PRIVACY POLICY
10MIN4BEAUTY
PRIVACY POLICY
Effective date: 06/29/2019
Last amended: 06/29/2019
Hello!
Here at 10MIN4BEAUTY, INC. (“10MIN4BEAUTY”), we care not only about your beauty and health but also about your privacy. In this Privacy Policy, we explain when, where, and why we collect personal data about people who visit https://10min4beauty.com/, https://10min4beauty.ru/ https://10min4beauty.mykajabi.com/ or 10min4beauty App (each referred to as “Website”) or use our services, how we use such data, the conditions under which we may disclose it to others, your rights in respect of your personal data, as well as how we keep it secure.
In case you have any questions about your privacy, send them at: support@10min4beauty.com.
This Policy is an integral part of our Terms of Service. Both Terms of Service and this Policy are bounding to our users.
Please take into account that we communicate with participants of our programs via WhatsApp or Telegram. However, we cannot be responsible for the privacy practices of WhatsApp Inc. or Telegram Messenger Inc., companies that run WhatsApp and Telegram applications. You should ensure that you are acquainted with WhatsApp Inc. Privacy Policy, Telegram Messenger Inc. Privacy Policy and agree to its terms.
We may change this Privacy Policy from time to time, so we ask you to check this page to ensure that you’re happy with all the changes. The additional notifications on any amendments will be sent to your email or will be published on the Website.
10MIN4BEAUTY consults people regarding face gymnastics. We share short videos that help people look younger without any cosmetics, Botox or plastics. We also run a blog with articles about face fitness and health lifestyle and provide other information services through our Website. You can find more information about us on the Website, as well as in our Terms of Service.
The Website is a product of 10MIN4BEAUTY, INC., a legal entity established under the laws of Delaware with registration number 7418493.
Personal data (or “data”) are any information relating to you and that alone or in combination with other pieces of information gives the opportunity to the person that collects and processes such information to identify you as an individual. Those can be your name, your identification number, your location data, or information related to your physical, physiological, genetic, mental, economic, cultural or social identity.
Processing of the information means any action with your personal data, for example, collection, recording, organization, structuring, storage, use, disclosure by any means and so on.
10MIN4BEAUTY collects from you the following data for the stated below purposes:
We collect and further process your name, surname and email address in order to create and run your account on the Website and to ensure your comfortable use of our services. We do so only at your request and the contractual basis applies to such processing. Without these data we will not be able to provide you with the opportunity of possessing the account on the Website.
Data from your account will be stored and processed by 10MIN4BEAUTY as long as we believe that you are interested in possessing the account on the Website. This means that we will delete such data if you delete your account.
We enable payments for our services and products through the third-party payment service provider named Stripe or PlayStore or AppStore. We do NOT collect any your payment data by ourselves, the processing is in full carried out by Stripe Inc. according to their security standards. The data collected and processed in order to enable you to perform payment include email address, payment card number, CVC code and expiration date. Without these data you will not be able to access our paid programs of face gymnastics. We ask you to read Privacy Policy of Stripe, PlayStore or AppStore Privacy Policy carefully so you know and fully understand how this service provider processes your data.
Nevertheless, we collect information about your purchases of our services and products for analytical, marketing and statistical purposes. Such collection is performed on the basis of our legitimate interest to promote our services and products and to understand how our business is developing. We may keep information about your purchases in the form that enables your identification no longer than for 1 year of the moment you delete your account. You may unsubscribe from our letters and messages of marketing nature at any time.
We send you our videos about face gymnastics and communicate with you via WhatsApp or Telegram application. Therefore, in order to provide you with ordered services, we need to process your phone number. We perform such processing on the contractual basis (this means that processing is necessary for the performance of a contract to which you are a party), without your phone number we will not be able to provide you with ordered services. We will process your number as long as you pay for the services. When your program ends and you do not renew it within 1 month, we stop processing your number for the mentioned purpose. However, we may further process your number on the basis of our legitimate interest for direct marketing purposes. We may send you an SMS with some information that in our opinion could be interesting for you not more frequently than once per month. You may unsubscribe from our list at any time: just drop us a line at support@10min4beauty.com
During the provision of services, you may also voluntary share with us some other personal data such as your photos. In most cases, we will not process such data for the purposes other than service provision.
