PRIVACY POLICY - Personal Data

A. PRIVACY STATEMENT

Nudipesona attaches particular importance to the processing, confidentiality, and security of your personal data. We are committed to offering you personalized services while respecting your privacy and personal choices.

The purpose of this privacy policy is to inform you in a clear, simple, and complete manner of the processing carried out on the personal data that you provide to us, their possible transfer to third parties as well as your rights and the options you have to control your information protect your privacy, in accordance with current regulations.

In this Statement, you will find information about:

1. Who are we
2. What data we may collect about you
3. How we collect or receive your data
4. For what purposes do we use your data
5. How long do we keep them
6. Who accesses your data
7. How we protect them and ensure their confidentiality
8. How we treat your preferences and your rights stemming from Hong Kong Regulation
9. How to contact us if you have questions about our use of your personal data
10. How we protect children's privacy
11. Modification of this privacy statement

 A1. WHO are we ?

Nudipesona

Nudipesona (head office), a private limited company under Hong Kong law with its head office located at 39 Wang Chiu Square 3, registered in the Hong Kong and Companies Register under number 57264524-000-01-24-A.

Nudipesona is a story of beauty and vibrant energy, passion, and discovery; it is also a story of the endless source of inspiration - Nature.

The creations of Nudipesona express the passion for beautiful gestures and exceptional objects. Nestled in the heart of a fast-paced, bustling city, we understand the importance of convenience and versatility. Seamlessly transitioning from exhilarating days of hiking and swimming to evenings spent with friends in the city, nature inspiration is transformed into multifunctional wear and accessories that accompany you on every adventure. That was the origin of the vision to support the lifestyles of individuals who love the outdoors. With our products, you can embrace the thrill of exploration knowing that you have the tools to make every moment count. 

 

A2. WHAT data do we collect about you?

"Personal data" means any information that identifies you either directly (such as your name) or indirectly (for example, using a unique customer number).

The personal data we collect depends on the point of contact through which you interact with us, as well as the purposes of this interaction as described in this Policy, and are also limited to those that are relevant and appropriate for this interaction. Visitors to the nudipesona.com website who view our products, information, and offers can choose to do so without logging in, and the same is true for point-of-sale search and browsing on social media. Unless you choose to interact with us through these contact points, for example:

• • • by creating an account and connecting to it,
    • by making a purchase on our site,
    • by subscribing to one of our programs or services,
    • by writing to us via the consumer contact forms,
    • or by writing us a comment in the free online order fields.

For one thing, for customers and others who sign up for programs or services, we need to collect certain relevant information from you. The information we collect is related to a given transaction as well as in the context of our business relationship with you. For example, if you make purchases on nudipesona.com, we must collect information to process (and, if necessary, execute and dispatch) your order, to ensure its tracking and invoicing, and to be able to respond to any after-sales inquiries you may have. For customers and others who sign up for our programs or services, we generally collect your contact information, contact preferences, and information that allows us to make recommendations to you about our products or services that may be of interest to you. We can centralize information about our customers to organize it in one place, as this helps us manage our relationship with you as well as your choices and preferences. Finally, if you subscribe to our newsletter, we collect your email address and mobile number.  

Depending on the data that you communicate to us or that you share with us, personal data may include information concerning:

• • • Your identity and contact details: surname, first name, postal address, email address, telephone number
    • Your interests
    • A history of your purchases (in-store or online, including your orders, tracking and invoices, amount and type of purchase) and your repairs
    • Your requests via our customer care service or our public relations service
    • The Nudipesona events in which you participate
    • Your size and lifestyle preferences
    • Your date of birth in order to benefit from the Birthday offers eligible according to your program.
    • Your satisfaction and comments on our programs, services, and products
    • The information that you specify is related to the possible undesirable effects that you could report to us.

Regarding your purchases, payments are made via a secure payment platform, supplemented by control measures, including encryption of contact details, in order to guarantee the security of purchases made and to fight against fraud. Your bank details are therefore not accessible on Nudipesona's servers.

We invite you to ensure that your data is regularly updated, either by modifying it directly on our sites or, by informing us in writing of any modification by referring to the dedicated section "How to contact us".

 

A3. HOW do we collect or receive your data?

