1.1 This Policy statement provides information on the obligations and policies of WAV Skincare LLC with respect to an individual customer’s Personal Data. WAV Skincare LLC undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.2 WAV Skincare LLC’s officers, management, and members of staff shall use reasonable efforts to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, WAV Skincare LLC. WAV Skincare LLC shall use reasonable efforts to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by WAV Skincare LLC shall be done in an appropriate manner and in accordance with the Act and this Policy.
1.3 By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to WAV Skincare LLC as well as to its respective representatives and/or agents (“Representatives”) (collectively referred to herein as “WAV Skincare LLC”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to WAV Skincare LLC’s authorized service providers and relevant third parties in the manner set forth in this Privacy Statement.
1.4 This Policy supplements but does not supercede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
1.5 For the purposes of this Policy, “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified — from that data; or from that data and other information which an organization has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of WAV Skincare LLC or that which shall be collected by WAV Skincare LLC in future.
2. Contacting the Data Protection Officer
2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of WAV Skincare LLC, WAV Skincare LLC shall provide and/or correct that data within 30 days and in a manner in accordance with its standard procedures as stated hereinafter.
2.2 To ensure that WAV Skincare LLC receives your complaints and inquiries, please send the same via email to WAV Skincare LLC at the following email address: email@example.com
2.3 Please note that if your personal data has been provided to us by a third party (e.g. a member via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to WAV Skincare LLC on your behalf.
2.4 Should you not wish WAV Skincare LLC to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from WAV Skincare LLC, you may opt out by sending a clearly worded email to firstname.lastname@example.org. Your request shall be processed within 30 days. Please note however that this may affect our ability to attend to your needs in the event where there is already an existing business relationship.
3. Statement of Practices
Types of Personal Data Collected:
3.1 As part of its day-to day activity, WAV Skincare LLC may collect from you, through various means, including via our websites, smart phone applications, marketing events such as events, road shows and any forms used by WAV Skincare LLC from time to time, some or all of the following Personal Data:
- Name (first and surname);
- Postal Address;
- Phone number (including mobile);
- Email address;
- Bank account/credit card details;
- Lifestyle preferences;
- Medical history;
- Skin information;
- Personal Data of your emergency contacts;
- IP addresses; and
- Photographs and images.
COOKIES and THIRD-PARTY TRACKING
Purpose of Collection of Personal Data
3.2 The above Personal Data mentioned in Clause 3.1 is collected for the purposes of:
- processing your application and registration of your membership and to ascertain if you are eligible for discounts, privileges or benefits or other related purposes;
- evaluating your skin-type and needs;
- customising your skincare products;
- to conduct market research and analysis;
- for direct marketing through voice calls; text messages; email; direct mail and facsimile messages;
- for payment and/or credit control purposes;
- to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback;
- for identification and treatment area access;
- for invitations to WAV Skincare LLC’s events and any other events related to skincare and wellness;
- maintaining and updating your membership details; and
- informing you of new developments, services, promotions of WAV Skincare LLC and other third parties which we are associated with.
Disclosure of Personal Data
3.3 In order to carry out the functions described above, WAV Skincare LLC may, from time to time, disclose your Personal Data between WAV Skincare LLC’s companies.
3.4 Without derogating from any of the above, WAV Skincare LLC may also disclose your Personal Data to the following third parties:
- Regulators and law enforcement officials;
- Third party service providers and consultants;
- Credit, debit and charge card companies, banks and other entities processing payment;
Potential buyers or investors of WAV Skincare LLC or any of WAV Skincare LLC’s companies;
- Any agent or subcontractor acting on WAV Skincare LLC’s behalf for the provision of WAV Skincare LLC’s services.
