Last updated September 12th, 2019

Thank you for choosing to be part of our community at Skincoach SL and Skincoach, Inc. (“Company”, “we”, “us”, or “our”). If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at info@skincoach.com.

In our Privacy Policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Apps and our Service.

This Privacy Policy applies your use of any online service location that posts a link to this Privacy Policy, and all features, content, and other services that we own, control, and make available through such online service location, including, but not limited to www.skincoach.com and www.myacnie.com (“Sites”), and our application(s) (“Apps”), (we refer to them collectively in this Privacy Policy as the “Service”).

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.

1. WHAT INFORMATION DO WE COLLECT?

Information You Provide

In Short: We collect information you provide directly via the Service, such as when you register an account, update your profile, access our content, make a purchase, contact customer support, or apply for a job.  We may use Service Providers (defined below) to collect this information. We may also collect information regarding your mobile device, when you use our Apps.The information we collect includes information that identifies you personally (whether alone or in combination). Some examples of information we collect include the following:

• Contact Data. We collect your first and last name, e-mail address, postal address, phone number, and other similar contact data.

• Credentials. We collect passwords, password hints, and similar security information for authentication and account access. 

• Demographic Data. We collect demographic information such as your age, gender, and country. 

• Payment Data. We collect data necessary to process your payment if you make a purchase, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.

• Profile Data. We collect your username, interests, favorites, and other profile data. 

• Contacts. We collect data about your contacts in order to fulfill a request by you, such as finding your contacts on the Service or inviting your contacts to join the Service. Such functionality is only intended for United States (“U.S.”) residents. By using this functionality, you acknowledge and agree that both you and your contacts are based in the U.S. and that you have your contacts’ consent for us to use their contact information to fulfill your request.

• Content. We collect the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide to customer support. We also collect the content of your communications as necessary to provide you with the services you use. For example, if you chat with another user through the Service, we need to collect the content of that chat to display it to you and the other user as you direct.

• Resume Data. We collect data as necessary to consider you for a job opening if you submit an application to us, such as your employment history, transcript, writing samples, and references. 

You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.

Information Collected Automatically

We automatically collect information about your device and how your device interacts with our Service. We may use Service Providers to collect this information. Some examples of information we collect include the following:

• Service Use Data. We collect data about the features you use, the pages you visit, the e-mails and advertisements you view, the products you purchase, the time of day you browse, your referring and exiting pages, and other similar information.

• Device Connectivity and Configuration Data. We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information. This data also includes IP address, MAC address, device advertising Id (e.g., IDFA or AAID), and other device identifiers.

• Location Data. We collect data about your device’s location, which can be precise (e.g., latitude/longitude data) or imprecise (e.g., location derived from an IP address or data that indicates a city or postal code level). 

We use various current – and later – developed technologies to collect this information (“Tracking Technologies”), including the following:

• Log Files. A log file is a file that records events that occur in connection with your use of the Service, such as your service use data. 

• Cookies. A cookie is a small data file stored on your device that acts as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings. 

• Pixels. A pixel (also known as a web beacon) is code embedded in a website, video, e-mail, or advertisements that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, e-mail, or advertisement that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from third parties that allow us track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.  

• Device Fingerprinting. Device fingerprinting is the process of analyzing and combining sets of information elements from your device’s browser, such as JavaScript objects and installed fonts, in order to create a “fingerprint” of your device and uniquely identify your device and apps.

• App Technologies. There are a variety of tracking technologies that may be included in our apps, and these are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include third party SDKs, which is code that sends information about your use to a server, and is in effect the app version of a pixel. These SDKs allow us track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.  

• Location-Identifying Technologies. GPS, WiFi, Bluetooth, and other location-aware technologies may be used to collect precise location data when you enable location-based services through your device. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.

Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.

For further information on Tracking Technologies and your rights and choices regarding them, see the sections entitled “Third Parties” and “Your Rights and Choices” below.

Information collected from other sources

In Short: We may obtain information about you from other third party sources. We protect data obtained from these third parties according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data.Examples of the information we receive from other sources include: social media networks; marketing leads and search results and links, including paid listings (such as sponsored links); partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities; data brokers from which we purchase demographic data to supplement the data we have.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent, including to:

• Manage our Service, including your registration and account.

• Perform services requested by you, such as to respond to your comments, questions, and requests, and provide customer service.

• Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.

• Prevent and address fraud, breach of policies or terms, and threats or harm. 

• Monitor and analyse trends, usage, and activities.

• Conduct research, including focus groups and surveys. 

• Improve the Service or other Company websites, apps, marketing efforts, products and services.

We also use information about you with your consent, including to:

• Verify your eligibility and deliver prizes in connection with Promotions you have entered.

• Send you communications regarding our and third party products, offers, promotions, rewards, events, and services that may be of interest to you. 

• Develop and display content, features, and advertising tailored to your interests on our Service as well as on other platforms and services.

• Fulfill any other purpose disclosed to you and with your consent. 

We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We share information with your consent, to comply with laws, to protect your rights, or to fulfill our legitimate interests as follows:

In Short: We share information with your consent, to comply with laws, to protect your rights, or to fulfill our legitimate interests as follows:

• Service Providers. We may share your information with our agents, vendors, and other service providers (collectively “Service Providers”) in connection with their work on our behalf. Service Providers assist us with services such as payment processing, data analytics, marketing and promotional services, Promotions, website hosting, and technical support. Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.  

• Affiliates. We may share your information with our related entities including our parent and sister companies. For example, we may share your information with our affiliates for customer support, marketing, and technical operations.

• Business Partners. We may share your information with our business partners in connection with offering you co-branded services, selling or distributing our products, or engaging in joint marketing activities. For example, we may share information about you with a retailer for purposes of providing you with product support.

• Promotions. Our Promotions may be jointly sponsored or offered by third parties. If you voluntarily choose to enter a Promotion, we may share your information with third parties a set forth in the official rules that govern the Promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a Promotion, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.

• Third Parties. We may share your information with third parties for purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Service) and in connection with tailoring advertisements, measuring and improving our Service and advertising effectiveness, and enabling other enhancements.

• Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business. 

• Security and Compelled Disclosure.We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information to protect the rights, property, life, health, security and safety of us, the Service or any third party. 

• Consent. We may share your information for any other purpose disclosed to you and with your consent. 

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.