As part of our relationships, the data we collect may be collected through the following contact points:

• • • Course on nudipesona.com
    • Nudipesona events in which you participate
    • Relationship with our public relations services
    • Contact with Customer Care
    • Forms that you fill out (online)
    • Digital applications with which you interact
    • Loyalty program from which you benefit
    • Third party data providers with whom you share information
    • Retailers for whom you agree to receive our communications
    • Satisfaction surveys or questionnaires to which you answer

We make sure to identify the personal data essential for the purpose for which it is collected by indicating it with an asterisk like this ‘(*)’ on each personal data collection form. If you do not fill in these mandatory fields, we will not be able to respond to your requests and/or provide you with the services requested. The other information is optional and allows us to know you better and improve our communications and services to you. Although not mandatory, we recommend that you fill them in to allow you to benefit from the best possible experience during our interactions with you.

During your purchase journey, you will be able to choose between i) logging into your existing Nudipesona account, ii) creating a new account, or iii) paying as a Guest (also called Guest Check out). This last purchasing experience is thus summarized as follows:

Payment for purchases as a Guest refers to the possibility for any Nudipesona customer or prospect to make a purchase in our online store without logging into an account. Your information is collected only for the process of payment and delivery of items or for Nudipesona in order to comply with applicable laws. In accordance with your express consent, the information may be used for analytical purposes by Nudipesona. Likewise, in accordance with your express consent, your information may also be used by Nudipesona for communication purposes via its preferred channel (for example: subscribe to a newsletter). 

  

A4. FOR WHAT PURPOSES is your data used by Nudipesona?

We are required to use your data for purposes defined according to the nature of our relationships. Thus, depending on the context in which your data is collected, it may be used for one or more of the following purposes:

• • • Managing your orders
    • Management of personalized content and Nudipesona communications (digital or not)
    • Managing your profile
    • Managing your loyalty program
    • Managing your requests in connection with Nudipesona
    • The management of events in which you register/participate
    • The management of our website and our digital applications
    • Management and improvement of our products and services, image and reputation
    • Transaction management (securing online payments, prevention of fraud, incidents related to payments and debts)
    • Analysis and personalization purposes: with your explicit consent (when required), we use your personal data to send you personalized communications (newsletters, offers, invitations, and surveys) and analyze your preferences and habits, anticipate your needs from your consumer profile. We can make you benefit from our personalized communications by means of emails, postal letters, SMS, or calls according to the communication preferences that you have indicated to us and your consumer profile (when authorized).

We ensure the legal basis for the processing of your data according to the purpose (s) concerned, which may be, depending on the context in which it is collected:

• • • Your explicit consent: for example, for the purposes of managing our personalized commercial offers, managing your browsing via cookies under the conditions defined by our Cookies Policy, or establishing your consumer profile in applicable cases;
    • The implementation of a contract, for example for your access to your customer account, the processing and follow-up of your orders;
    • A legal obligation when processing is required by law, for example, keeping purchase invoices to prevent fraud;
    • Our legitimate interest: for example, to improve our products and services, defend ourselves, or secure our tools.

  

A5. HOW LONG can we keep them?

We keep your personal data only for the time necessary for the purpose pursued. In general, your personal data is stored in our database, as shown in the table below: 

• A5.1 Data subject: Regular customer (ie: having a Customer profile)
  • Duration: 10 years from the date of the first purchase; 5 years for business development
  • Specificity: A first period of 5 years when your status is "active". A second period of 5 years is also when your status becomes ‘inactive’. If the status is still "inactive" after the second period of 5 years, your customer profile is deleted. The status becomes “active” when interacting with Nudipesona such as a purchase or an update of your profile.
• A5.2 Data subject: Prospect
  • Duration: 3 years from the date of data collection
  • Specificity: This period will be renewed each time you interact with Nudipesona (for example participation in an event) or your consent to continue interacting after this period.
• A5.3 Data subject: ‘Guest’ (i.e. not having a Customer profile)
  • Duration: For the duration of the transaction until the delivery of the order
  • Specificity: Intermediate archive of 5 years maximum from the end of the commercial relationship.
• A5.4 Data subject: Customer Care (ie: calls for assistance, complaints, or information)
  • Duration: For the duration of the request management, or by default 30 days maximum
  • Specificity: Intermediate archive of 5 years maximum from the end of the management of the request.
• A5.5 Data subject: Privileged interlocutors (eg agents, stylists, celebrity managers, artists) in relation to Nudipesona Public Relations services
  • Duration: 10 years from the date of your first contact
  • Specificity: This period will be renewed each time you interact with Nudipesona (for example a request for information).

