Privacy Policy

This Privacy Policy sets out how we, SKKN collects, stores and uses information about you when you use or interact with our website, skkn.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from June  21, 2022.

1. Privacy Policy   1
2. Summary 2
3. Our details 4
4. Information we collect when you visit our website 4
5. Cookies and similar technologies 4
6. Purposes of the processing 5
7. Where we receive information about you in error 11
8. Profiling 12
9. Disclosure and additional uses of your information 13
10. How long we retain your information 14
11. How we secure your information 15
12. Transfers of your information outside the european economic area 15
13. Contact form and email 16
14. E-newsletter 16
15. Google analytics 16
16. Payment processor 17
17. Your rights in relation to your information 17
18. Sensitive personal information 19
19. Changes to our privacy policy 19
20. Children’s privacy 19
21. California do not track disclosures 20
22. California consumer privacy act addendum 20

1.    Summary

This section summarizes how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

• Data controller:  (“SKKN”, “we” or “us”) Coty DTC Holdings, LLC 350 5^th Avenue 19^th Floor, New York, NY 10118-0110

How we collect or obtain information about you: when you provide it to us (e.g. by contacting us, place an order on our website, sign up for our email newsletter, take a quiz, or create an account). from your use of our website, using cookies and similar technologies, and occasionally, from third parties.
Information we collect: name, contact details, payment information e.g. your credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), your answers to quizzes or surveys, and information about your internet connection.

• How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.

• Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, and to fulfil any contracts we enter into with you, and where required by law or to enforce our legal rights.

• Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No.

• How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.

• How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary and by only trusted individuals that have been trained and briefed on appropriate handling of personal information.

• Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as web beacons on our website including essential, functional analytical and advertising cookies. For more information, please visit our cookies policy here: http://skkn.com/en-us/cookie-policy

• Transfers of your information outside the European Economic Area: We are a company based in the United States. In certain circumstances we transfer your information outside of the European Economic Area , including to the following countries: The United States of America, Canada, Ireland, the United Kingdom. Where we do so, we will ensure appropriate safeguards are in place.

• Use of automated decision making and profiling: we use automated decision making and/or profiling. We do this in order to protect our business from harm from fraud during the checkout process via our partner Signify (privacy policy here: https://www.signifyd.com/privacy/ ).
• Your rights in relation to your information
• to access your information and to receive information about its use
• to have your information corrected and/or completed
• to have your information deleted
• to restrict the use of your information
• to receive your information in a portable format
• to object to the use of your information
• to withdraw your consent to the use of your information
• to complain to a supervisory authority

• Sensitive personal information: we do not collect sensitive personal information on you.

Sensitive personal information: we collect what is commonly referred to as ‘sensitive personal information’ in only one instance on the site: skin tone preferences in your account on our website. Providing this information is completely optional, is only accepted with your explicit consent, and is securely stored on our web servers for use in personalizing our correspondence with you via email or on site. Any information stored can be viewed on your account page. This information can be deleted using the same mechanism that it is provided to us in your account page or by emailing us at data_privacy@cotyinc.com or filling out the contact form Please do not submit other sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.
For California Residents: If you are a California resident, please see the California Consumer Privacy Act (“CCPA”) Addendum for details on how we handle the personal information of California residents and how to exercise your rights under the CCPA.

2.    Our details

The data controller in respect of our website is (“SKKN”, “we” or “us”) .
You can contact the data controller by writing to Coty DTC Holdings, LLC 350 5^th Avenue 19^th Floor, New York, NY 10118-0110or sending an email to data_privacy@cotyinc.com If you have any questions about this Privacy Policy, please contact the data controller.

