SKINFIX INC. MASTER PRIVACY POLICY
Effective Date: March 27, 2023
We are Skinfix Inc. (referred to in this Policy as "Skinfix" or "we" or "us"), and this Policy describes how we collect, use and disclose the Personal Information of our customers, including Personal Information that has been transferred to or received from a third party. Skinfix is the controller of, and is responsible for, your Personal Information.
From time to time, we may change this Privacy Policy. We will notify you of any material changes to our Privacy Policy by posting an updated copy on our website. Please check our website periodically for updates. This version was last updated on 3/27/23.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
If you are a California or Virginia resident, please see the sections below regarding your rights with respect to your Personal Information. If you are a Canadian resident, please see the Canadian Residents section below for Canadian-specific information.
If you are a resident of the United Kingdom or the EU/EEA, please see our relating to the General Data Protection Regulation ((EU) 2016/679) (“EU GDPR”), the retained version of the EU GDPR in the United Kingdom (“UK”) and the Data Protection Act 2018 (together, the “GDPR”). If there is any inconsistency or conflict between our GDPR Privacy Policy and this Master Privacy Policy, our GDPR Privacy Policy shall prevail.
Personal Information
Personal Information includes any information about an identifiable individual. For Skinfix's purposes, this includes, but is not limited to, name, billing address, shipping address, email address, telephone number, credit card information, and banking information.
Personal Information may include business contact information, such as the name, title, business address, and telephone number of an employee of an organization. Whether such information is Personal Information will depend on where you are resident.
Personal Information also does not include anonymous or aggregated data that can no longer be used to identify a specific person. Our use of Device and Usage Information (see below) may be, for example, to calculate the percentage of users accessing a specific website feature. If we combine or connect such anonymous or aggregated data with other data so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.
Our Collection of Personal Information
We collect Personal Information that you provide directly to us. Whenever Skinfix collects Personal Information, we will disclose the purpose(s) for which we are collecting the information, the manner in which we plan to use the information, and the entities to whom the information will be disclosed – at or before the time we collect the information.
If you register an account with us on the Skinfix website, we collect your email address, as well as your user name and password. If you make a purchase through our website, we will collect your name and address, as well as your email address, so that your order may be fulfilled. For payments made through our website, we use trusted third-party payment processors, outlined below.
We also collect your email address (or mobile phone number) if you choose to subscribe to our newsletter via email or text message. You can unsubscribe from marketing emails or texts at any time by following the unsubscribe link in a message or by contacting us at info@Skinfix.com.
If you leave a review on our website, or reach out to our customer service team, we will also collect Personal Information from you (email, name, and other information required to provide service to you), as described below.
If you fail to provide Personal Information
Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you fail to provide that Personal Information when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
Change of Purpose
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.
Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Retail Partners
You can purchase Skinfix products via our retail partners (e.g., Sephora) across Canada, the United States, and the UK (“Retail Partners”). Please note that when you purchase Skinfix products through a Retail Partner, either online or in one of their stores, you are contracting directly with that Retail Partner and not with us.
The Retail Partner will control any Personal Information you provide to a Retail Partner. You should visit the Retail Partner’s website to review their privacy policy or contact them directly if you have any questions about how they collect, use, and disclose your Personal Information.
Information We Collect Automatically When You Interact with Us
When you access or use our website, we automatically collect certain information that may be Personal Information, including:
Customer Reviews and Testimonials
We utilize Yotpo Ltd. to provide services in connection with supporting customer reviews of our products and services. Yotpo provides our customers with the ability to submit reviews and comment on or rate goods, products, and services on our website and mobile application within the Yotpo Network (collectively, "User-Generated Content"). You should be aware that any information you provide in the area intended to collect such User-Generated Content will be published on a publicly facing website or mobile application and will be read, collected, and used by Yotpo, its subsidiaries, vendors, and clients. To submit User-Generated Content, you may have to create an account with us. As such, your account information may be collected by both Yotpo and Skinfix. For additional information, please see Yotpo’s
Our Use of Personal Information
We may use and disclose your Personal Information, alone or in combination with non-identifying information collected through this website (collectively, "Visitor Data"), to:
Sharing of Information
To perform any of the activities described in this Privacy Policy, we may use third-party service providers or partners with whom we may collaborate, including the following:
When we share your Personal Information with any third-party service provider, we only provide the information they need to perform the service. We have written contracts in place with them to ensure your information is only used as directed by us and that your privacy is secure and respected.
