Privacy Policy

  1. INTRODUCTION This policy sets out how NUTRIWOMEN (Pty) Ltd, 2nd Floor, Blu
    Bird Offices, 1 Park Road Birnam, Johannesburg, South Africa, 2196 (NUTRIWOMEN ,
    we or us) may use personal information that any user (you) provide or that we
    collect about you when you visit our website at www.NUTRIWOMEN.co.za (the
    website), use any (mobile) applications, provide your personal information to us
    on paper (in store or at events), enter, or apply to enter into an agreement
    with us, and you agree to be bound by it. “Personal information” includes any
    personal information as defined in the Protection of Personal Information Act 4
    of 2013.
  2. WHO IS IN CHARGE OF THE PROTECTION OF YOUR PERSONAL INFORMATION? NUTRIWOMEN
    determines the purposes and means of the processing of your personal information
    and is the responsible party for this website, all (mobile) applications and
    other mechanisms of use and processing which refer to this privacy policy.
  3. HOW IS PERSONAL INFORMATION COLLECTED? All our activities are based on
    stringent ethical principles and we are committed to protect the privacy of all
    visitors to our website and users of our (mobile) applications. For this reason,
    the way in which we collect and store information is dependent on how you use
    our website and related services.

3.1 PERSONAL INFORMATION COLLECTED THROUGH YOUR WEB AND MOBILE INTERACTION WITH
US Various technologies may be used on our websites and our (mobile)
applications in order to improve them, make them more user-friendly, effective
and secure. These technologies may lead to personal information being collected
automatically by us or by third parties on behalf of us. Examples of such
technologies are cookies, flash cookies and web analytics. 3.1.1 CLICK-STREAM
PERSONAL INFORMATION A visit to one of our websites results in personal
information that is sent from your browser to our server. This personal
information makes it possible to optimize our services and improve your
experience on our websites and apps. The personal information is automatically
collected and stored by us or by third parties on our behalf. This personal
information can include, in particular, the following: the user’s IP address the
date and time of the visit the referral URL (the site from which the visitor has
come) the pages visited on our website information about the browser used
(browser type and version, operating system, etc.)

3.1.2 COOKIES

WHAT ARE COOKIES? Cookies are small text files that are stored on your computer
or mobile device. For this section, we conveniently use “cookies” as an umbrella
term for techniques such as cookies, Flash cookies, web beacons and JavaScript.
They don’t take much space and they will be removed automatically when expired.
Some cookies expire at the end of your internet session, while others will be
saved for a limited amount of time.

WHY DO WE USE COOKIES? NUTRIWOMEN uses cookies to ensure your visit to our
website is as pleasant as possible. There are different types of cookies with
different uses. Some are there just to allow you to browse the website and see
certain features. Some give us an idea on your browsing experience, i.e. when
you have trouble finding what you are looking for, so we can improve and make
your future visit as pleasant as possible

NOTE: You can change your browser settings to delete or prevent cookies from
being stored on your computer or mobile device without your explicit consent.
The ‘help’ section in your browser should provide information on how to manage
your cookie settings.

3.2 PERSONAL INFORMATION PROVIDED BY YOU Besides the personal information
collected by automated means, we also process personal information which you
have provided to us. This includes, but is not limited to: your contact
information, including your first and last name, billing or delivery address,
birthdate and email address and, optionally, your telephone number. We need your
e-mail address and (optionally) telephone number so that we may contact you if
we have questions or information for you regarding your relationship with us;
other information required to process your order, such as information concerning
the products you have ordered, banking and/or credit card details; if you have
created an online profile, the preferences and interests stored in this profile
(please see below for further information concerning the profiles); if you have
contacted customer service, the details of the conversation, which may be
recorded and the contact history; personal information which we reasonably need
to perform our duties for purposes of marketing to you and managing your
marketing preference, any agreement we may have with you, or to operate your
account or any NUTRIWOMEN program that you have signed up for or fulfil our
regulatory or other business rights and obligations. All of this personal
information is characterized by the fact that you have provided this information
yourself. We use this information for the purposes described in this privacy
policy. You can always request to have your personal information accessed,
corrected or object to further processing (please see subsection 7).

3.3 THIRD PARTIES NUTRIWOMEN may collect personal information about you from
third parties such as fraud agencies, or Banks, in order to verify information
about you. Collection from third parties will always relate to your existing
relationship with us.

