NU SKIN GLOBAL PRIVACY NOTICE

LAST UPDATE: October 1, 2023


  1. Table of Content

    1. Table of Content 1

    2. Overview 2

    3. Who we are and how to contact us 2

    4. What Personal Data do we collect? 2

    5. How we use your Personal Data 3

    6. Sharing and transferring your Personal Data 3

      1. We do not sell your Personal Data 3

      2. We do not share your Personal Data with third parties for their own direct marketing purposes 3

      3. If you are a Brand Affiliate, we may share your Personal Data with other Brand Affiliates and customers 3

      4. If you are a customer, we may share your Personal Data with certain Brand Affiliates 4

      5. We may share your Personal Data within the Nu Skin group 4

    7. International Transfers 5

      1. International data transfers 5

      2. Data Privacy Frameworks 5

    8. How we protect your Personal Data 6

    9. How long do we keep your Personal Data 7

    10. What are your rights regarding your Personal Data 7

    11. Your marketing choices 8

    12. Your obligations 8

    13. Children 8

    14. Changes to the Privacy Notice 9

    Annex 1 – List of Nu Skin entities responsible for processing your Personal Data 10

    Annex 2 - List of personal data processing activities 19

  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.


  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);


      11 Referred to as “Business Partners” in Mainland China and “Brand Member” in Japan.

    • 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.

    1. 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.

    2. We do not share your Personal Data with third parties for their own direct marketing purposes

      Also, we do not share your Personal Data with 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.

    3. 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


      2 Does not apply to Mainland China.

      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.

    4. 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.

    5. 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).


  7. International Transfers

    1. 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).

    2. Data Privacy Frameworks

    Nu Skin International Inc. (NSI) complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Privacy Framework as set forth by the U.S. Department of Commerce. NSI has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and the from the UK in reliance on the UK Extension to the EU-U.S. DPF. NSI has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.

    Nu Skin is committed to the DPF Principles in connection with all personal data received from the European Union and, as applicable, the United Kingdom and/or Switzerland in reliance on the relevant parts of the DPF program. If there is any conflict between the terms in this privacy notice and the DPF Principles, the DPF Principles shall prevail.

    To learn more about the Data Privacy Framework (DPF) program and to view our certification, please visit https://www.dataprivacyframework.gov/.

    Nu Skin is responsible for both the processing of Personal Data it has received and the subsequent transfers to a third party acting as an agent on its behalf. Nu Skin complies with the DPF Principles for all onward transfers of Personal Data from the EU, UK and Switzerland, including the onward transfer liability provisions. NSI shall remain liable under the DPF Principles if its subprocessors process personal data in a manner inconsistent with the DPF Principles.

    In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, NSI commits to resolve DPF Principles-related complaints about our collection and use of personal data. EU, UK and Swiss individuals with inquires or complaints regarding how we process or handle the personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF or the Swiss-U.S. DPF are encouraged to first contact the NSI Privacy Office at privacyoffice@nuskin.com

    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://feedbackform.truste.com/watchdog/request .

    EU, U.K. and Swiss individuals are also entitled to contact their local data protection authorities and/or the DPF Program here: Assistance Services (dataprivacyframework.gov).

    With respect to Personal Data received or transferred pursuant to the Data Privacy 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. Nu Skin has further committed to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data.

    Moreover, under certain conditions, individuals may invoke binding arbitration for complaints regarding DPF compliance not resolved by us or the DPAs Panel. Additional details about the binding arbitration can be found here: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2


  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. Personal Data printed on paper will be shredded or incinerated.

    Personal Data stored in the form of an electronic file will be deleted using a technical method that renders the data so that it cannot be reproduced.


  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: 800-211-5200. 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 October 1, 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:

    • Customers, website visitors and app users (for the purpose of this section, a “customer” is anyone who purchases from Nu Skin directly, either on our Websites or Apps, or in our walk-in-centers/stores; “customers” also include the recipients of the newsletter or other marketing communications)

    • Brand Affiliates or Business Partners (ie. registered distributors)

    • Job Candidates

    • Office Visitors


  2. Your country or market:

    • If you are a Customer, look for the country/market in which you have registered your Nu Skin online account or make your purchases; if you visit our Websites or use our Apps, you will need to look for the Website or App country/market.

    • If you are a Brand Affiliate, look for the country/market in which you have registered your Nu Skin Brand Affiliate account.

    • If you are a Job Candidate, look for the country/market in which the Nu Skin office to which you apply for a job is located.

    • If you are an Office Visitor, look for the country/market in which the Nu Skin office which you are visiting is located.


