Privacy Policy
1. GENERAL PRINCIPLES
a. Owned and governed by Paremina, Inc. (“us”, “our”), with its registered office at 1712 Pioneer Ave Suite 253 Cheyenne WY, U.S.A., our website, available at www.paremina.com (“Website”) and our dedicated pages on social media (including our pages and accounts on Facebook, Twitter, LinkedIn, Instagram, and YouTube):
- provide users with information about our company and its services and products (including news and content about health and wellness);
- allow the online purchase of our products; and
- contain various channels to get in touch with us (contact forms, links to social media account, personalized offer messages, etc).
b. This Website and Social Media Privacy and Cookies Policy (“Privacy Policy”) explains how information relating to an identified or identifiable person (“Personal Data”) is collected, used and protected, and sets out policies and procedures relating to the collection and processing of Personal Data that you may provide us with when visiting our Website, social media pages or using one of the services described hereabove.
c. This Privacy Policy applies only to our Website and dedicated pages on social media. It does not apply to any offline service offered by our company. Please further note that if you follow us on social media, information you provide will also be subject to the privacy policy of the operator of the social media platform.
d. By using our Website or following us on our dedicated pages on social media, you consent to the collection and processing of your Personal Data in accordance with this Privacy Policy. If you do not consent to the terms of this Privacy Policy, please do not use the Website or our social media pages. Where the processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any time, it being however specified that such withdrawal will not affect the lawfulness of processing based on your consent before its withdrawal and such withdrawal may result in you no longer being able to make use of certain features of the Website or our dedicated pages on social media.
2. PERSONAL DATA WE COLLECT AND OUR USE OF SUCH PERSONAL DATA
a. The Personal Data that we collect through our Website and our dedicated pages on social media can be divided into two categories: (1) Personal Data that you provide us with, and (2) cookies.
i. PERSONAL DATA PROVIDED BY YOU THROUGH THE WEBSITE
- We further collect Personal Data from you when, on our Website, you fill out a contact form, subscribe to our newsletter, reply to a message proposing a personalized offer, create your personal account and place an order for a product. In this respect, we collect the Personal Data you provide to us.
- The Personal Data collected includes:
- first name;
- last name;
- postal address;
- email address;
- personal account password;
- telephone number;
- gender;
- date of birth;
- customer ID;
- order number;
- banking details.
- We use the Personal Data you provide us with in order for: (i) you to access our Website, (ii) to allow you to use the functionalities of our Website, (iii) to send you newsletters as per your subscription, (iv) to place orders and execute your purchases on our Website, (v) to provide you with information with regards to personalized offers, (vi) to respond to your requests, including refunds and complaints, and (vii) to comply with our legal obligations, such as calculating taxes.
- The legal basis we rely on to process the Personal Data you provide us with is article 13(1) of the FADP and article 6(1)(a) and (f) GDPR as applicable, which allows us to process personal data when the individual has given consent to the processing of his or her personal data, and on the basis of legitimate interest.
ii. COOKIES
1. What are cookies and what information do they collect?
- Cookies are files containing a small amount of data that are sent from a website to your browser and stored on your mobile or computer device. Other tracking technologies, such as beacons, tags and scripts (“Similar Technologies”), may also be used to collect and track information and to improve and analyze our Website.
- Through the use of cookies and similar technologies, we may collect Personal Data when you visit our Website or our dedicated pages on social media. In particular, we may identify certain usage data when you browse or click on content.
- The following information and Personal Data are collected through the use of cookies and Similar Technologies:
- The IP address of the device that can connect to the Internet and request the connection;
- The date and time of the connection;
- The location, if enabled on the device;
- The resources you access on the Website;
- The name and URL of the file accessed;
- The website/application from which the connection was made (referring URL);
- The browser you are using and, if necessary, the operating system of your Internet-enabled device, as well as the name of your service provider.
- In order to control or limit the collection of this information, you can:
- If available, set up your browser to refuse all cookies or to indicate when a cookie is being sent;
- Upon access to our Website, select which cookie(s) you allow and which cookie(s) you wish to block;
- Delete cookies and clear your browsing data directly from your browser’s settings.
- Please note that if you do not accept certain cookies, you may not be able to use some features of our Website.
