Naked for Satan Ltd.

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Privacy Policy

Data protection directive in accordance with the new General Data Protection Regulation (GDPR)

We would like to inform you that there are some changes in the Data Protection Act that will come into effect on May 25, 2018. It is a positive step that enhances your existing privacy and security rights and improves the protection of your personal information.

We have adjusted our privacy policy accordingly. Your trust is very important to us, and we commit to respecting your existing rights and protecting your personal information. Visit our Privacy Policy here.

SCOPE

Naked for Satan Ltd. (UK) in the following referred to as Naked4S, (Data Controller for EU), and our affiliates (“Naked for Satan", "Naked4S”, “we”, “us”, “our”) know how important privacy is to our customers, and we strive to be clear about how we collect, use, disclose, transfer, and store your personal information.

This Privacy Policy applies to any Naked4S device, website, customer service platform, or other online application that refers to or links to the Privacy Policy (collectively, our “Services”). This Privacy Policy applies regardless of whether you use a computer, mobile phone, tablet, TV, home appliance device, or other smart device to access our Services.

Below you will find a summary of the key messages contained in our Privacy Policy. For more detailed information on how we process your information, please continue to read below.

Information We Collect

We collect various types of information in connection with the Services, including:

  • Information you provide directly to us;
  • Information we collect about your use of our Services; and
  • Information we obtain from third party sources.
  • We may also seek your separate consent to collect information or separately notify you about how we collect your personal information in a manner that is not described in this Privacy Policy, as required for certain additional services.

    Use and Sharing of Information

    We use the information we collect, among other things:

  • To provide the Services you request;
  • To understand the way you use the Services so that we can improve your experience;
  • To understand more about our customers so that we can offer the most relevant communications, services, and experiences; and
  • To provide customised content and advertising with your separate consent where required.
  • We may share your information with:

  • Affiliates – the companies related to Naked4S Ltd. by common ownership or control.
  • Business partners – trusted companies that may provide information about products and services you might like (where you have provided your separate consent).
  • Service providers – companies that provide services for or on behalf of Naked4S.
  • Law enforcement – when we are required to do so or to protect Naked4S and its users.
  • Additional Information about Specific Products and Services

    • While this Privacy Policy applies to all our Services, we will also provide you with certain specific privacy supplements that contain additional information about our practices in connection with particular Services, where this is necessary. These supplements apply to your use of the Services they cover.

    Contact Us

    Naked for Satan Ltd., 20-22 Wenlock Road, London, England N1 7GU
    Registered in England & Wales No. 10540621
    E-Mail: board@nakedforsatan.com.


    Naked4S GLOBAL PRIVACY POLICY

    Effective Date: 25th May, 2018

    Naked for Satan Ltd. (UK), (Data Controller for EU), and our affiliates (“Naked4S”, “we”, “us”, “our”) know how important privacy is to our customers, and we strive to be clear about how we collect, use, disclose, transfer, and store your personal information.

    This Privacy Policy explains our information practices. This Privacy Policy applies to all Naked4S devices, websites, customer service platforms, or other online applications that refer to or link to the Privacy Policy (collectively, our “Services”).

    This Privacy Policy applies regardless of whether you use a computer, mobile phone, tablet, TV, home appliance device, or other smart device to access our Services. This policy also includes customer support for such devices, websites, or online applications.

    While this Privacy Policy applies to all our Services, we will also provide you with certain specific privacy supplements that contain additional information about our practices in connection with particular Services, where this is necessary. These supplements apply to your use of the Services they cover.

    It is important that you read the Privacy Policy and any supplemental policies provided by us carefully because these documents provide information on how your personal data is processed any time you use our Services.

    It is also important that you check back often for updates to the Privacy Policy. If we update the Privacy Policy, we will let you know in advance about changes we consider to be material by placing a notice on relevant Services or by emailing you, where appropriate. The most current version of the Privacy Policy will always be available here. You can check the “effective date” posted at the top to see when the Privacy Policy was last updated.