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


Contact Information

Guangdong Xing Chuang Daily-Use & Health Products Co Ltd

Room 15, 8/F, Jietai Plaza, No. 218-222 Zhongshan Six Rd., Yuexiu District, Guangzhou, Guangdong, PRC 48hrs_reply_china@nuskin.com

Nu Skin Argentina Inc.

Sucursal Argentina

Av. Olivera 1561 piso 2° of. “E” C1407IOC CABA

ARGENTINA

Tel: +54 801.45.0137

infoargentina@nuskin.com

Nu Skin Enterprises Australia Inc. 2/2 Eden Park Dr. Macquarie Park NSW 2113

AUSTRALIA

Tel: +64 2 9491 0900

australiainfo@nuskin.com

Nu Skin Beauty and Wellness Co. Ltd Factory No. 29 and first floor of Factory No. 23, Longyang Industrial Park, No. 1515 Yuan East Rd., Fengxian District, Shanghai, PRC 48hrs_reply_china@nuskin.com

Nu Skin Belgium NV

Da Vincilaan 9

The Corporate Village, Building Elsinore 1930 Zaventem

BELGIUM

Tel: +32 2 342 04 75

belgiumweb@nuskin.com

Nu Skin Canada, Inc. 75 West Center St. Provo, UT 84601, USA Tel: +1 801-345-1000

Nu Skin Chile

Camino Lo Echevers N° 550 Bodega 21, Comuna Quilicura Metropolitana de Santiago CHILE

Tel: +56 422 452 880 or 1-800-487-0800

infochile@nuskin.com

Nu Skin (China) Daily-Use & Health Products Co., Ltd

Factory No. 29 and first floor of Factory No. 23, Longyang Industrial Park, Fengxian District, Shanghai, PRD 48hrs_reply_china@nuskin.com

Nu Skin Colombia

Calle 93A # 14-17 Oficina 311 Bogotá D.C.

COLOMBIA

Tel: +57 (601) 508 6103

infocolombia@nuskin.com

Nu Skin Eastern Europe Kft. Kft. Alkotás utca 48-50 1123 Budapest

HUNGARY

Tel: +36 21 200 78 27

hungaryweb@nuskin.com

Nu Skin Enterprises Inc.

75 West Center

Provo, UT 84601

UNITED STATES OF AMERICA Tel: +1 800 487 1000

NSE Asia Products Pte Ltd

18 Cross Street

#06-01

Cross Street Exchange SINGAPORE 048423

Tel: +65 6837-3363

48hrs_reply_singapore@nuskin.com

Nu Skin Enterprises Hong Kong, LLC 10/F, Lee Garden II, 28 Yun Ping Road Causeway Bay

Hong Kong

Tel: +852 2837 7700

48hrs_reply_nshk@nuskin.com

Nu Skin Enterprises New Zealand, Inc Unit 16/180 Montgomerie Road Airport Oaks,

2022 Auckland NEW ZEALAND Tel: 0800 687 456

dsnewzealand@nuskin.com

Nu Skin Enterprises Philippines, LLC

23F ExquadraTower

1 Jade Drive Cor. Exchange Road Ortigas Business Center

1605 Pasig City PHILIPPINES

Tel: +63 2 868 75 46

48hr_reply_phils@nuskin.com

NSE Products Europe BV

Da Vincilaan 9

The Corporate Village, Building Elsinore 1930 Zaventem

BELGIUM

Tel: +32 2 342 04 75

belgiumweb@nuskin.com


NSE (Romania) SRL

Bucuresti, Str. Grigore Cobalcescu nr. 46, mansard, Camera 13, sector 1.

ROMANIA

Tel: +40 312 294 653

romaniaweb@nuskin.com

Nu Skin Enterprises Singapore Pte Ltd

331 North Bridge Road #18-01/06

Odeon Towers SINGAPORE 188720

Tel: +65 6837 3363

48hrs_reply_singapore@nuskin.com

NSE South Africa (PTY) Ltd.

