Effective Date: November 2025
Contact: naturound@naturound.com
Operator: Naturound, operated by Salegency Radosław Bartczak
Mieczysława Karłowicza 13/5, 40-145 Katowice, Poland
VAT: PL6431628580

1. Who We Are

Naturound is a global platform offering educational skincare content, digital programs, downloadable materials, and physical wellness products through:

• program.naturound.com (Circle community – programs, community, journals)
  

• naturound.com (Shopify store – ebooks, audiobooks, guides, physical products)
  

Naturound is operated by:

Salegency Radosław Bartczak
Mieczysława Karłowicza 13/5
40-145 Katowice, Poland

Email: naturound@naturound.com

Naturound complies with:

• GDPR & UK GDPR

• ePrivacy Directive

• CCPA/CPRA

• Colorado, Virginia, Connecticut, Utah Privacy Acts

• Australia Privacy Act

• New Zealand Privacy Act

• Thailand PDPA

• Singapore PDPA

• Japan APPI

• Korea PIPA

When this policy says “we,” “us,” or “our,” it refers to Naturound.

2. What Data We Collect

We only collect the data necessary to run Naturound, deliver orders, maintain memberships, and improve your experience.

We collect the following categories of data:

2.1. Account & Identity Data

• Name

• Email address

• Password (encrypted)

• Optional profile photo

• Country / region (if provided)

Collected when:

• You create an account on Circle

• You create a Shopify customer account

• You purchase a product

• You sign up for free access
  

2.2. Payment & Transaction Data

Processed securely through Stripe, Shopify Payments, and PayPal:

• Last 4 digits of card (we never see full number)

• Billing address

• Payment status

• Refunds & cancellations

• Order history

• Digital download logs (timestamps, IPs)

We never store or access your full card number.

2.3. Shipping & Delivery Data

Collected when you order physical products:

• Full shipping address

• Phone number (optional, sometimes required by carriers)

• Postal codes

• Delivery preferences

• Local customs documents (where applicable)

Shared only with trusted shipping partners such as:

• DHL / UPS / FedEx

• Local postal services

• Fulfillment centers / warehouses

• Shopify’s shipping integrations

2.4. User-Generated Content (Circle & Shopify)

You own everything you create, including:

• Glow Journal posts

• Photos

• Comments

• Messages

• Reviews on Shopify

• Testimonials (voluntary)

We store this securely and only use it:

• Within the community

• As allowed by the Terms & Conditions

• Externally only with your explicit consent

2.5. Technical & Analytics Data

Collected automatically through your device:

• IP address

• Device type, OS, browser type

• Timezone

• Cookies & tracking IDs

• Page views, clicks, navigation paths

• Session duration

• Abandoned cart events (Shopify)

• Community engagement events (Circle)

Tools used:

• Google Analytics / Consent Mode v2

• Meta Pixel

• TikTok Pixel

• Shopify analytics

• Circle analytics

• Email engagement tools (open rates, clicks)

2.6. Marketing & Communication Data

• Newsletter signup status

• Marketing preferences

• Email click & open tracking

• SMS preferences (if activated)

• Ad interaction data (anonymous)

We do not sell or share identifiable data with advertisers.

2.7. Sensitive Data

We do NOT collect sensitive categories such as:

• health conditions

• sexuality

• political opinions

• religion

• biometrics

If you voluntarily share skincare experiences in posts, this is entirely optional and you may delete it anytime.

3. How We Use Your Data

We use your data to support the smooth, safe, and enjoyable operation of Naturound.

