Date: January 31, 2025
Introduction
Your use of the Site and the Service provided by Skin from Within Wellness LLC (“LLC”) are subject to this Privacy Policy unless specifically stated otherwise. Capitalized terms not otherwise defined in this Privacy Policy have the same meaning as set forth in LLC’s Terms and Conditions of Use and Service found on this Site.
By using this Site and/or accepting the Service provided by LLC, You are acknowledging the most recent version of this Privacy Policy. LLC will update this Privacy Policy if necessary. If LLC makes any changes to the Privacy Policy, LLC will post the revised Privacy Policy and update the “Last updated” date at the top of the Privacy Policy.
If You are using the Service on behalf of an individual other than Yourself, You represent that You are authorized by such an individual to act on such an individual's behalf and that such individual acknowledges the practices and policies outlined in this Privacy Policy.
Limitations on Use by Minors
The Service is generally intended for individuals who are at least eighteen (18) years of age or such older age as may be required by applicable state law. Individuals who are below the age of eighteen (18) years (or such older age of majority) may use the Service if a parent or legal guardian provides consent to such use in accordance with the requirements set forth in our Terms and Conditions and the Service.
The Service and Site is not designed or intended to attract, and is not directed to, children under eighteen (18) years of age. If LLC obtains actual knowledge that LLC has collected personal information through the Site from a person under eighteen (18) years of age, LLC will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form.
Furthermore, if You are under eighteen (18) years of age, then You or Your parent or legal may at any time request that LLC removes content or information about You that is posted on the Site. Please submit any such request (“Request for Removal of Minor Information”) to LLC.
For each Request for Removal of Minor Information, please state “Removal of Minor Information” in the email or letter subject line, and clearly state the following in the body of the request:
•The nature of Your request
•The identity of the content or information to be removed
•The location of the content or information on the Site (e.g. by providing the URL)
•That the request is related to the "Removal of Minor Information"
•Your name, street address, city, state, zip code and email address, and whether You prefer to receive a response to your request by mail or email
LLC will not accept any Request for Removal of Minor Information via telephone or facsimile. LLC is not responsible for failing to comply with any Request for Removal of Minor Information that is incomplete, incorrectly labeled or incorrectly sent.
LLC is not required to erase or otherwise eliminate, or enable erasure or elimination of such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule or regulation requires LLC to maintain the content or information;; when the content or information is stored on or posted to the Site by a third party other than You (including any content or information posted by You that was stored, republished or reposted by the third party); when LLC anonymizes the content or information, so that You cannot be individually identified; when You do not follow the aforementioned instructions for requesting the removal of the content or information.
The foregoing is a description of LLC’s voluntary practices concerning the collection of personal information through the Service from certain minors, and is not intended to be an admission that LLC is subject to the Children’s Online Privacy Protection Act, the Federal Trade Commission’s Children’s Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.
Protected Information
When You access the Site or use the Service provided by LLC, You may provide information to LLC, including but not limited to, Your name, email address, address, phone number and certain transactional information, which LLC does not consider to be “protected health information” or “medical information.”
You may provide certain health or medical information that may be protected under applicable laws. LLC is not a “covered entity” under the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations and amendments from time to time (collectively, “HIPAA”). Information provided by LLC may include a third party that may or may not be a “covered entity” or “business associate” under HIPAA. As stated in the Terms and Conditions of Use, You agree that no relationship is created between LLC and said third party because LLC provided You information about that third party. It is important to note that HIPAA does not necessarily apply to an entity or person simply because there is health information involved, and HIPAA may not apply to Your transactions or communications with LLC. To the extent LLC may be deemed a “business associate”, however, and solely in its role as a business associate, -LLC, may be subject to certain provisions of HIPAA with respect to “protected health information,” as defined under HIPAA, that You provide to LLC (“PHI”). In addition, any medical or health information that You provide that is subject to specific protections under applicable state laws (collectively, with PHI, “Protected Information”), will be used and disclosed only in accordance with such applicable laws. However, any information that does not constitute Protected Information under applicable laws may be used or disclosed in any manner permitted under this Privacy Policy. Protected Information does not include information that has been de-identified in accordance with applicable laws.
By accessing the Site or using any part of the Service provided by LLC, You acknowledge and agree that any information that You submit to LLC, including medical or health information, is not intended to be used to treat or diagnose any medical condition. Please refer to the Terms and Conditions of Use describing in further detail the limitations of the Service provided by LLC. Such information is thus not considered Protected Information, and will be subject only to this Privacy Policy and any applicable state laws that govern the privacy and security of such information. For purposes of clarity, information You provide to LLC to register and set up an account on the Site, including name, date of birth, username, email address, address, and phone number, are not considered Protected Information.
