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PRIVACY POLICY
                            

Last updated March 12, 2019
                            
Thank you for choosing to be part of our community at Skin Coach SL (“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.
                            
TABLE OF CONTENTS
                            
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. HOW LONG DO WE KEEP YOUR INFORMATION?
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
6. DO WE COLLECT INFORMATION FROM CHILDREN UNDER THE AGE OF 13?
7. WHAT ARE YOUR RIGHTS AND CHOICES?
8. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 
9. WHAT ARE YOUR EUROPEAN PRIVACY RIGHTS?
10. DO WE MAKE UPDATES TO THIS POLICY?
11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?                                                                     

 

 

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. 
 
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.
 
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.  
                            
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 only the for purposes of training and maintaining our AI algorithm as integrated into the Services, and for no other purpose.                 
                            
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?        
                            
In Short: We share information only for the purposes of training and maintaining our AI algorithm as integrated into the Services, and for no other purpose, 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 data analytics, 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. 

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. 
 
For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.
                            
4. HOW LONG DO WE KEEP YOUR INFORMATION?
                            
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.
                            
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). 
                            
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
                            
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
                            
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
                            
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Apps is at your own risk. You should only access the Services within a secure environment.
                            
6. DO WE COLLECT INFORMATION FROM CHILDREN UNDER THE AGE OF 13?
                            
In Short: We do not knowingly collect data from or market to children under 13 years of age.
                            
The Service is intended for a general audience and not directed to children under thirteen (13) years of age. We do not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA or market to children under 13 years of age. By using the Service, you represent that you are at least 13 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Apps. If we learn that personal information from users less than 13 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such personal from our records. If you become aware of any personal we have collected from children under age 13, please contact us at info@skincoach.com, and we will remove such personal information to the extent required by COPPA.
                            
7. WHAT ARE YOUR RIGHTS AND CHOICES?
                            
In Short: You may review, change, or terminate your account at any time.

Review and Update of Account Information                    

You may access, update, or remove certain account information that you have voluntarily submitted to us through the Service by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. California residents and European data subjects have additional rights as set forth in the sections entitled “Your California Privacy Rights” and “Your European Privacy Rights” below.

Tracking Technology Choices                            

Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations. 
 
App Technologies. You can reset your device advertising Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. For information on how to do this on Apple devices, visit Apple.com or https://support.apple.com/en-us/HT202074. For information on how to do this on Android devices, visit Google.com. You can stop all collection of information via an app by uninstalling the app.  

Location-Identifying Technologies. The location data collected through an app depends on your device settings and app permissions. You can exercise choice over the location data collected through our apps by (i) for GPS data, disabling location in your device settings or disabling location permissions to that app; (ii) for Bluetooth data, disabling Bluetooth and any Bluetooth scanning option in your device settings; or (iii) for WiFi data, disabling WiFi and any WiFi scanning option in your device settings. You can stop collection of all location data via an app by uninstalling the app.  
 
Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
 
Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly. 
 
Communications
 
E-mails. You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or e-mailing us at the e-mail address set forth in the section entitled “Contact Us” below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt-out of non-promotional e-mails, such as those about your account, transactions, servicing, or Company’s ongoing business relations.

 
Please note that your opt-out is limited to the e-mail address and device used and will not affect subsequent subscriptions.                     
                            
8. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
                            
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.
 
Company may share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Company is not required to respond to requests made by means other than through the provided e-mail address or mail address.
 
Any California residents under the age of eighteen (18) who have registered to use the Service and posted content or information on the Service, can request that such information be removed from the Service by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.
                                            
9. WHAT ARE YOUR EUROPEAN PRIVACY RIGHTS?

If you are a data subject in the European Economic Area (“EEA”), you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
 
To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
 
If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. 


10. DO WE MAKE UPDATES TO THIS POLICY?
                            
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
                            
We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.
                            
11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
                            
If you have questions or comments about this policy, you may email us at info@skincoach.com or by post to:
                            
Skin Coach SL 
Diagonal 640, 2F
Barcelona 08017
Spain