Effective Date: October 28, 2019
The “Gladskin Service” and the “Service(s)” mean any websites, and other services under the control of Micreos North America, Inc. or its affiliated entities, whether partial or otherwise, in connection with providing an online or digital platform for Gladskin’s services in the US, including us.gladskin.com. The Gladskin Service connects users (“you, “user,” “users”) to information about our skin treatment products and, if you choose, allows you to purchase products directly from our online shop.
“Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, email address, phone number, or payment information. We do not consider Personal Information to include information that has been de-identified so that it does not allow a third party to easily identify a specific individual.
“Health Information” is Personal Information about past, present, and future health or medical conditions or treatments that is derived from medical histories, prescriptions, medical records, or similar medical sources and commonly released in connection with patient care, treatment, and insurance reimbursement payments.
“Your User Content” or “User Content” means the information that you may post, submit, upload, publish, display, transmit, or otherwise share through the Gladskin Service, including but not limited to product reviews, data, text, files, software, sound, photos, videos, graphics, artwork, ideas, opinions, and comments. We do not consider Your User Content to be Personal Information.
THE GLADSKIN SERVICE COLLECTS YOUR INFORMATION
We collect Personal Information when you:
- Register to use the Gladskin Service
- Use the Gladskin Service or provide feedback about the Service
- Make purchases on the Gladskin Service
- Communicate with us
Personal Information Collection. You may register to use the Gladskin Service or to make purchases through the Gladskin Service. To register, you may need to provide Personal Information, such as your name, phone number, mailing address, and email address.
Using the Gladskin Service or Posting Product Reviews. We collect Personal Information from you as you use the Gladskin Service. For example, you may share reviews about products you have used. We collect any information you post or provide in connection with using the Gladskin Service.
Purchases. When you make online purchases, returns, or exchanges, or place items in your online shopping cart, we may collect Personal Information related to your order, including payment card information, billing and delivery information, and any delivery instructions you may provide.
Our site uses Shopify, an online e-commerce platform, to manage our online shop. For more information on Shopify’s privacy practices, including any information they may collect about you, please visit: https://www.shopify.com/legal/privacy.
Customer Support. We may collect Personal Information through your communications with our customer support team.
Location Information from Your Mobile Device. We may collect and store your location information if you enable your mobile device to send it to us. Collection of this information may improve the provision of the Gladskin Service.
Cookies, Automatic Data Collection, and Related Technologies. When you visit the Gladskin Service, we and third parties that provide certain functionality on the Gladskin Service may engage, receive and record information from your browser, including your IP address, and from cookies, web beacons, pixels, and similar technology. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Gladskin Service may not work properly. By using the Gladskin Service, you are authorizing us to gather, parse, and retain data related to the provision of the Gladskin Service. This information may be used to improve the quality of the Gladskin Service, such as to store your preferences and customize the Gladskin Service, to determine information about the usage of our site and communications, or to prevent fraud. Our partners also may collect and combine information collected on the Gladskin Service and via email with other information about your online activities over time, on other devices, and on other websites, if those website also use the same partners.
Cookie Deletion and Browser Do-Not-Track. You may be able to change browser settings to block and delete cookies when you access the Gladskin Service through a web browser. However, if you do that, the site may not work properly. The Gladskin Service does not respond to browser do-not-track.
HOW GLADSKIN USES YOUR INFORMATION
We use Personal Information to
- Fulfill your requests for products and services and communicate with you about those requests
- Send you or display to you information about products, services, or other content you have requested
- Facilitate and improve the Gladskin Service and your user experience on the Gladskin Service
- Communicate with you.
Vendors and Service Providers. Gladskin discloses information it collects through the Gladskin Service, including Personal Information, to third party vendors and service providers for our business purposes so they can perform services for us.
Purchases and Payment Processing. If you make a purchase through the Gladskin Service, we or our third party payment processors may collect your credit card number or other payment account information, billing information, and other data necessary to facilitate the purchase. By providing such information, you agree to our sharing that information with third parties as necessary to process your payment and confirm and fulfill your orders.
Internal and Service-Related Usage. We use information, including Personal Information, for internal and service-related purposes only and may provide it to third parties to allow us to facilitate the Gladskin Service. We may use and retain any data we collect to provide and improve our services.
Your User Content Posted to the Gladskin Service. You may post Your User Content to the Gladskin Service to post products reviews, maintain your Gladskin account, and for Gladskin to provide information about the content you post. For example, you may share Personal Information and Health Information in reviews that can be viewed by other community members. When you post Your User Content, our employees and service providers may review it. Your User Content will be publicly available, so do not post any information that you want to keep private.
Communications, Newsletters, Other Publications. We may send emails to the email address you provide to us for informational and operational purposes, such as customer service, system maintenance, security and verification. We may also send you information about products, services, or other content you have requested, including newsletters, blogs, media, and other resources and publications. If you call us with questions about the Micreos Service, your account, or your purchases, we may collect and use the information you provide on the call.
Marketing. We may use your Personal Information and other information to display ads or communicate with you by email or otherwise to provide you with information we think may be of interest to you. You may opt out of emails by using the opt-out link in an email. Aggregate Data. We may deidentify and aggregate data collected through the Gladskin Service and use it for any purpose. Such information does not identify you individually.
