INFORMATION ON THE PROCESSING OF PERSONAL DATA pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR)

Premise
This information is provided for the site "www.dailysilkyskin.com" (Site) owned by Initians LLC, with registered office in Lewes, 16192 Coastal Highway - Delaware, USA, ZipCode 19958 (Company), as Data Controller .

Purchases on the Site
Upon your conferment, your personal data will be processed to allow you to make purchases on the Site.

Marketing
Subject to your consent, the Company may process the personal data you provide in order to send you advertising material and/or newsletters relating to its own products or those of third parties.

Soft spamming
The Company may use, for the purpose of direct sale of the products offered for sale through the Site, the e-mail coordinates provided by you in the context of a purchase on the Site, even without your consent, provided that it is a product similar to the one object of the previous sale (so-called soft spamming). However, you may refuse this treatment at any time by communicating your opposition to the Company.

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In compliance with the GDPR, we hereby inform you that the Company will process your personal data under the following conditions.

Art. 1. Purpose and legal basis of the processing. Compulsory or optional provision. Consequences of refusal to treatment.

The processing of personal data is aimed at achieving the following purposes:

a. to allow compliance with the obligations deriving from the law or regulations in force, in particular, in the administrative, accounting and public safety fields. The legal basis of the processing is the need for the Company to carry out pre-contractual measures adopted at the request of the interested party or to fulfill a legal obligation;

b. in the case of placing an online purchase order, to allow the conclusion of the purchase contract and the correct execution of the operations connected to the same (and, if necessary according to sector legislation, to fulfill tax obligations). The legal basis of the processing is the Company's obligation to execute the contract with the interested party or to fulfill legal obligations;

c. limited to the e-mail coordinates provided by you in the context of a purchase through the Site, to allow the direct offer by the Company of similar products (so-called soft spamming), provided that you do not object to such treatment in the manner prescribed by this information. The legal basis of the processing is the Company's legitimate interest in sending this type of communication. This legitimate interest can be considered equivalent to the interested party's interest in receiving "soft-spam" communications;

d. subject to your consent, for sending newsletters and for carrying out market surveys, also aimed at assessing the degree of user satisfaction, and for sending advertising material relating to the Company's and/or third party products, to means of systems such as email (marketing purposes); The legal basis of the processing is the consent of the interested party;

e. if the chat service is operational, allow the activation of the service, through which the user can contact and be contacted by the Company, subject to your consent, while browsing the Site. The legal basis is the Company's legitimate interest in perform this type of activity. This legitimate interest can be considered equivalent to the interest of the interested party to use the chat service of the Site;

f. to respond to your requests through the customer care service. The provision is optional, but your refusal will make it impossible for the Company to answer your questions through this service. The legal basis of the processing is the Company's legitimate interest in following up on user requests. This legitimate interest is equivalent to the user's interest in receiving a response to communications sent to the Company;

g. to respond by email, telephone, mail to your requests. The provision is optional, but your refusal will make it impossible for the Company to respond to your requests. The legal basis of the processing is the Company's legitimate interest in responding to user requests. This legitimate interest is equivalent to the user's interest in receiving responses to communications sent to the Company.

The provision of data for the purposes referred to in point b) is purely optional. However, since this processing is necessary to allow registration on the Site as well as to make a purchase on the Site, your refusal to provide the data in question will make it impossible to register on the Site and make this purchase through the Site.

The consent to the processing of your data for marketing purposes is purely optional. Failure to consent will only imply the consequences described below.

Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to the Company's and/or third party products as well as the impossibility for the Company to carry out market surveys, also aimed at assessing the degree of user satisfaction, as well as to send you newsletters.

Without prejudice to the foregoing, it is understood that the Company may in any case use your personal data for the sole purpose of correctly fulfilling the obligations established by the laws in force and the obligations deriving from the contractual relationships between you and the Company.

We remind you that you may also object to the processing of your personal data via the appropriate link at the bottom of any promotional email sent by the Company.

Payment card data
To make a payment using one of the payment cards offered on the Site, the user must enter the confidential data of the payment card directly on a page which will communicate via secure encryption protocol with the payment service provider (who will act as independent data controller), without passing through the Company's server which, therefore, will not process such data in any way. The data will be acquired in encrypted format.

