Privacy policy

Privacy policy

We respect your privacy and are committed to protecting it through our compliance with this privacy policy
(“Policy”). This Policy describes the types of information we may collect from you or that you may provide
(“Personal Information”) on the website (“Website” or “Service”) and any of its
related products and services (collectively, “Services”), and our practices for collecting, using, maintaining,
protecting, and disclosing that Personal Information. It also describes the choices available to you regarding
our use of your Personal Information and how you can access and update it.

This Policy is a legally binding agreement between you (“User”, “you” or “your”) and Natural Body Essentials
(“Natural Body Essentials”, “we”, “us” or “our”). If you are entering into this agreement on behalf of a business or
other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case
the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not
agree with the terms of this agreement, you must not accept this agreement and may not access and use the
Website and Services. By accessing and using the Website and Services, you acknowledge that you have read,
understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of
companies that we do not own or control, or to individuals that we do not employ or manage.


Collection of personal information


You can access and use the Website and Services without telling us who you are or revealing any information
by which someone could identify you as a speci몭c, identi몭able individual. If, however, you wish to use some of
the features offered on the Website, you may be asked to provide certain Personal Information (for example,
your name and e-mail address).
We receive and store any information you knowingly provide to us when you create an account, make a
purchase, or 몭ll any forms on the Website. When required, this information may include the following:
Account details (such as user name, unique user ID, password, etc)
Contact information (such as email address, phone number, etc)
Basic personal information (such as name, country of residence, etc)
You can choose not to provide us with your Personal Information, but then you may not be able to take
advantage of some of the features on the Website. Users who are uncertain about what information is
mandatory are welcome to contact us.

Privacy of children

We do not knowingly collect any Personal Information from children under the age of 13. If you are under the
age of 13, please do not submit any Personal Information through the Website and Services. If you have reason
to believe that a child under the age of 13 has provided Personal Information to us through the Website and
Services, please contact us to request that we delete that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this
Policy by instructing their children never to provide Personal Information through the Website and Services
without their permission. We also ask that all parents and legal guardians overseeing the care of children take
the necessary precautions to ensure that their children are instructed to never give out Personal Information
when online without their permission.

Use and processing of collected information

We act as a data controller and a data processor in terms of the GDPR when handling Personal Information,
unless we have entered into a data processing agreement with you in which case you would be the data
controller and we would be the data processor.

Our role may also differ depending on the speci몭c situation involving Personal Information. We act in the
capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure
your access and use of the Website and Services. In such instances, we are a data controller because we
determine the purposes and means of the processing of Personal Information and we comply with data
controllers’ obligations set forth in the GDPR.

We act in the capacity of a data processor in situations when you submit Personal Information through the
Website and Services. We do not own, control, or make decisions about the submitted Personal Information,
and such Personal Information is processed only in accordance with your instructions. In such instances, the
User providing Personal Information acts as a data controller in terms of the GDPR.
In order to make the Website and Services available to you, or to meet a legal obligation, we may need to collect
and use certain Personal Information. If you do not provide the information that we request, we may not be able
to provide you with the requested products or services. Any of the information we collect from you may be used
for the following purposes:

Create and manage user accounts
Ful몭ll and manage orders
Deliver products or services
Improve products and services
Send administrative information
Send marketing and promotional communications
Send product and service updates
Respond to inquiries and offer support
Request user feedback
Improve user experience
Post customer testimonials
Enforce terms and conditions and policies
Protect from abuse and malicious users
Respond to legal requests and prevent harm
Run and operate the Website and Services
Processing your Personal Information depends on how you interact with the Website and Services, where you
are located in the world and if one of the following applies: (i) you have given your consent for one or more
speci몭c purposes; this, however, does not apply, whenever the processing of Personal Information is subject to
California Consumer Privacy Act or European data protection law; (ii) provision of information is necessary for
the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is
necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task
that is carried out in the public interest or in the exercise of o몭cial authority vested in us; (v) processing is
necessary for the purposes of the legitimate interests pursued by us or by a third party.
We rely on the following legal bases as de몭ned in the GDPR upon which we collect and process your Personal
User’s consent
Note that under some legislations we may be allowed to process information until you object to such
processing by opting out, without having to rely on consent or any other of the legal bases above. In any case,
we will be happy to clarify the speci몭c legal basis that applies to the processing, and in particular whether the
provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter
into a contract.

