SkinIO's Privacy Policy
Effective Date: February 22, 2021
This Privacy Policy (“Privacy Policy”) describes the information that SkinIO, Inc. (“SkinIO,” “we,” “us” or “our”) collects, uses, shares, and stores, including personal information (i.e., information that personally identifies you, such as your name, email address or contact information, or other data that can be reasonably used to infer this information) specifically in connection with the operation and use of SkinIO’s websites, including skinio.com, services, products and mobile apps (collectively, the “Services”). Please carefully review this Privacy Policy and our Terms of Service available at www.skinio.com/terms (the “Terms of Service”). Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as terms defined in our Terms of Service.
BY USING THE SERVICES, YOU AGREE TO ALLOW US TO COLLECT AND PROCESS INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. YOU CAN CHOOSE NOT TO PROVIDE CERTAIN INFORMATION. IF YOU CHOOSE NOT TO PROVIDE SUCH INFORMATION, HOWEVER, YOU MIGHT NOT BE ABLE TO USE OR TAKE ADVANTAGE OF MANY OF OUR SERVICES.
(a) “Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. In this Privacy Policy, we do not include Protected Health Information (defined below) in the definition of “Personal Information” because Protected Health Information has different treatment under HIPAA and other applicable laws.
(b) “Protected Health Information” is personally identifiable health information that is protected by the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”).
(c) For certain information provided to us through some of Services, we have entered into agreements with our clients (including, but not limited to, healthcare providers, health systems, employers, etc., “Clients”) that govern our use of such information (the “Transaction Documents”). This Privacy Policy supplements the Transaction Documents. To be clear, if you are a patient, member, employee of a Client, a visitor to one of our Sites, or otherwise accessing or interacting with any of the Services but are not doing so as a customer of ours under a Transaction Document, you are a user but not a customer of the Services (i.e., not a Client), and some of the terms of this Privacy Policy won’t apply to you. Additionally, if you are a patient, member, employee or other user of a Client, this Privacy Policy does not govern our use of Protected Health Information provided to us through the Services. Our use of such Protected Health Information is governed by the Transaction Documents with such Client and applicable law, including without limitation HIPAA. If you have questions related to the processing of Protected Health Information under a Transaction Document, please contact SkinIO.
We receive and store any information (i) you provide when you create an Account (as defined in the Terms of Service) and/or when you use the Services, and (ii)a Client provides pursuant to a Transaction Document with SkinIO to provide certain Services to the extent such information is required in order to enable your use of such services. Examples of information we collect are:
(a) Registration Information. When you create an Account, we will collect personal information, which may include your name, address, telephone number, email address, and healthcare provider affiliation. A Client may also provide the same or similar information so that we can invite you to participate in the Services. We collect this information to identify you, provide you access to certain Services, and communicate with you.
(b) User Content. Some of our Services may allow you to create, post or upload content, such as data, text, photographs, graphics, messages, or other materials that you create or provide to us (“User Content”), which may include information about yourself.
(c) Device and Internet Information. When using the Services, we and our third-party service providers may use cookies and similar technologies (such as web beacons, tags, scripts and device identifiers) to collect your browsing history, search history, and the IP address, geolocation, and identification number of the device that you use to access the Services. We collect this information to enable and personalize your online experience. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited.
(d) Customer Service. When you correspond with us about the Services, we collect information to: track and respond to your inquiry; investigate any breach of the Terms of Service, this Privacy Policy or applicable laws or regulations; and analyze and improve our Services.
(e) Protected Health Information. We collect your Protected Health Information that either you or your healthcare provider(s) submit, transmit or upload through the Services.
