PRIVACY POLICY

MUSHO. LIFE LTD - ONLINE PRIVACY POLICY 

Welcome to this website (“Site”), which is owned or operated by Musho. Life Ltd, a company incorporated in England and Wales with company registration number 13905924, and whose registered office is located at 128, City House, London, EC1V 2NX, United Kingdom (“Musho”). Musho is also referred to in this Privacy Policy as “we”, “us” or “our”.

Musho values its customers and respects their privacy. Your visit to the Site and your use of any of the services or features we provide is subject to our Terms and Conditions.

This Privacy Policy (together with our Terms and Conditions, Cookies Policy and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. We are the data controller in respect of your personal data. Please read this Privacy Policy carefully to understand our views and practices regarding your personal data and how we will treat it.

Our website is not intended for, and should not be used by, children under the age of 13. We do not knowingly or intentionally collect any information from children under the age of 13.

This Privacy Policy does not cover information that you submit on any other websites. For example, if you post something on third-party sites such as Facebook, Twitter, Instagram, or YouTube ("Third Party Sites"), that information is governed by the privacy policies on those websites and is not governed by this Privacy Policy. Similarly, if you post something on another website operated by any member or brand within our group ("Associated Sites"), for example on www.unnamedbeauty.com, that information is governed by the privacy policies on those Associated Sites and is not governed by this Privacy Policy. You should always check the Terms and Conditions and Privacy Policies posted on Third Party Sites and Associated Sites.

1. How/when we collect personal information from you

Information you give us: You may give us personal information about you when you:

• visit our website;

• fill in forms on our Site or when you correspond with us by phone, e-mail or otherwise;

• register to use our Site (which you must do if you would like to use some of the services and features we offer on our Site), subscribe to our marketing communications and services including the CODE loyalty programme, or place an order on our Site;

• submit enquiries, feedback, suggestions, ideas or other information;

• participate in our customer satisfaction surveys or other market research;

• fill in any of our product suitability questionnaires (such as skincare or make-up suitability) and/or

• communicate with us via social networking websites, third-party apps, or similar technologies.

Information we receive from other sources: we may receive information about you if you use any of the other websites we (or any member or brand within our group) operate or other services we provide. In this case, we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Site. We are also working closely with third parties (including, for example, sub-contractors in technical, payment and delivery services, advertising networks, marketing services, analytics providers, search information providers, credit reference agencies, etc.) and may receive information about you from them.

2. Personal information we collect about you:

We may collect and process the following personal information about you, that you submit to us, such as:

• contact details (such as your name, address, email address and telephone number);

• demographic information (such as age and/or other information that may identify you as an individual);

• passwords and other authentication information;

• responses to any customer satisfaction surveys or market research (unless these are provided anonymously);

• social media handles;

• financial and credit card information;

• your marketing preferences.

• additional information you choose to provide us including your date of birth, hair colour, eye colour, make-up tone, skin tone, skin type and beauty preferences.

We may also collect information from you automatically. For example, if you contact us with a complaint or query, we may keep a record of any phone number used to call our customer service number as well as the correspondence and the period of time it took for us to deal with a query or any request you had. We may also record your levels of satisfaction with the services we have provided. We will also collect and store your purchase history.

We may also automatically collect personal information from you using cookies and other similar technologies. A cookie is a small file of letters and numbers that we may set on your device. You can find more information about the individual cookies we use and the purposes for which we use them in our Cookie Policy. This type of information may include the following:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet;

• your login information

• browser type and version, time zone setting, browser plug-in types and versions;

• operating system and platform; and

• information about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information such as scrolling, clicks, and mouse-overs; methods used to browse away from the page.

Our international sales facilitation and fulfilment partner is All Stars Prop Co Limited (“Tradestars”), a company with an overseas entity (Company registration number OE002037), whose registered office is at 33-37 Athol Street, Douglas, Isle of Man, IM1 1LB. If you purchase products from this Site, your personal data may be collected and used by Tradestars for the purposes of fulfilling your order and delivering products to you. This Privacy Policy only relates to the use of your data by Musho. Please refer to the privacy policy available here; https://tradestars.space/privacy-policy-2/ terms for further details on how your personal data will be used by them.

3. Use made of your personal information

We may use personal information held about you in the following ways:

• to fulfil your order (including acknowledging your order and communicating with you if there is any issue regarding the fulfilment of your order);

• to make sure your order is delivered correctly;

• to provide you with a birthday gift as part of the CODE loyalty programme;

• to operate and administer the Code loyalty programme (including the provision of rewards), which may include the sharing of information with carefully selected third-party partners;

• to maintain your account;

• to allow you to book an appointment with us or to attend an event;

• to allow you to complete any surveys we send you (if you wish to) or to comment on or review our products or services, to help us improve them;

• to provide you with a more personalised beauty experience (which may include using the information you provide on our suitability questionnaires to automatically recommends suitable products to you);

• for accounting, billing, reporting and audit purposes;

• for credit checking or screening;