When we no longer need to use your personal data, it is deleted from our systems and our registers or made anonymous so that it can no longer be identified, subject to retention for archival purposes. Claims and litigation management as well as to meet our legal and/or regulatory obligations and / or to respond to requests from authorities authorized to make the request.

 

A6. WHO can access your data?

Your data is intended for the services of Nudipesona concerned by your requests. We ensure that only duly authorized persons can access your personal data when this is necessary for the aforementioned purposes.

We do not pass your data on to third parties for commercial purposes.

We are only required to communicate your information if necessary, and if possible in a form that does not allow direct identification to:

• • • Our trusted third-party providers, act as subcontractors according to our instructions and on our behalf only.

For example, we entrust certain services to third parties responsible for delivering a product to you, payment service providers and transaction security against fraud, third parties who assist us in the organization of our events, third parties providing services IT, digital communication, and public relations agencies, third parties who assist us in customer care, third parties who assist us in qualitative surveys of our products, programs or services.

• • • Our trusted third-party partners wish to know your preferences and consumption trends for our programs and services in order to improve visibility, accessibility, and performance.
    • Our trusted third-party partners assist us in the management of your orders. In particular, we entrust certain services to third parties responsible for delivering a product to you, to payment service providers, and to providers ensuring the security of anti-fraud transactions.

Please note that these partners may act as data controllers; in this case, they have their own privacy policies. We illustrate some examples in the list below:

• • • SF orders and deliveries (delivery) and any other service provider in management.
    • Shopify (website host) and any other service provider in the management of your e-commerce shopping experience.
    • Payments and transaction security (securing transactions against electronic commerce fraud), PayPal (payment service provider), and any other payment service provider, verification, or banking provider.
    • Third parties wish to know your interests so that they can build similar audiences and target prospects corresponding to your profile. In the context of this specific processing, we are not the data controller relating to prospecting and you will not be the subject of prospecting, your data being only used to constitute profiles similar to yours.
    • Third Parties in the event of a change of control or of status or company name, for legal reasons, or with your prior consent.

You can also choose to disclose your personal data to our partners, advertisers, and affiliates by following a link to and from their websites. Please note that these websites apply their own privacy policy.

We may also offer you the possibility of using your social media connection data. Please note that in this case, you are sharing your profile information with us. The personal data shared depends on the configuration of the social network platform. Please note that these social networks apply their own privacy policy.

 

A7. HOW do we protect and ensure the confidentiality of your data?

We take all the necessary precautions to guarantee the confidentiality and security of your data and to prevent it from being distorted, damaged, destroyed, or from unauthorized third parties having access to it.

We ask our partners and group companies to maintain a level of protection similar to ours concerning your personal data. The security measures put in place are evaluated and updated to face new threats and new challenges.

 

A8. HOW are consumer preferences and individual rights treated?

In accordance with HK applicable laws and requirements, Nudipesona has put in place measures to guarantee respect for the rights of individuals with regard to personal data that we (or our third parties) have about them. This includes, for example, the right to know the data that we hold about you or to obtain a copy, as well as the limited rights to modify your data, to request erasure, or to object to the processing of your data.

We encourage those who have given their data to us to keep it up-to-date (for example, if you change your email address, address, or telephone number), so that we keep your correct information in our files. We also encourage consumers to update their preferences with us, for example regarding products and frequency of contact, so that we can customize our service to suit your expectations and needs.

Finally, we offer individuals the right to withdraw their consent from our programs and offers at any time. To do this, or to exercise any of these other rights, please use or the contact possibilities in the section "How to contact us" below. For people wishing to access their data, we also need authentication to ensure that we do not provide personal data to an unauthorized person.

 

A9. HOW to contact us ?

Please contact us in the manner below if you wish to exercise these rights or if you have questions or complaints regarding the processing of your personal data.