  1. HOW WILL WE USE YOUR PERSONAL INFORMATION? We will only process your
    information insofar it is adequate, relevant and not excessive, including for
    the purposes set out below: For purposes relating to your agreement or
    relationship with us or your order; e.g., to notify you regarding the status of
    your order or delivery. We may use your personal information to assess your
    creditworthiness, for which we may use third parties. If you have provided us
    with your personal information in relation to a promotion, event, (mobile)
    application, etc., we may send you emails or other messages which relate to the
    service you have requested. We may use personal information collected about you
    to enhance and update our current personal information records. If you contact
    customer service, we will use your personal information (including your contact
    history) so that customer service is able to process your request and provide
    you with the best service possible. If you have given us your personal
    information during the sale of a product or service, we will inform you about
    similar products and services. We may also contact you to ask for your feedback
    after the sale of a product or service. In case of an interrupted sales process
    we will send you a reminder. You can immediately unsubscribe from any of these
    notifications at any time at no cost by clicking on a link in the corresponding
    e-mail or other message (see further below in clause 7).

We may contact you via the contact details provided by you (including per
regular mail, e-mail, SMS, telephone or any other electronic means) for
marketing, advertising and opinion research purposes of the NUTRIWOMEN brand,
meaning that your information will be shared with other companies. This includes
for example information related to products of NUTRIWOMEN, ecommerce activities,
special offers, promotions as well as information on local store openings, local
store activities of the NUTRIWOMEN brand. In order to be able to contact you
with information which is of special interest for you, your overall interaction
with NUTRIWOMEN (such as but not limited to your shopping behaviour in e-shops,
in NUTRIWOMEN physical stores, your use of loyalty programmes, your ratings and
reviews of products, your contact history with our customer service, your
newsletter clicks/ opening results, your surfing behaviour (web tracking), the
newsletter types you are subscribed to, your participation in promotions or
events, your interactions with skin coach and your use of (mobile)
applications), will be combined, analysed and used. We may provide your contact
personal information for marketing, advertising and opinion research purposes.
In section 8 you can find information on your rights, for example on how you can
withdraw your consent or correct your personal details. We may use your personal
information to comply with our regulatory or other rights and obligations and in
general to carry out any other reasonable business operation considering our
business and the relationship between the parties.

  1. DISCLOSURE OF INFORMATION One of our core principles is that we will treat
    your personal information with care and confidentiality. We will not sell your
    personal information to third parties. We will share your personal information
    with third parties (i) as set out in this policy; (ii) if required by law; or
    (iii) if you have consented to it. We will share your personal information for
    purposes of (i) with the following third parties: any company we use to provide
    a service on our behalf or to provide a service to us; any company who provides
    us with products or services, and or delivery of those products, only to the
    extent that it is reasonably required to provide the product or service; any
    payment system we may use; regulatory and governmental authorities, ombudsmen,
    or other authorities, including tax authorities, where we are requested by them
    to do so;) any other third party, if we are allowed to do so in law. Where we
    use service providers and personal information operators working on behalf of
    NUTRIWOMEN, these third parties are granted access to the personal information
    they require in order to carry out the particular service. The service providers
    and personal information operators are contractually obliged to treat all
    personal information in the strictest confidence. It is also contractually
    forbidden for them to use the personal information in any other way than
    required. The necessary steps are taken to ensure that our service providers and
    the operators working on behalf of NUTRIWOMEN protect the confidentiality of
    your personal information. These services may for example include hosting and
    maintenance services, analysis services, e-mail messaging services, delivery
    services, handling of payment transactions, solvency check and address check,
    etc. We will also share your personal information with employees who need access
    to it in order to fulfil their employment duties. The same principles that apply
    to service providers will also apply to employees.
  2. CROSS BORDER FLOW OF PERSONAL INFORMATION Some of the persons (including
    NUTRIWOMEN representatives, third parties, employees) to whom we legitimately
    disclose Personal Information may be situated outside of the Republic of South
    Africa (RSA), in jurisdictions that may not have similar data protection laws to
    the RSA. However, all recipients agree to effectively adhere to the principles
    for processing of information in accordance with POPIA and our applicable data
    processing agreements.
  3. RETENTION We will retain your personal information in terms of our retention
    policies and the applicable laws. If we keep your personal information longer
    than is strictly necessary for purposes of this agreement, we will either
    de-identify your personal information, or keep it for research or statistical
    purposes only. During the period of retention, we will continue to implement
    reasonable and appropriate security measures.
  4. YOUR RIGHTS If you provide us with personal information via our websites or
    any other channels, this is done on an entirely voluntary basis. If you choose
    not to provide the requested information, various customer benefits may not be
    available to you. In certain cases, only those people that have submitted the
    necessary personal information to us are able to order products, use certain
    services and in other ways avail themselves of the activities and offers
    available on our website and (mobile) application and via our loyalty programme.
    As transparency and fair play are particularly important issues for us, we
    provide various options, depending on the exact circumstances, in order to help
    you retain control over your personal information. These options may include
    accessing, displaying and editing your personal information online. It may also
    be possible to unsubscribe from services or delete user accounts or to receive
    information about the personal information held by NUTRIWOMEN.