GLADSKIN MAY DISCLOSE YOUR INFORMATION
We may share your information:
- With our third-party service providers
- With other users or social networks, at your direction
- To comply with legal obligations
- To protect and defend our rights and property
- With your permission
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the Gladskin Service, including payment processing vendors.
Displaying to Other Users. The content you post to the Gladskin Service, such as your product reviews, may be displayed on the Gladskin Service to other users. Other users of the Gladskin Service also may be able to see this information, and other information including your name and “Verified Buyer” status. We are not responsible for privacy practices of the other users who will view and use User Content you publicly post.
Social Networking and Other Website Services. The Gladskin Service may allow you to share information, including Personal Information, with third-party services and social networking websites, such as Facebook, Twitter, Instagram, and Youtube. We do not share your Personal Information with them unless you direct the Gladskin Service to share it. Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings on their websites.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect yours’, ours’ or others’ rights, property, or safety.
Third Parties for Their Marketing Purposes. We may also share, sell, and rent your information to other businesses for their business purposes, including to offer or advertise services and products that may interest you as permitted by applicable law. This includes sharing with third parties who directly market products to you, as well as third parties who share your information with others for their marketing purposes.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information. We may also disclose your Personal Information with your permission.
With Your Permission. We may also disclose your information with your permission.
PERSONALIZED ADVERTISING PREFERENCES
We may share your Personal Information with third party marketing companies that use ad networks that rely on your browsing history on websites and other information to show you personalized advertisements as you use the internet. For example, if you browse our skincare products on our site or look at similar products on other sites, we may show you ads as you continue to browse the Internet.
You can opt out of receiving personalized advertisements on your browser or device from advertisers or advertising networks who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations. Links to those sites are here:
Network Advertising Initiative
- Browser Opt-Out: http://www.networkadvertising.org/choices/
Digital Advertising Alliance
- Browser Opt-Out: http://www.aboutads.info/choices/
- Browser Opt-Out: https://adssettings.google.com/
- Browser Opt-Out: http://facebook.com/about/ads
When you opt out of personalized advertising, you may continue to see online advertising on the Gladskin Service and/or our ads on other websites and online services.
You may also be able to opt out of advertisements in other ways, including:
- Opt out through website-specific mechanisms. Some websites, such as Facebook, offer their own opt-out methods. Please refer to the website that you are visiting for additional information.
- Browser-based opt outs. Some internet browsers (e.g., Internet Explorer, Firefox, Chrome) offer their own opt outs for personalized advertising. The ad networks and ad service providers we participate with may not recognize these opt outs.
- Mobile opt outs. Many mobile devices offer their own device-specific opt outs for personalized advertising. Please refer to your device settings and instructions for additional information.
Gladskin uses third-party analytics companies on the Gladskin Service.
- Google Analytics. To learn more about Google Analytics’ privacy practices and any opt-out choices Google offers, click here: https://policies.google.com/privacy.
- Adobe Analytics. To learn more about Adobe Analytics’ privacy practices and any opt-out choices it offers, click here: https://www.adobe.com/privacy.html.
- Facebook. To learn more about Facebook’s privacy practices and any opt-out choices it offers, click here: https://www.facebook.com/privacy/explanation.
SECURITY OF YOUR INFORMATION
By using the Gladskin Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Gladskin Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Gladskin Service or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at firstname.lastname@example.org.
We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Gladskin Service is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.
This site is intended for U.S. users only; if you are visiting from the E.U., please visit us at
https://www.gladskin.com/. By using the Gladskin Service, you will transfer data to the United States.
CALIFORNIA PRIVACY RIGHTS
If you are a minor under 18 and have an account or profile on the Gladskin Service, you may ask us to remove reviews or other content that you posted on any given site by writing to firstname.lastname@example.org. We will begin to process your request within 30 days. After completing the request, we may continue to hold your content and information and such content and information may remain publicly available if your association with the content and information is removed (e.g., we anonymize the post) or another user posted, copied, or re-posted the content and information.
California Shine the Light Law
Under California’s “Shine the Light” law, California residents who provide Personal Information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information shared, the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year, and descriptions of the likely types of marketing the third parties would send.
To obtain this information from us, please send an email message to email@example.com or mail us at the address below with “Request for California Privacy Information” on the subject line and in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
NEVADA PRIVACY RIGHTS
Nevada residents have the right to submit a verified request directing Gladskin not to sell their personal information. If you are a Nevada resident, and would like to submit such a request, please send your request to firstname.lastname@example.org.
LINKS TO THIRD-PARTY WEBSITES
UPDATING YOUR INFORMATION OR POSING A QUESTION OR SUGGESTION
Data Retention. We will retain your information for as long as your account is active or as needed to provide you the Gladskin Service. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Account Deactivation and Deletion. If you no longer desire to use the Gladskin Service, you may deactivate or delete your account by sending us an email to email@example.com. Deactivating your account puts your account on hold and is the same as you telling us not to delete any information because you might want to reactivate your account at some point in the future. When you delete an account, you are requesting that your account and the information stored therein be permanently deleted from the Gladskin Service. You should only delete your account if you are sure you never want to reactivate it. Please note, certain data you have provided may continue to exist in aggregate form that cannot be used to identify you.
Micreos North America, Inc.