/Apps (including Stela and Vera), in store or through the phone. |
- Contact information: your name, title, address, email address or telephone number - Billing or financial information: bank account details, credit/debit card details, or any information or data required to verify and/or process payment transactions - Product information: your purchase history, details of products you purchased, product returns, preferred products |
To: - Process your order including delivering the product to the address you indicated - Manage payment - Manage any contact you have with us about your order - Manage any dispute relating to a purchase - Contact you about your order, including to provide you with information regarding the shipping and delivery status of your order |
The performance of a contract: so you can make purchases and we can manage the associated logistics |
| - Keep records of our product sales to our customers | To comply with a legal obligation: to request and keep information we are required to by law (for instance, for tax purposes) | ||
| - Contact you to finalise your order where you have saved your shopping cart or placed products in your cart without completing the checkout process - Secure your transactions against fraud - If you place a purchase using a registered account, we will add this transaction to your profile so we can understand your interests and preferences and you will see a record of your transactions with us within your account (where applicable) - Do research and development based on aggregate data, including but not limited to statistics about sales, market analysis, development of products and services - Train AI models and improve machine learning for Nu Skin products and services |
Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools; or your explicit consent where required by law |
||
| - Inform you when a product you wanted to purchase is available |
Your consent: so you can be informed of product availability |
||
| Newsletter and marketing subscription Personal Data collected when you subscribe to receive our marketing communications either via email or SMS. |
- Contact information: your name, email address or telephone number | To: - Send you email and/or SMS marketing communications (where you have asked us to) which may be tailored to your “profile” based on the personal data we know or learn about you and your preferences |
Your consent: so you can receive marketing communications from us |
| - Keep an up to date suppression list if you have asked not to be contacted; and/or | To comply with a legal obligation: to request and keep information we are required to by law (maintain suppression lists) | ||
| - Run analytics or collect statistics | Our legitimate interests: (i) to improve our products and services; and (ii) better engage with you | ||
| Events and Incentive Trips registration and participation Personal Data collected during the registration phase to an Event or an incentive trip, or during your participation at such an event or trip. |
- Contact information: your name, title, address, email address or telephone number - Biographical information: your gender, birthdate, nationality, marital status, photograph or videos containing your image, information about family life (including family, children, hobbies or interests) - Identification information: your passport number or national ID number, permanent resident identification number, details or documents or photocopies of the aforesaid identification documents, to the extent permissible under applicable laws - Registration data: event/incentive trips registrations, subscriptions, downloads, or username/passwords, data requested in sign-up or registration forms, or related information such as feedback or survey responses - Billing or financial information: your bank account details, credit/debit cards details - Health-related data: your allergies, medical condition or other ailments - Technical information: your IP address, browser information, or device information (when you attend an Event remotely) |
To: - verify your eligibility to participate in an Event or Incentive Trip - register your participation in an Event or Incentive Trip - make the necessary travel and other booking arrangements - send you relevant information about the Event or Incentive Trip and notify you about changes to these - authenticate your identity when you attempt to gain access to and attend an Event, whether physically or remotely |
The performance of a contract: to confirm and make your booking, registration and other travel arrangements |
| - offer you a customized experience that suits your needs and requirements (incl. dietary requirements) - enable you to partake in a prize drawing or competition or to complete a survey - add your participation to your profile so we can understand your interests and preferences |
Your consent: where we ask you to leave a review or take a survey or provide health-related data, or where you want to receive a customized experience | ||
| - promote our brand, for instance by using on the Website, in marketing materials or in other marketing tools, (i) testimonials given by you during Nu Skin’s Events or Incentive Trips, or (ii) recordings or images of your appearances and/or performances at Nu Skin’s Events or Incentive Trips | Our legitimate interests: (i) to improve our products and services; and (ii) better engage with you | ||
| Adverse event / product complaint reporting Personal Data collected when you report online or on the phone (i) an adverse event that occurred from your use of our products or (ii) a complaint regarding our products. |
- Contact information: your name, title, address, email address or telephone number - Health-related information: data related to your health or medical history as required for processing the adverse event or the product complaint if such information is relevant to evaluate, classify or assess the product complaint - Other information you have shared with us about yourself in relation to your enquiry (which may include welfare, health data or call recordings) |