Payment processing

In case of Services requiring payment, you may need to provide your credit card details or other payment
account information, which will be used solely for processing payments. We use third-party payment
processors (“Payment Processors”) to assist us in processing your payment information securely.
Payment Processors adhere to the latest security standards as managed by the PCI Security Standards
Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Sensitive and
private data exchange happens over a SSL secured communication channel and is encrypted and protected
with digital signatures, and the Website and Services are also in compliance with strict vulnerability standards
in order to create as secure of an environment as possible for Users. We will share payment data with the
Payment Processors only to the extent necessary for the purposes of processing your payments, refunding
such payments, and dealing with complaints and queries related to such payments and refunds.
Please note that the Payment Processors may collect some Personal Information from you, which allows them
to process your payments (e.g., your email address, address, credit card details, and bank account number) and
handle all the steps in the payment process through their systems, including data collection and data
processing. The Payment Processors’ use of your Personal Information is governed by their respective privacy
policies which may or may not contain privacy protections as protective as this Policy. We suggest that you
review their respective privacy policies.

Managing information

You are able to delete certain Personal Information we have about you. The Personal Information you can
delete may change as the Website and Services change. When you delete Personal Information, however, we
may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply
with our obligations to our a몭liates and partners, and for the purposes described below. If you would like to
delete your Personal Information or permanently delete your account, you can do so on the settings page of
your account on the Website or simply by contacting us.

Disclosure of information

Depending on the requested Services or as necessary to complete any transaction or provide any Service you
have requested, we may share your information with our a몭liates, contracted companies, and service providers
(collectively, “Service Providers”) we rely upon to assist in the operation of the Website and Services available
to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to
Personal Information. We will not share any personally identi몭able information with third parties and will not
share any information with una몭liated third parties.

Service Providers are not authorized to use or disclose your information except as necessary to perform
services on our behalf or comply with legal requirements. Service Providers are given the information they need
only in order to perform their designated functions, and we do not authorize them to use or disclose any of the
provided information for their own marketing or other purposes.

Retention of information

We will retain and use your Personal Information for the period necessary as long as your user account remains
active, to enforce our agreements, resolve disputes, and unless a longer retention period is required or
permitted by law.

We may use any aggregated data derived from or incorporating your Personal Information after you update or
delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal
Information shall be deleted. Therefore, the right to access, the right to erasure, the right to recti몭cation, and the
right to data portability cannot be enforced after the expiration of the retention period.

Transfer of information

Depending on your location, data transfers may involve transferring and storing your information in a country
other than your own. However, this will not include countries outside the European Union and European
Economic Area. If any such transfer takes place, you can 몭nd out more by checking the relevant sections of this
Policy or inquire with us using the information provided in the contact section.

Data protection rights under the GDPR

If you are a resident of the European Economic Area (“EEA”), you have certain data protection rights and we aim
to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If
you wish to be informed what Personal Information we hold about you and if you want it to be removed from
our systems, please contact us. In certain circumstances, you have the following data protection rights:
(i) You have the right to withdraw consent where you have previously given your consent to the processing of
your Personal Information. To the extent that the legal basis for our processing of your Personal Information is
consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.

(ii) You have the right to learn if your Personal Information is being processed by us, obtain disclosure
regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing

(iii) You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You
also have the right to request us to complete the Personal Information you believe is incomplete.

(iv) You have the right to object to the processing of your information if the processing is carried out on a legal
basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an
o몭cial authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to
such processing by providing a ground related to your particular situation to justify the objection.

(v) You have the right, under certain circumstances, to restrict the processing of your Personal Information.
These circumstances include: the accuracy of your Personal Information is contested by you and we must
verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and
request the restriction of its use instead; we no longer need your Personal Information for the purposes of
processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing
pending the veri몭cation of whether our legitimate grounds override your legitimate grounds. Where processing
has been restricted, such Personal Information will be marked accordingly and, with the exception of storage,
will be processed only with your consent or for the establishment, to exercise or defense of legal claims, for the
protection of the rights of another natural, or legal person or for reasons of important public interest.

(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us.
These circumstances include: the Personal Information is no longer necessary in relation to the purposes for
which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object
to the processing under certain rules of applicable data protection law; the processing is for direct marketing
purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to
erasure such as where processing is necessary: for exercising the right of freedom of expression and
information; for compliance with a legal obligation; or for the establishment, to exercise or defense of legal

(vii) You have the right to receive your Personal Information that you have provided to us in a structured,
commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another
controller without any hindrance from us, provided that such transmission does not adversely affect the rights
and freedoms of others.

(viii) You have the right to complain to a data protection authority about our collection and use of your Personal
Information. If you are not satis몭ed with the outcome of your complaint directly with us, you have the right to
lodge a complaint with your local data protection authority. For more information, please contact your local
data protection authority in the EEA. This provision is applicable provided that your Personal Information is
processed by automated means and that the processing is based on your consent, on a contract which you are
part of, or on pre-contractual obligations thereof.