3.1. To Provide and Manage Your Account

• Creating and maintaining your Shopify or Circle account

• Personalizing your dashboard

• Providing access to digital downloads, lessons, and programs

• Saving your progress in community spaces

Legal basis: Performance of Contract

3.2. To Process Orders (Digital & Physical)

• Accepting payments

• Sending receipts

• Confirming digital delivery

• Delivering physical products

• Providing customer support

• Managing refunds

Legal basis: Contract / Legal Obligation

3.3. To Run the Naturound Community

• Moderating posts

• Supporting members

• Allowing safe interaction

• Enabling Glow Journals and progress logs

Legal basis: Legitimate Interest + Contract

3.4. To Improve Our Services

• Analytics

• Feature improvements

• Troubleshooting

• Performance monitoring

Legal basis: Legitimate Interest

3.5. To Send Essential Service Emails

Examples:

• Account creation confirmation

• Order receipts

• Digital download links

• Renewal notices

• Password resets

• Changes to Terms and Policies

Legal basis: Contract / Legal Obligation

3.6. To Send Optional Marketing

Only when you explicitly opt in:

• Newsletters

• Exclusive offers

• Product announcements

• Wellness content

• Program invitations

You can unsubscribe anytime with one click.

Legal basis: Consent

3.7. To Protect Our Platform

We use certain data to:

• Detect fraud (Shopify fraud analysis)

• Secure logins (IP + device tracking)

• Prevent abuse or spam

• Meet regulatory obligations

Legal basis: Legitimate Interest / Legal Requirement

4. Legal Basis (GDPR & UK GDPR)

We process your data under these bases:

• Contract

To deliver your purchases and community access.

• Consent

For newsletters, optional emails, cookies, marketing.

• Legitimate Interest

To improve the platform, keep users safe, prevent fraud.

• Legal Obligation

Tax records, accounting, regulatory compliance.

5. Marketing & Advertising

Naturound uses respectful, minimal, privacy-first marketing.

We may use:

• Email marketing (with optional consent)

• Social ads (Meta, TikTok, Google)

• Lookalike audiences (only anonymous signals)

• Promotional banners or updates

We DO NOT:

• Sell personal data

• Share your identifiable data with advertisers

• Use your community posts for ads without explicit consent

You can withdraw marketing consent anytime.

6. User-Generated Content (UGC)

Everything you create belongs to you.

✔ Within Naturound

We may display your:

• Posts

• Photos

• Comments

• Glow Journal entries

for community engagement.

✔ Outside Naturound

We only use UGC externally with your explicit, written consent.

This includes:

• Social media

• Website

• Testimonials

• Ads (never without permission)

You can withdraw consent anytime by email.

7. How We Share Your Data

We share personal data only with trusted providers who help us operate Naturound, process orders, or meet legal requirements.

We never sell personal information.

We never share identifiable data with advertisers.

Below is the full list of data-sharing categories.

7.1. Service Providers (Processors)

We share necessary data with:

• Shopify (Store Platform & Checkout)

For: checkout, payments, customer accounts, order history, fraud detection.
Location: Canada / Global
Compliance: GDPR, CCPA/CPRA, SCCs.

• Stripe (Payments)

For: secure card processing, fraud prevention, refunds.
We never see your full card number.

• Circle.so (Community Platform)

For: hosting accounts, posts, groups, comments, notifications.
Location: United States
Compliance: GDPR SCCs.

• Analytics Tools

Google Analytics / Consent Mode v2
Meta Pixel
TikTok Pixel
All anonymized.

• Email Service Providers

For newsletters, reminders, program updates.

• Shipping Providers

Only when you order a physical product:
DHL, UPS, FedEx, Local Post
(We share name, address, phone if needed, order reference.)

• Fulfillment & Warehousing Partners

If used for packing and delivering physical orders.

• Customer Support Tools

For troubleshooting, refunds, order questions.

All service providers sign confidentiality, data protection, and security agreements.

7.2. Legal Authorities (Only if Required)

We may disclose data if required by:

• tax authorities

• customs authorities

• law enforcement

• courts

• regulatory bodies

We limit disclosures to what is strictly required by law.

7.3. Business Transfers

If Naturound undergoes a merger, acquisition, restructuring, or asset transfer, your data may transfer to the new operator — but only under the same privacy protections.

