Gladskin US Privacy Notice

Last revised date:  November 14, 2024

This Privacy Notice for Micreos North America (Gladskin) (“Gladskin”, "we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services (collectively, "Services"), including when you:

• Visit our website at gladskin.com;
• Purchase our products;
• Create an account;
• Communicate with us;
• Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using our Table of Contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources.

How do we process your information? We process your information to provide, improve, and administer our Services, process and fulfill purchases, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We utilize reasonable organizational and technical processes and procedures to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us at privacy@gladskin.com. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

1. What information do we collect?
2. How do we process your information?
3. When and with whom do we share your personal information?
4. Do we use cookies and other tracking technologies?
5. How long do we keep your information?
6. How do we keep your information safe?
7. Do we collect information from minors?
8. Your Privacy Rights and Choices
9. California Disclosures
10. International Users
11. Text Messaging Program
12. Do we make updates to this Privacy Notice?
13. How can you contact us about this Privacy Notice?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us, including when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, purchase our products or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• mailing addresses
• usernames
• passwords
• contact preferences
• contact or authentication data
• billing addresses
• debit/credit card numbers
• skin condition information

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. We utilize third party payment processors to process payments.

You may choose to subscribe for recurring purchases in which case we will process your payment information on a recurring basis. You may make changes to your subscriptions through your customer account profile.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Contact and Conversation Data. We collect the information that you provide to us when you contact us by email, telephone, chat or through a contact form. We use this information to respond to your queries and fulfill our customers’ requests. From time to time our interactions with you will be conducted over the telephone or videoconference, and such telephone calls and video conferences may be recorded.  The conversations may be stored in a customer relations management platform and used by Gladskin and its service providers.

Use of the website’s chat feature is completely voluntary. Chat sessions are recorded and stored in a customer relations management platform and used by Gladskin and its chat service provider. We may use or disclose the chat session information in accordance with this Privacy Notice. If you do not consent to these terms, please do not use the chat feature and contact us via email. We may now or in the future provide customer support via a chatbot or email that utilizes artificial intelligence (AI) and natural language processing (NLP) to understand customer questions and automate responses to them, simulating human conversation.

Skin Condition Data. The Services offer a “Skin Quiz” which elicits information about your skin conditions. We use this data to offer recommendations for products that may be beneficial for you. Taking the quiz and providing skin condition information is entirely optional.

Surveys and Contests. From time to time we may offer surveys and contents. We collect the information you provide if you choose to participate. Furthermore, we may occasionally sponsor a contest or conduct a poll where, in order to participate, users must enter personal information, including name, phone number and address. We will collect and process this information in furtherance of our users’ desire to participate in such contests and polls. Occasionally, we may conduct a contest or poll through one of our third-party marketing agencies. In such cases, the collection and processing of participants’ personal information will be done by such third parties and subject to such third parties’ own privacy policies.

User Content: We process user-generated information that you provide to us in connection with survey responses, comments, reviews, questions, and suggestions.

Financial Incentives: Gladskin has implemented a loyalty program to reward its repeat customers. We may adjust the terms of participation from time to time. You may also receive a gift when you sign up to receive email communications from us. You may choose to provide your birth day and month to receive a discount or reward on your birthday. Our collection of certain personal information about you allows us to operate the loyalty programs. Any gifts or discounts that are offered as a result of your signing up for our loyalty program or subscribing for email communications are based upon our reasonable determination of the value that we receive from collecting and retaining personal information about you in connection with operating our business. The estimated value considers a variety of factors, including, without limitation, our expenses incurred in collecting and processing the information, our expenses incurred in providing rewards to you, and the estimated marginal increase in revenue that we may derive from information related to a specific loyalty program participant.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services. Please see Section 4 below regarding our use of cookies and similar technologies.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your name or contact information, but it may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in Section 4 below.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information see Section 4 below.
• Contest and Surveys. To conduct contests and surveys and communicate with you for research purposes.
• To post testimonials. We post testimonials on our Services that may contain personal information.
• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• Enforce our Rights. To protect and defend our rights and property as well as the rights of our users, affiliates, and third parties.
• Compliance. To comply with legal obligations and regulations to which we and its affiliates are subject and cooperate with regulators, other appropriate agencies or authorities and law enforcement bodies, both within your jurisdiction and internationally.
• Pursuant to Agreements. For other purposes that we tell you about when you register or provide data about yourself to us.
• Legitimate interest. For other legitimate business and lawful purposes.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with third parties who provide services on our behalf.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information.

The categories of third parties we may share personal information with include technology providers, payment processors, email providers, advertising platforms, order fulfillment service providers, delivery companies, and professional advisors.