To: - prevent, monitor and manage adverse events - evaluate, classify and assess the adverse event and/or product complaint - maintain the information in a product complaints database for reference |
To comply with a legal obligation: to keep information we are required to and/or to meet health and safety requirements |
| - follow up on such reports and/or complaints | The performance of a contract: to provide you with the service you have requested, for example, so we can offer a compensation | ||
| Online browsing and use of our Apps Personal Data collected by cookies or similar technologies when you browse Nu Skin Website/Apps (including Stela and Vera) or on third-party website/apps where we have cookies, pixels or other similar technologies. |
- Technical information: your IP address, browser information, or device information; - Website usage information: data related to your use of our Website or Apps including where you came from, login details, location, data related to your navigation on our Website/Apps (incl. scroll/mouse movement, but in a manner that does not identify you), pages/ content you looked at, clicked or tapped on, duration of your visit; and/or products you searched for and/or selected |
To: - maintain security and manage access to our systems, Website and Apps; - collect insights into how you interact with our services so that we can personalize our communications with you and improve our Website and Apps; - measure the effectiveness of our services and collect information to improve our products and services; - ensure your data security is maintained, and our systems kept up to date to continue servicing you - allow proper functioning of our Website and Apps |
Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools. |
| - tailor our services for you, that is to show you recommendations, marketing, or content based on your profile and interests; and/or display our websites in a tailored way, for example, show you products we think you might like - deliver targeted advertising (e.g. online advertisements for products which may be of interest to you, based on your previous behaviour; and/or ads and content on social media platforms or other websites) Read our Cookies policy for more information |
Your consent: to store cookies, pixels or other similar technologies on your device | ||
| Social Media Platforms Personal Data collected from your activity on social media platforms. |
We may get information you publicly post on social media platforms or use it to better understand how customers view our products/services or interact with us. For example, we may use public posts to identify beauty trends. Where possible, we do this in way that we are unable to directly identify you. We may also collect your personal data when you mention us on social media platforms. The personal data we collect may include: - Social media handle; - Photo; and/or - Any comments mentioned in your post. If we want to re-use any content you post on social media platforms, we will always ask your permission first (see ‘User Generated Content’ below). |
To: - Monitor and improve our websites and apps - Run analytics or collect statistics |
Our legitimate interests: (i) to improve our products and services; and (ii) better engage with you |
| User generated Content Personal Data collected when you submit content (for example images or testimonials) on one of our Website/Apps/social media platforms or accept our re-use of any content you posted on social media platforms. |
- Contact information: your name or alias, email address or telephone number; - Biographical information: your gender, photograph or videos containing your image, personal description or preferences, information about family life (including family, children, hobbies or interests); - Social media profile: where you use your social media login or share this personal data with us. |
To: - Use the content you have created and/or shared in accordance with the specific terms and conditions accepted by you e.g. to post your review/content and to promote our products; |
Your consent: to provide you with the service you have requested, for example, so you can upload the content of your choice |
| - Add your content to your profile so we can understand your interests and preferences; and/or - Run analytics and statistics. |
Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools | ||
| Enquiries Personal Data collected when you reach out to customer service or account management to ask questions relating to our products and their use, or your purchases, account or rights. |
- Contact information: your name, title, address, email address or telephone number; - Other information you have shared with us about yourself in relation to your enquiry (which may include welfare, health data or call recordings). |
To: - Answer and manage your enquiries |
The performance of a contract: to respond to your enquiries. |
| - Run analytics and statistics - Add your questions or concerns to your profile so we can understand your interests and preferences |
Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools | ||
| Surveys, panel discussions and focus groups Personal Data collected when you participate and complete a survey, or particate in a panel discussion or focus group |
- Contact information: your name, title, address, email address or telephone number - Biographical information: your gender, birthdate, nationality - Other information you have shared with us about yourself in relation to the survey, panel discussion or focus group (which may include sensitive personal information such as data relating to race or ethnic origin, religious or philosophical beliefs, medical or health conditions) - Technical information and Website usage information (see section regarding "Online browsing and use of our Apps" where the surveys are carried out online) |
To: - achieve the objectives further described in the surveys, panel discussions or focus groups including but not limited to improving our product and services |
Your consent: where you agree to participate to the survey, panel discussion or focus group and answer the questions |
