Privacy Policy

1. INTRODUCTION

1.1 Welcome to the "BorntheKorea" platform run by MIMICLUBRED northeast Asia Limited and its affiliates (individually and collectively, "MIMICLUBRED", "we", "us" or "our"). MIMICLUBRED takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all Users of our Shopee platform (the "Platform") (we refer to the Platform and the services we provide as described on our Platform collectively as the "Services"). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data.

1.2 "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information

1.3 By using the Services, registering for an account with us, visiting our Platform, or accessing the Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM. If we change our Privacy Policy, we will post those changes or the amended Privacy Policy on our Platform. We reserve the right to amend this Privacy Policy at any time.

2. WHEN WILL MIMICLUBRED COLLECT PERSONAL DATA?

2.1 We will/may collect personal data about you:

when you register and/or use our Services or Platform, or open an account with us;
when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails;
when you use our electronic services, or interact with us via our application or use services on our Platform. This includes, without limitation, through cookies which we may deploy when you interact with our application or website;
when you carry out transactions through our Services;
when you provide us with feedback or complaints;
when you register for a contest; or
when you submit your personal data to us for any reason

The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

3. WHAT PERSONAL DATA WILL MIMICLUBRED COLLECT?

3.1 The personal data that MIMICLUBS may collect includes but is not limited to:

name;
email address;
date of birth;
billing address;
bank account and payment information;
telephone number;
gender;
information sent by or associated with the device(s) used to access our Services or Platform;
any other information about the User when the User signs up to use our Services or Platform, and when the User uses the Services or Platform, as well as information related to how the User uses our Services or Platform; and
aggregate data on content the User engages with.
3.2 You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. We reserve the right at our sole discretion to require further documentation to verify the information provided by you.

3.3 If you sign up to be a user of our Platform using your social media account (“Social Media Account”), link your meclio account to your Social Media Account or use any meclio social media features, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider's policies, and we will manage and use any such personal data in accordance with this Policy at all times.

3.4 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing. Further information on opting out can be found in the section below entitled "How can you withdraw consent, remove, request access to or modify information you have provided to us?" .

This Privacy Policy sets out how we, Meclio.net collect, store and use information about you when you use or interact with our website, MIMICLUBS, and our mobile app (collectively, our website)

This Privacy Policy went into effect on the date that it was last updated on December 18, 2019.

Contents

Summary
Our details
Information we collect when you visit our website
Information we collect when you contact us
Information we collect when you interact with our website
Information we collect when you place an order on our website
Our use of automated decision-making and profiling
How we collect or obtain information about you from third parties
Disclosure and additional uses of your information
How long we retain your information
How we secure your information
Transfers of your information outside the European Economic Area
Your rights under the GDPR in relation to your information
Your right to object to the processing of your information for certain purposes
Sensitive Personal Information
Changes to our Privacy Policy
Children’s Privacy
California Do Not Track Disclosures
Copyright, credit and logo
Your California Privacy Rights

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

Data controller: https://www.mimiclubred.com/

How we collect or obtain information about you:
- when you provide it to us (e.g. by contacting us , placing an order on our website, sign up for our email newsletter, take a quiz, or create an account).
- from your use of our website, using cookies and similar technologies, and
- occasionally, from third parties.

Information we collect: name, contact details, payment information e.g. your credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), your answers to quizzes or surveys, and information about your internet connection.

How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfill our contractual obligations, to advertise our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.

Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, and to fulfill any contracts we enter into with you, and where required by law or to enforce our legal rights.

Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No. We do not sell personal information, and we will not sell personal information except as described in this Privacy Policy or if we provide you with notice and a right to opt-out of such sale.

How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.

How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary and by only trusted individuals that have been trained and briefed on appropriate handling of personal information.

Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as web beacons on our website including essential, functional analytical and advertising cookies. For more information, please visit our cookies policy here: https://www.mimiclubs.com/

Transfers of your information outside the European Economic Area: We are a company based in the United States. In certain circumstances we transfer your information outside of the European Economic Area , including to the following countries: The United States of America, Canada, Ireland, the United Kingdom. Where we do so, we will ensure appropriate safeguards are in place, including the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.

Use of automated decision making and profiling: we use automated decision making and/or profiling. We do this in order to protect our business from harm from fraud during the checkout process via our partner Signify (privacy policy here: https://www.signifyd.com/privacy/ ).

Your rights under the GDPR in relation to your information
- to access your information and to receive information about its use
- to have your information corrected and/or completed
- to have your information deleted
- to restrict the use of your information
- to receive your information in a portable format
- to object to the use of your information
- to withdraw your consent to the use of your information
- to complain to a supervisory authority

Sensitive personal information: we do not collect sensitive personal information on you.