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale, reorganization, joint venture, assignment, transfer, liquidation or other disposition of company assets, financing, or acquisition of all or a portion of our business to another company.
• We may share your information with our affiliates. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Compliance with law. We may disclose information (within or outside your country of residence) if we have a good faith belief that disclosure is necessary by law or the legal process, to protect and defend our or others’ interests or property, or to enforce agreements you enter into with us.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We may use tracking pixels (clear GIFs or pixel tags) that are embedded on a page of a website or in communications such as email messages. These technologies help us verify when a certain page of a website is viewed, when a message or advertisement is opened, when links are clicked and other content in a message is viewed, and the originating source of a click or view.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

We utilize Google Analytics (GA4) and may share your information with Google to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

We operate social media pages on third party networks and have social media icons on our website. When you visit or link to our social media pages, data is processed both by us and the applicable social media provider. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers.  Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms.

If you would like to opt-out of accepting cookies altogether, you can generally set your browser to not accept cookies or to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. However, certain features of our Services may not work if you delete or disable cookies. While you are free to decline cookies, doing so may prevent you from taking full advantage of the features of our Services.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will store your personal information and isolate it from any further processing until deletion is possible.

Notwithstanding the generality of the foregoing, we store email addresses and the associated user profile (which includes order history) for marketing purposes until the user requests to have their information deleted from our systems.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we use commercially reasonable efforts to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 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 may have collected from children under age 18, please contact us at privacy@gladskin.com.

8. YOUR PRIVACY RIGHTS AND CHOICES

In Short:  You may review and change certain information contained in your profile, and you terminate your account at any time. We will do our best to honor the privacy rights of your jurisdiction of residence.

Privacy Rights: We are committed to facilitating the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale or sharing of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations.  If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at privacy@gladskin.com.

How to Exercise Your Rights: To exercise these rights, you can contact us by emailing us at privacy@gladskin.com. 

Request Verification: Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals: Under certain US state data protection laws, you may have the right to appeal our decision if we decline to take action regarding your request.  Please email us at privacy@gladskin.com to submit an appeal. We will 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 your appeal is denied, you may submit a complaint to your state attorney general.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us at privacy@gladskin.com. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting us at privacy@gladskin.com. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information: You may delete your account at any time. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

9. CALIFORNIA DISCLOSURES

Do-Not-Track: Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. We do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If we become subject to a law or regulation that requires us to recognize a standard for online tracking (such as Global Privacy Control) in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California "Shine The Light" Law: California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request to us by email to privacy@gladskin.com with “California Shine The Light Rights” in the subject line.

California Consumer Privacy Act: At this time, Gladskin is not a “business” subject to the California Consumer Privacy Act.

10. INTERNATIONAL USERS

The Services are hosted and operated in the United States and are intended for and directed to users in the United States. If you are a user accessing the Services from the European Union, please visit our website at www.gladskin.eu. Please be advised that through your continued use of the Services, which are governed by U.S. law, this notice and our other policies that govern your use of the Services, you are transferring your personal information to the United States and you consent to that transfer. The Services are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than those of the United States. Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers and, by using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

11. TEXT MESSAGING

By consenting to Gladskin’s SMS/text messaging program (the “SMS Program”), you agree to receive recurring SMS/text messages from and on behalf of Gladskin through your wireless provider to the mobile number you provided, even if your mobile number is registered on any state or federal Do Not Call list. Text messages may be sent using an automatic telephone dialing system or other technology. Service-related messages may include updates, alerts, and information (e.g., order updates, account alerts, etc.). Promotional messages may include promotions, specials, and other marketing offers (e.g., cart reminders). These messages may use information automatically collected based on your actions while using our Services and may prompt messaging such as cart abandon messages. To the extent you voluntarily opt to have notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number and when you read a text message. 

You understand that you do not have to sign up for the SMS Program in order to make any purchases, and your consent is not a condition of any purchase with Gladskin. Your participation in the SMS Program is completely voluntary.

You may opt-out of the SMS Program at any time. Text the single keyword command STOP in reply (to +18447212566) or click the unsubscribe link (where available) in any text message to cancel. You'll receive a one-time opt-out confirmation text message. No further messages will be sent to your mobile device, unless initiated by you. If you have subscribed to other Gladskin mobile message programs and wish to cancel, except where applicable law requires otherwise, you will need to opt out separately from those programs by following the instructions provided in their respective mobile terms. For text messaging support or assistance, text HELP in reply (to +18447212566) or email hello@gladskin.com.

If you opt-in to the SMS Program, we will use information you provide through the SMS Program to transmit your mobile messages and respond to you, if necessary. This includes sharing information with platform providers, phone companies, and other third-party service providers who assist us in the delivery of mobile messages.  As with all information we collect, we reserve the right at all times, to the extent permitted by law, to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect our rights or property.

12. DO WE MAKE UPDATES TO THIS PRIVACY NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws and to reflect any changes in our data handling practices.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated revised date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?

If you have questions or comments about this notice, please email us at privacy@gladskin.com.

14. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?