The use, retention, and handling of your Visitor Data may also be governed by the policies and procedures of such third-party service providers.
We may also disclose your Personal Information to comply with a legal or regulatory obligation, protect and defend Skinfix's rights or property, protect the safety of our customers and website users or the public, or to protect against legal liability.
Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will – where required by applicable law – direct the recipient to use your Personal Information in a manner that is consistent with this Policy. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your Personal Information.
You may withdraw consent for the above uses at any time (except towards the use of such information to fulfill Skinfix's legal obligations) by contacting us at the contact information listed below. By withdrawing consent, you may limit our ability to provide certain services to you. The non-identifying information we collect is set out below.
We may also share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you.
Advertising and Analytics
We allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our website and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. Skinfix and others may use this information to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Websites and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit AdChoices.
We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert Personal Information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that third-party platforms may offer you choices about whether you see these types of customized ads.
Retention of Personal Information
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. However, we will take reasonable steps to destroy or permanently anonymize the Personal Information we hold if it is no longer needed for the purposes for which it was collected.
We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
Details of retention periods for different aspects of your Personal Information are available in our retention policy which you can request from us by contacting us.
Safeguarding your Personal Information
The security of your Personal Information is very important to us. We use physical, electronic, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.
In addition, we limit access to your Personal Information to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Information on our instructions, and they are subject to a duty of confidentiality.
When Skinfix transmits any Personal Information to other websites, it is protected through encryption, such as the Secure Sockets Layer (SSL) protocol. While transmission of information via the internet is not completely secure, we believe our measures reduce the likelihood of security problems to a level appropriate to the sensitivity of the data involved.
We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Links to Other Websites
Our website may contain links to, or advertisements about, non-Skinfix websites. Other websites may also reference, advertise, or link to the Skinfix Site. You may be able to post content to third-party Social Networking Sites on which we maintain a presence. If you choose to do this, we will provide information to the Social Networking Site(s) and receive information from them in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the applicable terms of use and privacy policies. We are not responsible for the availability, accuracy, content, products, or services of third-party Social Networking Sites.
While you are using the Skinfix website, you may be linked or directed to other third-party websites that are beyond our control. These third-party websites may have privacy policies and terms of use that differ from ours. Please carefully review these policies. We are not responsible for any actions or policies of such third parties.
Transfer of Information to Other Jurisdictions and Protection of Information
Skinfix is based out of Canada and has service providers in Canada, the United States, and other countries. Therefore, we, and our service providers, may transfer your Personal Information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction.
We will take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it. Please see our jurisdiction-specific privacy policies for more information.
Note that some of our third-party service providers are subject to foreign laws, including laws requiring Personal Information disclosure to government agencies in those countries.
Children
Our website and the services we provide to our customers are not aimed at children. Skinfix customers must be at least the age of majority in their jurisdiction to create an account with us or to sign up for our newsletter. We will not knowingly collect Personal Information from anyone under the age of 13. If you believe that a child under 13 has provided Personal Information to us, please contact us, using the details below. We will delete that information from our systems.
CANADIAN RESIDENTS
If you are a Canadian resident, this section also applies to you.
Consent: By submitting Personal Information to Skinfix, or our service providers and agents, you consent to the collection, use, disclosure, and transfer of your Personal Information in accordance with this Privacy Policy and as permitted or required by law. You may withdraw your consent at any time to the collection, use, disclosure, or transfer of your Personal Information time by contacting Skinfix at the email address provided below. If you withdraw your consent (or if you decide not to provide certain Personal Information), you acknowledge that Skinfix may not be able to provide you or continue to provide you with certain products, services, or information that may be of value to you.
Access and Correction: Skinfix will take reasonable steps to ensure the Personal Information we hold is accurate, complete, and up to date. Upon your written request and subject to certain exceptions provided by law, Skinfix will inform you of your Personal Information's existence, use, and disclosure and give you access to that information. Skinfix may charge a minimal fee for providing such access to you. If you believe that the personal information that Skinfix holds about you is not accurate or complete, you may write to Skinfix at the email address provided below. If you are able to establish that the information is not accurate or complete, Skinfix will take reasonable steps to delete and/or correct the information to be accurate, complete, and up to date. To facilitate a request to correct or update information, Skinfix may ask you to provide additional information to confirm your identity. Any such information will only be used for the purpose of confirming your identity and will not be retained by Skinfix. You can also update your own account information by logging in to your account.