- List of cookies that we use:
- Session cookies/Similar Technologies: cookies/Similar Technologies used to operate the Website;
- Preference cookies/Similar Technologies: cookies/Similar Technologies used to save your preferences and various settings;
- Security cookies/Similar Technologies: cookies/Similar Technologies used for security purposes;
- Cookies/Similar Technologies from external services: cookies/Similar Technologies used for the purpose of providing an interactive service such as the contact form;
- Analytics cookies/Similar Technologies: cookies/similar technologies used for the purpose of measuring activity on the Website.
2. For what purpose do we collect information using cookies?
- We use cookies and similar technologies that we collect in order to:
- Enable access to our Website;
- Make certain features of our Website available and to provide you with additional functionality, such as showing you products you recently viewed, estimating taxes and shipping when you purchase products on our Website and keeping track of your shopping cart contents;
- Improve the Website and our dedicated pages on social media;
- Store information about your preferences, enabling us to customize our Website in accordance with your personal interests;
- Speed up your searches;
- Ensure the security of the Website;
- Anonymously collect statistical information regarding the use of the Website, particularly to quantify the audience and usage patterns.
- For information about the processing and use of the data by Facebook, Twitter, LinkedIn, Instagram and YouTube, as well as the related rights and settings options for the protection of your privacy, please refer to the privacy policy of the relevant social media platform.
3. Legal basis for processing
- The purpose of the implementation of all of the above is to maintain and monitor the performance of our Website and to constantly look to improve our Website and its services. The legal basis we rely on to process your Personal Data is article 13(1) of the Swiss Federal Act on Data Protection (“FADP”) as well as article 6(1)(f) of the European General Data Protection Regulation (“GDPR”) as applicable, which allows us to process personal data when it is necessary for the purpose of our legitimate interests.
- In addition, cookies and other functionalities mentioned above which would go beyond the purpose of our legitimate interests (for example, analytics cookies and cookies used for marketing purposes), are implemented upon your acceptance through the means of our cookie banner.
3. WHERE WE STORE YOUR PERSONAL DATA AND CROSS-BORDER DISCLOSURES OF YOUR PERSONAL DATA
a. We take data protection issues seriously and we have chosen to store your Personal Data on Infomaniak servers in Switzerland.
b. We use the services of some third-parties, some of which are operated outside Switzerland or the European Economic Area, notably in the United States of America. We thus transfer your data to one of these third-parties’ databases outside Switzerland or the European Economic Area, including countries which may not have an adequate level of protection for your Personal Data compared with that provided in Switzerland or the European Economic Area. In such event and unless provided otherwise in this Privacy Policy, we enter into agreements with such third-parties ensuring an adequate level of protection for your Personal Data. By providing us with your Personal Data, you agree that we may transfer, store and process your Personal Data outside Switzerland or the European Economic Area – in particular in the USA – and acknowledge that governments in certain countries such as the USA have broad powers to access data for security, crime prevention and detection and law enforcement purposes.
4. NON-DISCLOSURE OF YOUR PERSONAL DATA
a. We will not sell your Personal Data to third parties. We will not share or otherwise make your Personal Data to third parties except as provided in this Privacy Policy.
5. ACCESS TO YOUR PERSONAL DATA BY THIRD PARTIES
a. IN GENERAL
- As noted above, we may compile usage statistics relating to our Website or our dedicated pages on social media based notably on your Personal Data. We may publish those statistics or share them with third parties in an aggregated form such that they do not include your Personal Data.
- Please note that we do not seek your Personal Data from other third-party sources, nor do we actively cross-reference your Personal Data with information from other third-party sources.
b. SOCIAL MEDIA AND THIRD-PARTY WEBSITES
- Where we provide links to websites of third parties (e.g. in a newsletter), this Privacy Policy does not cover how such third party processes your Personal Data. We encourage you to read the privacy policies related to the other websites you visit.
- Our Website and dedicated social media pages contain links that direct you to social networks such as Facebook, Twitter, LinkedIn, Instagram and YouTube, in order to connect you with the content displayed on these social media platforms. When you access social media or another website via our Website or one of our dedicated pages on social media, responsibility for compliance with data protection is to be guaranteed by the respective providers.