Nudipesona

- By email: contactus@nudipesona.com

- By phone: +852  95552088                                                                            -

For the sake of speed of management of your requests, it is advisable to favor the email address.

 

A10. HOW does Nudipesona protect the privacy of children?

Nudipesona has adopted practices aimed at avoiding collecting or storing information on children under the age of 18. If we learn that we have mistakenly collected information from people under the age of 18, we will purge it immediately, except to answer a single question or request from the person, their parent, or legal guardian.

 

B. NOTICE ABOUT COOKIE MANAGEMENT

This Notice about cookies applies when visiting the website available at nudipesona.com (hereinafter the “Website”)

The purpose of this cookie policy is to inform you of the source and use of browsing information collected during your visit to the Website and the tools provided to allow you to express your choices about cookies.

 

B1. WHAT is a cookie?

Subject to your choices, when visiting the Website, a text file may be placed on your device (computer, smartphone, tablet), courtesy of your web browser.

This text file is a cookie. During its validity or registration period, it will allow the sender to identify your device on future visits. 

Some cookies are essential for using the Website, others optimize and personalize the contents displayed.

 

B.2 WHO sends the cookies on our website?

Cookies that may be saved to your device when you visit the Website pages are issued by Nudipesona and/or third parties. Only the cookie issuer is likely to read or modify the information contained within it.

Cookies sent by Nudipesona are mainly related to the operation of the Website.

The others are third-party cookies sent by our partners or advertising agencies, via the advertisements shown on our Website. The examples below are for illustration purposes:

Personal_id (twitter.com)

Role: When Twitter acts as a third-party host, it collects data via a range of plug-ins and integrations, which are primarily used for targeting and tracking.

Link to privacy policy: https://twitter.com/en/privacy 

Nudipesona makes every effort to ensure that third-party cookies are issued and used in compliance with the applicable regulations.

 

B3. WHAT is the purpose of the cookies issued via the website?

Subject to your choices, various cookies may be installed on your device for the purposes detailed below. For the sake of transparency and in as much depth as possible, we inform you of the purposes of the third-party cookies that we are aware of, and the ways in which you can make choices about these cookies. All cookies may be cross-referenced with your customer data in order to personalize your experience, limit commercial interaction, ensure the proper functioning of your loyalty benefits, improve our services, and guarantee your satisfaction.

 

• B3.1 Essential cookies for Website operations

“Essential” cookies are necessary for Website browsing and allow you to use the Website’s main features.

For example, these cookies are intended particularly for:

- saving your choices or desire not to make a choice about tracker cookies;

- service authentication;

- saving the contents of a shopping cart;

- customizing the interface.

Removing them may make it hard to browse the Website or may make it impossible to place an order. These cookies may be installed on your device by Nudipesona or its service providers.

These cookies enable or facilitate digital communications and/or may be strictly necessary for the provision of an online communication service at your express request. As a result, they do not require your prior consent. Saving or reading such cookies is necessary for the provision of the service and will be based on Nudipesona’s legitimate interest in implementing such processing for the proper use of its Website.

 

• B3.2 Personalization cookies

Personalization cookies allow us to personalize and improve your user experience, for example by making your searches easier and optimizing your shopping experience. They also allow us to adapt the look of the Website to your device display during your visits.

These Cookies are issued by Nudipesona and/or by our service providers. The issue and use of cookies by third parties on our Website may also be subject to the privacy protection policies of these third parties.

Such cookies are saved or read, subject to your prior consent. If you refuse these cookies, you will not be able to benefit from the functionalities described in this paragraph.

 

• B3.3 Analytical cookies

Analytical cookies make it possible to gauge the audience for various Website content, and to establish visitor statistics and volumes in order to evaluate and improve our service ergonomics. These cookies include those used to create similar profiles that will be prospected according to your information.

These Cookies are issued by Nudipesona and/or by our service providers. The issue and use of cookies by third parties on our Website may also be subject to the privacy protection policies of these third parties.

The information communicated to technical service providers is transmitted in the form of aggregate statistics and traffic volumes, excluding any personal information. These statistics are reconciled with the traffic statistics of other websites, as well as with your customer data.

Such cookies are saved or read, subject to your prior consent. Refusing the implementation of or deleting such cookies does not affect your Website browsing but is likely to prevent us from ensuring the best quality of service we wish to offer our visitors.