Canada's Anti Spam Law ("CASL"): We will only send you commercial electronic messages ("CEMs") where we have your express or implied consent to do so. Your consent to receive CEMs is implied where we have an existing business relationship with you, or you have reached out to us and made an inquiry within a specific time frame. You may unsubscribe from receiving CEMs at any time by clicking the unsubscribe button on an email or following the direction provided in a text message.
CALIFORNIA RESIDENTS
If you are a California resident, you may have certain rights with respect to your Personal Information, including the following rights:
1) The right to know, by way of our Policy and any specific inquiries you direct to us, where Personal Information we have about you comes from, what we use that information for, whether it is being disclosed or sold, and to whom it is being disclosed or sold;
2) The right to "opt-out" of Skinfix's sale of your Personal Information to any third parties, in the event Skinfix sells data;
3) The right, with some exceptions, to have your Personal Information deleted from Skinfix's possession or control; and
4) The right to receive equal service and pricing from Skinfix even if you exercise any of your privacy rights.
California Civil Code Section 1798.83 permits users of the Site who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. A California resident may also use an authorized agent to submit a right to access request or a request to delete. To make such a request, to learn more, or if you have any questions or concerns about your California privacy rights, please visit the Privacy Notice for California Residents.
VIRGINIA RESIDENTS
If you are a Virginia resident, you may, upon request, have certain rights with respect to your Personal Information, including the following rights:
Skinfix will respond to any of the above requests within forty-five days. Skinfix may extend this deadline once by an additional forty-five days when reasonably necessary, considering the complexity and number of your requests, so long as we inform you of the extension within the initial forty-five-day response period along with the reasons for the extension. All requests pursuant to the above rights should be submitted to
info@skinfix.com
or
PO BOX 2065
Fall River NS B2T 1K6
Canada
If Skinfix declines to take action regarding your request, Skinfix shall inform you within the deadlines discussed above, along with the justification for that decision. Should you choose to, you may appeal the decision not to take action (or to take limited action) by submitting an appeal within fourteen days of receipt of Skinfix's initial response to the following:
or
PO BOX 2065
Fall River NS B2T 1K6
Canada
Within sixty days of receipt of your appeal, Skinfix shall inform you in writing of any action taken or not taken, in response to the appeal, including a written explanation of the reasons for the decisions. If unsatisfied, you may file a complaint with the Virginia Attorney General at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.
COLORADO RESIDENTS
If you are a Colorado resident, you may, upon request, have certain rights with respect to your Personal Information, including the following rights:
Skinfix will respond to any of the above requests within forty-five days. Skinfix may extend this deadline once by an additional forty-five days when reasonably necessary, taking into account the complexity and number of your requests, so long as we inform you of the extension within the initial forty-five-day response period along with the reasons for the extension. All requests pursuant to the above rights should be submitted to:
info@skinfix.com
or
PO BOX 2065
Fall River NS B2T 1K6
Canada
If Skinfix declines to take action regarding your request, Skinfix shall inform you within the deadlines discussed above, along with the justification for that decision. Should you choose to, you may appeal the decision not to take action (or to take limited action) by submitting an appeal within fourteen days of receipt of Skinfix's initial response to the following:
info@skinfix.com
or
PO BOX 2065
Fall River NS B2T 1K6
Canada
Within forty-five days of receipt of your appeal, Skinfix shall inform you in writing of any action taken or not taken, in response to the appeal, including a written explanation of the reasons for the decisions. Skinfix may extend this period by sixty days where reasonably necessary, considering the complexity and number of requests serving as the basis for the appeal. If unsatisfied, you may file a complaint with the Colorado Attorney General at https://coag.gov/file-complaint/.
AUSTRALIAN RESIDENTS
If you are a resident of Australia, Skinfix will process your information in accordance with the Australian Privacy Principles and other applicable territory laws.
If you wish to access Personal Information held by Skinfix or to correct Personal Information held by Skinfix about you, please submit your request to:
info@skinfix.com
Skinfix will respond to your request within twenty (20) days or provide a reason why it cannot respond as requested. If Skinfix declines to take action regarding your request, Skinfix shall inform you within the deadlines discussed above, along with the justification for that decision. Should you choose to, you may appeal the decision not to take action (or to take limited action) by submitting an appeal within fourteen days of receipt of Skinfix's initial response to the following:
info@skinfix.com
Within forty-five days of receipt of your appeal, Skinfix shall inform you in writing of any action taken or not taken, in response to the appeal, including a written explanation of the reasons for the decisions. Skinfix may extend this period by sixty days where reasonably necessary, taking into account the complexity and number of requests serving as the basis for the appeal.
