PRIVACY POLICY

Last Updated March 15, 2021

Skinary App, Inc. ("Skinary," "we," "us," or "our") is a digital health company that operates a health tracking mobile application that helps users track skin texture, breakouts and flare-ups with a skin diary (the “App”). We are committed to respecting and protecting your privacy. We have adopted this Privacy Policy to inform you how and for what purposes we are collecting, processing, and using your Personal Data (as defined herein). We recommend that you read this Privacy Policy in full, along with our Terms of Use. We will take the steps needed to ensure that your Personal Data and Usage Information will only be used in ways that are in compliance with this Privacy Policy. By using the App, you agree to the collection and use of information in accordance with this policy. 

INFORMATION COLLECTION AND USE

We collect several different types of information for various purposes, including, but not limited to, to provide and improve our App, to personalize our App for you and to communicate with you.

TYPES OF DATA COLLECTED

PERSONAL DATA

While using the App, we may ask you to provide us with certain personally identifiable information that can be used to contact you, identify you and increase accuracy of the information we provide to you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • General Information

    • Email address

    • Gender

    • First name and last name 

    • Zip Code

  • Information related to your skin habits that you provide us through the “diary” including, but not limited to:

    • your skin type, tone, texture, 

    • your diet, 

    • your menstrual cycle, 

    • your sleep habits,

    • your mood, 

    • photos of your face and skin that you upload,

    • your travel habits, and other information that you voluntarily input into the App. 

  • Information you consent to provide to the App through your Apple Health App, Samsung Health, Google Fit, or any similar health tracking app on your cellular device. Such imported Personal data may include: exercise time, workout activities, body fat percentage, mindfulness, and other data about your health. In order for us to process any data under this category we will explicitly ask your consent at registration screen. 

  • Information you consent to provide to the App through your cellular device, including location and access to your camera. You may turn these features on and off at any time. 

 

 

USAGE DATA

We may also collect information on how the App is accessed and used (“Usage Data”). This Usage Data may include information such as your phone’s hardware model, mobile network information, unique device identifiers, IP address, time zone, the pages of our App that you visit, the time and date of your visit, the time spent on those pages, engagement with particular features and other diagnostic data.

TRACKING & COOKIES DATA

We use cookies and similar tracking technologies to track the activity, performance and analytics and important functionality on our App and to hold certain information.

Cookies: From time to time, we may use “cookies” to keep track of your visit and use of the App. A cookie is a small piece of data that your browser stores on your computer’s hard drive and is used to collect information, such as identifying those areas of the App that you have used in the past in order to enhance your next visit to the App. You can choose whether to accept cookies by changing the settings on your cellular device. Each browser is a little different, so look at your Help menu to learn the correct way to modify your cookies.

Unique Identifier: We may assign you a unique internal identifier to help keep track of your future visits. We use this information to gather aggregate demographic information about our visitors, and we use it to personalize the information you see on the App and some of the electronic communications you receive from us. We keep this information for our internal use, and this information is not shared with others.

 

 

USE OF DATA

Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date. We will only retain personal information for as long as necessary for the fulfilment of those purposes.

We use the collected data for various purposes, including, but not limited to:

  • To provide and maintain the App

  • To notify you about changes to our App

  • To allow you to participate in interactive features of our App when you choose to do so

  • To provide customer care and support

  • To provide analysis or valuable information so that we can improve the App

  • To monitor the usage of the App

  • To detect, prevent and address technical issues

  • To improve and develop new features of the App, including artificial intelligence and machine learning

 

STORAGE OF DATA

 

We store the information and Personal Data you share with us on "cloud" servers owned and operated by third party providers. Our current provider is Amazon Web Services (AWS). Our App is designed to encrypt all stored data using encryption algorithms. For information about Amazon Web Service's privacy protection and data security practices, please visit http://aws.amazon.com/security.

 

INFORMATION SHARING

  • Advertising Purposes. We allow our advertising and affiliate partners access to information by placing cookies or our App.

  • Corporate Family. We share information within our corporate family, such as with subsidiaries, joint ventures, or affiliates, in order to carry out our business efficiently and to the extent permitted by law. 

  • Corporate Reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction and such information would be part of the assets sold. We would share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.

  • To Prevent Harm. We will share information if we believe it is necessary to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.

  • Legal Purposes. We will share information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of service or other contracts; to defend against legal claims or demands; or to comply with the requirements of any applicable law.

