1. OUR APPROACH TO PRIVACY
1.1 Skin PS Brands is a company registered in California, US with its registered address at 8645 Hayden Place Culver City, CA 90232 (“we”, “us”, “our” or “Skin PS”).
1.3 We operate an e-commerce platform, which we make available through our website slmdskincare.co.uk (our "Skin PS Website")
2. WHO IS RESPONSIBLE FOR THE USE OF YOUR PERSONAL INFORMATION
Skin PS is the controller of the personal information we hold about you in connection with your use of the Service. This means that we determine and are responsible for how your personal information is used.
3. PERSONAL INFORMATION WE COLLECT FROM YOU WHEN YOU USE THE SERVICE, AND HOW WE USE IT
3.1 We collect personal information that you voluntarily submit directly to us when you use the Service. This can include information you provide to us when you set up an account on the Skin PS Website, fill in a form / survey on the Skin PS Website, purchase a product, correspond with us by phone, e-mail or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, or use some other feature of the Skin PS Website.
3.2 This information may include, for example, your contact and payment details. If you choose not to provide such personal information, we may not be able to provide those parts of the Service to you or respond to your other requests.
3.3 The table at Annex 1 [lower on this page] sets out in detail the categories of personal information we collect about you and how we use that information when you use the Service, as well as the legal basis which we rely on to process the personal information and recipients of that personal information.
4. INFORMATION WE COLLECT ABOUT YOU AUTOMATICALLY
4.1 We also automatically collect personal information indirectly about how you access and use the Skin PS Website, and information about the device you use to access the Skin PS Website when you visit our Service, read our emails, or otherwise engage with us. We use this information to provide you the features and functionality of the Skin PS Website, to monitor and improve the Skin PS Website and to develop new products and services. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar tracking technologies.
4.2 The table at Annex 2 [lower on this page] sets out in detail the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and recipients of that personal information. For more information on cookies and other tracking technologies we use, please see Section 10 below.
4.3 We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
4.4 We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Skin PS Website and developing new products and features. We may also share such anonymised and aggregated information with others.
5. HOW LONG WILL WE STORE YOUR PERSONAL INFORMATION
5.1 We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.
5.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.
6. RECIPIENTS OF PERSONAL INFORMATION
6.1 We may share your personal information with the following (as required in accordance with the purposes set out in Annexes 1 and 2):
(a) Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services.
We have listed examples of the type of service providers that we use in Annexes 1 and 2.
(b) Partners and affiliates: Dr. Pimple Popper & SkinPhysicians and Surgeons.
(c) Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
7. MARKETING AND ADVERTISING
7.1 From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.
7.2 Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you. You can stop receiving promotional email communications from us by clicking on the unsubscribe link provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).
7.3 For UK residents, we will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or by updating your preferences via your account on the Skin PS Website.
8. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
8.1 Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored by our cloud hosting provider on secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
8.2 International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are accessing our Skin PS Website from the UK, your personal information will be processed outside of the UK including in the United States.
8.3 In the event of such a transfer, we ensure that: (i) the personal information is transferred to countries recognised as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.
9. RIGHTS FOR UK USERS
9.1 If you are accessing our Skin PS Website from the UK, in accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
(a) Right of access. The right to obtain access to your personal information along with certain related information.
(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
(f) Right to withdraw consent. If you have provided consent for the processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.
9.2 You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
9.4 Information about how to contact your local data protection authority is available here.
10. COOKIES AND SIMILAR TECHNOLOGIES USED ON OUR WEBSITE
10.2 Cookies are pieces of code that allow for personalisation of our Website experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes.
10.3 Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the preferences or settings page of your web browser. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
10.4 We use the following types of cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of our Skin PS Website. They include, for example, cookies that enable you to log into secure areas of our Skin PS Website, use a shopping cart or make use of e-billing services.
(b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Skin PS Website when they are using it. This helps us to improve the way our Skin PS Website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These are used to recognise you when you return to our Skin PS Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
(d) Targeting cookies. These cookies record your visit to our Skin PS Website, the pages you have visited and the links you have followed. We will use this information to make our Skin PS Website and the advertising displayed on it, and the marketing messages we send to you more relevant to your interests. We may also share this information with third parties who provide a service to us for this purpose.
(e) Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our Skin PS Website. These third parties are responsible for setting out their own cookie and privacy policies.
10.5 Please see Annex 3 for more information about the cookies we use on the Skin PS Website.
10.6 With the exception of strictly necessary cookies, you will only receive cookies when you have given us your consent to do so. In addition, if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of our Website. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.
(a) Cookie settings in Internet Explorer
(b) Cookie settings in Firefox
(c) Cookie settings in Chrome
(d) Cookies settings in Safari web and iOS.
10.8 Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.
11. TRACKING TECHNOLOGIES USED IN OUR EMAILS
11.1 Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.
11.2 Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display "remote images", "remote content" or "images" by default.
11.3 Some browsers also give you the option of downloading and installing extensions that block pixels and other tracking technologies.
12. INTEREST BASED ADVERTISING
12.1 We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history and use of the Skin PS Website. We may share, or we may permit third party online advertising networks, social media companies and other third party services to collect information about your use of the Skin PS Website over time so that they may play or display ads on the Skin PS Website, on other websites, apps or services you may use (including Facebook), and on other devices you may use.
12.2 Typically, but not always, this information is collected through cookies and similar tracking technologies. These third parties may collect, or we may share, mobile identifiers, such as the ID for Advertising for iOS (IDFA), Google Advertising ID, as well as your device's IP address, information about other applications on your device, your location, information about your use of the Skin PS Website, email address or hashed data and information about which advertisements you have seen or clicked on.
12.3 We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
12.4 We may also use certain forms of display advertising and other advanced features through Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
12.5 We and our third-party partners may also link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to the Skin PS Website. We may also work with third party partners who employ tracking technologies, or the application of statistical modelling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as user ID) with third party advertising partners to help recognise you across devices. We and our partners can use this cross-device linkage to serve interest-based advertising and other personalised content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.
12.6 You may be able to limit the use of these identifiers for interest-based advertising on a particular device through the settings on your device by selecting "limit ad tracking" (iOS) or "opt out of interest based ads" (Android). You may also be able to opt-out of some, but not all, interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
12.7 To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit:
(a) the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices;
(b) the DAA’s resources at www.aboutads.info/choices; and/or
(c) Your Online Choices at www.youronlinechoices.eu.
12.8 Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You would need to perform the opt-out on each browser or device you use.
12.9 Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or devices, or use another operating system, you will need to opt-out again.
12.10 Please note that opting out of interest-based advertising does not mean you will no longer see advertising on your device – it just means that adverts may no longer be tailored to your interests.
13. CONTROL OVER YOUR INFORMATION
13.1 You may update your profile information, such as your contact information, and may change some of your data sharing preferences on your Account page/by emailing us at email@example.com.
14. LINKS TO THIRD PARTY SITES
14.1 The Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
15. OUR POLICY TOWARDS CHILDREN
15.1 The Service is not directed at persons under 18. Skin PS does not permit children under the age of 18 to create or maintain an account or register as a user on the Skin PS Website. We do not knowingly collect or solicit personal information from any persons under the age of 13. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at firstname.lastname@example.org.
16. CHANGES TO THIS POLICY
17. NOTICE TO YOU
18. CONTACTING US