    INFORMATION WE COLLECT

    Information you provide directly

    Some Services enable you to give us information directly. For example:

  • A number of our Services enable users to create accounts or profiles. In connection with these Services, we will ask you to provide certain information about yourself to set up the account or profile. For example, you submit certain information about yourself, such as your name, date of birth, and email address when you create a Naked4S account.
  • If you contact our Customer Services team to discuss a product or service, make an enquiry, or lodge a complaint, we will collect information from you regarding the service you require from Naked4S. Such information collected will include your name, and depending on the nature of your query, may also include your home address, telephone number, email address, and device identifier.
  • Some of our Services enable you to communicate with other people. Those communications will be transmitted through our systems.
  • If you allow the sharing of Contacts information with us, the telephone numbers of the people in Contacts will be collected by us to facilitate file sharing and messaging with the people in your Contacts. You can turn off the file sharing and messaging features or restrict the scope of sharing by going to your profile settings.
  • Information about your use of the Services

    In addition to the information you provide, we will collect information about your use of our Services through software on your device and other means. We will collect:

  • Device information - such as your hardware model, device hardware information, IMEI number and other unique device identifiers, phone number, serial number, sales code, access recording, current software version, MCC (Mobile Country Code), MNC (Mobile Network Code), MAC address, IP address, cookies, pixels, subscription information, operating system versions, and settings of the device you use to access the Services.
  • Log information – diagnostic, technical, error and usage information such as the time and duration of your use of the Service, search query terms you enter through the Services, and any information stored in cookies that we have set on your device.
  • Location information – such as your device’s GPS signal or information about nearby Wi-Fi access points and cell towers that may be transmitted to us when you use certain Services and enable this function.
  • Voice information – such as recordings of your voice that we make (and store on our servers) when you enable this function and use voice commands to control a Service, or when you contact our Customer Services team.
    (Note that if we work with a third party service provider that provides speech-to-text conversion services on our behalf, this provider may receive and store certain voice commands in accordance with the contract concluded between us and our trusted third party service provider.)
  • Naked4S Keyboard information – the words that you type when you enable the ‘Predictive text’ feature. This feature may be offered in connection with your Naked4S account to synchronise the data for use on your other Naked4S mobile devices. You can clear the data by going to the Predictive text settings.
  • Other information about your use of the Services, such as the apps you use, the websites you visit, and how you interact with content offered through a Service.
  • Information from third party sources

    We may receive information about you from publicly and commercially available sources (as permitted by law), which we may combine with other information we receive from or about you. We also may receive information about you from third party social networking services when you choose to connect with those services.

    Other Information We Collect

    We also may collect other information about you, your device, or your use of the Services in ways that we describe to you at the point of collection or otherwise with your separate consent where required.

    You can choose not to provide us with certain types of information (e.g. information we request during Naked4S account registration), but doing so may affect your ability to use some Services. We will provide you with relevant information at the time of collection to help you make an informed decision.

    USING YOUR INFORMATION

    We will use the information we collect for the following purposes:

  • to register you or your device for a Service;
  • to provide a Service or feature you request;
  • to provide customised content and provide personalised services based on your past activities on our Services with your separate consent if required;
  • for advertising, such as providing customised advertisements, sponsored content, and sending you promotional communications with your separate consent if required;
  • for assessment and analysis of our market, customers, products, advertising campaigns, and services to help us better understand, through statistical processes where necessary, more about our customers in order to offer the most relevant communications, services and experiences to you.
  • to ask you for your opinions on our products and services and to carry out customer surveys with your separate consent if required;
  • to understand the way people use our Services so that we can improve them and develop new products and services;
  • to provide maintenance services and support for your device;
  • to facilitate the provision of software updates;
  • to conduct free prize draws, prize competitions, or promotions, as permitted by law; and
  • otherwise with your separate consent.
  • We combine information from or about you, including across different Services or devices, for purposes consistent with this Privacy Policy. For example, we use your Naked4S account details across all of the Services that require a Naked4S account. We also base our recommendations, customised content, and personalised features for your enhanced experience on the Services on the information you provide to us directly, through using the Services, browsing our website or through information provided to us from our trusted third parties to provide us with a better understanding of our customers. Where we use trusted third parties to enrich our database, we ensure that there is a legally enforceable agreement between us and the third party provider to ensure that any combined data has been lawfully obtained from you. Depending on the reason for which we combine the data, and on the requirements of applicable law, specific controls for such combination will be made available to you, for instance in device or application settings menus, or by visiting our webpage which provides you with the opportunity to exercise your individual rights under data protection law.