 

• B3.4 Sharing cookies (social links)

Our Website may include third-party computer applications that allow you to share Website content with others, or to publish your visit or opinion of Website content to these other persons. This is notably the case for “Share” and “Like” buttons on social networks such as Facebook, Twitter, Instagram, Pinterest, etc.

The social network providing such application buttons is likely to identify you through this button, if you use the button, and even if you have not used this button but are signed in to the social network when you consult the Website (open session during your browsing). Share buttons will allow you to connect the contents consulted to your user account.

We have no control over the process social networks use to collect information about your Website browsing and associated with the personal data at their disposal. We invite you to consult the privacy protection policies of these social networks.

 

• B3.5 Advertising cookies

Advertising cookies are not essential for browsing but allow you to see more relevant advertisements personalized to your interests on the Website as well as other websites you may browse. As such, advertising cookies allow, for example, the display of advertising, capping the display (not presenting the same advertising to a user in a repetitive manner), combatting click fraud, billing the display service, the measurement of targets more interested in the advertising to better understand the audience, etc.

Advertising content personalization can also be achieved by using our partner’s technology, to associate your device’s Website browsing information with the data you provided us when you registered. 

Saving or reading such cookies is subject to your prior consent. Refusing these advertising cookies has no impact on your use of the Website, nor will it stop advertising on the Website. However, we will be unable to offer you advertising that takes your interests into account.

 

B4. HOW LONG are the cookies kept?

Cookies saved on your device have a maximum lifespan of thirteen (13) months. At the end of this period, personal data collected through the cookies will be deleted.

 

 

B.5 HOW to manage cookies saved in your device?

Cookies saved on your device result from the settings you have chosen during your visit, which can be modified at any time under the conditions detailed in this cookie policy.

There are various ways to manage the implementation of cookies, as presented below.

If your device is used by more than one person and operates more than one browser, we cannot be certain that the services and advertisements sent to your device are appropriate for your personal use of your device, rather than of another user of your device. If you choose to share your device and browser cookie settings with others, you are responsible for doing so at your own discretion.

Each browser has different settings. These are usually described in your browser help menu. We therefore recommend reading it. This will show you how to change your cookie preferences.

• • • For Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
    • For Safari: https://support.apple.com/en-euro/guide/safari/sfri11471/mac
    • For Chrome:  https://support.google.com/chrome/answer/95647?hl=en&hlrm=en
    • For Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
    • For Opera: https://help.opera.com/en/latest/web-preferences/#cookies

Please note: any choices in your browser settings concerning the acceptance or refusal of cookies will be likely to modify your Internet browsing experience and your access to the Website and certain services requiring the use of these same cookies.

 

C. NOTICE ABOUT SOCIAL LOGIN

Privacy Notice – Register using social providers

C.1 FOR WHAT ACTIVITIES personal data are processed

By creating a Nudipesona account, logging on to nudipesona.com via Google, Facebook, or Instagram, or binding your Nudipesona account to your Google, Facebook, and Instagram accounts, in this case, you are sharing your profile information with us. The personal data shared depends on the configuration of the social network platform.

In order to facilitate the account creation process, we can pre-fill the account creation form with information retrieved from the social provider account.

 

C2. WHAT data are exactly involved :

The types of information that Nudipesona can collect depend on the settings selected for that provider and are subjected to the processing details under their own established privacy policies. Here are the types of information per

• • • Google: first name and last name, e-mail, language preferences (not used), profile picture (not used)
    • Facebook: first name and last name, e-mail, profile picture (not used)

 

C3. WHO is the Data controller:

Nudipesona (registered office), a private limited company under Hong Kong law whose registered office is located at 39 Wang Chiu Road, Enterprise Square 3, Kowloon Bay, Hong Kong whom you share your information.

Please note that your social media connection data is administered and managed by the above-listed social media platforms acting on your social media account and may act as a Data Controller. Please note that these social networks apply their own privacy policy, settings, and standards.

 

C4. WHERE can I find further information? 

Please contact us as below if you wish to exercise your rights under applicable HK Data Protection Laws or if you have any questions or complaints regarding the processing of your personal data.

- By email at contactus@nudipesona.com