8. How Shopify Uses Your Data

Shopify processes some data on our behalf.
Examples:

✔ Checkout & Payments

• Name

• Email

• Address

• Payment method

• Order details

• IP address

• Fraud analysis flags

✔ Customer Accounts

• Login details

• Order history

• Saved addresses

✔ Analytics

Shopify collects behavioral data such as:

• pages viewed

• cart actions

• device & browser info

• referral information

Shopify may use aggregated, anonymized data to improve its services.

Shopify does not sell personal information.

9. Physical Product Shipping & Fulfillment

When you purchase a physical product, we collect and share necessary fulfillment data.

9.1. Data collected for shipping:

• Full name

• Full address

• Phone number (optional / required in some countries)

• Email (for updates)

• Order items

• Tracking number

• Customs declarations (outside EU)

9.2. Shared only with:

• postal carriers

• shipping companies

• customs authorities

• warehouses

• fulfillment centers

• Shopify Shipping partners

We do not authorize shipping partners to use your data for marketing.

10. International Data Transfers

Naturound operates globally.
Your data may be stored or processed in:

• EU

• United Kingdom

• United States

• Canada

• Singapore

• Australia

Where data leaves your region, we apply recognized safeguards:

✔ Standard Contractual Clauses (SCCs)

✔ UK International Data Transfer Addendum

✔ PDPA transfer mechanisms (TH/SG)

✔ APPI cross-border rules (Japan)

✔ PIPA safeguards (Korea)

We ensure protection equal to GDPR-level standards.

11. Cookies & Tracking

Naturound uses cookies to:

• remember your preferences

• keep your cart active

• improve the site

• analyze usage

• deliver secure checkout

• measure ad performance (anonymous only)

Full details are provided in the Naturound Cookie Policy (v1.0).
This Privacy Policy only references cookies; they are not described in detail here.

You can control cookies via:

• browser settings

• cookie banner preferences

• opt-out links (where available)

12. Data Retention

We keep your data only as long as needed.

✔ Account data

Stored until deleted by you.

✔ Shopify order data

Stored for 5 years for tax and legal compliance.

✔ Payment records

Stored per financial and anti-fraud obligations.

✔ Community posts (UGC)

Stored until you delete them or close your account.

✔ Shipping & fulfillment data

Retained for up to 24 months for customer service and delivery confirmation.

✔ Marketing consents

Stored until you opt out.

✔ Technical logs

Short-term retention (14–180 days depending on system).

You can request deletion of your data anytime (see Section 13).

13. Your Rights

Depending on your country, you have the right to:

✔ Access

Receive a copy of your personal data.

✔ Rectification

Correct inaccurate or outdated information.

✔ Erasure (“Right to be Forgotten”)

Delete your account and associated data.

✔ Restriction

Pause certain processing activities.

✔ Objection

Object to processing based on legitimate interest.

✔ Portability

Receive your data in a machine-readable format.

✔ Withdraw Consent

Stop newsletters and marketing anytime.

✔ Opt-Out of Sale or Sharing (California)

Naturound does not sell personal data, but California residents may still opt out.

✔ Lodge a Complaint

EU: Data Protection Authority
UK: ICO
Thailand: PDPC
Singapore: PDPC
US: State Attorney General
Australia / NZ: Local privacy regulators

We will respond within 30 days of your request.

Contact: naturound@naturound.com

14. Children’s Privacy

Naturound is for individuals 16+.

If you are under 16:

• you must have verified parental consent to join

• you may not purchase paid items without consent

Guardians may request deletion of a minor’s data anytime.

15. Security Measures

Naturound uses:

• encryption

• secure servers

• SSL certificates

• password hashing

• access control

• monitoring & logging

• fraud detection (Shopify)

Despite our protections, no system is 100% immune to security incidents.

If legally required, we will notify you of any breach.