If we would like to place your photos on our Website or within some advertising materials, in particular in our “before/after” section, we will ask for you consent before such placing. We will process these data for our marketing purposes. We will store such photos as long as you do not withdraw your consent. We may also delete such photos in case we no longer need them.
When you subscribe to our newsletters or purchase any of our services, we collect and further process your email address in order to send you messages with some useful information about health habits and beauty or with some information of promotional nature. We do so on the basis of our legitimate interest for direct marketing purposes. You may always opt-out from our newsletters, clicking the respective link in each message.
Personal data collected when you register on our mailing list will be stored as long as you are interested in receiving our emails. We consider that you’re interested until you unsubscribe from the mailing list (by clicking the respective link contained in each of our emails).
In order to send you newsletters, we use the services of GetResponse as provided by GetResponse Sp. z o.o. (Polish limited liability company) — they help us to do so effectively and in the way that is convenient for you.
In order to improve and optimize the work of our website, in order to understand your needs and provide services and advertisements that are relevant to you, we may collect your Usage Data. Usage Data reflect your behavior on our website, for example such data show which pages you have viewed and for how long. We also may collect IP-addresses, the source of the traffic, information regarding the device and operation system, information about the version of the device (mobile or desktop), information about connections regarding identifiers of the one user on different devices/browsers.
We may collect such data only if you give us a consent to do so.
Personal Information We Collect
Information you give us. Personal information you may provide through the Website or otherwise communicate to us includes:
Contact information. Your contact details - only your name.
Account information. If you use features of the Website that require a user account, we collect the information you provide to allow us to create your account.
User generated content. We may collect content or other information that you provide or create when you interact with the Website.
How We Use Your Personal Information
We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:
To operate the Website. We use your personal information:
to provide, operate and improve the Website;
to communicate with you about the Website, including updates and support, and administrative messages;
to communicate with you about courses you participate;
to understand your needs and interests, and personalize your experience with the Website; and
to respond to your requests, questions and feedback related to the Website.
What face data is 10min4beauty App collecting?
We may collect only the information that you provide or create when you interact with the 10min4beauty App, including the information about your mimic habits.
For what purposes are we collecting this information?
We collect information about your habits and your target areas for exercising in order to offer you the most suitable courses and exercises, which can be found in the 10min4beauty App.
Will the data be shared with any third parties? Where will this information be stored?
The data about your habits or your face will not be stored and/or shared with third parties.
Sensitive personal information. We do NOT collect any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin; political opinions, religion or other beliefs; health, biometrics or genetic characteristics; criminal background or union membership) through the 10min4beauty App or otherwise.
Retention
We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested). When we have no ongoing legitimate business need to process your personal information, we will delete it.
We collect Usage Data with the help of the following third-party services:
Google Analytics. With the use of Google Analytics, we collect such data as IP-Address, your device model, screen resolution and operation system, session durations, your location. Basing on these data, we analyze your needs and interests, evaluate effectiveness of our campaigns and improve our Website to make its content relevant to you and the Website itself available for smooth viewing with your device.
The cookies are tiny pieces of code that remain in your device after you have visited any website. When you use that website for the next time, these pieces enable website owners to provide you with information customized for your needs.
By giving the consent to 10MIN4BEAUTY for using cookies you make our Website more efficient, fast, and safe. Please note that you may block, delete, or disable saving cookies on your device. You can find more information about how we use cookies in our Cookies Policy.