- When you establish a connection to a social media platform or another website, your browser connects directly to the server of the relevant service provider. Through this connection, the social media platform or website receives the information that your browser has accessed the relevant page of our Website or our dedicated social media page, even if you do not have an account with such social media platform or if you are not logged into the relevant social media account. This information (including your IP address) is transmitted from your browser directly to the service provider’s server and stored there. If you are logged in to your account with the relevant social media platform, such platform may immediately link your visit to our Website or social media page to your account. If you interact with our Website or social media page, for example by clicking on the “Like” or “Share” icon, this information will also be transmitted directly to the social media service provider’s server and be stored there.
- Please refer to the privacy policy of the relevant social media platform or website for information regarding the purpose and scope of the collection of Personal Data by the relevant service provider, the further processing and use of such Personal Data by the relevant service provider, as well as the related rights and settings to enable the protection of your Personal Data.
c. CONTRACTORS AND AFFILIATES
- We may give certain independent contractors and affiliates access to the Personal Data you made available to us through our Website or our dedicated pages on social media. Those contractors and affiliates assist us with the operation of our Website or our dedicated pages on social media as well as data management and marketing activities. All those contractors and affiliates are required to sign contracts in which they promise to protect Personal Data using procedures similar to ours, unless otherwise provided for in this Privacy Policy.
- The purpose of sharing your Personal Data with such third-parties is to support our business and to maintain and to constantly look to improve our Website and the services it offers to our users. The legal basis we rely on to process your Personal Data in such a manner is article 13(1) FADP and article 6(1)(f) GDPR as applicable, which allows us to process personal data for the purposes of our legitimate interests.
d. CHANGE IN CONTROL OR SALE
- We may also share your Personal Data, subject to a confidentiality agreement, as part of a sale, merger or change in control, or in preparation for any of these events. Your Personal Data may be transferred to a successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other transfer of some or all of our assets, whether as a growing concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Website users is amongst the assets transferred.
e. LEGAL DISCLOSURES
- We may also use your Personal Data (including your communications) if we think it’s necessary for security purposes, to investigate possible fraud or other violations of this Privacy Policy and/or attempts to harm other users of our Website or our dedicated pages on social media. Hence, we may use your Personal Data to investigate, respond to and resolve complaints and issues relating to our Website or our dedicated pages on social media.
- It is possible that we will need to disclose your Personal Data when required by law or if we have a good faith belief that disclosure is necessary to (i) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (ii) enforce our agreements with you, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our Website or our dedicated pages on social media (such as by sharing with companies facing similar threats); or (v) exercise or protect the rights and safety of our users, personnel, or others.
- We attempt to notify users about legal demands for their Personal Data when appropriate in our judgment and technically feasible, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
- The purpose of sharing your Personal Data with the aforementioned authorities is to support our obligation within the meaning of article 13(1) FADP and article 6(1)(c) GDPR as applicable, which allows us to process personal data when it is necessary for compliance with a legal obligation to which we are subject.
f. SPECIFIC THIRD-PARTIES
- We notably share your Personal Data with Shopify Inc., a company based in the U.S, who provides cookies and plug-ins, allowing us to, amongst others, show you products you’ve recently viewed, keep track of your shopping cart contents while you browse on our Website and estimate taxes and shipping.
- We notably share your Personal Data with Shopify Inc., a US based company, for the purpose of payment processing when you buy products on our Website. In order to ensure an adequate level of protection of your Personal Data, we have entered into the EU Standard Contractual Clauses in order to transfer your Personal Data from Switzerland to the USA.
- We use Google Analytics, which is a service offered by Google Inc. (“Google”), that generates detailed statistics about a website’s traffic and traffic sources. Google Analytics uses cookies stored on your computer and your IP address (unless anonymized by use of the appropriate settings) to help analyze how users use our Website. According to Google, Google (i) may transfer this information to third parties in case of a statutory obligation or if a third-party processes data on behalf of Google, and (ii) under no circumstances, Google will combine or associate your IP address with other data stored at Google. We have not entered into an agreement ensuring an adequate level of protection for your Personal Data with Google within the meaning of Section 3.2 above. You hereby consent that we may use the services provided by Google Analytics.
- In order to send you marketing information in an electronic format, we may use the services of Klaviyo, a third-party U.S. based company, which may thus be provided with your Personal Data. We have not entered into an agreement ensuring an adequate level of protection for your Personal Data with Klaviyo within the meaning of Section 3.2 above. You hereby consent that we may use the services provided by Klaviyo. You may opt out from receiving any such information by sending an email to info@paremina.com. Upon receipt of your request, we will promptly notify you by email that your request is being handled. Please note that it may take up to ten days to have your request fully processed. You may therefore receive marketing information during this period of time.