Your California Privacy Rights
to request access to your personal information
to request deletion of your personal information
to request disclosures about your personal information
to direct us not to sell your personal information

Our details

The data controller with respect to our website is "Born the korea" of 141, hyunam ro, suji gu yongin si, Korea or sending an email to Born the korea

If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

We may collect the following information about you through the use of our website:

Real name, alias, unique personal identifier, online identifier, Internet Protocol address, account name, driver’s license number, or other similar identifiers;
Physical characteristics;
Commercial information, or other purchasing or consuming histories or tendencies;
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement;
Audio, electronic, visual, or similar information;
Inferences drawn from any of the information identified in this section to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, and attitudes.

Web server log information

We use a third party server to host our website called Shopify Inc., the privacy policy of which is available here https://www.shopify.com/legal/privacy. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Our website servers are located in the United States of America and Canada and, accordingly, your information is transferred outside the European Economic Area (EEA). For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area]].

Use of website server log information for IT security purposes

Our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, We/we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our and a third party’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.

Cookies and similar technologies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies and similar technologies on our website, including essential, functional, analytical and advertising cookies and web beacons. For further information on how we use cookies, please see our cookies policy which is available here: https://www.mimiclubs.com/

You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email and Contact Form

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use a third party email provider/customer service management tool to store emails and messages you send us. Our third party email provider is Zendesk, Inc. located in the United States. Their privacy policy is available here https://www.zendesk.com/company/customers-partners/privacy-policy/

Emails you send us will be stored outside the European Economic Area on our third party email provider’s servers in the United States and other locations based on their sub-processors. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Mail

If you contact us by mail, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

SMS messaging

When you sign up to receive text messages from us on our website or opt to receive news, offers, updates on out-of-stock items from us by entering your name and phone number and clicking subscribe or ticking a box at checkout indicating that you would like to receive text messages from us, we collect your phone number, information about your browser, information about the page you signed up on, and any other additional information you may provide to us.

Legal basis for processing:

Your consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent:

You give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

We use a third-party service to send out our text messages and administer our telephone list, Attentive. Their privacy policy is available here: https://attentivemobile.com/privacy/.

Information you submit to subscribe for our text messages will be stored outside the European Economic Area on our third party text message provider’s servers in Canada. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in text messages]

We use technologies such as web beacons (small graphic files) in the texts we send to allow us to assess the level of engagement our texts receive by measuring information such as the delivery rates, open rates and click through rates which our texts achieve. We will only use web beacons in our texts if you have consented to us doing so. For more information on how we use web beacons in our texts, see our cookies policy which is available here:https://www.mimiclubs.com/

For more information about our third-party text message service provider, please see their privacy policy which is available here:https://www.mimiclubred.com/.

E-Newsletter

When you sign up for our e-newsletter on our website or opt to receive news, offers, updates on out-of-stock items from us by entering your name and email address and clicking subscribe or ticking a box at checkout indicating that they would like to receive your e-newsletter, we collect your email address , information about your browser, information about the page you signed up on, and any other additional information you may provide to us.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

We use a third party service to send out our e-newsletter and administer our mailing list, Klaviyo. Their privacy policy is available here: https://www.klaviyo.com/privacy .

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’s servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails]

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

For more information on how we use web beacons in our e-newsletter emails, see our cookies policy which is available here: https://www.mimiclubred.com/

[For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://www.klaviyo.com/privacy

Registering on our website

When you register and create an account on our website, we collect the following information: Email address, IP address, and any other information you provide to us when you complete the registration form.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: registering and administering accounts on our website to provide access to content, secure access to order history and status for customers and to facilitate the running and operation of our business.

Transfer and storage of your information

Information you submit to us via the registration form on our website will be stored outside the European Economic Area on our third party hosting provider’s servers in The United States and Canada. Our third party hosting provider is Shopify with servers located throughout North America and where its sub-processors may be located. Their privacy policy is available here: https://www.shopify.com/legal/privacy

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Information we collect when you place an order on our website

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Information collected when you place an order

Mandatory information

When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable), billing name, and information about your browser.

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.

Optional information

We also collect optional information from you, such as your telephone number or information about how your experience was in the form of a survey. We also ask you if you would like to receive marketing communications from us. For further information, see ‘Marketing communications’ in this section below.

If you do not supply the optional information requested at checkout, such as telephone number. We will not be able to contact you by phone or SMS.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation.
Legitimate interests: finding out how a customer’s experience was to improve your business’ website or to be able to contact the customer by phone where (if necessary) in relation to their order.[2]

AND

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Legitimate interests: you consent to us processing any optional information you provide by submitting that information to us.

Processing your payment

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use a third party payment processor (Shopify Payments) and a fraud gateway to ensure that your order is not fraudulent (Signify inc). Your payment will be processed by Shopify Payments.

