TENDERLY PRIVACY POLICY
Effective Date: September 2025
This Privacy Policy describes how Tenderly collects, uses, and protects your personal information, including health-related skincare data. We are committed to transparency and compliance with international privacy standards.
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INFORMATION WE COLLECT
Personal Information
- Name, phone number, email address
- Delivery address and payment information
- WhatsApp contact details
- Order history and product preferences
Skincare and Health-Related Information
- Skin type, sensitivity, and concerns
- Allergy history and product reactions
- Current skincare routine and products used
- Pregnancy/nursing status for safety screening
- Medical conditions affecting skincare (voluntarily provided)
- Photos of skin reactions (with explicit consent)
Usage Information
- Website browsing behavior and preferences
- Product search and purchase patterns
- Customer service interaction history
- Consultation responses and recommendations
Technical Information
- IP address, browser type, and device information
- Cookies and similar tracking technologies
- Website analytics and performance data
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HOW WE USE YOUR INFORMATION
Primary Purposes
- Product Safety Screening: Assess suitability and prevent adverse reactions
- Order Fulfillment: Process orders, payments, and deliveries
- Customer Support: Provide consultation and resolve issues
- Product Recommendations: Suggest suitable products based on skin profile
- Safety Monitoring: Track and report adverse events to health authorities
Health Data Specific Uses
- Contraindication screening for active ingredients
- Personalized skincare routine development
- Adverse reaction analysis and prevention
- FDA and health authority reporting compliance
- Product development and safety improvements
Marketing Communications (Optional)
- Product updates and new launch notifications
- Educational skincare content and tips
- Exclusive offers and promotions
- Customer satisfaction surveys
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LEGAL BASIS FOR PROCESSING
We process your information based on:
- Contract Performance: Fulfilling orders and providing services
- Legitimate Interest: Product safety, business operations, and improvements
- Legal Obligation: Regulatory compliance and safety reporting
- Explicit Consent: Marketing communications and optional health data
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INFORMATION SHARING AND DISCLOSURE
We DO NOT Sell Personal Information
Tenderly never sells, rents, or trades customer personal information or health data to third parties for marketing purposes.
Limited Sharing for Business Operations
We may share information with:
- Payment Processors: Secure payment processing only
- Delivery Partners: Address information for shipping only
- Healthcare Partners: With consent, for consultation services
- Legal Authorities: When required by law or for safety reporting
Health Information Sharing
Skincare and health data is shared only:
- With licensed healthcare providers for consultation (with consent)
- With regulatory authorities for adverse event reporting (anonymized when possible)
- For emergency medical situations (with customer authorization)
Service Providers
Third-party service providers who assist with business operations are contractually bound to protect customer information and use it only for specified purposes.
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DATA RETENTION
Account Information
- Active customer data: Retained while account is active
- Inactive accounts: Data deleted after 3 years of inactivity
- Legal requirements: Retained as required by law
Health and Safety Data
- Reaction history: Retained for 7 years for safety monitoring
- Consultation records: Retained for 5 years for continuity of care
- Anonymous safety data: May be retained indefinitely for research
Marketing Data
- Consent-based marketing data: Deleted immediately upon opt-out
- Transaction history: Retained for 7 years for business records
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YOUR PRIVACY RIGHTS
Access and Portability
- Request copies of your personal information
- Receive data in portable format for transfer
- Review how your information has been used
Correction and Updates
- Update personal information and preferences
- Correct inaccurate health information
- Modify skincare profile and allergies
Deletion Rights
- Request deletion of personal information
- Remove health data (subject to safety retention requirements)
- Close account and delete associated data
Marketing Opt-Out
- Unsubscribe from marketing communications
- Opt out of promotional WhatsApp messages
- Stop personalized product recommendations
Health Data Controls
- Withdraw consent for health data processing
- Limit sharing with healthcare partners
- Request anonymization of reaction reports
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DATA SECURITY
Technical Safeguards
- Encryption of sensitive data in transit and at rest
- Secure servers with restricted access
- Regular security audits and updates
- Multi-factor authentication for staff access
Organizational Safeguards
- Staff training on data protection requirements
- Need-to-know access principles
- Incident response and breach notification procedures
- Regular review of data handling practices
Health Data Special Protection
- Enhanced encryption for medical information
- Separate storage systems for health data
- Additional access controls and audit trails
- Compliance with medical data protection standards
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INTERNATIONAL DATA TRANSFERS
Cross-Border Processing
Some information may be processed in countries with different privacy laws. We ensure adequate protection through:
- Contractual data protection clauses
- Adequacy decisions from relevant authorities
- Explicit consent for sensitive data transfers
Regional Compliance
- Botswana: Compliance with local privacy and consumer protection laws
- GDPR (EU customers): Full compliance with European privacy requirements
- CCPA (California customers): Compliance with California privacy rights
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COOKIES AND TRACKING
Essential Cookies
- Session management and security
- Shopping cart and payment processing
- Basic website functionality
Analytics Cookies
- Website performance and usage patterns
- Customer experience improvements
- A/B testing for website optimization
Marketing Cookies (Optional)
- Personalized product recommendations
- Retargeting advertisements
- Social media integration
Cookie Controls
You can control cookies through browser settings, though disabling essential cookies may affect website functionality.
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CHILDREN'S PRIVACY
We do not knowingly collect information from individuals under 18. Parents must provide consent and supervision for minors using our products. If we discover we have collected information from a child without proper consent, we will delete it immediately.
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PRIVACY POLICY UPDATES
We may update this Privacy Policy to reflect:
- Changes in privacy laws and regulations
- New product features or services
- Improvements in data protection practices
- Business operation changes
Significant changes will be communicated via:
- Email notification to registered customers
- Website banner notifications
- WhatsApp messages for important updates
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CONTACT INFORMATION
Privacy Questions and Requests
Privacy Officer: info@tenderly.store
WhatsApp: +267 74033153
Data Subject Rights Requests
- Email specific requests to: rights@tenderly.co.bw
- Include account information and specific request details
- We will respond within 30 days of verified requests
Health Data Concerns
For health-related data questions:
- Immediate concerns: WhatsApp +267 74033153
- Detailed inquiries: info@tenderly.store
- Medical emergencies: Contact healthcare provider first
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REGULATORY COMPLIANCE
This Privacy Policy complies with:
- Botswana data protection and consumer laws
- General Data Protection Regulation (GDPR) for EU customers
- California Consumer Privacy Act (CCPA) for California residents
- FDA and health authority reporting requirements
- International cosmetic industry privacy standards
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YOUR CONSENT
By using our website and services, you consent to the collection and use of your information as described in this Privacy Policy. For health-related data, we obtain explicit consent through separate agreement processes.
You may withdraw consent at any time, though this may limit our ability to provide certain services or ensure product safety.
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This Privacy Policy reflects our commitment to protecting customer privacy while ensuring the highest standards of product safety and regulatory compliance in the skincare industry.