16. Additional Regional Disclosures

Naturound serves a global audience.
Some users receive specific additional rights based on where they live.

16.1. California (CCPA / CPRA)

California residents have the right to:

• Know what personal information we collect

• Know how it is used and shared

• Access their information

• Request deletion

• Correct inaccuracies

• Opt out of “sale” or “sharing” of personal data

• Limit use of sensitive personal data

Naturound does not sell personal information and does not share data for behavioral advertising in a way that identifies you.

To request: Email: naturound@naturound.com

16.2. Nevada Residents

Under Nevada privacy law, you may opt out of the “sale” of personal information.
Naturound does not sell personal information.

16.3. Virginia / Colorado / Connecticut / Utah

Residents of these U.S. states have rights to:

• Confirm if we process your data

• Access data

• Correct data

• Delete data

• Opt out of targeted advertising (Naturound uses only anonymous signals)

• Opt out of sale or profiling

To exercise rights: naturound@naturound.com

16.4. Australia & New Zealand

Your privacy rights follow:

• Australian Privacy Act

• New Zealand Privacy Act

You may request access, correction, and deletion anytime.

16.5. Thailand (PDPA)

PDPA grants rights to:

• Access

• Correction

• Deletion

• Data portability

• Objection

• Withdrawal of consent

Naturound complies with PDPA transfer rules for international processing.

16.6. Singapore (PDPA)

For Singapore residents, processing may rely on:

• Express consent

• Deemed consent (e.g., necessary to fulfill a purchase)

• Legitimate interests with balancing tests

You may withdraw consent anytime.

16.7. Japan (APPI)

Japanese residents may contact: naturound@naturound.com to request

• Disclosure

• Correction

• Suspension

• Deletion

16.8. South Korea (PIPA)

Korean residents have rights to request:

• Access

• Correction

• Suspension

• Deletion

Data transfers follow PIPA safeguards.

17. Do Not Track (DNT)

Some browsers offer a “Do Not Track” feature.
There is no universal standard for response, so Naturound does not currently respond to DNT signals.

We respect your privacy through:

• cookie preferences

• marketing opt-outs

• global privacy controls where supported

18. Your Consent Choices

You control your privacy.

✔ Email Marketing

Unsubscribe anytime via link at the bottom of every email.

✔ Cookies & Tracking

You can manage cookies through:

• browser settings

• privacy tools

• Naturound Cookie Policy

• the cookie banner (where required)

✔ UGC Consent

You decide what we may use outside the community.
Withdraw anytime.

✔ Account Deletion

Delete your Circle account anytime.
For Shopify, email us to remove your account and order history (except legally required records).

19. Data Minimization

We collect and process only what is necessary for:

• purchasing

• community access

• security

• performance

• analytics

• legal compliance

We do not collect data “just in case.”

20. Automated Decision-Making

Naturound does not use automated decision-making that has a legal or significant effect on users.

Shopify may use automated fraud detection to protect transactions.
This does not affect your ability to purchase unless clear fraud risk is detected.

21. Third-Party Links

Naturound may link to external sites (e.g., ingredient suppliers, social media).
Those sites have their own privacy policies.
We are not responsible for their practices.

22. Changes to This Policy

We may update this Privacy Policy for legal, technical, or business reasons.

You will be notified at least 14 days before major changes.

Continued use of Naturound after updates means you accept the new version.

The latest version is always available at: https://www.naturound.com/privacyandcookiespolicy

23. Governing Language

If this policy is translated, the English version prevails for legal purposes.

24. How to Contact Us

For privacy questions, data requests, or complaints:

naturound@naturound.com

Postal address:
Naturound (Salegency Radosław Bartczak)
Mieczysława Karłowicza 13/5
40-145 Katowice, Poland

We respond within 30 days.

Closing Note 

Your glow journey is personal — and so is your data.
We protect both with the same intention:

calm, clarity, safety, and respect.

Thank you for trusting Naturound with your care 🤍