Shopify Payments collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policy via the following link(s): Shopify Payments: https://pay.shopify.com/tos-privacy-policy

Signify: https://www.signifyd.com/privacy/

Transfer and storage of your information

Shopify Payments is located in Canada. Information relating to the processing of your payment is stored outside the European Economic Area on our [third party payment processor’s servers in Canada and the United States.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Marketing communications

At checkout and upon first arriving to the site you will have the option of receiving marketing communications from us.

Our similar goods and services

You can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by ticking a box to opt out or clicking ‘unsubscribe’ in any email from us.

We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: direct marketing and advertising our products and services.

Transfer and storage of your information

We use a third party service to administer our mailing list, Klaviyo, Inc. Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’s servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons [and similar technologies] in emails

We use technologies such as web beacons (small graphic files in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

For more information on how we use web beacons in our emails, see our cookies policy which is available here: https://meclio.net/pages/cookie-policy

For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://www.klaviyo.com/privacy

Our goods and services

You can opt in to receiving marketing communications from us in relation to our goods and services by email ticking a box indicating that you would like to receive such communications during checkout or at any time while browsing the site by entering your email address into our newsletter sign-up form.

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

Use of web beacons [and similar technologies] in emails

For more information on how we use web beacons in our emails, see our cookies policy which is available here: https://www.mimiclubs.com/

For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://www.klaviyo.com/privacy

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include partner companies who we are doing a joint promotion with.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

How we use your information

The personal information that you provide to us via our website may be used by us for the following purposes:

To conduct auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
To debug to identify and repair errors that impair existing intended functionality.
For short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer's experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
To perform services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
To undertake internal research for technological development and demonstration.
To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
To advance a person's commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.
Any other legitimate business activities not otherwise prohibited by law.

Our use of automated decision-making and profiling[3]

We use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or significantly affects you.

You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: https://meclio.net/pages/cookie-policy

Automated decision making

Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.

Use of automated decision making for display advertising]

We automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is available here: https://meclio.net/pages/cookie-policy

Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.

Significance and envisaged consequences: cookies will be used to recognise the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.

How to object: you can block these cookies by using the cookies control management tool on our site or by opting out of seeing personalised ads by following the instructions here: https://support.google.com/ads/answer/2662922?hl=en-GB]. For further information, please see our cookies policy: https://meclio.net/pages/cookie-policy

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Use of profiling for web analytics

Our web analytics services, Google Analytics and Qubit, Inc. collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on) and how much you are spending on our site. We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy. Information collected about you, once collected is anonymised and stored on an aggregate basis. IP addresses are anonymized at the point of collection on our site. Third-party vendors may collect personal information about your online activities over time and across different websites when you use our website.

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by using our cookie control tool and your location will be analysed based on your IP address. We may target advertisements or content on our site based on the level of interest we receive from certain visitors and their behaviour on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation) and the basis upon you give us consent to use this by opting into cookie tracking.

[Legitimate interest: : improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires. Also to serve advertisements to you which seem most relevant to the visitor.

Use of profiling in marketing emails

We use web beacons in our marketing emails to analyse who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons if you have consented to their use in accordance with our cookies policy (https://www.mimiclubs.com/ ).

Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons), including open rates, click through rates, and what items you clicked on in an email.

How to object: You may object to this by contacting us at helpcenter@MIMICLUBRED.COM or you may opt out by using our cookie control tool.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

Email provider(s), including Klaviyo Inc. Their privacy policy is available here: klaviyo.com/privacy
Customer Service System Provider: Zendesk Inc. Their privacy policy is available here:
IT service provider(s), including Shipping Easy and Microsoft Azure. Their privacy policies are available here: https://support.shippingeasy.com/hc/en-us/articles/115003637406-Privacy-Policy https://privacy.microsoft.com/en-us/privacystatement
Hosting provider(s), including Shopify Inc. Their privacy policy is available here: shopify.com/privacy

Our third party service providers are located in the United State and Canada.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display all the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email at helpcenter@mimiclubs.com and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/]

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

Sharing your information within our business’ group of companies, including Seed Beauty for internal administrative purposes, including client, customer and employee information.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business effectively.

AND

Legal basis for processing: necessary to perform a contract [or to take steps at your request prior to entering into a contract] (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need to share your information with other companies in order to be able to meet our contractual obligations to you or to take steps at your request prior to entering a contract., for example because of the services or information you have requested.

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of the United States of America.[4]

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United States’ legal framework, we have a legitimate interest in complying with these obligations.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Order information: when you place an order for goods and services, we retain that information indefinitely or until you request that we delete unless this conflicts with our compliance of a legal responsibility.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form,we will retain your information for as long as it takes to respond to and resolve your enquiry and indefinitely afterward unless it is requested to be deleted AND it does not interfere with our compliance with laws and our legitimate business interest.