3.    Information we collect when you visit our website

4.      We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information. Cookies and similar technologies

 

1. Use of cookies on our website

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use cookies and similar technologies on our website, including essential, functional, analytical and advertising cookies and web beacons. For further information on how we use cookies, please see our cookies policy which is available here: http://skkn.com/en-us/cookie-policy You can reject some or all of the cookies we use on or via our website by (i) changing your browser settings or non-essential cookies by (ii) using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

1. Use of web beacons [and similar technologies] in emails

We use technologies such as web beacons (small graphic files in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.
For more information on how we use web beacons in our emails, see our cookies policy which is available here: http://skkn.com/en-us/cookie-policy
For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://www.adobe.com/privacy/policy.html

5.    Purposes of the processing

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Purpose	Description	Legal basis	Justification for legal basis
Information we collect when you contact us
Contact form	When you send us a contact form through our website, we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).	Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) GDPR	Where your contact us about the providing of goods or services or the steps taken at your request prior to the providing of goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Mail	If you contact us by mail, we will collect any information you provide to us in any postal communications you send us.	Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) GDPR	Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
E-Newsletter	When you sign up for our e-newsletter on our website or opt to receive news, offers, updates on out-of-stock items from us by entering your name and email address and clicking subscribe or ticking a box at checkout indicating that they would like to receive your e-newsletter, we collect your email address , information about your browser, information about the page you signed up on, and any other additional information you may provide to us.	Your consent (Article 6(1)(a) GDPR	You give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.
Registering on our website	When you register and create an account on our website, we collect the following information: Email address, IP address, and any other information you provide to us when you complete the registration form.If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.	Your consent (Article 6(1)(a) GDPR	You give your consent to create your account, to allow you to authenticate yourself and place an order, to allow you to update your account
Information to process your order
Information collected when you place an order	When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable), billing name, and information about your browser.If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.	Necessary to perform a contract (Article 6(1)(b) GDPR	We need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Improvement of the products and services offered on the Website	To carry out satisfaction surveys (requests for opinions, surveys, etc.)to take into account, publish and, only if necessary, moderate your opinions on purchased productsto carry out customer studies (product tests, sales statistics, etc.)	Our legitimate interests (Article 6(1)(f) GDPR	Finding out how a customer’s experience was to improve your business’ website or to be able to contact the customer by phone where (if necessary) in relation to their order.[2]
Processing your payment	After you place an order on our website you will need to make payment for the goods or services you have ordered.	Necessary to perform a contract (Article 6(1)(b) GDPR	To fulfil your contractual obligation to pay for the goods or services you have ordered from us.
Marketing and self-advertisement
Marketing communications	At checkout and upon first arriving to the site you will have the option of receiving marketing communications from us.Our similar goods and servicesYou can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by ticking a box to opt out or clicking ‘unsubscribe’ in any email from us.We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.	Consent (Article 6(1)(a) GDPR	You give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.
Third parties
Information received from third parties	Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include partner companies who we are doing a joint promotion with.It is also possible that third parties with whom we have had no prior contact may provide us with information about you.Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.We also collect optional information from you, such as your phone number or information about how your experience was in the form of a survey. We also ask you if you would like to receive marketing communications from us. For further information, see ‘Marketing communications’ in this section below.If you do not supply the optional information requested at checkout, such as phone number. we will not be able to contact you by phone or SMS.	Consent (Article 6(1)(a) of the General Data Protection Regulation).	Where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.
Disclosure and use of your information for legal reasons
Preventing fraud and criminality	Indicating possible criminal acts or threats to public security to a competent authorityIf we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.	Compliance with a legal obligation Article 6.1(c) GDPR	Preventing crime or suspected criminal activity (such as fraud).
Disclosure of information in connection with the enforcement or potential enforcement our legal rights	We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).	Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).	Enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings	We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.	Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).	Resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements	We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.	Compliance with a legal obligation Article 6.1(c) GDPR	Legal obligations to disclose information which are part of the applicable laws.

 

6.    Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

1. Our use of automated decision-making and profiling[3]

We use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.
You have the right to object to our use of automated decision making and profiling described in this section. You can do that by (i) opting-out of cookies and similar technologies in accordance with the method described in the relevant section below or (ii) by writing to us in this regard. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

1. You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: http://skkn.com/en-us/cookie-policy Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.
2. Significance and envisaged consequences: cookies will be used to recognise the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.