• for authentication and identity checks and to distinguish you from other users;

• for credit, debit or other payment card verification and screening;

• to record images for security purposes;

• for debt collection;

• safety, security, training, legal and administrative purposes and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• for customer care support and services such as identifying your shopping preferences and requirements;

• to monitor your use of our website to improve the user experience and to ensure that content is presented in the most effective manner for you and for your device;

• to improve your shopping experience with us and tailor any marketing or advertising so that it is more relevant to you, for example to keep you up-to-date on our latest fragrance, perfumes, candles, cosmetics, makeup, and body care products, promotional offers and events;

• to notify you of any changes to our services including our CODE loyalty programme; and/or

• to conduct marketing analysis to allow us to assess trends and the effectiveness of our advertising and marketing campaigns (including using your personal information to evaluate, analyse or predict certain personal aspects relating to you, such as your preferences, economic situation, interests, and/or location) for example, to build a picture of your interests so that we may tailor our communications to you to ensure they are relevant and of interest to you and so that when you visit our site we can tailor your experience so that it is easier to shop with us.

We may also match or combine the information we collect from you and the information you provide to us with information we receive from other sources (such as social media platforms). We may use the combined information for the purposes set out above (depending on the types of information we receive). This may include your contact details, demographic data, your social media interactions, preferences, shopping habits, interests, geographic location and age or age range. We may use this personal information to tailor and show advertisements more relevant to you either on our website or on third party websites (including social media platforms).

4. Legal basis for processing

We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:

• Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.

• Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights. For example, we will rely on this

legal basis when we conduct certain market analysis to understand our customers in sufficient detail so we can create new services and improve the profile of our brand.

• Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a product from us and we need to use your contact details and payment information in order to process your order and send the product to you.

• Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

5. Opt-Out of direct marketing

You can at any time tell us not to send you marketing communications (i) by email by clicking on the unsubscribe link within the marketing emails you receive from us; or (ii) by SMS by following the “STOP” instructions provided with the message or (iii) by postal mail by following the instructions that may be included in a particular promotion. If you have registered with us, you may also opt out of receiving postal mail from us by logging into your account and amending your preferences.

6. Disclosure of your information

They may use the information in accordance with their privacy policies for purposes such as financial reporting and analysis; strategic planning; the development of customer segmentation and metrics to provide a consistent view of our customer base; the creation of inspiring content and editorial features, and the development of new products and collaborations to enhance your experience as a customer of Musho or other brands within the group.

From time to time we retain the services of other carefully selected and monitored companies and individuals to perform functions on our behalf in connection with the successful operation and continuous improvement of this Site and our services. We may share your information with selected third parties including:

• Suppliers and sub-contractors for the performance of any contract we enter into with them or you (e.g., in order to process your order and maintain your account, including the authorisation and validation of credit or debit card transactions, the provision of delivery services, the analysis of data, etc.). These companies or individuals may be provided with access to your personal details in order to fulfil their function but may not use such information for any other purpose.

• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. Online retargeting is a form of online advertising that allows us and some of our advertising partners to show you advertising based on your browsing patterns and interactions with our websites. For example, when you have visited our website and then moved to another site, you may start seeing our adverts displaying special offers or reminding you of the products you were browsing on our website. The technology behind these adverts is based on cookies. More information about how we use cookies and how you can, if you wish, turn off cookies is included in our Cookie Policy. This processing constitutes profiling under the UK/EU GDPR. We process your personal data in this way as it is in our legitimate interest to offer you a personalised experience on our sites and to provide you with personalised advertising and marketing, and depending on

the mode that such personalized advertising and marketing are conducted, subject to your consent for the use of your personal information for direct marketing if/where applicable.

• Analytics and search engine providers that assist us in the improvement and optimisation of our Site.

We do not provide your personal details to other companies or individuals for their marketing purposes unless you have indicated when you registered that you wish to receive information about other companies’ products, offers and services in areas including luxury beauty, fragrance and cosmetics.

We may also disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

• if Musho (or its ultimate holding company and its subsidiaries) or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

We may share your personal data where we are under duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our other terms and conditions or other agreements, or to protect our rights, property, or safety (or the rights, property, safety of our customers or others). This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

7. Where we store and process your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside of the country in which it was originally collected including countries, which have less strict, or no data protection laws, when compared to those in the EEA or the UK.

The reason for this transfer is that some of the operations we need managed in order to complete our contract with you are located outside of the EEA or the UK, for instance, it may be processed by staff working outside of the EEA or the UK who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

Where your personal data is transferred in this way, we will take all steps reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this Privacy Policy. In these cases, we rely on approved data transfer mechanisms (such as standard contractual clauses) to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

8. Security and passwords

We use the latest strong encryption technology to ensure that all transactional information is protected to the highest standard. Transactional information includes any credit or debit card details, your personal contact information together with any other names and addresses you provide when you place an order for delivery to another address, and your purchasing history. If you have given your consent prior to entering the details required for the ordering process, our Site will retain your Musho account details

such as your name, address, email address and purchasing history. Each time you log into your Musho account to create a new order you must re-enter your credit card details.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

9. Third Party Websites

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

10. Social Media

FACEBOOK PLUGINS (LIKE & SHARE BUTTONS)

Our website may include plugins for the social network Facebook, Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA. The Facebook plugins can be recognized by the Facebook logo or the Like button on our site. For an overview of Facebook plugins, see https://developers.facebook.com/docs/plugins/.