(a) In addition to the purposes for which we collect your Personal Information and Protected Health Information listed in Section 2 above, we may use your Personal Information and/or Protected Health Information for the following purposes, except as prohibited by applicable Transaction Document:
i. To provide you with the Services, create and maintain your Account, communicate with you, and provide other features and functionality to you.
ii. To personalize the Services, including to remember your preferences, provide personalized content and information, and track your use of the Services.
iii. To market to you, including to send you marketing messages and other Services-related communications, or to ask you to participate in surveys about your use or experience with the Services.
iv. To improve and further develop the Services, including to perform quality control activities, help us build new products, and improve the existing Services.
v. To provide customer support, including to answer your questions, resolve disputes, and/or investigate and troubleshoot problems or complaints.
vi. To enforce our rights and for other legal purposes, including to provide you with legally required notices, to enforce our Terms of Service, or to alert you to changes in our policies or agreements that may affect your use of the Services.
(b) Aggregate Information. We may also use information collected from you or the Services in a non-personally identifiable or aggregate form to help us improve the Services, make sales, marketing, and business decisions. This information is not Personal Information or Protected Health Information because it does not identify you or any particular individual or disclose your or any particular individual’s data.
(c) We may use third-party service providers to perform some of these functions. Those service providers are restricted from sharing your Personal Information or Protected Health Information for any other purpose.
(a) Under no circumstance will we share your Personal Information or Protected Health Information for any commercial or marketing purpose unrelated to the Services without your prior permission. We will not rent or sell our customer lists that include your Personal Information without your prior permission. We may share your Personal Information or Protected Health Information (i) for the reasons we tell (a) you when we collect it or (b) in a Transaction Document, or (ii) in the following ways:
i. With Your Consent. We may share Personal Information and Protected Health Information when we have your consent.
ii. At Your Direction. We may share your Personal Information and Protected Health Information with third parties when you direct us to. For example, if you request that we share your Personal Information and/or Protected Health Information with a designated healthcare provider, we will share your information with that healthcare provider.
iii. For External Processing. We may engage contractors, service providers, and third-party technicians (collectively, the “Subcontractors”) to assist us with some of the data processing, storage and use described in this Privacy Policy, including to help answer your questions. Our Subcontractors may include marketing, operations, and technology vendors. These Subcontractors may also assist with monitoring our servers (including third-party servers used by SkinIO) for technical problems. These Subcontractors (as well as SkinIO’s employees) may be given access to certain Personal Information about you or your Account if necessary to provide those services. In no event will these Subcontractors be allowed to use this data for purposes not permitted under this Privacy Policy or the Terms of Service.
iv. As Part of Business Transitions. If SkinIO participates in the sale or transfer of SkinIO business and/or all or part of its assets, your Personal Information and Protected Health Information may be among the items sold or transferred. We will require that any purchaser treat our data in accordance with this Privacy Policy and any Transaction Document.
v. For Legal Reasons. We will share Personal Information and/or Personal Health Information with third parties if we have a good faith belief that access, use, preservation or disclosure of the information is required by SkinIO to (i) comply with any applicable law, regulation, legal process or enforceable government request; (ii) enforce SkinIO’s policies (including the Terms of Service) or contracts, including in connection with the investigation of potential violations; (iii) detect, prevent or otherwise address fraud, security or technical issues; (iv) lawfully protect the rights, property or safety of SkinIO, our customers and users of the Services or the public.
(b) Aggregate Information. We may share non-personal information (for example, aggregated or anonymized customer data) publicly and with our partners. We will take steps to ensure that this non-personal information does not identify you, and we require any of our partners who have access to that non-personal information to do the same.
We use industry-standard methods and procedures to keep your Personal Information and Protected Health Information safe and secure when it is transmitted over your home network and through the Internet to the SkinIO’s servers, including any third-party servers utilized by SkinIO, where your information is processed. Unfortunately, the Internet and any technical system cannot be guaranteed to be 100% secure or error-free, and we cannot ensure or warrant the security of any information you transmit to us via the Internet. The transmission of such information is entirely at your own risk.
The Services are intended for use only in the United States of America. All information collected by the Services will be processed in and subject to the laws of the United States. If you are not located in the United States, such laws may not provide the same level of protection for your Personal Information and Protected Health Information as those in your home country. By using the Services and providing us your Personal Information and Protected Health Information, you consent to the transfer of your Personal Information and Protected Health Information to, and processing of your Personal Information and Protected Health Information in, the United States.