    We offer a variety of choices about how we use your information. You can make choices about whether to receive promotional communications from us by initially subscribing, and if you change your mind, by following the unsubscribe instructions included in the communication. In addition, you can also make choices by changing your settings for specific Services when we give you a just-in-time notice, or by visiting relevant webpages. You can also contact us if you need assistance controlling your choices.

    Naked4S processes personal data for the purposes described above. Naked4S’s legal basis to process personal data includes processing that is: necessary for the performance of the contract between you and Naked4S (for example, to provide you with the Services and to identify and authenticate you so you may use certain Services); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for Naked4S’s legitimate interests (for example, to manage our relationship with you and to improve the relevance of our communications, experiences, and customer service) and based on consent by our customers (for example, to communicate with you about our products and services and provide you with marketing information), which may subsequently be withdrawn at any time by contacting us as specified in the Contact Us section of this Privacy Notice without affecting the lawfulness of processing based on consent before its withdrawal.

    SHARING YOUR INFORMATION

    We may disclose your information internally within our business to the relevant teams such as, without limitation, the customer services team, the legal team, the finance team, the sales team, and where you have chosen to receive marketing messages, the marketing teams. We may also disclose your information to the following entities, only to the extent that this will be necessary to perform the Services:

  • Business Partners.
  • We also may share your information with trusted business partners, including without limitation, wireless carriers, retailers, and distributors. These entities may use your information to provide you with services you request and to make predictions about your interests, and may provide you with promotional materials, advertisements, and other materials with your separate consent.

  • Service Providers.
  • We also may disclose your information to carefully selected companies that provide services for or on behalf of us, such as companies that help us with repairs, customer contact centres, customer care activities, advertising, conducting customer satisfaction surveys, billing, or that send emails on our behalf. These entities are limited by contractual provisions in their ability to use your information for purposes other than providing services for us.

  • Other Parties
  • When Required by Law or as Necessary to Protect Our Services. There may be instances when we disclose your information to other parties:

  • to comply with the law or respond to compulsory legal process (such as a search warrant or other court order);
  • to verify or enforce compliance with the policies governing our Services; and
  • to protect the rights, property, or safety of Naked4S, or any of our respective affiliates, business partners, or customers.
  • Other Parties in Connection with Corporate Transactions. We may disclose your information to a third party as part of a merger or transfer, acquisition or sale, or in the event of a bankruptcy.
  • Other Parties with Your Consent or at Your Direction. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you separately consent to or request such sharing.
  • KEEPING YOUR INFORMATION SECURE

    We take protection of your data seriously, and have put in place appropriate physical and technical measures to safeguard the information we collect in connection with the Services. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.

    INTERNATIONAL TRANSFER OF DATA

    Your use of our Services will involve the transfer, storage, and processing of your personal information outside of your country of residence, to United Kingdom, consistent with this policy. In addition, your use of the Services may also involve the transfer, storage, and processing of your personal information to other countries; such countries include, without limitation, countries in the European Economic Area, the United States of America, China, Singapore, Canada and Japan. Please note that the data protection and other laws of countries outside the European Economic Area to which your information may be transferred might not be as comprehensive as those in your country. We will take appropriate measures, in compliance with applicable law, to ensure that your personal information remains protected. Such measures include the use of Standard Contractual Clauses to safeguard the transfer of data outside of the EEA. For more information, or to obtain a copy of the contractual agreements in place, please contact us at privacy@nakedforsatan.com.

    YOUR RIGHTS

    You have the right to request details about the information we collect about you and to request us to correct inaccuracies in that information, to object to or request the restriction of processing, and to request access to, or the erasure or portability of your information. Under the laws of some jurisdictions, we may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardise the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. If you would like to make a request to access your information, please contact us at privacy@nakedforsatan.com.

    If you request deletion of personal information, you acknowledge that you may not be able to access or use the Services and that residual personal information may continue to reside in Naked4S’s records and archives for some time, in compliance with applicable law, but Naked4S will not use that information for commercial purposes. You understand that, despite your request for deletion, Naked4S reserves the right to keep your personal information, or a relevant part of it, in line with the below section on “Data Retention” and applicable laws. Naked4S may suspend, limit, or terminate your access to the website for violating the Naked4S Terms of Use when necessary to protect the rights, property, or safety of Naked4S, or any of our respective affiliates, business partners, employees, or customers.