When you visit our site, a direct connection between your browser and the Facebook server is established via the plugin. This enables Facebook to receive information that you have visited our site from your IP address. If you click on the Facebook “Like button” while you are logged into your Facebook account, you can link the content of our site to your Facebook profile. This allows Facebook to associate visits to our site with your user account. Please note that, as the operator of this site, we have no knowledge of the content of the data transmitted to Facebook or of how Facebook uses these data. For more information, please see Facebook’s privacy policy at https://de-de.facebook.com/policy.php.

If you do not want Facebook to associate your visit to our site with your Facebook account, please log out of your Facebook account.

TWITTER PLUGIN

Functions of the Twitter service may be integrated into our website. These features are offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. When you use Twitter and the “Retweet” function, the websites you visit are connected to your Twitter account and made known to other users. In doing so, data will also be transferred to Twitter. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it will be used by Twitter. For more information on Twitter’s privacy policy, please go to https://twitter.com/privacy.

Your privacy preferences with Twitter can be modified in your account settings at https://twitter.com/account/settings.

11. Analytics and Advertising

GOOGLE ANALYTICS

This website uses Google Analytics, a web analytics service. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.

Google Analytics cookies are stored based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in analyzing user behaviour to optimize both its website and its advertising.

BROWSER PLUGIN

You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Objecting to the collection of data

You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set to prevent your data from being collected on future visits to this site: Disable Google Analytics.

For more information about how Google Analytics handles user data, see Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.

12. Plugins and Tools

YOUTUBE

Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.

If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited.

If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.

YouTube is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.

Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy.

SOUNDCLOUD

On our pages, plugins of the SoundCloud social network (SoundCloud Limited, Berners House, 47-48 Berners Street, London W1T 3NF, UK) may be integrated. The SoundCloud plugins can be recognized by the SoundCloud logo on our site.

When you visit our site, a direct connection between your browser and the SoundCloud server is established via the plugin. This enables SoundCloud to receive information that you have visited our site from your IP address. If you click on the “Like” or “Share” buttons while you are logged into your SoundCloud account, you can link the content of our pages to your SoundCloud profile. This means that SoundCloud can associate visits to our pages with your user account. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it will be used by SoundCloud. For more information on SoundCloud’s privacy policy, please go to https://soundcloud.com/pages/privacy.

If you do not want SoundCloud to associate your visit to our site with your SoundCloud account, please log out of your SoundCloud account.

SPOTIFY

Features of the Spotify music service are included on our pages. This service is provided by Spotify AB, Birger Jarlsgatan 61, 113 56 Stockholm, Sweden. The Spotify plugins can be recognized by the green logo on our site. For an overview of the Spotify Plugins, see https://developer.spotify.com.

Thus, when you visit our pages about the plugin a direct connection can be established between your browser and the Spotify server. This enables Spotify to receive information that you have visited our site from your IP address. If you click the Spotify button while you are logged into your Spotify account, you can link the content of our pages to your Spotify profile. This means that Spotify can associate visits to our pages with your user account.

More information can be found in the Spotify privacy policy at https://www.spotify.com/de/legal/privacy-policy/.

If you do not want Spotify to associate your visit to our site with your Spotify account, please log out of your Spotify account.

13. Data Retention and Destruction

We store data for as long as it is necessary to provide products and services to you and others as long as we are legally required to do so. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.

14. Rights of Data Subjects

You have certain rights in relation to your personal information. These include: the right to object to the processing of your information for certain purposes, the right to access your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information. To the extent the processing is based on your consent, you may withdraw your consent at any time.

If you wish to exercise any of your rights, please send your request via the link here or alternatively, you may contact us via email at customerservices@spacenk.com or by post to:

Head of Customer Experience

Musho. Life LTD

128 City Road, London

EC1V 2NT, United Kingdom

We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights, please contact us using the contact details below.

You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns, we request that you initially contact us (using the contact details below) so that we can investigate, and hopefully resolve, your concerns.

15. Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy.

16. Contact

Questions, comments, or requests regarding this Privacy Policy are welcomed and should be addressed by email to info@musho-life.com

17. UK data protection representative

Representative in the United Kingdom:

FAO: Chief Technology Officer Musho. Life LTD

128, City Road, London, EC1V 2NX, United Kingdom

18. EU data protection representative

Representative of controllers or processors not established in the European Union (Article 27 GDPR):

ePrivacy GmbH Große Bleichen 21 20354 Hamburg Germany

https://www.eprivacy.eu