Ground & 1st Floor C/O Spaces, 22 Magwa Crescent, Waterfall City, Midrand 1682

Tel: +27 875 503 103

southafricasupport@nuskin.com

Nu Skin Enterprises (Thailand) Limited 319 Chamchuri Square Building, 15th Fl., Phayathai Road, Pathumwan,

10330 Bangkok THAILAND

Tel: +66 0 2791 8500

48hr_reply_thailand@nuskin.com

NSE Ukraine LLC

Velika Vasilkovska street 72A floor 8, office 174

03680 Kiev UKRAINE

Tel: +380 0 800 30 19 84

ukraine@nuskin.com

Nu Skin Enterprises Viet Nam Limited Liability Company

2F, 280 Nam Ky Khoi Nghia, Vo Thi Sau Ward, District 3, Ho Chi Minh City VIETNAM

Tel: +84 028 7106 8838

48hrs_reply_vietnam@nuskin.com

Nu Skin French Polynesia

Nu Skin Enterprises New Zealand, Inc. 2/2 Eden Park Dr. Macquarie Park NSW 2113

AUSTRALIA

Tel: +64 2 9491 0934

pacifiquesud@nuskin.com

Nu Skin Germany GmbH

Taunusstrasse 57

55118 Mainz GERMANY

Tel: +49 613149 09 108

germanyweb@nuskin.com

Nu Skin International Inc.

75 West Center

Provo, UT 84601

UNITED STATES OF AMERICA Tel: +1 800 487 1000

Nu Skin Israel Inc.

Omarim Street 11, Building Menivim, Industrial Park

8496500 Omer ISRAEL

Tel: +972 376-311-04

Israelweb@nuskin.com

Nu Skin (Malaysia) Sdn. Bhd

Lot 2.5.1, Level 2, PNB Perdana (Commercial Centre), No. 10, Jalan Binja 50450 Kuala Lumpur

MALAYSIA

Tel: +60 3 2170 7700

48hrs_reply_malaysia@nuskin.com

Nu Skin Netherlands BV

Amundsenweg 2

5928 LT Venlo

THE NETHERLANDS Tel: +31 850 02 18 53

netherlandsweb@nuskin.com

Nu Skin New Caledonia

Nu Skin Enterprises New Zealand, Inc. 2/2 Eden Park Dr. Macquarie Park NSW 2113

AUSTRALIA

Tel: +64 2 9491 0934

pacifiquesud@nuskin.com

NuSkin Pharmanex (B) Sdn Bhd (Nu Skin Brunei Experience Center) D2, Blk D, Lot 11620, Jalan Gadong BE1718 Bandar Seri Begawan BRUNEI DARUSSALAM

Tel: +673 2 422 225

48hrs_reply_brunei@nuskin.com

Nu Skin Scandinavia A/S Augusthus, Amager Fælledvej 106 300 København S, Denmark

Tel: +45 78 73 06 02

neucustomerservice@nuskin.com

Nu Skin Taiwan, LLC, Taiwan Branch

7F-1, No. 189, Section 2 Jiuzong Road

Neihu District Taipei City, 114 TAIWAN

Tel: +886 02 8752 - 8555

nstwinfo@nuskin.com


Pharmanex (Huzhou) Health Products Co., Ltd

No. 819-1, Xinzhu Road, Zhejiang, PRC 48hrs_reply_china@nuskin.com

PT Nusa Selaras Indonesia (PT Nu Skin Distribution Indonesia)

Jl. Jend Gatot Subroto 44 Kuningan Barat Area Gd. City Plaza

10th Fl., Suite 1001-1002

Mampang Prapatan Jakarta Selatan DKI Jakarta 12710

INDONESIA

Tel: +62 21 5095 9855

48hrs_reply_indonesia@nuskin.com

Shanghai Nu Skin Chuang Xing Daily-Use & Health Products Co Ltd

Room 408-2 and 408-6, 75 Tian Lin East Road, Xuhui District, Shanghai, PRC 48hrs_reply_china@nuskin.com

Pharmanex Electronic-Optical Technology (Shanghai) Co., Ltd.

Room 206, Building T3-11, No. 5001 Huadong Road, Jinqiao Export Processing Zone (South District), Pudong New Area, Shanghai, PRC 48hrs_reply_china@nuskin.com

Nu Skin Japan Co., Ltd.

Nu Skin Peru S.A.C.



Tokyo Toranomon Global Square 14F,

Av. Los conquistadores 1118 Interior 6

1-3-1 Toranomon, Minato-ku,

Urbanización Santa Cruz

Tokyo, Japan 105-0001

San Isidro

Tel: +81-3-6626-1234

PERU

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

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)



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

  • 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

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




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


- 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

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

Our legitimate interests: (i) to improve our products and services; and (ii) better engage with you



device information (when you attend an Event remotely)

your appearances and/or performances at Nu Skin’s Events or Incentive Trips






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,

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



assessments established by your previous employers

- Any additional information contained in your application or in your self-recorded videos (e.g., sound

or images)

  • 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;

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



  • 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.

  • 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