    DATA RETENTION

    We will not keep your personal data for longer than is necessary for the purpose it was collected. This means that data will be destroyed or erased from our systems when it is no longer required. We take appropriate steps to ensure that we process and retain information about you based on the following logic:

  • at least the duration for which the information is used to provide you with a service;
  • as required under law, a contract, or with regard to our statutory obligations; or
  • only for as long as is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or for statistical purposes, subject to appropriate safeguards.
  • THIRD PARTY LINKS AND PRODUCTS ON OUR SERVICES

    Our Services may link to third party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by websites or other services. You should exercise caution and review the privacy statements applicable to the third party websites and services you use.

    We also make available to you certain products or services (e.g. apps available through Galaxy Apps or Apps) developed by third parties. Naked4S is not responsible for these third party products or services.

    Third Parties that Provide Content, Advertising, or Functionality for Our Services

    Some of the content, advertising, and functionality on our Services may be provided by third parties that are not affiliated with us. In such circumstances, we have entered into contractual agreements with such third parties. For example:

  • We enable you to watch video content provided by content providers;
  • Third parties develop apps that we make available through the Galaxy Apps or Apps;
  • Certain third parties may serve advertising or keep track of which advertisements users see, how often they see those advertisements, and what users do in response to them; and
  • We enable you to share certain materials on the Services with others through social networking services such as Facebook, Twitter, Google+, and LinkedIn.
  • These third parties may collect or receive certain information about your use of the Services, including through the use of cookies, pixels, beacons, and similar technologies, and this information may be collected over time and combined with information collected across different websites and online services. Naked4S does not control the data collection and use practices of these companies. Some of these companies participate in industry-developed programmes designed to provide consumers with choices about whether to receive targeted advertising. Please visit the websites operated by the Network Advertising Initiative “https://networkadvertising.org” and Digital Advertising Alliance “https://www.aboutads.info/” to learn more. You should exercise caution and review the privacy statements applicable to the third party websites and services you use.

    If you connect with a social networking service, we may receive and store authentication information from that service to enable you to log in, as well as other information that you allow us to receive when you connect with these services.

    Also, please note that if you choose to connect with a social networking service on a device used by people in addition to you, those other users may be able to see information stored or displayed in connection with your account on the social networking service(s) with which you connect. We recommend that you log out of any such sites and only share information with individuals that you trust.

    COOKIES, BEACONS, AND SIMILAR TECHNOLOGIES

    We, as well as certain third parties that provide content, advertising, or other functionality on our Services, use cookies, pixels, beacons, and other technologies in certain areas of our Services, as explained in more detail below.

    Cookies

    Cookies are small files that store information on your computer, TV, mobile phone, or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices, and/or browsing sessions. Cookies serve many useful purposes. For example:

  • Cookies can remember your sign-in credentials so you don’t have to enter those credentials each time you log on to a service.
  • Cookies help us and third parties understand which parts of our Services are the most popular because they help us to see which pages and features visitors are accessing and how much time they are spending on the pages. By studying this kind of information, we are better able to adapt the Services and provide you with a better experience.
  • Cookies help us and third parties understand which ads you have seen so that you don’t receive the same ad each time you access a Service.
  • Cookies help us and third parties provide you with relevant content and advertising by collecting information about your use of our Services and other websites and apps.
  • When you use a web browser to access the Services, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. The operating system of your device may contain additional controls for cookies.

    Please note, however, that some Services may be designed to work using cookies and that disabling cookies may affect your ability to use those Services, or certain parts of them.

    We use the following types of cookies on our website:

    Essential Cookies
    which enable you to order products and receive services from our website;

    Performance Cookies
    which enable us to analyse the performance and design of our website and detect errors. For example, this type of cookie allows us to recognise that you have visited our website before and shows which sections of our website are most popular by allowing us to see which pages visitors access most frequently and how much time visitors spend on each page. We use, without limitation, Google Analytics, Adobe, and similar analytics cookies to achieve this.

    For example, the information generated by the cookie about the use of the website will normally be stored on a Google server in the United States. However, if you are located within the EU or the European Economic Area, your IP address will be shortened by Google beforehand. In exceptional cases only, your full address will be transmitted to a Google server in the United States and shortened there. On our behalf, Google will use this information for the purpose of compiling reports on website activity and providing other services relating to website activity and internet usage. The IP address transmitted from your browser as part of Google Analytics will not be associated with any other data held by Google. You may prevent web usage data (including your IP address) generated by the cookie from being transmitted to Google and processed there if you download and install this Browser-Plugin (https://tools.google.com/dlpage/gaoptout?hl=en).