With reference to the payment card data, it should be noted that the processing of your personal data is necessary to allow the conclusion of the online purchase contract with the Company. Failure to provide this data, therefore, will not allow you to complete the online purchase process.

Particular or judicial data
The Company does not process particular or judicial data.

Art. 2. Processing methods
The processing of your personal data will mainly be carried out with the aid of electronic or automated means, according to the methods and with the tools suitable for guaranteeing its security and confidentiality in accordance with the GDPR.

The information acquired and the methods of treatment will be pertinent and not excessive with respect to the type of services rendered. The data will also be managed and protected in environments whose access is under constant control.

Art. 3. Communication and dissemination of data
Your data may be communicated:

• to all those subjects (including the Public Authorities) who have access to personal data by virtue of regulatory or administrative provisions
• to companies or third parties responsible for printing, enveloping, shipping and/or delivery and/or collection of products purchased through the Site
• to post offices, couriers or shippers in charge of delivering the products purchased through the Site
• to banks and companies that manage the national or international payment circuits through which online payments are made for products purchased through the Site
• to companies, consultants or professionals who may be in charge of the installation, maintenance, updating and, in general, the management of the Company's hardware and software or which the Company uses for the provision of its services
• to external companies responsible for sending advertising communications on behalf of the Company
• to the company in charge of carrying out the customer care activity
• to subjects who manage online payment transactions
• to all those public and/or private subjects, natural and/or legal persons (legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Chambers and Labor Offices, etc.), if the communication is necessary or functional to the correct fulfillment of the obligations deriving from the law.

The data concerning you will not be disclosed, except in anonymous and aggregated form, for statistical or research purposes.

Art. 4. Data Controller
The Company, as Data Controller of personal data, can be contacted at the following addresses:

Through the contact form on the Site.

Art. 5. Retention of personal data
The user's data will be kept only for the time necessary to guarantee the correct provision of the services offered and in any case within the terms established by the legislation or by the provisions of the Guarantor for the Protection of Personal Data.

In any case, it is understood that personal data will be stored and processed for marketing purposes for the period of time permitted by law and by the provisions of the Guarantor for the Protection of Personal Data. At the end of this period, the Company may ask the user to renew his consent to the processing of his data for these purposes or to make them anonymous and keep them only for statistical or historical purposes.

Art. 6. Rights of the interested party
Pursuant to art. 13 of the Privacy Regulation, the Company informs you that you have the right to:

• ask the Company for access to personal data and the correction or cancellation of the same or the limitation of the treatment that concerns you or to oppose their treatment, in addition to the right to data portability
• revoke the consent at any time without prejudice to the lawfulness of the treatment based on the consent given before the revocation
• propose a complaint to a supervisory authority (e.g.: the Guarantor for the protection of personal data).
• The above rights may be exercised by making an informal request to the Company to the contacts indicated above.

Art. 7. Modifications
The Company reserves the right to make changes to this information at any time, giving suitable publicity to users of the Site and guaranteeing in any case adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this information.

Text Marketing Terms and Conditions:
We are using a text messaging platform, which is subject to the following terms and conditions. By opting-in for our text marketing and notifications in, you agree to these terms and conditions.
By entering your phone number in the checkout and initialising a purchase, subscribing via our subscription form or a keyword, you agree that we may send you text notifications (for your order, including abandoned cart reminders) and text marketing offers. You acknowledge that consent is not a condition for any purchase.
Your phone number, name and purchase information will be shared with our SMS platform "SMSBump Inc, an European Union company with office at Sofia, Bulgaria, EU. This data will be used for sending you targeted marketing messages and notifications. Upon sending the text messages, your phone number will be passed to a text messages operator to fulfill their delivery.
If you wish to unsubscribe from receiving text marketing messages and notifications reply with STOP to any mobile message sent from us or use the unsubscribe link we provided you with in any of our messages. You understand and agree that alternative methods of opting out, such as using alternative words or requests will not be accounted for as a reasonable means of opting out. Message and data rates may apply.
For any questions please text "HELP" to the number you received the messages from. You can also contact us for more information. If you wish to opt out please follow the procedures above.