| Our Premises Personal Data collected when you visit our premises e.g. our offices or walk-in-centers (live centers, experience centers, etc). |
- CCTV footage; - Attendance/visitor forms (which may include the collection of identification data or contact information, as well as welfare or health data). |
To: - Assist in the prevention and detection of crime and manage enquiries - Help ensure the safety and security of information located or stored within the premises, and assets |
Our legitimate interests: (i) prevent fraud and criminal activity; and (ii) secure our tools |
| - Help ensure the health, safety and security of employees and visitors | To comply with legal obligation: to meet health and safety requirements. | ||
| Job application Personal Data collected as part of your application for a job at Nu Skin. |
- Contact information: your name, title, address, email address or telephone number - Biographical information: your gender, birthdate, nationality, photograph, preferences, hobbies, interests, family situation, civil status - Educational background information: your academic titles, diplomas, schools, or universities attended, skills or merits related - Professional records information: your professional experience, duration of previous job contracts, previous position titles, practice areas, assessments established by your previous employers - Any additional information contained in your application or in your self-recorded videos (e.g., sound or images) |
To: - complete, fulfil and process your application, including any subsequent stages of the recruitment process - communicate with you and to provide you with any service related to your application - fulfil identity verifications - respond to your inquiries and support needs and to fulfil or comply with any other request you may have - allow you to manage your application |
The performance of a contract: to respond and process your application to one of our job offers |
| - conduct background checks, in accordance with local laws - consider and contact you should a relevant position arise in the near future |
Our legitimate interests: find the best candidates for our job offers | ||
| Vera Skin Consultation Personal Data collected as part of your use of our virtual Vera Skin Consultation service. |
- Contact information: your name or email address - Biographical information: your gender, age range, location or photograph - Lifestyle information: your skin routine, sleeping habits, or water intake - Health-related information: your skin sensitivity, skin type or skin concerns - Ethnicity-related information: your Ethnic origin - Tracking metrics: the stage of your consultation, or whether you have added a product to your cart or purchased it - Customer insights: the results of your product recommendations or what features of the app are being used |
To: - provide you with a tailored skin care routine, and product recommendations, that meet your needs, through the use of algorithms and artificial intelligence - enable you to keep track of your recommendations over time - improve our products and services - facilitate sharing product information, product recommendations, or user experience to your social networks if you choose to -facilitate sharing your results and product recommendations with your sponsor (if you are a customer) or other Brand Affiliates |
The performance of a contract: to provide you with the service you have requested, for example, so you can receive the product recommendation; |
| Your explicit consent: to the extent that we process special category data or share your data with your sponsor/Brand Affiliates | |||
| - do research and development based on aggregate data, including but not limited to statistics about sales, market analysis, development of products and services - improve our products and services, including training AI models and improving machine learning for Nu Skin products and services |
Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools; or your explicit consent where required by law |
||
| Vera Shade Finder Personal Data collected as part of your use of our virtual Vera Shade Finder service. |
- Biographical information: your gender, age range, location or photograph; - Ethnicity-related information: your Ethnic origin |
To: - provide you with product recommendations that meet your needs, through the use of algorithms and artificial intelligence - enable you to keep track of your recommendations over time |
The performance of a contract: to provide you with the service you have requested, for example, so you can receive the product recommendation; |
- facilitate sharing product information, custom recommendations, or user experience to your social networks if you choose to |
Your consent: so you can share your photos or product information on your social networks | ||
| - improve our products and services, including training AI models and improving machine learning for Nu Skin products and services | Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools | ||
| Vera Selfie Timeline Personal Data collected as part of your use of our virtual Vera Selfie Timeline service. |
- Biographical information: your gender, age range, location or photograph; | To: - enable you to keep track of your evolution or progress over time |
The performance of a contract: to accede to your request to use the Vera Selfie Timeline |
| - facilitate sharing before and after photos if you choose to - facilitate sharing product information, custom recommendations, or user experience to your social networks if you choose to |
Your consent: so you can share your photos on your social networks | ||
| - improve our products and services, including training AI models and improving machine learning for Nu Skin products and services. | Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools; or your explicit consent where required by law |
||
| Vera device management Personal Data collected as part of your use of our virtual device management services (for example Vera LumiSpa iO service). |