3.5 WAV Skincare LLC may disclose your Personal Data to the above-mentioned parties also in the occurrence of any of the following events:
- To the extent that WAV Skincare LLC is required to do so by the law;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise or defend WAV Skincare LLC’s legal rights;
- To the purchaser (or prospective purchaser) of any business or asset which WAV Skincare LLC is (or is contemplating) selling;
- To any person and/or entity for the purpose of processing such information on WAV Skincare LLC’s behalf;
- To third parties who provide services to WAV Skincare LLC or on its behalf;
- To any third party that purchases WAV Skincare LLC or WAV Skincare LLC’s business or any part of WAV Skincare LLC or WAV Skincare LLC’s business;
- With your consent; and For the purposes of disaster recovery.
Optional Provision of Personal Data
3.6 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve WAV Skincare LLC’s products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent WAV Skincare LLC from providing the service to you. This type of data includes, but is not limited to:
- Your age;
- Salary range and employment details;
- Education and Profession;
- Hobbies and leisure activities;
- Other related products and services subscribed to;
- and Family and household demographics.
3.7 Under certain circumstances, telephone calls made to any of WAV Skincare LLC’s companies to order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your consent for the collection, use and disclosure of such Personal Data for the purposes of our records, following up with your enquiry and/or transaction, and for quality control and training purposes.
4. Accuracy of Personal Data
Where possible, WAV Skincare LLC will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, WAV Skincare LLC is able to validate the data provided against pre-existing data held by WAV Skincare LLC. In some cases, WAV Skincare LLC is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of WAV Skincare LLC, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to email@example.com.
5. Protection of Personal Data
WAV Skincare LLC uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside WAV Skincare LLC, other than to you or as described in this Policy. However, WAV Skincare LLC cannot ensure or warrant the security of any information you transmit to WAV Skincare LLC and you do so entirely at your own risk. In particular, WAV Skincare LLC does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of WAV Skincare LLC’s physical, technical, or managerial safeguards.
6. Access and Correction of Personal Data
6.1 In accordance with Clause 2.1 of this Policy, you have the right to:
a) check whether WAV Skincare LLC holds any Personal Data relating to you and, if so, obtain copies of such data; and
b) require WAV Skincare LLC to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
6.2 WAV Skincare LLC reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 6.1(a). Upon payment of the requisite fee under Clause 6.1(a) and/or receipt of your request under Clause 6.1(b), your request shall be processed within 30 days.
6.3 If you wish to verify the details you have submitted to WAV Skincare LLC or if you wish to check on the manner in which WAV Skincare LLC uses and processes your personal data, WAV Skincare LLC’s security procedures mean that WAV Skincare LLC may request proof of identity before we reveal information. This proof of identity will take the form of full details of name, membership number and NRIC or Passport or Fin number. You must therefore keep this information safe, as you will be responsible for any action that WAV Skincare LLC takes in response to a request from someone using your details. We would strongly recommend when you login to your online account in our websites that you do not use the browser’s password memory function as that would permit other people using your terminal to access your personal information.
7. Storage and Retention of Personal Data
WAV Skincare LLC will delete, as reasonably possible, or otherwise anonymize any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of WAV Skincare LLC and where the Personal Data is deleted from WAV Skincare LLC’s electronic, manual, and other filing systems in accordance with WAV Skincare LLC’s internal procedures and/or other agreements.
8. Contacting you
To the extent that any of the communication means which you have provided WAV Skincare LLC with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by checking the box on the consent form, or by any other means of indication, you hereby grant WAV Skincare LLC your clear and unambiguous consent to contact you using all of your communication means you have provided to WAV Skincare LLC including using via voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Paragraph 3.2. This will ensure your continued enjoyment of WAV Skincare LLC’s promotional rates and services
9. Change Policy
WAV Skincare LLC reserves the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by WAV Skincare LLC. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
10. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of United States of America in the State of California. You hereby submit to the non-exclusive jurisdiction of the U.S. courts.
11.1 This Policy only applies to the collection and use of Personal Data by WAV Skincare LLC. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. WAV Skincare LLC does not share your Personal Data with third party websites. WAV Skincare LLC is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
11.2 WAV Skincare LLC will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites
11.3 WAV Skincare LLC’s websites do not target and are not intended to attract children under the age of 16 years old. WAV Skincare LLC does not knowingly solicit personal information from children under the age of 16 years old or send them requests for personal data.