If you wish to make a complaint about a breach of the Australian Privacy Principals or a registered APP code that binds Skinfix, you may submit such a complaint to:
info@skinfix.com
Skinfix will respond to your complaint within forty-five (45) days.
Changes to the Policy
We may change this Policy from time to time and notify you of material changes by posting the changed or modified Policy on our Site. Any changes will be effective immediately upon the posting of the revised Policy unless otherwise specified.
Contact:
If you have any questions, comments, or requests regarding this Privacy Policy, you have a complaint, or you would like to exercise your right to access or correct your Personal Information, as set out above, you can contact us in the following ways:
Skinfix Inc.
1701 Hollis St. Suite 800
Halifax N.S
B3J 3M8
Tel: 902-455-1575
Email: info@Skinfix.com
Cookies
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly.
We use the following cookies on our website:
|
Session Cookie |
When Deleted |
Purpose |
|
ASP.NET_SessionId |
After browsing session |
Manages active browsing session |
|
__cf_bm |
30 min |
Shopify uses Cloudflare Network as a Service for edge routing. |
|
__kla_id |
2 years |
Set by Klaviyo. Used to collect information on the visitor's behaviour. This Information is used for internal analytics and is used to optimize the website. It also register if the visitor has subscribed to news letter. |
|
_fbp |
1 year |
Set by Facebook to deliver advertisement when they are on Facebook or a digital platform powered by Facebook advertising after visiting this website. |
|
_ga |
2 years |
Set by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the Site's analytics report. The cookies store Information anonymously and assign a randomly generated number to identify unique visitors. |
|
_gat |
1 day |
Set by Google Universal Analytics to throttle the request rate to limit the collection of data on high traffic sites. |
|
_gcl_au |
90 days |
Used by Google Analytics to understand user interaction with the website. |
|
_gid |
Session |
Set by Google Analytics. The cookie is used to store Information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visited in an anonymous form. |
|
_landing_page |
2 weeks |
Used to track landing pages (Shopify). |
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_orig_referrer |
2 weeks |
Used to track landing pages (Shopify). |
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_pay_session |
Session |
Used for enabling secure checkout and payment function on the website (Shopify). |
|
_s |
30 min |
Shopify analytics. |
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_shopify_d |
Session |
Shopify analytics. |
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_shopify_evids |
Session |
Shopify analytics. |
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_shopify_s |
30 min |
Shopify analytics. |
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_shopify_sa_p |
30 min |
Shopify analytics relating to marketing & referrals. |
|
_shopify_sa_t |
30 min |
Shopify analytics relating to marketing & referrals. |
|
_shopify_y |
1 year |
Shopify analytics. |
|
_y |
1 year |
Shopify analytics. |
|
cart_currency |
2 weeks |
An essential cookie for the secure checkout and payment function on the website (Shopify). |
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cto_bundle |
1 year |
Set by Criteo. Collects visitor behavior to display more relevant ads. |
|
currency |
2 weeks |
Used to store the currency preference of the user. |
|
KL_FORMS_MODAL |
30 min |
Set by Klaviyo for newsletter sign up forms. |
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mp_a6c0abcb7b5e56fdacf7220338c4ae0c_mixpanel |
1 year |
Set by Mixpanel, used for analytics. |
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secure_customer_sig |
2 years |
Used in connection with customer login for Shopify. |
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shopify_pay_redirect |
1 year |
Used in enabling secure payment and checkout from the e-commerce store (Shopify). |
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swym-cu_ct |
1 year |
Set by Swym for Back in Stock Product Alerts. |
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swym-email |
1 year |
Set by Swym for Back in Stock Product Alerts. |
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swym-o_s |
30 min |
Set by Swym for Back in Stock Product Alerts. |
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swym-pid |
1 year |
Set by Swym for Back in Stock Product Alerts. |
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swym-session-id |
Session |
Used for separating the users from each other. It expires when the session ends. |
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swym-swymRegid |
1 year |
Set by Swym for Back in Stock Product Alerts. |
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test_cookie |
1 year |
Set by doubleclick.net. The purpose of the cookie is to determine if the user's browser supports cookies. |
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uid |
Session |
Set by Criteo. Used to measure the number and behavior of the visitors to the website anonymously. The data includes the number of visits, average duration of the visit on the website, pages visited, etc. for the purpose of better understanding user preferences for targeted advertisements. |