  • With Your Consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time by writing us at support@skinary.app.  

  • Aggregated information. We may share aggregated, anonymized or de-identified information, which cannot reasonably be used to identify you, with our partners or research institutions. For example, we may share, including, without limitation, in articles, blog posts and scientific publications, general age demographic information and aggregate statistics about certain activities or symptoms from data collected to help identify patterns across users. Sharing such data contributes to the advancement of scientific research on skin health and further develops the artificial intelligence needed to improve the App.

TRANSFER OF DATA

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there. By using the App, you consent to such collection, storage and processing in the United States, though the United States and other jurisdictions may not afford the same level of data protection as considered adequate in your own country. We will take reasonable steps to protect your Personal Data. Note that your Personal Data may be available to the United States government or its agencies under legal process made in the United States.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

SECURITY OF DATA

The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use reasonable means to protect your Personal Data, we cannot guarantee its absolute security. There is always some risk that an unauthorized third party may find a way around our security system.

SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate, administer, operate, host, configure, design, maintain and provide internal support for our App (“Service Providers”), to or to assist us in analyzing how our App is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are contractually obligated not to disclose or use it for any other purpose.

LINKS TO OTHER APPS

Our App may contain links to other Apps that are not operated by us. If you click on a third-party link, you will be directed to that third party’s App. We strongly advise you to review the Privacy Policy of every App you visit to understand how that third party collects and uses your information. You should be aware that any information you disclose to these third parties once you access these third party Apps or websites is not subject to this Privacy Policy.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party Apps, websites or services. Our App does not endorse and is not responsible for the privacy practices of these third parties. 

 

YOUNG USERS

We are committed to protecting the privacy of children. Our App is not intended or designed to attract anyone under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us at support@skinary.app. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

OPT-OUT

You may choose to prevent us from disclosing or using your Personal Data under certain circumstances (“opt out”).  You may opt out of any disclosure or use of your Personal Data for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization by e-mailing us at support@skinary.app or by following the procedures set forth in an electronic communication from us, if applicable.  Furthermore, even where your Personal Data is to be disclosed and used in accordance with the stated purposes in this Privacy Notice, you may elect to opt out of such disclosure to and use by a third party that is not acting as our agent.  There are some uses from which you cannot opt out, such as to provide products, features or services that you have requested from us.

Please note that making such requests does not ensure complete or comprehensive removal of the content. For example, we may retain your de-identified information indefinitely. Simply contact us to exercise any of your privacy rights. We may engage you to better understand the motivation the content and motivation of any request. 

CALIFORNIA RESIDENTS

FOR RESIDENTS OF CALIFORNIA ONLY. Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your Personal Data with third parties. If you reside in California and have provided your Personal Data to us, you may request information about our disclosures of certain categories of Personal Data to third parties for direct marketing purposes in the preceding calendar year. 

 

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change or replace this Privacy Policy at any time and from time to time. We will state the date this Privacy Policy was last updated. We encourage you to review our Privacy Policy on a regular basis. If you do not accept the terms of this Privacy Policy, we ask that you do not register with us and that you exit the App immediately.

GOVERNING LAW

These terms and conditions are governed by and construed in accordance with the laws of New York, and you irrevocably submit to the exclusive jurisdiction of the courts in that State or location.

ACCEPTANCE OF THESE TERMS

By creating a profile or signing up to use the App, you explicitly consent that:

I. WE MAY STORE AND PROCESS YOUR PERSONAL DATA YOU PROVIDE THROUGH THE USAGE OF THE APP AND THROUGH THE ACCOUNT CREATION SOLELY FOR THE PURPOSES INDICATED IN THIS PRIVACY POLICY. SUCH PURPOSES MAY INCLUDE SENDING YOU INFORMATION AND REMINDERS THROUGH THE APP OR TO THE EMAIL ADDRESS.

II. WE WILL NOT TRANSMIT ANY OF YOUR PERSONAL DATA TO THIRD PARTIES UNLESS OTHERWISE IS PROVIDED BY THIS PRIVACY POLICY.

PLEASE NOTE THAT WE WILL NEVER SHARE YOUR EXACT AGE OR ANY DATA RELATED TO YOUR HEALTH AND WELLBEING WITH ANY THIRD PARTIES.

CONTACT US

If you have any questions about this Privacy Policy, the practices of this App, or wish to exercise your rights related to your Personal Data, please contact us at:

Email: support@skinary.app 

 

Effective date: march 25, 2020