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Privacy Policy

This document (the "Privacy Policy") applies to all products and services offered by NN Shoes (en.nn.shoes) fully owned by NN Shoes LLC ("NN Shoes," "we," or "us"). Privacy Policy informs you of NN Shoes' policies regarding the collection, use and disclosure of any personal information you provided to NN Shoes through the Website, App, Services or otherwise. This Privacy Policy shall serve as an integral part of our Terms of Use (the "Terms").

We respects your privacy and the integrity of your personal identifiable information ("Personal Data"). This Privacy Policy sets out the principles NN Shoes follows when collecting, using, disclosing, retaining and removing Personal Data and describes other important topics relating to your privacy. This policy applies to any individual's Personal Data which is in our possession or under our control.

1. INFORMATION COLLECTION AND USE

1.1. Information you provide:
We may collect your Personal Data from you when you interact with our Service, this may include, for example, registering user account, completing know-your-customer process for your identification ("KYC"), signing up for news and updates, using our Services and/or contacting us via various means of communication.

By voluntarily providing us with your Personal Data, whether through the Website, App or otherwise, you consent, agree and accept that we, as well as our respective representatives and/or agents may collect, use, disclose your Personal Data as described in this Privacy Policy. Additionally, by giving your consent for us to process your Personal Data, you hereby represent that you are the owner of such Personal Data and you are authorised to provide it to NN Shoes.

Please note, that processing of Personal Data covers a wide range of actions with connection to Personal Data. Processing may be performed by manual, automated or other means and includes collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.

1.2. Information we collect from you:
We collect Personal Data through the process of setting up the account, using the Services, signing up for updates, contacting Support Team. We may also collect the information within the process of verification which is created to identify the level of risk the customer holds. Accordingly, we may collect and process the following data:

Contact information
when you create an account with NN Shoes, go through the identification process and verify your identity, subscribe to the NN Shoes news and updates, contact us by any communication means possible or participate in an online survey, including your full name, country of citizenship, mailing address, telephone number, and email address.

Payment information
when you go through the verification process and/or use to our Services, including your PayPal account information or credit/debit card number.

User account data
when you create an account with NN Shoes or communicate with us via App, including your username and password to access the Services within NN Shoes.

Personal opinions made known to us
when you participate in an online survey, including feedback or responses to surveys.


2. USAGE OF YOUR PERSONAL DATA

We may process you Personal Data for the purposes described in this Privacy Policy with your consent, for compliance with a legal obligation NN Shoes may be subject to, as a contractual obligation to provide Services to merchants or our partners, or when it necessary for the purposes of legitimate interests pursued by NN Shoes.

We use, store, and process information, including your personal information, about you in order to carry out provide and ensure your access to the Services, improve and develop NN Shoes, and maintain a trusted and safer environment and comply with our legal obligations.

2.1. Providing and ensuring the access to the Services, improving and developing NN Shoes
• You Personal Data will allow us comply with our contractual obligations, including to perform the agreement with you, the exercise of rights arising from this agreement and for performance of the obligations arising from the agreement.
• We will use your contact information and identification information to process your inquiries and requests.
• Your user account data, contact information and the data we collect automatically in the course of your usage of the Services is used to provide you with the Services and personalise the approach to you, including managing your user account, providing customer support, sending updates, collecting fees, etc.
• Device and log information is also used to measure and improve the Services that are available on the Website and the App.
• Payment Information to forward them directly to the Payment Service Provider for processing payment. Note, that NN Shoes will not be able to access your bank account , wallet or credit/debit card details at any time.
• We may also use the information about you for any other purpose for which the information was collected, provided that such purpose was disclosed to you at the time of collection or you provided a separate consent for processing your data for such purpose.

2.2 Creating and maintaining a trusted and safer environment
We use your personal data to:
• Enforce obligations owed to us.
• Carry out financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes.
• Resolve any disputes with any of our users, responding to queries or feedback, and enforce our agreements with third parties.
• Enforce our Terms of Use and other policies.

We process this information given our legitimate interest in protecting the NN Shoes, to measure the adequate performance of our contract with you, and to comply with applicable laws.

2.3 Providing, personalising, measuring, and improving our Advertising and Marketing.
Should you indicate so separately via the App or the Website, we will use your contact information to send you latest announcements, updates, news and/or upcoming events, promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about NN Shoes Services):
• To personalise, measure, and improve our advertising;
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.