8.1 RIGHT TO OBJECT AND UNSUBSCRIBE All marketing material that NUTRIWOMEN sends
to you that for instance contain a newsletter or marketing content, include the
option to unsubscribe to the receipt of the marketing material, by following the
relevant instructions in the communication.

8.2 RIGHT TO REQUEST INFORMATION AND TO CORRECT IT It is possible to access and
correct your personal information through online, web and mobile services, where
you have signed up for membership(s). You may also submit a Promotion of Access
to Information (PAIA) request. This is done through our PAIA Manual and Form
located here.

  1. SECURITY OF THE INFORMATION AND PERSONAL INFORMATION INTEGRITY We take
    reasonable appropriate technical and organisational measures to protect personal
    information against accidental or unlawful destruction, loss, alteration,
    unauthorised use, disclosure or access, in particular where the processing
    involves the transmission of personal information over a network, and against
    all other unlawful forms of processing and misuse. We make use of electronic and
    computer safeguards such as firewalls and data encryption. We have physical and
    electronic access control to our buildings and information. We only authorise
    access to information to those employees and operators who require it to fulfil
    their designated responsibilities. When you use the website, we may give you an
    access number, username, password and/or personal identification number (“PIN”).
    You are responsible to maintain the secrecy and confidentiality of your
    username, access number, password and/or PIN. We will report any security breach
    to both the Regulator and the individuals or companies involved.
  2. PROTECTION OF CHILDREN’S PERSONAL INFORMATION AND SPECIAL PERSONAL
    INFORMATION NUTRIWOMEN understands that it has a responsibility to protect the
    privacy of children and only intends to collect and use the personal information
    of children under the age of 18 in compliance with applicable laws. We encourage
    parents and other guardians to surf the Internet together with their children
    and enjoy the internet in a responsible manner.

If a child under the age of 18 attempts to register himself or herself, he or
she may initially be asked to provide the information as described in the above
section entitled “what personal information is collected”. In addition, he or
she may be asked for consent from the parent/guardian to the registration and
NUTRIWOMEN may require additional information from the parent or guardian to
complete the registration. The personal information submitted by and collected
about the child during the course of his or her visit (e.g. via cookies) may be
used as described above. We do not intend to process any “special personal
information” about you, as defined in law, which includes e.g. political,
religious or health-related information, except if we are under a legal
obligation to do so.

  1. SOCIAL NETWORKS Our website and (mobile) applications provide you with
    Social Plug-ins from various social networks. If you choose to interact with a
    social network, your activity on our website or via our (mobile) applications
    will also be made available to social networks such as Facebook and Twitter.

If you are logged in on one of these social networks during your visit to one of
our websites or (mobile) applications, the social network might add this
information to your profile. If you are interacting with one of the Social
Plug-ins, this information will be transferred to the social network. In case
you do not want a personal information transfer, please log off on your social
network before you use our website or (mobile) applications.

We do not control this personal information collection and personal information
transfer via the Social Plug-ins. Please read the privacy policies of those
social networks for detailed information about the collection and transfer of
personal information, what rights you have and how you can achieve satisfactory
privacy settings.

  1. GEOLOCATION SERVICES We offer location-enabled services within some of our
    (mobile) applications, such as Google Maps. If you use those (mobile)
    applications, the companies that provide these services may receive information
    about your actual location (such as GPS signals sent by a mobile device) or
    information that can be used to approximate a location. You can generally enable
    or disable your location services in your device or browser settings.