Collection of Personal InformationLLC may collect personal information You provide to us. For example:
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Name and contact information, such as Your name, email address, phone number, and billing and physical addresses.
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Demographic data, such as Your gender, date of birth and zip code.
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Payment information, such as Your credit card number, financial account information, and other payment details.
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Content and files, such as photographs, videos, documents, and other files You upload to the Site. This includes email messages and other communications You send to us.
Sensitive personal information:
o
Government ID. LLC may collect government-issued identifiers such as driver’s license or passport number.
oAccount access information. LLC collects information such as a username or account number in combination with a password, security or access code, or other credential that allows access to your account.
oSensitive demographic data. You may provide information concerning racial or ethnic origin.
oContents of communications. LLC collects the contents of communications that You make via the Site.
oBiometric information. LLC may use biometric information to verify Your identity prior to your use of the Site and Service.
oHealth data. You may provide information concerning Your health, sex life, sexual orientation.
LLC does not collect such Sensitive Data as Your religious or philosophical beliefs, political opinions, trade union membership, or information about criminal convictions and offences.
Where LLC is required to collect personal data by law, or under the terms of the Agreement and You do not provide LLC with that data when requested, LLC may not be able to perform the Agreementt (for example, to deliver goods or services to You). If You do not provide LLC with the requested information, , then LLC may in its sole discretion terminate the Agreement. Please see the Terms and Conditions of Use and Service for a description of LLC’s rights to terminate the Agreement.
Information we collect automatically. When You access the Site, LLC may collect some information automatically. For example:
•Identifiers and device information. When You visit the Site, the web servers automatically log Your Internet Protocol (IP) address and information about Your device, including device identifiers (such as MAC address); device type; and Your device’s operating system, browser, and other software including type, version, language, settings, and configuration. The Site stores and retrieves cookie identifiers, mobile IDs, and other data.
•Geolocation data. Depending on Your device and app settings, LLC may collect geolocation data when You use the Site.
•Usage data. Your activity on Site including the URL of the website from which You came to the Site, pages you viewed, how long You spent on a page, access times, and other details about Your use of and actions on our site. In some instances, such usage data may be sensitive personal information if it relates to Your browsing activity on health-related pages on the Service.
We may collect and process your personal data in different ways as provided above as well as:Communication Data that includes any communication that You send to us whether that be through the contact form on the Site, through email, text, social media messaging, social media posting or any other communication that You send us.
Customer Data that includes data relating to any purchases of goods and/or services such as Your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details.
User Data that includes data about how You use the Site and any online services together with any data that You post for publication on the Sitee or through other online services. This may include product, content, files, courses, quizzes, surveys or any other content You upload to or create on the Site.
Technical Data that includes data about Your use of our website and online services such as Your IP address, Your login data, details about Your browser, length of visit to pages on the Site, page views and navigation paths, details about the number of times You use the Site, time zone settings and other technology on the devices You use to access the Site. The source of this data is from LLC’s analytics tracking system.
Marketing Data that includes data about Your preferences in receiving marketing from LLC and LLC’s third parties and Your communication preferences.
LLC may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to You (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising LLC serves You.
Other Information Collected
LLC may collect information about You by You providing the information directly to LLC (for example by filling in forms on the Site or by sending LLC emails). LLC may automatically collect certain information from You as You use the Site by using cookies and similar technologies.
LLC may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment such as Stripe and Paypal and delivery services, such as data brokers or aggregators.
LLC may also receive data from publicly available sources such as European Commision EU VAT database.
Third parties or publicly available sources
LLC may receive personal information about You from various third parties and public sources as set out below. When a Third Party Service is enabled, LLC is authorized to connect and access Other Information made available to LLC in accordance with LLC’s agreement with the Third Party Provider. LLC does not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services. Third party integrations may include
Zapier.com : Integrations, Automation
MailChimp.com : Mailing Service
Google.com : Analytics, reCAPTCHA
DigitalOfficePro.com : PowerPoint to HTML5 Technology
SlideServe.com , SlideOrbit.com : Slide Hosting Service
Facebook.com : Facebook Login, Meta Pixel Segment.io : Customer Data Management
Use of InformationGenerally, LLC does not rely on consent as a legal ground for processing your personal information. When You are asked to provide personal information, You may decline. You may use web browser or operating system controls to prevent certain types of automatic data collection. But if You choose not to provide or allow information that is necessary for the Service or Your use of the Site, then LLC may in its sole discretion terminate the Agreement. Please see the Terms and Conditions of Use and Service for a description of LLC’s rights to terminate the Agreement.
Use of Personal InformationLLC uses the personal information You provide for purposes described in this Privacy Policy or as otherwise disclosed to You, subject to the limitations addressed in the “Protected Information” section above. For example, LLC may use personal information for the following purposes:
In general, LLC will only use Your personal information when legally permitted. The most common uses of Your personal information are:
Where LLC needs to perform the Agreement.