6. MANAGEMENT OF YOUR PERSONAL DATA
a. YOUR RIGHTS
- To the extent possible, you may exercise your rights as described below, by sending us an email at info@paremina.com. Please note that we may ask you to prove your identity before responding to requests based on the rights below, or otherwise related to your Personal Data.
- Right to access and update your Personal Data: Whenever we process your Personal Data, we take reasonable steps to ensure that your Personal Data is kept accurate and up-to date for the purposes for which it was collected.
- Right to delete your Personal Data: You may request the deletion of your Personal Data at any time, subject to any retention obligations imposed on us. We may retain de-personalized (anonymous) information after the deletion of your Personal Data.
- Right of rectification: You have the right to obtain the rectification of your Personal Data if it is inaccurate or incomplete.
- Right to object to processing: Within the limits of the law, you have the right to object to our processing of your Personal Data.
- Right to restriction: You have the right to request that we restrict the processing of your Personal Data.
- Right to data portability: You have the right to be provided with a copy of the Personal Data we have on you in a structured, machine-readable and commonly used format.
- Right to withdraw consent: You have the right to withdraw your consent at any time where we relied on your consent to process your Personal Data.
- Right to complain to a supervisory authority: You have the right to complain to a data protection supervisory authority with regards to our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA) or in Switzerland.
b. PROTECTION OF YOUR PERSONAL DATA AND DATA BREACH
- The security of your Personal Data is important to us, but no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use technical and organizational commercially acceptable means to protect your Personal Data against manipulation, partial or complete loss and unauthorized access by a third-party, we cannot guarantee its absolute security.
- In the event of a data breach, or in the event that we suspect a data breach, we will (i) use our best efforts to promptly notify you, where technically feasible, and (ii) cooperate with you to investigate and resolve the data breach, including without limitation by providing reasonable assistance to you in notifying injured third-parties. We will give you prompt access to such records related to a data breach as you may reasonably request; provided such records shall be our confidential information, and we shall not be required to provide you with records belonging to, or compromising the security of, other users.
- In the event of a data breach, or in the event that we suspect a data breach, we will in addition notify the competent authorities in accordance with applicable law.
c. RETENTION OF YOUR PERSONAL DATA
- We retain the Personal Data you provide to us to the extent necessary to provide you access to and use of our Website or our dedicated pages on social media and of their functionalities (for instance our newsletter or contact form), as well as to the extent required to comply with our legal obligations (for example, if we are required to retain your Personal Data under applicable law), to resolve a dispute or to enforce agreements we have entered into and our internal regulations.
- The length of time we retain cookies and similar technologies depends on their purpose and is always the same, regardless of who the Personal Data relates to.
- We reserve the right to store the data in a depersonalized (i.e. anonymous) form after deletion of your Personal Data.
7. PERSONAL DATA RELATED TO CHILDREN
a. We do not provide services specifically targeted at children and we do not proactively collect Personal Data from children.
8. AMENDMENT OF THIS PRIVACY POLICY
- We may change this Privacy Policy at any time by posting a new version on this page or on a successor page, without prior notification. You shall be notified of any change to the Privacy Policy through a notice on the Website home page. By continuing to access or use our Website or our dedicated pages on social media after such notification becomes effective, you agree to be bound by the revised terms. If you do not agree to the new terms, please do not use the Website and our dedicated pages on social media.
- However, we will always handle your Personal Data in accordance with the Privacy Policy that was in effect at the time of collection.
- The new version of the Privacy Policy will become effective on the date it’s posted, which will be listed at the top of the page as the new effective date.
9. MISCELLANEOUS
- Our failure to enforce any right or provision of this Privacy Policy will not be considered a waiver of those rights.
- If any provision of this Privacy Policy is held invalid or unenforceable by a court, the remaining provisions of this Privacy Policy will remain in effect.
- This Privacy Policy constitutes the entire agreement between you and our company regarding the privacy and cookie policy of our Website and our dedicated pages on social media. It supersedes and replaces any prior agreements we may have had between us regarding the privacy and cookie policy of our Website and our dedicated pages on social media.
10. ANY QUESTIONS OR COMPLAINTS?
a. Should you have questions or complaints regarding this Privacy Policy, please contact us by email at info@paremina.com.