NU SKIN GLOBAL PRIVACY NOTICE
LAST UPDATE: October 1, 2023
Table of Content 1
Overview 2
Who we are and how to contact us 2
What Personal Data do we collect? 2
How we use your Personal Data 3
Sharing and transferring your Personal Data 3
We do not sell your Personal Data 3
We do not share your Personal Data with third parties for their own direct marketing purposes 3
If you are a Brand Affiliate, we may share your Personal Data with other Brand Affiliates and customers 3
If you are a customer, we may share your Personal Data with certain Brand Affiliates 4
We may share your Personal Data within the Nu Skin group 4
International Transfers 5
International data transfers 5
Data Privacy Frameworks 5
How we protect your Personal Data 6
How long do we keep your Personal Data 7
What are your rights regarding your Personal Data 7
Your marketing choices 8
Your obligations 8
Children 8
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
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.
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.
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).
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.
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.
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.
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.
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.
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.
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).
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).
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
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.
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.
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:
In addition, if you are in the EEA or in Thailand you have the following rights:
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).
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.
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.
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.
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.
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:
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
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 |
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|
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 |
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|
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 |
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|
Chile |
Nu Skin International Inc. and Nu Skin Chile |
Nu Skin International Inc. and Nu Skin Chile |
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|
Colombia |
Nu Skin International Inc. and Nu Skin Colombia |
Nu Skin International Inc. and Nu Skin Colombia |
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|
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 |
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|
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 |
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|
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 |
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|
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 |
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|
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 |
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|
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 |
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|
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 |
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|
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 |
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|
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 |
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|
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 |
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|
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 |
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|
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 |
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|
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 |
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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 |
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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 |
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|
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 |
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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 |
Nu Skin Enterprises Australia Inc. 2/2 Eden Park Dr. Macquarie Park NSW 2113 AUSTRALIA Tel: +64 2 9491 0900 |
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 |
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 |
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 |
Nu Skin Eastern Europe Kft. Kft. Alkotás utca 48-50 1123 Budapest HUNGARY Tel: +36 21 200 78 27 |
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 |
Nu Skin Enterprises Hong Kong, LLC 10/F, Lee Garden II, 28 Yun Ping Road Causeway Bay Hong Kong Tel: +852 2837 7700 |
Nu Skin Enterprises New Zealand, Inc Unit 16/180 Montgomerie Road Airport Oaks, 2022 Auckland NEW ZEALAND Tel: 0800 687 456 |
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 |
NSE Products Europe BV Da Vincilaan 9 The Corporate Village, Building Elsinore 1930 Zaventem BELGIUM Tel: +32 2 342 04 75 |
NSE (Romania) SRL Bucuresti, Str. Grigore Cobalcescu nr. 46, mansard, Camera 13, sector 1. ROMANIA Tel: +40 312 294 653 |
Nu Skin Enterprises Singapore Pte Ltd 331 North Bridge Road #18-01/06 Odeon Towers SINGAPORE 188720 Tel: +65 6837 3363 |
NSE South Africa (PTY) Ltd. Ground & 1st Floor C/O Spaces, 22 Magwa Crescent, Waterfall City, Midrand 1682 Tel: +27 875 503 103 |
Nu Skin Enterprises (Thailand) Limited 319 Chamchuri Square Building, 15th Fl., Phayathai Road, Pathumwan, 10330 Bangkok THAILAND Tel: +66 0 2791 8500 |
NSE Ukraine LLC Velika Vasilkovska street 72A floor 8, office 174 03680 Kiev UKRAINE Tel: +380 0 800 30 19 84 |
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 |
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 |
Nu Skin Germany GmbH Taunusstrasse 57 55118 Mainz GERMANY Tel: +49 613149 09 108 |
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 |
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 |
Nu Skin Netherlands BV Amundsenweg 2 5928 LT Venlo THE NETHERLANDS Tel: +31 850 02 18 53 |
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 |
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 |
Nu Skin Scandinavia A/S Augusthus, Amager Fælledvej 106 300 København S, Denmark Tel: +45 78 73 06 02 |
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 |
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 |
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. |
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Tokyo Toranomon Global Square 14F, |
Av. Los conquistadores 1118 Interior 6 |
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1-3-1 Toranomon, Minato-ku, |
Urbanización Santa Cruz |
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Tokyo, Japan 105-0001 |
San Isidro |
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Tel: +81-3-6626-1234 |
PERU |
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?* |
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*the following lists of data elements are intended to provide key examples and not necessarily be exhaustive in nature |
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*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. |
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To:
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The performance of a contract: so you can create and manage your account |
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 |
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- offer personalised services based on your characteristics |
Your consent: so you can receive personalised services from us |
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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. |
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To:
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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) |
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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
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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 |
(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 |
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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. |
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To:
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) |
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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 |
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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 |
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- Inform you when a product you wanted to purchase is available |
Your consent: so you can be informed of product availability |
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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) |
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- Run analytics or collect statistics |
Our legitimate interests: (i) to improve our products and services; and (ii) better engage with you |
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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. |
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To:
or remotely |
The performance of a contract: to confirm and make your booking, registration and other travel arrangements |
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 |
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- 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 |
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device information (when you attend an Event remotely) |
your appearances and/or performances at Nu Skin’s Events or Incentive Trips |
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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. |
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To:
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 |
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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. |
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To:
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. |
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Your consent: to store cookies, pixels or other similar technologies on your device |
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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:
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:
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Our legitimate interests: (i) to improve our products and services; and (ii) better engage with you |
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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. |
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 |
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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 |
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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. |
recordings). |
To: - Answer and manage your enquiries |
The performance of a contract: to respond to your enquiries. |
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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 |
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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 |
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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 |
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Our Premises Personal Data collected when you visit our premises e.g. our offices or walk-in-centers (live centers, experience centers, etc). |
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To:
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. |
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Job application Personal Data collected as part of your application for a job at Nu Skin. |
position titles, practice areas, |
To:
application |
The performance of a contract: to respond and process your application to one of our job offers |
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assessments established by your previous employers - Any additional information contained in your application or in your self-recorded videos (e.g., sound or images) |
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Our legitimate interests: find the best candidates for our job offers |
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Vera Skin Consultation Personal Data collected as part of your use of our virtual Vera Skin Consultation service. |
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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 |
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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 |
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Vera Shade Finder Personal Data collected as part of your use of our virtual Vera Shade Finder service. |
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To:
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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 |
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- 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 |
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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 |
you choose to |
Your consent: so you can share your photos on your social networks |
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- 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 |
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Vera device management Personal Data collected as part of your use of our virtual device management services (for example Vera LumiSpa iO service). |
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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 |
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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 |
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Nu Skin Connect Personal Data collected as part of your use of the Nu Skin Connect customer resource management tool. |
preferences, hobbies, interests; |
To:
Connect |
The performance of a contract: to provide you with the service you have requested |
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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 |
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enJoy Rewards and other loyalty programs Personal Data collected as part of your participation in the enJoy Rewards Program. |
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 |
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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. |
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TR90 challenge Personal Data collected as part of your participation in our TR90 challenge. |
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To:
the TR90 Challenge app |
The performance of a contract: to accede to your request to participate in the TR90 challenge |
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 |
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- 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 |
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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:
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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 |
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