Please note that sometimes we may process your data for the period longer than indicated above. Such processing could be carried out by 10MIN4BEAUTY only for statistical purposes and subject to the appropriate safeguards in accordance with applicable data protection laws.
What are statistical purposes? Statistical purposes mean any collection and processing of personal data necessary for statistical surveys or to produce statistical results. Those statistical results may further be used for different purposes, for example, we use them in order to assess our business development, understand the market demands and improve our services. The statistical purpose implies that respective statistical result does not include personal data, but only aggregate data.
In most cases, we will anonymize your data before starting to process it for the statistical purposes. As a result, such data will be no longer considered personal and its use will be not governed by data protection laws.
Note that we may process your personal data not only on the basis of your consent or at your request, but also when the processing is necessary:
In all cases, we will notify you about applied legal basis for processing and other relevant details, before we start processing your personal data on the specific legal basis. However, we will not, if we are forbidden to do so in accordance with our obligations under any applicable legislation.
If 10MIN4BEAUTY decides to change the purposes of processing specified above, we will inform you on such changes prior to the use of your personal data within the newly set purposes. The notification on such changes will be sent to you via email or WhatsApp/Telegram and you will have to provide your consent for the amended purposes (unless additional purpose of processing is compatible with those listed above).
Please note that in no case we sell your data or make any decision based solely on automated processing that may produce legal effects or similarly significant effects.
In order to provide high-quality services, 10MIN4BEAUTY hires people, enters into agreements with independent contractors as well as cooperates with other services providers, companies and organizations. For those reasons, some of your personal data can be passed to the mentioned persons.
First of all, our employees may have access to your data. Then, we may transfer your data to our sub-contractors and affiliates. Where applicable, we secure such transmission by including standard contractual clauses adopted by the European Commission into our data processing agreements.
10MIN4BEAUTY uses only secure places of storage, our own servers in secure data center.
In the frames of using third-party services when collecting and processing Usage Data, we may transfer your data to the following companies:
(1) Google LLC (the USA)
Google LLC provides 10MIN4BEAUTY with the services of Google Analytics. The company is located in the United States of America and complies with the requirements of the EU-US Privacy Shield. Here is some information on data protection practices of Google LLC.
(2) GetResponse Sp. z o.o. (Poland)
GetResponse Sp. z o.o. runs well-known service named GetResponse andhelps 10MIN4BEAUTY to deal with newsletters. It is a limited liability company with its registered office in Gdansk, Poland. As the EU-based company they have committed to adhering to requirements of the General Data Protection Regulation of the EU. Please find more information about how they process personal data here.
(3) Stripe, Inc. (the USA)
Stripe Inc. is a payment service provider. It is a US-based company that adheres to the Privacy Shield Principles. We use their services to let you easily pay for any our program you may be interested in. You may read about how they deal with privacy and security matters here.
(4) QSOFT, LLC (the USA)
QSOFT LLC. is a CRM (www.amoCRM.com) service provider. It is a US-based company that adheres to the Privacy Shield Principles. You may read about how they deal with privacy and security matters here.
In all cases, if we pass your personal data to other persons, we ensure that your personal data is being protected and used only within the purposes specified in this Privacy Policy. This is achieved by using only certified services and products, signing agreements on protection of personal data with contractors and partners, as well as taking technical measures to ensure the information is protected when stored, used and while being processed and transferred.
You also have to know that 10MIN4BEAUTY may disclose your personal data to enforce and comply with the law. In other words, 10MIN4BEAUTY may disclose information necessary for the investigation or legal process on official request or the official bodies acting within their powers.
You have a right to access to your personal data processed by 10MIN4BEAUTY and right to data portability
This means that you can ask 10MIN4BEAUTY what personal data of yours is processed. You can also ask for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties which have access to information. You have a right to request from 10MIN4BEAUTY your personal data in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller, if the processing is based on your consent or on contract and the processing is carried out by automated means.