We use the Google Maps service to assist you in finding the nearest NUTRIWOMEN
store. To facilitate this, we load an image from Google Maps or Bing Maps,
saving the route, personal information and map image on our server. During the
period of retention, we will continue to implement reasonable and appropriate
security measures.

WEB ANALYTICS BY GOOGLE ANALYTICS The web analytic services on our website and
(mobile) applications are provided by Google Analytics
(www.GoogleAnalytics.com). This means that when you visit our website or
(mobile) applications, a cookie by Google Analytics will be stored on your
computer or mobile device, except when your browser settings do not allow for
cookies (see clauses 3.1.2 above).

This further means that when you visit our website or (mobile) application, the
web analytics personal information described above in clause3.1– including the
“click-stream personal information”, the personal information from “web beacons
and tracking links” and information stored in Google Analytics’ cookies – will
be sent to Google Analytics for analysis for and on behalf of NUTRIWOMEN. Please
note that if you have created an online profile at our website or (mobile)
application and if you are logged on in this profile, a unique number
identifying this profile is also being sent to Google Analytics in order to
match the web analytics personal information to this profile.

Google Analytics acts as an agent to NUTRIWOMEN, which means that NUTRIWOMEN
solely determines the purposes for which the personal information is being used
and that Google Analytics will not disclose the information to any third parties
(except when required to do so by law or court order). In privacy terms, this
means that NUTRIWOMEN is the “responsible party” and Google Analytics the
“operator”. You can find out more about the relationships between NUTRIWOMEN and
Google Analytics in the Google Analytic’s privacy policy under “Privacy Policy
for Our Provision of Services” at
https://www.GoogleAnalytics.com/company/privacy.php#services.

  1. RE-TARGETING TECHNOLOGIES Our website and (mobile) application use
    re-targeting technologies. This enables us to show our visitors, who were
    already interested in our shop and our products, advertisements from us on
    partner websites. We believe that the display of a personalised, interest-based
    advertising is more interesting for our users than advertising that does not
    have a personal connection.

We also work with other companies who use tracking technologies to serve ads on
our behalf across the Internet. These companies may collect information about
your visits to our websites or (mobile) applications and your interaction with
our communications, including advertising.

Re-targeting technologies analyse your cookies and display advertisement based
on your past surfing behaviour. For further information on cookies, please refer
to clause 3 of this privacy policy.

  1. CONTACT INFORMATION If you have any questions about the processing of your
    personal details or about our privacy policy you are welcome to contact us. You
    can send an email to [email protected]
  2. CHANGES TO THIS POLICY NUTRIWOMEN is committed to the fundamental principles
    of privacy and personal information protection. We therefore regularly review
    our privacy policy in order to keep it up to date and compliant with privacy and
    personal information protection principles and the law. This privacy policy may
    be changed from time to time in order to keep pace with (i) new developments and
    opportunities relating to the Internet; (ii) our business operations and (iii)
    also to stay in line with prevailing legislation. Changes to the policy will be
    publicized on our website along with an updated version of the privacy policy.
  3. LIMITATION We are not responsible for, give no warranties, nor make any
    representations in respect of the privacy policies or practices of linked or any
    third party websites.
  4. THE INFORMATION REGULATOR Whereas we would appreciate the opportunity to
    first address any queries regarding our processing of your personal information,
    you have the right contact the Information Regulator, whose contact details are:
    The Information Regulator (South Africa) JD House, 27 Stiemens Street,
    Braamfontein, Johannesburg, 2001 P.O. Box 31533, Braamfontein, Johannesburg,
    2017 Complaints email: [email protected] General enquiries email:
    [email protected]
  5. MEMBERSHIP & PERSONAL DATA NUTRIWOMEN (“we”, “us”, “our”) is committed to
    protecting all the information you share with us. We follow stringent procedures
    to help protect the confidentiality, security, and integrity of data stored on
    our systems. Our website encrypts your personal information using secure socket
    layer (ssl) technology to provide for the secure transmission of all data. only
    those of our employees and/or our affiliates, affiliate brands, our third party
    service providers and agents and other contractual third parties(“authorized
    third parties”) who may need access to your information in order to provide you
    marketing, advertising and promotional information, materials and/or documents
    relating to us and our affiliate brand(s) products, services and activities,
    and/or products, for creating membership to NUTRIWOMEN programs and activities
    of third parties that we may collaborate with, via your selected communication
    channels are allowed such access.

1st April 2022