3. SHARING AND DISCLOSURE

3.1 We may, based on your consent, our agreements with third parties, and in compliance with applicable laws on data privacy, disclose your Personal Data to any personnel of NN Shoes or to the personnel of the third party, whether located in the Russian Federation or elsewhere, in order to carry out the purposes set out above. Please be assured that when we disclose your Personal Data to such parties, we require them to ensure that any Personal Data disclosed to them are kept confidential and secure. For more information about the third parties with whom we share your Personal Data, you may, where appropriate, wish to refer to the agreement(s) and/or Terms of Use that govern our relationship with you or our customer. You may also contact us for more information at hello@nn.shoes.

3.2 Rest assured that NN Shoes does not sell or trade your Personal Data to any third parties.

3.3 In addition, NN Shoes may use other third party authorised processors such as technical service providers, identity verification services, mail carriers, IT companies, communication agencies, and hosting providers to process your data in order to provide you the Services. For example, your data may be stored in servers hosted by third party cloud service providers such as Google, Amazon, Microsoft Azure, etc., which may be located anywhere around the world. The data stored in such servers is secured and cannot be accessed by any third parties. Please contact NN Shoes to receive and updated list of such authorised processors at hello@nn.shoes. Any such authorised processor shall be obliged to adhere to the restrictions set forth in this Privacy Policy and the applicable data protection laws.

4. COMPLIANCE WITH LAW

4.1 NN Shoes may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorised third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against NN Shoes, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Use, or (v) to protect the rights, property or personal safety of NN Shoes, its employees, its Users, or members of the public.

4.2 Where appropriate, we may notify users about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would create a risk of any related illegal activity on NN Shoes's property, platform and/or human resources. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that User about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

5. YOUR RIGHTS

5.1 You have a right to be informed of Personal Data controlled by NN Shoes, a right to access Personal Data, a right to rectification/correction, a right to withdraw the consent , a right to erasure and restriction of processing and a right to object. You also have the right to receive from NN Shoes a structured, common and machine-readable format of Personal Data you provided to us. You can only exercise such rights against NN Shoes directly over the information that NN Shoes holds as data controller.

5.2 We can only adhere to your request and provide information if we have Personal Data about you through you having made contact with us directly and/or you using our App, Website and/or Service.

5.3 Where you have provided consent, you may withdraw it at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing it. Whenever you withdraw consent, you acknowledge and accept that this may have a negative influence on the quality of use of NN Shoes Website, App and/or Services. You further agree that NN Shoes shall not be held liable with respect to any loss and/or damage to your Personal Data if you choose to withdraw consent.

5.5 Where Personal Data is processed for the above purposes on the basis of NN Shoes's legitimate interests, under the GDPR, you may object to such processing at any time.

5.6 You may exercise any of the rights described in this section by sending a respective request to hello@nn.shoes. Please note that we may ask you to verify your identity before taking further action on your request.

5.7 Managing your information
You may access and update some of your information through your Account settings. For example, if you have chosen to connect your Account to a third-party in the App, you can change your settings and remove permission for the for the third-party to access your Personal Data by changing your Account settings. You are responsible for keeping your personal information up-to-date.

6. DATA RETENTION

We will retain your personal information only for so long as it is required for the purposes for which it was collected. This period may extend beyond the end of your relationship with us, but only for so long as is reasonably necessary for us to have sufficient information to respond to any legal issues that may arise after the end of your relationship with us or for as long as required by law. When your personal information is no longer required, we will destroy, delete or convert it into an anonymous form.

7. COMMUNICATION

We may occasionally send you notification emails about updates to our product, legal documents, offer customer support or marketing emails. Except for cases where we are required to do so by law (e.g. notifying you of a data breach), you shall have the opportunity to unsubscribe from receiving these messages free of charge.

8. PROTECTION OF PERSONAL INFORMATION

We endeavour to maintain appropriate physical, procedural and technical safeguards with respect to our offices and information storage facilities in order to prevent any loss, misuse, or unauthorised access, disclosure, or modification of your personal information.

We further protect personal information by restricting its access to those employees, contractors, advisers, affiliates and service providers that we determine to reasonably require access to such information for any of the purposes stated in this Privacy Policy.

9. COOKIES

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your device from a web site and stored on your device's hard drive.

We use cookies to collect information such as to confirm that you are logged in; compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of services provided by NN Shoes or third parties. For more information, please refer to our Cookie Policy.

10. INFRINGEMENT OF PRIVACY

If you have any questions related to this policy or in case of any suspected infringement of your privacy, please contact us at hello@nn.shoes.

The Privacy Policy of NN Shoes is subject to the Russian law (except the conflict of laws rule) and any disputes shall be brought exclusively to courts located in the Russian Federation.