California privacy rights

Consumers residing in California are afforded certain additional rights with respect to their Personal
Information under the California Consumer Privacy Act (“CCPA”). If you are a California resident, this section
applies to you.

In addition to the rights as explained in this Policy, California residents who provide Personal Information as
de몭ned in the statute to obtain Services for personal, family, or household use are entitled to request and obtain
from us, once a calendar year, information about the categories and speci몭c pieces of Personal Information we
have collected and disclosed.

Furthermore, California residents have the right to request deletion of their Personal Information or opt-out of
the sale of their Personal Information which may include selling, disclosing, or transferring Personal
Information to another business or a third party for monetary or other valuable consideration. To do so, simply
contact us. We will not discriminate against you if you exercise your rights under the CCPA.

How to exercise your rights


Any requests to exercise your rights can be directed to us through the contact details provided in this
document. Please note that we may ask you to verify your identity before responding to such requests. Your
request must provide su몭cient information that allows us to verify that you are the person you are claiming to
be or that you are the authorized representative of such person. If we receive your request from an authorized
representative, we may request evidence that you have provided such an authorized representative with power
of attorney or that the authorized representative otherwise has valid written authority to submit requests on
your behalf.

You must include su몭cient details to allow us to properly understand the request and respond to it. We cannot
respond to your request or provide you with Personal Information unless we 몭rst verify your identity or authority
to make such a request and con몭rm that the Personal Information relates to you.


Do Not Track signals


Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to
have your online activity tracked. Tracking is not the same as using or collecting information in connection with
a website. For these purposes, tracking refers to collecting personally identi몭able information from consumers
who use or visit a website or online service as they move across different websites over time. The Website and
Services do not track its visitors over time and across third-party websites. However, some third-party websites
may keep track of your browsing activities when they serve you content, which enables them to tailor what they
present to you.


Social media features


Our Website and Services may include social media features, such as the Facebook and Twitter buttons, Share
This buttons, etc (collectively, “Social Media Features”). These Social Media Features may collect your IP
address, what page you are visiting on our Website and Services, and may set a cookie to enable Social Media
Features to function properly. Social Media Features are hosted either by their respective providers or directly
on our Website and Services. Your interactions with these Social Media Features are governed by the privacy
policy of their respective providers.


Email marketing


We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to
keeping your e-mail address con몭dential and will not disclose your email address to any third parties except as
allowed in the information use and processing section. We will maintain the information sent via e-mail in
accordance with applicable laws and regulations.

In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and
provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or
marketing emails by following the unsubscribe instructions included in these emails or by contacting us.
However, you will continue to receive essential transactional emails.

Links to other resources


The Website and Services contain links to other resources that are not owned or controlled by us. Please be
aware that we are not responsible for the privacy practices of such other resources or third parties. We
encourage you to be aware when you leave the Website and Services and to read the privacy statements of
each and every resource that may collect Personal Information.

Information security


We secure information you provide on computer servers in a controlled, secure environment, protected from
unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical
safeguards in an effort to protect against unauthorized access, use, modi몭cation, and disclosure of Personal
Information in our control and custody. However, no data transmission over the Internet or wireless network
can be guaranteed.

Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and
privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and
all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii)
any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
As the security of Personal Information depends in part on the security of the device you use to communicate
with us and the security you use to protect your credentials, please take appropriate measures to protect this


Data breach

In the event we become aware that the security of the Website and Services has been compromised or Users’
Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but
not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including,
but not limited to, investigation and reporting, as well as noti몭cation to and cooperation with law enforcement
authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we
believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise
required by law. When we do, we will send you an email, get in touch with you over the phone, mail you a letter.

Changes and amendments

We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our
discretion. When we do, we will revise the updated date at the bottom of this page, post a noti몭cation on the
main page of the Website. We may also provide notice to you in other ways at our discretion, such as through
the contact information you have provided.

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless
otherwise speci몭ed. Your continued use of the Website and Services after the effective date of the revised
Policy (or such other act speci몭ed at that time) will constitute your consent to those changes. However, we will
not, without your consent, use your Personal Information in a manner materially different than what was stated
at the time your Personal Information was collected.

Acceptance of this policy


You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and
using the Website and Services and submitting your information you agree to be bound by this Policy. If you do
not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.

Contacting us

If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or
if you wish to exercise your rights, we encourage you to contact us using the details below:
Data protection o몭cer: Stripe Payment Gateway
We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to
exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data
protection laws.
This document was last updated on November 28, 2021