Privacy Policy

Effective date: 4/27/23

We are committed to protecting the privacy and security of the information we collect from you and to being transparent about the ways in which we collect and process your information. This Privacy Policy explains how we collect, use, disclose and manage your personal information that you provide to us when using our websites or other online services, as well as our privacy practices. This Privacy Policy applies, without limitation, to any individual or entity that (i) uses a website that links to this Privacy Policy, (ii) creates an account on one of our websites, or (iii) otherwise provides any personal information to us.

WHEN YOU ACCESS OR USE THIS WEBSITE, OR OTHERWISE PROVIDE ANY INFORMATION TO US, YOU AGREE TO THIS PRIVACY POLICY, INCLUDING THE MANNER IN WHICH WE USE YOUR INFORMATION, WHETHER OR NOT YOU HAVE AN ACCOUNT WITH US. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE SUBSEQUENTLY MAKE TO THIS PRIVACY POLICY, YOU MUST STOP USING THE WEBSITE OR OTHERWISE PROVIDING ANY INFORMATION TO US.

The website contains links to other websites. This Privacy Policy does not apply to information collected on or through any such third-party websites. We are not responsible for the privacy practices of such third parties or the content of their websites. Such third parties have their own privacy policies and you should review those privacy policies to determine their privacy practices.

Information We Collect, Purpose and Use

Category	Purpose of Collection	Disclosed to Third Parties
User provided information, such as contact information (first name and last name, email address, or phone number), payment information, and other information you provide us directly (message content)	We use this information to fulfill your orders, answer and manage your questions or complaints, provide you with information you request, for advertising and marketing purposes, and for analytics, statistics and research.	We may need to disclose this information to service providers such as our cloud storage, payment processing, order management, shipping fulfilment, data analytics, and operations providers. We may also disclose this information to third parties for advertising and marketing purposes.
Location Information (geolocation information and commercial information)	We use this information to provide you customized services near you and for marketing.	We may need to disclose this information to service providers such as our cloud storage, payment processing, order management, shipping fulfilment, data analytics, and operations providers. We may also disclose this information to third parties for advertising and marketing purposes.
Survey responses	We use your survey responses to improve our services and better understand your preferences.	We may need to disclose this information to service providers such as our cloud storage providers, data analytics, and survey processing providers.
Information shared directly by users while engaging in public activities on the website (reviews, comments, etc.)	We publish this information on our website along with your content and may republish on affiliate websites or in advertisements.	In addition to publishing publicly, we may need to disclose this information to service providers such as our cloud storage, payment processing, order management, shipping fulfilment, data analytics, and operations providers. We may also disclose this information to third parties for advertising and marketing purposes.
Sweepstakes or Contests	We use this information to determine and contact winners.	We may need to disclose this information to service providers such as our cloud storage providers, data analytics and survey processing providers. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
Referral information (pages that you visit before and after using the website, browsing history, and search history)	We use this information to better understand how you arrived at our website to customize your experience on our services and to evaluate our marketing programs.	We may need to disclose this information to service providers such as our cloud storage, order management, data analytics, operations providers and marketing providers.
Website and account usage information (e.g. order history, wait lists, pages viewed, and customer service inquiries)	We use this information to better understand how you use the service and to customize your experience on our services.	We may need to disclose this information to service providers such as our cloud storage, payment processing, order management, shipping fulfilment, data analytics, and operations providers.
Device level information (e.g. internet and other network activity information, including ADIDs, cookies, IP address, and other device hardware and software information)	We use this information to protect the security of your account and remember your personalized settings. We may also use certain device level information for advertising and marketing purposes.	We may need to disclose this information to service providers such as our cloud storage providers, data analytics providers, and advertising partners.
Inferred Data (e.g. inferred user information, preferences or tastes)	We may use this information to provide you with recommendations and customize your experience, optimize or improve our services, and run analytics, statistics and research.	We may need to disclose this information to service providers such as our cloud storage, data analytics, operations providers, and advertising partners.
Audio and Visual Information (the public spaces in our physical locations may be protected by CCTV.)	We may use this information for the purpose of preventing crime and for your safety and the safety of our employees.	We may need to disclose this information to service providers such as our security and CCTV providers or to law enforcement.
Employment Applications	We will collect and use your information to assess your qualifications and maybe to contact you.	We may need to disclose this information to service providers such as our cloud storage, data analytics, and recruitment and other operations providers.

We also receive the categories of information described above from other sources, including from users of our website, and third-party services and organizations. For example, if you access any social media or similar services through our website to login or to share information about your experience with our products or services with others, we may collect information from these third-party services.