E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
whether we have any legal basis to continue to process your information (such as your consent);
how valuable your information is (both now and in the future);
any relevant agreed industry practices on how long information should be retained;
the levels of risk, cost and liability involved with us continuing to hold the information;
how hard it is to ensure that the information can be kept up to date and accurate; and
any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
using secure servers to store your information;
verifying the identity of any individual who requests access to information prior to granting them access to information;
using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website;
only transferring your information via closed system or encrypted data transfers

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we and our data processors process data may have laws which are different, and potentially not as protective, as the laws of your own country.

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

Server log information

Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our third party hosting company , Shopify. You can access their privacy policy here: www.shopify.com/privacy

Country of storage: Canada and the United States

Safeguard(s) used: our third party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield.

Contact form and Email

Information you submit to us via our contact form is transferred outside the EEA and stored on our third party email and customer service systems. Our email provider is Klaviyo Inc. You can access their privacy policy here: www.klaviyo.com/privacy. Our customer service system provider is Zendesk. You can access their privacy policy here: https://www.zendesk.com/company/customers-partners/eu-data-protection/

Country of storage: United States. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: our third party email provider has self-certified its compliance with the EU-U.S. Privacy Shield

E-Newsletter

Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: Klaviyo. You can access their privacy policy here: www.klaviyo.com/privacy

[Country of storage: The United States. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: our[third party mailing list provider has self-certified its compliance with the EU-U.S. Privacy Shield.

Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Payment Processor

Information you submit to us by our third party payment processor, Shopify Payments, is transferred outside the EEA and stored on their servers. You can access their privacy policy here: https://pay.shopify.com/tos-privacy-policy

Country of storage: The United States and Canada. These countries are not subject to an adequacy decision by the European Commission.

Safeguard(s) used: our payment processor has self-certified its compliance with the EU-U.S. Privacy Shield.

Your rights under the GDPR in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by sending an email to help@mimiclubred.com

to request access to your informationand information related to our use and processing of your information;
to request the correction or deletionof your information;
to request that we restrict our useof your information;
to receive information which you have provided to us in a structured, commonly used and machine-readable format(e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
to object to the processing of your information for certain purposes(for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to Born the Korea, 141, Hyunam ro , Suji gu, Yongin si, Korea or sending an email to : help@mimiclubred.com

to object to us using or processing your information where we use or process it in order to carry out a task in the public interestor for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
to object to us using or processing your information for direct marketing purposes(including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

clicking the unsubscribe linkcontained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: https://meclio.net/pages/cookie-policy

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time. Unless otherwise stated, any modifications to our Privacy Policy will go into immediate effect after they have been posted.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new “last updated” date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its “last updated” date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to help@mimiclubred.com

We do not sell the personal information of California consumers if we have actual knowledge that the consumer is less than 16 years of age, unless the consumer, in the case of consumers between 13 and 16 years of age, or the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized the sale of the consumer’s personal information.

California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here:https://www.mimiclubred.com/

This website does not respond to browser “Do Not Track” signals.

Third Party Links

We may include third party links on our website. By including a link to a third-party website, we do not endorse or recommend any products or services offered or information contained at the third-party website. These third-party websites have separate and distinct privacy policies from ours and we have no responsibility or liability for the content and activities of these third-party websites. Such third party may have a privacy policy different from that of ours and the third-party website may provide less security protection than our website. If you decide to visit a third-party website via a link contained on the website, you do so at your risk.

Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, please contact us at help@mimiclubred.com

Your California Privacy Rights

Under the USA Consumer Privacy Act, USA residents have the right to:

Request that a business delete any personal information about the consumer which the business has collected from the consumer.
Request that a business that collects personal information about the consumer disclose to the consumer, free of charge, the following:

The categories of personal information that it has collected about that consumer.
The categories of sources from which the personal information is collected.
The business or commercial purpose for collecting or selling personal information.
The categories of third parties with whom the business shares personal information.
The specific pieces of personal information it has collected about that consumer.

Request that a business that sells the consumer’s personal information, or that discloses it for a business purpose disclose, free of charge, to the consumer:

The categories of personal information that the business collected about the consumer.
The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal was sold, by category or categories of personal information for each third party to whom the personal information was sold.
The categories of personal information that the business disclosed about the consumer for a business purpose.

Direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.

To exercise any of the consumer’s rights as described in this section, please submit a request to us by:

Emailing us at help@mimiclubred.com

Only you, a person registered with the California Secretary of State that you authorize to act on your behalf, or a person you designate to us as an authorized agent may make a request related to your personal information.

If we have reason to believe that someone, alleging to act on your behalf, is not your authorized agent, we may request that you designate an authorized agent for purposes of making a request as described in this section.

We will not discriminate against you if you choose to exercise any of your rights as described in this section.

Privacy Policy

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