    Functional Cookies
    which allow us to deliver a better user experience. For example, this type of cookie ensures that the information displayed on your next visit to our website will match up with your user preferences, or your Naked4S account from which you linked to our website, or the fact that you linked to our website via an email sent to you by Naked4S or one of our trusted third party service providers contacting you on our behalf.

    Advertising Cookies
    which enables us and our carefully selected partners to deliver advertisements to you, or contact you directly where you have separately consented to such communications, which match your interests by, for example, collecting information about products you have browsed or ordered on our website. For example, and without limitation, we use Google remarketing tags to allow our retail partners to advertise products which you have browsed on our website. For further information about how Google remarketing tags work, please click here: https://www.google.co.uk/think/products/newremarketing-tag.html.

    Our website may also display content from a third party website or service, which may result in cookies from third parties being stored on your hard drive or browser. We do not control the storage of these cookies and you should refer to the privacy policies of the relevant third party for more information.

    Other Local Storage
    We, along with certain third parties, may use other kinds of local storage technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and HTML5 local storage, in connection with our Services. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings. For information about disabling or deleting information contained in Flash cookies, please click here “https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html”.

    Beacons and/or Pixels

    We, along with certain third parties, also may use technologies called beacons or pixels that communicate information from your device to a server. Beacons and pixels can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon and pixels, and the IP address of your device. We and certain third parties use beacons and pixels for a variety of purposes, including to analyse the use of our Services and (in conjunction with cookies) to provide content and ads that are more relevant to you.

    When you access and use our Services (except for websites provided by third party service providers), you will be asked to provide your separate consent to the storage of cookies (which includes other local storage technologies, beacons, pixels and other information on your devices) by us. You will also be asked to provide your separate consent to the access of such cookies (which includes local storage technologies, beacons, pixels and information) by us and by the third parties mentioned above. Your experience of our website/Services may be affected if you do not accept cookies, and further information will be provided to you at the time we ask you for this specific consent.

    SOCIAL NETWORK PLUGINS

    Our Services make use of social network plugins (“Plugins”). When you use a Service that contains Plugins, information may be directly transferred from your device to the operator of the social network. We have no influence on the data gathered by the Plugin. If you are logged into the social network, your use of our Service can be referenced to your social network account. If you interact with the Plugins, for example by clicking “Like”, “Follow”, or “Share”, or enter a comment, the information may automatically show in your social network profile. Even if you are not logged into your social network account, it may be possible that the Plugins transmit your IP address to the social network operators. Please consider this when using our Services.

    For information about the social network operators of the Plugins used in our Services (“Operators”) please see below:

    Operators of Plugins used in our Services

    If you are a member of one or more of the following social networks and do not want the Operator to connect the data concerning your use of our Services with your member data already stored by the Operator, please log out of the social network before using our Services.

    Facebook Data controller: Facebook Ireland Limited, Hanover Reach, 5–7 Hanover Quay, 2 Dublin, Ireland (“Facebook”). For further information you may visit Facebook’s privacy policy website at “https://www.facebook.com/about/privacy/”.

    Google+ Data controller: Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). For further information you may visit Google’s privacy policy website at “https://www.google.com/privacy”.

    LinkedIn Data controller: LinkedIn Ireland, Gardner House, Wilton Place, Wilton Plaza, Dublin 2, Ireland (“LinkedIn”). For further information you may visit LinkedIn’s privacy policy website at “http://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv”.

    Twitter Data controller: Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA (“Twitter”). For further information you may visit Twitter’s privacy policy website at “https://twitter.com/privacy”.

    CONTACT US

    If you have any specific questions, please contact us (EU Data Controller) at:

    Naked for Satan Ltd., 20-22 Wenlock Road, London, England N1 7GU
    Registered in England & Wales No. 10540621
    E-Mail: board@nakedforsatan.com.

    You may lodge a complaint with the relevant supervisory authority if you consider that our processing of your personal data infringes applicable law. Contact details for all EU Supervisory Authorities can be found here: (http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080).


    London, May 25, 2018

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