Introduction
SkinIO, Inc. (“SkinIO,” “we,” “us,” and “our”) takes your privacy seriously. This Privacy Notice for California Residents (“Notice”) supplements the information contained in SkinIO’s Privacy Policy (the “Privacy Policy”) and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and capitalized terms used in this Notice that are not otherwise defined herein have the same meaning as defined by the CCPA. If you are a California resident, in the event of a conflict between the terms of this Notice and the terms of the Privacy Policy, the terms of this Notice will apply.
Scope
This Notice only applies to you if you are a California resident.
This Notice applies only to Personal Information that we collect, but does not apply to information excluded from the scope of the CCPA. By accessing or using our website, services products and mobile applications (collectively, the “Services”), and/or submitting your information to us, you understand and consent to our collection and use of your Personal Information as described herein. Should SkinIO’s stated use of your information as outlined within this Notice change, or should SkinIO begin to use your information in a manner in which is not outlined in this Notice, we will notify you.
Personal Information We Collect
We may collect Personal Information about you when you provide it to us, when we observe it from your actions or use of the Services, when we to obtain it from third parties (for example, from your employer or health system if they offer you access to the Services as an employee or member), when we obtain it from publicly available sources, or as otherwise described in the Privacy Policy. More information about SkinIO’s specific practices regarding SkinIO’s use of your Personal Information can be found in the Privacy Policy.
We have collected the following categories of Personal Information from our consumers within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
How We May Use Personal Information
We may use the Personal Information we collect for the purposes set forth in the Privacy Policy. Our use of Personal Information may also include specific purposes of which you are apprised at the time of collection.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Right to Know
You have the right to request that we disclose certain information to you about our collection and disclosure of your Personal Information over the past 12 months (subject to certain limitations at law). Once we receive and confirm your verifiable consumer request (see the section labelled “Submitting a Request”), we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of Personal Information that we have disclosed to third parties for a Business Purpose, and the categories of recipients to whom this information was disclosed.
- The specific pieces of Personal Information we collected about you.
How We Share Personal Information
Personal Information we collect may be shared with a third party for a Business Purpose, including service providers. We may share your information with our service providers solely for them to fulfill their obligations to us and on our behalf. Our service providers are not permitted to share, sell or otherwise use your information outside of their relationship with us. More specific information about SkinIO’s sharing of Personal Information can be found in the Privacy Policy.
We may share your Personal Information with the following categories of CCPA third parties:
- Vendors and service providers, including for data analytics and marketing our Services to you.
- Third parties integrated into our Services.
- Third parties as required by law and similar disclosures.
- Third parties in connection with a merger, sale, or asset transfer.
- Other third parties for whom we have obtained your permission to disclose your Personal Information.
In the preceding twelve (12) months, SkinIO has disclosed the following categories of Personal Information for a Business Purpose:
- Category A – Identifiers.
- Category B – California Customer Records personal information categories.
- Category C – Protected classification characteristics under California or federal law.
- Category F – Internet or other similar network activity.
We do not Sell your Personal Information.
Right to Deletion
The CCPA gives you the right to request that we delete Personal Information we have collected from you. In certain circumstances, we may not delete all Personal Information we have collected from you, as permitted under the CCPA. Information on how to submit a request to us is provided below.
Submitting a Request
Please submit your CCPA request by emailing privacy@skinio.com or by calling 1 (855) 754-6400. We will be in contact with you to verify your identity, as required under the CCPA, before any response is provided. In order to verify your identity, we will ask you to provide information that we may have already collected in order to match your identity with the Personal Information we previously obtained. We will make our best efforts to verify your identity or the identity of your agent without requesting additional information that we may not have previously collected. If you are making a request through an authorized agent, we will verify your agent’s identity as well, and the agent’s written authorization from you to act on your behalf. Failure to provide sufficient information to verify an identity will result in our inability to respond to a request.
Nondiscrimination
The CCPA prohibits discriminatory treatment of California residents with respect to exercising your rights under the CCPA.
Contact Us
Please reach out to us with any questions or concerns you may have about this Notice and practices by emailing privacy@skinio.com or by calling 1 (855) 754-6400.
We reserve the right to update this Notice from time to time and without further notice. If we make any material changes to this Notice, we will notify you through a notice on our website. Continued use of our Services following posting of such changes constitutes your acknowledgement of such changes and your agreement to be bound by the changes. If you do not agree, you should immediately discontinue your use of our Services.