You have a right to request from 10MIN4BEAUTY to rectify your personal data
This means you can require all the inaccurate personal data concerning you being corrected. You can also complete the personal data if you feel there is a need to do so.
You have a right to request 10MIN4BEAUTY to erase personal data
You can request 10MIN4BEAUTY to erase personal data if its processing is no longer necessary to achieve purposes for which it was collected as well as if there are no legal grounds for the processing. In most cases, 10MIN4BEAUTY will erase it unless otherwise required by legislation.
You have a right to restrict the processing of your personal data by 10MIN4BEAUTY
In some cases, prescribed by law you will be able to restrict the processing of your personal data, for example, if you contest the accuracy of your personal data being processed or in case 10MIN4BEAUTY is not interested in processing of your personal data any longer, but you want 10MIN4BEAUTY to do this on different reasons, for example, to bring some claim for somebody and, instead of the erasure of information, its processing will be just restricted.
You have a right to withdraw your consent
You can withdraw your consent for the collection and processing of your personal data by 10MIN4BEAUTY at any time by contacting us, without affecting the lawfulness of processing based on consent before its withdrawal. After we at 10MIN4BEAUTY receive such withdrawal request from you, we will process it in a timely manner and we will no longer process your personal data, unless otherwise is set by law.
You have a right to object to processing of your personal data by 10MIN4BEAUTY
In some cases, prescribed by the applicable laws you can object to processing of your personal data.
You have a right to object to processing of your personal data when the processing is related to the performance of our task carried in the public interest or in the exercise of official authority vested in us; or we process your data to pursue our or third party’s legitimate interests, and you believe that such interests are overridden by your interests or fundamental rights and freedoms.
If you make a request objecting to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing.
Please note that when processing of your personal data is carried for direct marketing purposes, you have the right to object at any time to such processing without providing any justification. We will no longer process your data for such direct marketing purposes. You may refer to relevant sections of this Privacy Policy to learn whether we process your data for direct marketing purposes.
How to exercise your rights as to your personal data?
Any requests to exercise your rights can be directed to 10MIN4BEAUTY through the contact details provided below. These requests are free of charge.
10MIN4BEAUTY will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if 10MIN4BEAUTY is overwhelmed by the number of requests or the request at issue is complicated and requires a lot of action. 10MIN4BEAUTY will inform you of any such extension within one month of receipt of the request, together with the reasons of such delay.
If you have doubts as to our reply or reaction, or absence of such, you have the right to lodge a complaint with a supervisory authority that is empowered to process such complaints in your country.
10MIN4BEAUTY processes your data using computers and/or other IT enabled tools. 10MIN4BEAUTY takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. For example, 10MIN4BEAUTY uses verified contractors that might have access to the data as specified in Section 3 of the Privacy Policy with which the relevant data processing agreements are signed. We also guide and train our personnel to process your data securely according to our internal data protection policies.
The privacy of children is one of our concerns. Here at 10MIN4BEAUTY we can provide services only in case you are aged 16 or older. If you are under 16 you will need to get your parent’s/guardian’s permission before submission of any personal data to 10MIN4BEAUTY. If you are underage, and there are no data as to your parent’s/guardian’s permission to use our Website, please do not provide us with your consent for data processing. In such case, we will not collect or process your personal data that can be processed on the basis of the consent, and you will have a limited use of our Website.
If any personal data of yours would be under the breach, we would inform you and the respective data protection agencies as to the accidents without undue delay, if there are high risks of violation of your rights as data subject. We would also do our best to minimize any such risks.
We hope this Privacy Policy helped you to understand how your personal data will be dealt here at 10MIN4BEAUTY. We will take care of it, so you can explore our Website and not be concerned over your privacy.
Your 10MIN4BEAUTY team
Owner and Data Controller:
10MIN4BEAUTY, INC.
2035 Sunset Lake Rd, suite B-2
Newark, New Castle, DE, the USA
Contact email: info@10min4beauty.com