Where LLC needs to process data in accordance with Your instructions.
Where it is necessary for LLC’s legitimate interests (or those of a third party) and Your interests and fundamental rights do not override those interests.
Where LLC needs to comply with a legal or regulatory obligation
Purpose of Use
Product and service delivery. To provide and deliver the Service, including troubleshooting, facilitating Your movement through the Site, confirming Your location, improving, and personalizing those services.
Business operations. To operate LLC’s business, such as billing, processing Your payments, accounting, administering Your account, improving internal operations, securing LLC’s systems, detecting fraudulent or illegal activity, verifying your identity, and meeting LLC’s legal obligations. Additionally, to protect or enforce LLCs’ rights and properties.
Product improvement, development, and research. To develop, test, or improve the Service and Site.
Personalization. To understand You and Your preferences to provide the Service.
Customer support. To provide customer support, fulfill Your requests, and respond to your questions.
Communications. To send you information about LLC including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages. Additionally, to communicate with You by letter, email, text, telephone, or other forms of communication.
Marketing. To communicate with You about new services, offers, promotions, rewards, contests, upcoming events, and other information about LLC’s services.
Advertising. To promote and market LLC and/or services offered via the Service.
Categories of Personal Information
Contact information, demographic data, payment information, content and files, biometric information, identifiers and device information, geolocation data, usage data, inferences. Sensitive information: government ID, account access information, sensitive demographic data, contents of communications, biometric information for identification, health data.
Sensitive information: health data, * Contact information, demographic data, identifiers and device information, geolocation data, usage data, inferences. Sensitive information: health data, information about sex life or sexual orientation.
Disclosure of Personal Information
LLC may disclose personal information with Your consent or as LLC determines is necessary to complete Your transactions or provide the Services You have requested or authorized. Subject to the limitations described in the “Protected Health” section above, LLC may disclose each of the categories of personal information described above, to the types of third parties described below, in connection with the provision of the Service or as otherwise permitted or required by law. For example, LLC may disclose information about You to:
•Service providers. LLC may provide personal information to vendors or agents working on LLC’sr behalf for the purposes described in this Privacy Policy. For example, companies LLC has hired to provide customer service support or assist in protecting and securing LLC’s systems and services may need access to personal information to provide those functions.
•Marketing/Ad Partners. LLC may provide personal information to marketing and advertising partners. For example, LLC may disclose identifying information to an advertising partner in order to deliver personalized advertising to You or for the purpose of delivering advertisements to other people with similar interests to You.
•Financial services & payment processing. When You provide payment data, LLC will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services
•Corporate transactions. LLC may disclose personal information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of LLC’s business or assets.
•Legal and law enforcement. LLC will access, disclose, and preserve personal information when LLC believes that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
•Security, safety, and protecting rights. LLC will disclose personal information if LLC believes it is necessary to:
o Protect LLC’s customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
o Operate and maintain the security of LLC’s services, including to prevent or stop an attack on LLC’s computer systems or networks; or
o Protect the rights or property of LLC or others, including enforcing LLC's agreements, terms, and policies.
Marketing communications
LLC’s lawful ground of processing Your personal data to send You marketing communications is either Your consent or LLC’s legitimate interests (namely to grow LLC’s business).
Under the Privacy and Electronic Communications Regulations (PECR), LLC may send you marketing communications from LLC if
You made a purchase or asked for information from LLC about its services or You agreed to receive marketing communications and in each case You have not opted out of receiving such communications.
If You are a limited company, LLC may send you marketing emails without Your consent. However, You can still opt out of receiving marketing emails from us at any time.
Before LLC shares Your personal data with any third party for their own marketing purposes LLC will get your express consent.
You can ask LLC or third parties to stop sending You marketing messages.
If You opt out of receiving marketing communications this opt-out does not apply to personal information provided as a result of other transactions, such as purchases, warranty registrations etc
Other Disclosures of Your Personal Data
LLC may have to share Your personal information with the parties set out below:
Online Course platform provider Zenler.com who will be data processor of Your information. LLC has entered into a data processing addendum with Zenler to process Your information.
Other companies in LLC’s group provide IT and system administration services and undertake leadership reporting.
Service providers who provide cloud infrastructure, video hosting, live video platforms, email provider, IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Government bodies that require us to report processing activities. require reporting of processing activities in certain circumstances.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.
LLC may share Your personal information to third parties which involves transferring Your information outside the European Economic Area (EEA).
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to Your personal information, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Third parties service providers may be based outside the European Economic Area (EEA) so their processing of Your personal information will involve a transfer of data outside the EEA.
LLC may request your explicit consent to the specific transfer of the above information. You will have the right to withdraw this consent at any time.