(a) Generally.
i. SkinIO generally stores your Personal Information and Protected Health Information (including personal information provided when creating an Account) on SkinIO’s and/or SkinIO-designated third-party servers until you choose to edit or delete such information. In addition, except as otherwise prohibited by law, SkinIO may store your Personal Information and Protected Health Information in order to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws as provided in this Privacy Policy.
ii. You can access, edit or update your Personal Information from these servers through the controls in your Account.
iii. If you no longer wish to participate in our Services, or no longer wish to have your Personal Information and Protected Health Information be processed, you may delete your Personal Information and Protected Health Information by emailing privacy@skinio.com. Once you submit your request, we will send an email to the email address linked to your Account requesting that you confirm your deletion request. Once you confirm your request, this process cannot be cancelled, undone, withdrawn, or reversed. Once you confirm your request, your Personal Information and Protected Health Information will be deleted, subject to the limitations set forth in Section 7(a)(i).
Cookie Policy.
We use both session and persistent cookies on our website to improve your online experience. Session cookies are stored on your device during a single visit to the website, and they are deleted as soon as you close your browser. Persistent cookies remain on your device until they expire or you choose to delete them from your browser cache, and they are reactivated each time you visit the website that created them.
(a) Cookie Use. We may use cookies for the following purposes:
i. Authentication. To keep you secure while you are logged in and to help ensure that (i) your password works, (ii) that you stay logged in when you move between pages on the website, and (iii) the website looks consistent during your visit.
ii. Analytics. To collect information about how you use our website, such as which pages you visit and if you experience any errors. These cookies collect only aggregate information and we use them to improve how our website works, and measure how effective our content is.
iii. Marketing. To measure how you interact with our marketing communications to determine, among other things, how effective a marketing campaign is.
(b) Similar Technologies. We may use other similar data collection technologies (like web beacons, flash cookies, or pixels) to track how you use our Services and to help us manage content on our Services by informing us what content is effective.
(c) Managing Cookies. You can manage and block cookies by adjusting the settings in your web browser. Each browser works differently, so please refer to your browser’s help menu. Unless you have adjusted your browser settings, our system will issue cookies as soon as you visit our Sites. Please note that if you set your browser to block cookies, either immediately or at a later time, you may not be able to access secure areas of the Services and other parts of the Services may also not work properly or may be limited.
(d) Internet-based Advertising. We may use cookies to deliver content and advertisements specific to your interests and online behavior. These advertisements may appear on our website or elsewhere on the Internet. We may also allow third-party advertisers that are presenting advertisements for us to set and access their cookies, pixels, tags, and scripts on your computer. The advertisers’ use of cookies and these other technologies is subject to their own privacy policies.
Third-Party Websites and Services.
When using the Services you may come across links or references to third-party websites and services that we do not operate or control. If you provide your Personal Information or Protected Health Information to that third party through its websites or services, you will be subject to that third party’s privacy practices and policies and terms of use. This Privacy Policy solely applies to Personal Information and Protected Health Information collected by SkinIO. Except as specifically indicated, SkinIO does not review or endorse those third parties, and is not responsible for the privacy practices of these third-party organizations.
Minors.
None of the Services are designed for, intended to attract, or directed toward children under the age of eighteen (18). By using the Services, you represent that you are at least eighteen (18). If we learn that personal information from users less than eighteen (18) years of age has been collected, we will deactivate the Account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age eighteen (18), please contact us at privacy@skinio.com.
California Requirements.
If you are a California resident, the California Consumer Privacy Act (CCPA) may provide you with additional rights regarding our use of your information. To learn more about your rights under the CCPA, visit our CCPA Privacy Notice at www.skinio.com/ccpa.
Policy Changes.
Please note that this Privacy Policy may change from time to time. When we make material changes to this Privacy Policy, we will give you notice by posting an alert through the Services or by sending you an email to the email address we have on file.
171 N Aberdeen St. Suite 400
Chicago, IL 60607
privacy@skinio.com
+1 855 754 6400