1. General

1.1. Responsible Party

The responsible legal entity is: Newsha Single Member P.C

Email: info@newshadrinks.com

The data protection officer of the responsible party is: Mr. Shahryar Nassaj

E-mail: privacy@newshadrinks.com

1.2. Scope of Newsha Single Member P.C Privacy Policy

This Privacy Policy applies to all users of information systems and websites run by all entities belonging to Newsha Single Member P.C (referred to herein as “Newsha’, “we”, “us” and “our”).

The following rules describe how we handle information relating to an identified or identifiable person (Personal Data) for services performed through all our information systems and websites (Systems).

Users (consist of all individuals around the world, who connect to and use Systems) expressly consent to the Processing of their Personal Data as described in this Privacy Policy. Processing has the meaning of any operation with Personal Data, irrespective of the means applied and the procedure, and in particular the collection, transfer, storage, use, revision, disclosure, archiving or destruction of Personal Data.

This Privacy Policy is effective on 21st March 2019.

Newsha Single Member P.C may amend this Privacy Policy at any time by posting the amended terms on its Systems. All amended terms automatically take effect 30 days after they are initially posted and disclosed. The continued use of the Systems after any such changes shall constitute the consent of the User to such changes.

1.3. Principles of Processing Personal Data

1.3.1. Purpose and Scope of Processing

Our primary purpose in collecting Personal Data is to provide Users with safe and efficient services. So, protection of your personal data on our website is important to us. As a rule, we only process the personal data of our users to the extent required in order to provide a functional website as well as our services related to our Terms and Conditions.

1.3.2. Data Deletion and Storage Period

Regardless of possible revocation of your consent, we process and store your personal data as long as and to the extent required in order to satisfy the respective purposes.

1.3.3. Recipients

We will only pass your personal data to other third parties, if it is necessary to carry out your payment transaction, your purchase or orders, for example as part of order processing, customer data is transmitted to the systems of third parties to transact payments (with banks, credit card reservation or bookings).

We do not sell or rent Users’ Personal Data to third parties for their marketing purposes without Users’ explicit consent. If Users do not wish to receive marketing communications from us, they simply indicate their preference at any time via e-mail to: privacy@newshadrinks.com

We may also share Users’ Personal Data with:

- Fulfillment centers

- Service providers under contract who help with the business operations (such as for example fraud investigations, bill collection, customer support, support from sales consultants).

- Other third parties to whom Users explicitly ask us to send their Personal Data.

- Law enforcement agencies, other governmental agencies or third parties in response to a request for information relating to a criminal investigation, alleged illegal activity or any other activity that may expose us or Users to legal liability. The Personal Data we disclose may include User ID and User ID history, name, city, telephone number, email address, or anything else that we deem relevant.

1.4. Rights of the Data Subjects

If we collect or process personal data on this website, then you are the data subject within the meaning of the EU General Data Protection Regulation [GDPR].

In this case you have the right of access, the right to rectification and erasure of your data, the right to restriction of processing, a right of objection to processing and the right to data portability. In this case, you are most welcome to email us at privacy@newshadrinks.com

1.5. Revocation of Declarations of Consent

If you have given us your consent to process your personal data, then you may revoke such consent at any time via e-mail to: privacy@newshadrinks.com

A revocation shall not affect the legality of the processing carried out up to that point.

2. Processing of Personal Data

2.1. Provision of the Website

Each time our website is accessed, data and information are automatically processed by the computer system of the invoking computer.

The following data is collected:

- Name of your Internet service provider

- IP address

- Date and Time of access

- The browser type and version

- The website from which you visit our website

This information is evaluated for statistical purposes and subsequently deleted. The individual user remains anonymous.

Furthermore, our website responds to browser do-not-track signals.

2.2. Contact Form and Email

In order to improve our customer service, on our website we provide you with a contact form which can be used to contact us electronically. Any processing of personal data is only used to handle your request.

If you use email to contact us, the data entered will be transmitted to us and stored. This data includes: name, first name, postal address, e-mail address, telephone number, information about your interest(s).

2.3. Online Office – Sign up Process

2.3.1. Purpose of the Processing

Your data which you communicate to us via the Registration form, will be stored and used exclusively for purposes connected with the registration and processing of your interest in cooperating with us.

While you order, personal information is gathered from you by us. In this context your information is stored safely by us; this means you have the advantage of not having to enter your personal data again with every order. The information includes in particular your name, email address, tel. number, mobile number, address and information on invoices. The information you provide here is exclusively used to simplify your order process, for administrative purposes and in-house analyses.