• How to object: you can block these cookies by using the cookies control management tool on our site or by opting out of seeing personalised ads by following the instructions here: https://support.google.com/ads/answer/2662922?hl=en-GB]. For further information, please see our cookies policy.

7.    Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

1. Use of profiling for web analytics

Our web analytics services, Google Analytics and Qubit, Inc. use collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on) and how much you are spending on our site. We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy. Information collected about you, once collected is anonymised and stored on an aggregate basis. IP addresses are anonymized at the point of collection on our site.
Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.
Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by using our cookie control tool and your location will be analysed based on your IP address. We may target advertisements or content on our site based on the level of interest we receive from certain visitors and their behaviour on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation) and the basis upon you give us consent to use this by opting into cookie tracking.
[Legitimate interest: : improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires. Also to serve advertisements to you which seem most relevant to the visitor.

1. Use of profiling in marketing emails

We use web beacons in our marketing emails to analyse who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons if you have consented to their use in accordance with our cookies policy (http://skkn.com/en-us/cookie-policy).

1. Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.
2. Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons), including open rates, click through rates, and what items you clicked on in an email.

• How to object: You may object to this by contacting us at data_privacy@cotyinc.com or you may opt out by using our cookie control tool.

1. Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
2. Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content.

8.    Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

1. Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

• Customer Service System Provider: Zendesk Inc. Their privacy policy is available here:
• Hosting provider(s), including Shopify Inc. Their privacy policy is available here: shopify.com/privacy

Our third party service providers are located in the United State and Canada.
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

1. Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/]
You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

9.    How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

1. Retention periods

Order information: when you place an order for goods and services, we retain that information indefinitely or until you request that we delete unless this conflicts with our compliance of a legal responsibility.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form ,we will retain your information for as long as it takes to respond to and resolve your enquiry and indefinitely afterward unless it is requested to be deleted AND it does not interfere with our compliance with laws and our legitimate business interest.
E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

1. Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

• the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
• whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
• whether we have any legal basis to continue to process your information (such as your consent);
• how valuable your information is (both now and in the future);
• any relevant agreed industry practices on how long information should be retained;
• the levels of risk, cost and liability involved with us continuing to hold the information;
• how hard it is to ensure that the information can be kept up to date and accurate; and
• any relevant surrounding circumstances (such as the nature and status of our relationship with you).

10.  How we secure your information

1. List of security measures

We understand that you care how your personal information is used and/or shared with others, and we value your trust and seek to safeguard your personal information.
 
We take appropriate technical and organisational measures, including physical and administrative, to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
• using secure servers to store your information;
• verifying the identity of any individual who requests access to information prior to granting them access to information;
• using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website;
• only transferring your information via closed system or encrypted data transfers.

1. Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

 

11.  Transfers of your information outside the European Economic Area

We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we and our data processors process data may have laws which are different, and potentially not as protective, as the laws of your own country.
Your information will be transferred and stored outside the European Economic Area (EEA) or the United Kingdom (UK) in the circumstances set out below, notably toward the United States of America (USA), which does not offer the same level of protection of your personal data. We will also transfer your information outside the EEA or the UK or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
Server log information
Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our third party hosting company, Shopify. You can access their privacy policy here: www.shopify.com/privacy
Country of storage: Canada (country benefiting from an adequacy decision) and the United States (transfer subject to the European Commission’s Standard Contractual Clauses)

 

12.  Contact form and Email

Information you submit to us via our contact form is transferred outside the EEA and stored on our third party email and customer service systems. Our email provider is Adobe Inc..You can access their privacy policy here: https://www.adobe.com/privacy/policy.html.
Country of storage: United States(transfer subject to the European Commission’s Standard Contractual Clauses).

 

13.  E-Newsletter

Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and the UK  and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: Adobe Inc. You can access their privacy policy here: https://www.adobe.com/privacy/policy.html

14.  Country of storage: United States (transfer subject to the European Commission’s Standard Contractual Clauses). Text marketing

Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and the UK and stored on our third party mailing list provider’s servers. Our third party text marketing provider is: Attentive Mobile, Inc. You can access their privacy policy here: https://www.attentivemobile.com/privacy
Country of storage: United States (transfer subject to the European Commission’s Standard Contractual Clauses).