In addition to the uses and disclosures described above, we also may share information with third parties as follows:

Corporate Affiliates. We may share your information with our corporate affiliates for promotional purposes or to customize your experience.
Business Transfers. We may share your information in connection with a substantial corporate transaction, such as a merger, consolidation, asset sale, or initial public offering.
Legal Purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of the company, our affiliates, users, or the public.
With Your Consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Policy.

The Company does not sell information to third parties. The Company does, however, permit third parties to collect the information described above through our websites and services, and discloses that information with third parties for business purposes as described in this Privacy Policy, including for marketing purposes. For instance, we may disclose information to third parties to send you promotions, or to advertise on third-party sites or apps based on your online activities across different sites, services, and devices. The information practices of these third parties are not covered by this Privacy Policy. Moreover, because it is unclear whether this type of disclosure constitutes a “sale” of personal information under the California Consumer Privacy Act of 2018 (CCPA), we allow California residents and any other individuals to exercise their rights under the act—see below for more information.

Use of Web Technologies

We and our third-party advertising and analytics providers use cookies, tracking pixels and local storage including log files, to collect information from your browser or device. By using our website or services, you consent to our use of these technologies.

The types of cookies and similar technologies used by us and our partners in connection with the website can be classified into the five categories below.

Type of cookie	What it does
Functional Cookies	These cookies are essential to provide you with the website and any services available through this website and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for, like transactional pages and secure login accounts, would not be possible. In addition, these cookies allow us to: · Save your location or language preference · Remember your log-in data
Preference Cookies	Preference cookies record information about choices you’ve made and allow us to tailor the website to you. These cookies mean that when you continue to use or come back to the website, we can provide you with our services as you have asked for them to be provided. These cookies allow us to: · Save your location or language preference · Remember your log-in data · Store other website preferences.
Performance Cookies	We use performance/analytics cookies to analyze how the website is accessed, used, or is performing in order to provide you with a better user experience and to maintain, operate and continually improve the website. These cookies allow us to: · Better understand our website visitors so that we can improve how we present information; · Test different design ideas for particular pages; · Collect information about website visitors such as where they are located and what browsers they are using; · Determine the number of unique users of the website; · Improve the website by measuring any errors that occur; and · Conduct research and diagnostics to improve product offerings. Among other technologies, we use Google Analytics, which is a web analytics tool that helps us understand how users engage with the website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve the website. The reports disclose website trends without identifying individual visitors. For more information on Google Analytics, see here. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.
Advertising Cookies	We allow third party companies, including advertising and social media companies, to place cookies on our website. These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet. Cookies also allow us and third parties to know whether you have seen an ad or a type of ad, and how long it has been since you’ve last seen it. This information is used to help tailor the ads you see and to measure the effectiveness of ads. We can use information from one device to help personalize your experience on another device. Because of how cookies work, we cannot access cookies placed by third parties, nor can the third parties access the data in cookies used by us.

Your Rights and Choices

You may be entitled, in accordance with applicable law, to request access to and/or a copy of certain information we have about you, to request that we delete certain information we have about you, or request more information about our privacy practices. See below under EU Citizens or California Residents for more information.

Limiting Tracking Using Your Settings

You can block cookies and similar technologies by changing your device, app or browser settings. Blocking essential cookies, however, are likely to impact your use of the website.

Opt-Out of Third-Party Tracking

Our website uses third parties such as network advertisers to serve advertisements on our website and traffic measurement services to analyze traffic on our website. Third-party ad serving enables us to target advertisements to you. Our website’s third-party ad network providers, the advertisers, the sponsors and/or traffic measurement services can themselves set and access their own cookies and other technologies on your computer and track certain behavioral information regarding users of your computer via an IP address or other device identifier. These third-party cookies and other technologies are set to, among other things: (a) help deliver tailored advertisements to you; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. Note that any images (or any other parts of a web page) served by third parties in association with third party cookies can serve as web beacons, which enable third parties to carry out the previously described activities. Third party cookies, web beacons and other third-party technologies are governed by each third party’s specific privacy policy, not this one.

You can visit http://www.networkadvertising.org/understanding-online-advertising/ to learn more about interest-based advertising and your choices regarding having this information used by third parties and your “opt out” choices. Opting out through the Digital Advertising Alliance (the “DAA”) or the National Advertising Initiative (the “NAI”) only means that those DAA or NAI members will no longer be able to deliver targeted content and/or ads to you, which will affect our website as well as other unaffiliated websites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit these opt out pages, or you subsequently erase your cookies, use a different computer or change web browsers, your opt out choices could not (or could no longer) be effective.

Click http://www.networkadvertising.org/choices/ for the NAI opt-out page. Click http://www.aboutads.info/choices/ for the DAA opt-out page.