Users agree that we may also use their Personal Data to:

The execution of your purchases, transactions or other orders.

Provide the services and customer support you request;

Resolve disputes, collect fees, and troubleshoot problems;

Customize, measure and improve our services, content, and advertising;

 Tell Users about our products, targeted marketing, service updates, and promotional offers based on their communication preferences

Send marketing communications via email or mobile (which Users may choose not to receive at any time by following the instructions provided with the communication)

Compare Personal Data for accuracy, and verify it with third parties.

The following as long as we have received your consent:

Using the information stored in your user profile, to offer you the possibilities of individual services and optimal use of our Website.

In order to provide you with individual offers and information personally interesting to you. Of course you also have an opportunity to tell us that you do not want (or no longer want) to be sent such offers and/or information. We will, of course, respect that.

2.3.2. Collection and Processing of Registration Data

Online sign-up requires that certain personal data indicated with mandatory fields in the respective online registration form be provided. Furthermore, you have the option of sending us further details.

Once you enter your registration data and click on the “Submit” button, they will be transmitted and collected on a server in Germany; the server is now hosted and administered by a service provider commissioned on our behalf and even later elsewhere in the world where we have facilities in compliance with applicable data protection laws and regulations, even if the level of legal protection is lower than in the User’s country of residence.

We will take all reasonable steps in order to ensure that your data is handled carefully and completely.

However, for this purpose your registration data must be truthful, complete and up-to-date. Therefore, please inform us immediately with regard to any changes in your data. You may review the data that you have entered at any time and make any changes by revising your data or adding information or send us a request to do so.

We may collect and store the following personal information, including Personal Data:

Email address, physical contact information, and (depending on the service used) sometimes financial information, such as credit card or bank account numbers;

Shipping, billing and other information Users provide to purchase or ship an item;

Correspondence through Systems, and correspondence sent to us;

Other information from Users’ interaction with Systems, services, content and advertising, including computer/device and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;

Additional information we ask Users to submit to authenticate themselves (e.g. we will ask Users to send copies of ID, or passport to verify their identity and personal details):

Additional information may be collected as per applicable policy.

2.4. Google Analytics

We use Google Analytics to understand how visitors engage with our sites and apps. This means that when you visit our website or use one of our mobile applications your browser automatically sends certain information to Google. This includes, for example, the web address of the page that you're visiting and your IP address. You will find the details of how the Google technology collects and processes data following this link https://www.google.com/policies/privacy/partners/.

3. Accessing, Reviewing, Changing, and Deleting Users’ Personal Data

3.1. Accessing, Reviewing and Changing Personal Data

Users can see, review and change most of their Personal Data by signing in to Systems (within the personal, password-protected area.). Generally, we will not manually modify Users’ Personal Data because verifying their identity remotely may prove difficult. Thus, it is Users’ responsibility to update promptly their Personal Data if it changes or is inaccurate.

Should you wish not to receive any messages or information about offers and special promotions and Newsletter from us, which you had previously agreed to receive, simply send an email to us at the following address: privacy@newshadrinks.com

3.2. Deletion of Data

You also have the right upon request to delete your data stored with us free of charge and at any time. To delete them, please go through “Termination of Distributorship” menu in your virtual office.

If you do not arrange for your data to be deleted, then your data will be processed until the day we receive your “Termination of Distributorship” request.

We do retain Personal Data from closed accounts to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, and take other actions otherwise permitted by law.

4. Security Information

Through technical and organizational measures we protect your data against unauthorized access, loss and destruction.

We treat Personal Data as a valuable asset and preserve it with various methods (encryption, passwords, physical security, etc.) to protect Users’ Personal Data against unauthorized access and disclosure. However, third parties may unlawfully intercept or access transmissions or private communications between Users and Systems. Therefore, although we deploy significant effort to protect Users’ privacy, we do not promise that Personal Data or private communications will always remain private.

Users’ password is the key to their account. Users shall use unique numbers, letters, and special characters, and do not disclose their password to anyone. If Users share their password or their Personal Data with others, they shall remember that they are responsible for all actions taken in the name of their account. If Users lose control of their password, they may lose substantial control over their Personal Data and may be subject to legally binding actions taken on their behalf. Therefore, if Users’ password has been compromised for any reason, they should immediately notify us and change their password.