- Tracking metrics: your usage of our services, routine logs, and routine history - Customer insights: the results of your routines and interactions with our services - Device information: paired usage logs, device management, events (e.g. device drop), warranty details |
To: - provide you with customized routines and insights that meet your needs, through the use of algorithms and artificial intelligence - enable you to keep track of your usage over time - improve our products and services - facilitate sharing before and after photos if you choose to - facilitate sharing product information, custom routines, or user experience to your social networks if you choose to -facilitate sharing your results and product recommendations with your sponsor (if you are a customer) or other Brand Affiliates |
The performance of a contract: to provide you with the service you have requested, for example, so you can receive the product recommendations, track usage, and customized routines |
| Your explicit consent: to the extent that we process special category data or share your data with your sponsor/Brand Affiliates | |||
| - do research and development based on aggregate data, including but not limited to statistics about sales, market analysis, development of products and services - improve our products and services, including training AI models and improving machine learning for Nu Skin products and services |
Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools; or your explicit consent where required by law |
||
| Nu Skin Connect Personal Data collected as part of your use of the Nu Skin Connect customer resource management tool. |
- Contact information: your name, title, address, email address or telephone number; - Biographical information: your gender, birthdate, photograph or videos containing your image, preferences, hobbies, interests; - Social media profile: where you use your social media login or share this personal data with us; - Usage Information: your activity or transaction history (device used to log in, the time of day, the time spent on the app, location, actions completed or IP address); - Product information: your purchase history, details of products that we have sold to you, product returns, preferred products; - Location Information: your location Information, that includes GPS data from devices or a rough estimate of location from IP Addresses. |
To: - verify you have the authorization needed for the use of Nu Skin Connect - provide Nu Skin Connect to you and allow your use of Nu Skin Connect |
The performance of a contract: to provide you with the service you have requested |
| - monitor and analyze your use of Nu Skin Connect, including how you use and share marketing content created by Nu Skin, as well as the messages sent through Nu Skin Connect in order to ensure the conformity of such messages with our Policies and Procedures (Nu Skin does not have access to the content of your messages and only searches for the use of prohibited terms) - enable Nu Skin Connect’s technical administration, including the improvement of Nu Skin Connect’s functionality and user-friendliness - do research and development based on aggregate data, including but not limited to statistics about sales, market analysis, development of products and services; |
Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools | ||
| enJoy Rewards and other loyalty programs Personal Data collected as part of your participation in the enJoy Rewards Program. |
- Contact information: your name, title, address, email address or telephone number; - Product information: your purchase history, details of products that we have sold to you, product returns, preferred products; - Customer insights: the results of your participation, point redemption, or involvement in the rewards program; - Tracking metrics: the tier of your participation, loyalty, or whether you have achieved certain status. |
To: - offer and manage our loyalty programs and provide you with enJoy Rewards benefits |
The performance of a contract: to accede to your request to join the enJoy Rewards Program |
| - run analytics and statistics - add your participation to your profile so we can understand your interests and preferences |
Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools. | ||
| TR90 challenge Personal Data collected as part of your participation in our TR90 challenge. |
- Contact information: your name, title, address, email address, telephone number, nuskin ID - Biographical information: your gender, birthdate, voice and portrait - Health-related information: your lifestyle, diet, daily exercise, height, weight, body fat percentage |
To: - verify you have the authorization needed for your participation to the TR90 challenge - allow registration to participate in the TR90 challenge - enable you to use the features of the TR90 Challenge app |
The performance of a contract: to accede to your request to participate in the TR90 challenge |
| - enable you to use the reservation function for measuring the TR90 challenge - allow the TR90 challenge app to provide weight maintenance related services |
Your consent: to provide you with the service you have requested, for example, so you can upload the content of your choice | ||
| - monitor and analyze your use of TR90 challenge | Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools | ||
| IoT devices Personal Data collected as part of your usage of our IoT connected devices (for example ageLoc LumiSpa iO device). |
- Device information: usage logs, device management, events (e.g. device drop), warranty details | To: - do research and development based on aggregate data, including but not limited to statistics about market analysis, development of products and services; - fulfill warranty obligations |
Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud or criminal activity; and (iv) secure our tools The performance of a contract: to provide you with the service you have requested in line with your purchase |
| - enable user experience within our apps | Your consent: to provide you with the service you have requested, for example, to pair your device | ||