Click http://www.youronlinechoices.com/opt-out-interface for the Ad Tech Network opt-out page.

Opt-Out of Direct Marketing

We use tracking pixels and similar technologies in some emails and push notifications which enable us to understand whether you have opened the email and how you have interacted with it. If you have enabled images, cookies will also be set on your computer or mobile device and will also be set if you click on any link within the email.

If you want to be removed from our marketing list and do not want us to send you email, postal mail or other messages about our products and services, you can opt out. To do so, please send an email to support@simplifiedskin.com, with the word “REMOVE” in the subject line.

Do Not Track

When you use the website, you may have set your browser or other means used to access the website to send “do not track” requests to us. At this time, we do not respond to such “do not track” requests, although we may choose to do so in the future.

EU Citizens

As described more fully below, as our parent company is based in the United States, we primarily process data in the United States and many of our servers and offices are in the United States.

If you are a user in the EU, you have the right to access personal data we hold about you and to have certain personal data corrected or erased. You also have the right to data portability, and to restrict certain processing of your data in certain circumstances. You also have the right to complain to your data protection authority if you have any complaints about how we process your personal information.

You have the right to object to our processing of your personal data at any time, and you can withdraw your consent to marketing at any time.

To make any of these requests please use this form. We will respond as soon as practicable and no later than one month after receipt of your request. We will request proof of identification to verify your identity.

We reserve the right to deny or restrict fulfillment of your request in certain cases, such as when your access to data places another individual’s privacy rights at risk, or the continued processing or your data is necessary to comply with a legal obligation. If so, we will notify you of the reason(s) for this denial.

In the event that you have a concern about our collection and processing of your data, please contact us first at support@simplifiedskin.com and we will do our best to fix it. You also, have the right to lodge a complaint directly with your local supervisory authority.

California Residents

If you are a California resident, you may make requests to us as provided by the CCPA and set out below. We will review all requests received and determine the extent to which and how to respond. We will not discriminate against any California resident who makes such requests.

You may:

request from us a list of: (i) the personal information that we have collected about you; (ii) the categories of third parties to whom we have disclosed your personal information; and (iii) the categories of third parties to whom we have sold your personal information. You have the right to up to 2 access requests each twelve 12 months
request to delete your account and your personal information
request, at any time, to direct us to stop “selling” (for the purposes of the CCPA) your personal information

You may contact us to make the requests described above by completing <<form>>. We will not use the information you provide as part of your request for any other purpose other than to fulfill your request.

You may also submit such requests through an authorized agent. To designate an authorized agent, please send us a notarized power of attorney / notarized letter authorizing said agent. Requests from agents that do not submit such proof that they have been authorized by you to act on their behalf will be denied.

International Users

Our parent company is based in the United States, and some of our servers and offices are headquartered in the United States. Please be aware that information you provide to us or that we obtain as a result of your use of the website, an account, or any services provided by us will be processed and transferred to, and be subject to the laws of, the United States. The privacy and data protection laws in the United States will be different from similar laws in your country of residence. By using the website or an account, or by providing us with your information, you consent to the collection, transfer, storage and processing of information to and within the United States. If our cookies or other software detects IP addresses located in a country outside the United States, we reserve the right to modify or deny access to any and all of our services.

Privacy Policy Updates

We reserve the right to change this Privacy Policy at any time, so please review it on a regular basis. Any changes made to this Privacy Policy will be posted here and we will notify you of any material changes. The date stamp at the top of the page represents the last day this Privacy Policy was updated. If you have questions about this Privacy Policy, you can contact us at support@simplifiedskin.com. By maintaining an Account with us, or by using or accessing any services provided by us or the website, you will be deemed to have acknowledged our Privacy Policy.

Manage Accurate Information

If your personally identifiable information changes, or if you no longer choose to use our services or the website, you can contact customer service by email, telephone or postal mail at the contact information listed below to assist you with changes to your Account. To the extent your Account closes or becomes inactive, we will continue to protect your information as described in this Privacy Policy.

Data Retention and Security

Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.

We take reasonable precautions to protect the confidentiality and security of your personally identifiable information by using industry recognized security safeguards, including physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personally identifiable information. Unfortunately, no data security system or method of transmission over the Internet is completely secure. Therefore, while we strive to protect your personally identifiable information within industry standards, we cannot guarantee its absolute security.

Our employees are trained and required to safeguard your information. Our internal controls limit access to personally identifiable information based on job functionality.

No Information Collected from Children

We do not knowingly collect or sell any information from children, as defined by applicable law, without parental consent or as otherwise permitted by applicable law.

Contact Us

If you have any questions or suggestions regarding this Privacy Policy, please contact by email: support@simplifiedskin.com.