 

15.  Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/
Country of storage: United States of America.

 

16.  Payment Processors

Information you submit to us by our third party payment processors:
Shopify Payments, is transferred outside the EEA and stored on their servers. You can access their privacy policy here: https://pay.shopify.com/tos-privacy-policy
Country of storage: Canada (country benefiting from an adequacy decision) and the United States (transfer subject to the European Commission’s Standard Contractual Clauses)Global-e, does not transfer personal data outside the EEA and stores the personal data on their servers. You can access their privacy policy here: https://www.global-e.com/en/privacy-policy/ 

17.  Country of storage: Ireland. Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by filling out our contact form or sending an email to data_privacy@cotyinc.com

• to request access to your information and information related to our use and processing of your information;
• to request the correction or deletion of your information;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
• to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
• to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

• https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
• https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
 

1. Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

1. How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

1. Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to Coty DTC Holdings, LLC (“SKKN”, “we” or “us”) located  at 350 5th Avenue, 19th Floor, New York, NY 10118-0110,sending an email to: data_privacy@cotyinc.com or filling out the contact form.

• to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
• to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

• clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: http://skkn.com/en-us/cookie-policy Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, we will not process it and will delete it.

 

18.  Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

19.  Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to data_privacy@cotyinc.com

 

20.  California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org
For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: http://skkn.com/en-us/cookie-policy

21.  California Consumer Privacy Act Addendum

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), SKKN, is providing the following details regarding the categories of Personal Information about California residents that we have collected (online and offline) or disclosed within the preceding 12 months. This CCPA Notice does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us.

Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.

We collected the following categories of Personal Information:
Identifiers, such as name, contact information, IP address and other online identifiers;
Personal information, as defined in the California customer records law, such as name and contact information, and payment card number;
Characteristics of protected classifications under California or federal law, such as skin tone or color;
Commercial information, such as transaction information and purchase history;
Internet or network activity information, such as browsing history and interactions with our website;
Geolocation data, such as IP location;
Electronic and similar information; and
Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.


We collect this Personal Information from you as well as from our joint marketing partners. We use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including using Personal Information to:

Fulfill your requests, process your transactions, and respond to your inquiries;
Develop, improve, repair, and maintain our products and services;
Personalize, advertise, and market our products and services;
Conduct research, analytics, and data analysis;
Maintain our property and our records, and undertake quality and safety assurance measures;
Conduct risk and security control and monitoring, and detect and prevent fraud;
Perform accounting, audit, and other internal functions, such as internal investigations and record-keeping;
Carry out corporate transactions, such as mergers, joint ventures or acquisitions; and
Comply with law, legal process, and internal policies, and exercise and defend legal claims.

We disclosed the following Personal Information to third parties for our operational business purposes:
Identifiers, such as name, contact information, IP address and other online identifiers;
Personal information, as defined in the California customer records law, such as name and contact information, and payment card number;
Characteristics of protected classifications under California or federal law, such as skin tone or color;
Commercial information, such as transaction information and purchase history;
Internet or network activity information, such as browsing history and interactions with our website;
Geolocation data, such as IP location;
Electronic and similar information; and
Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

We disclosed these categories of Personal Information to: our affiliates and trusted third-party service providers.

We DO NOT “sell” your Personal Information for money. Rather we share your information with select marketing partners that pool that information with information from other members of the marketing network to improve marketing outcomes for you. This may constitute a “sale” under the CCPA, and therefore we may have “sold” the following categories of Personal Information:
Identifiers, such as contact information, IP address, and other online identifiers;
Personal information, as defined in the California customer records law, such as contact information;
Internet or network activity information, such as browsing history and interactions with our website; and
Geolocation data, such as IP location.

If you are a California resident, you may request that we:

Disclose to you the following information covering the 12 months preceding your request:
The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
The specific pieces of Personal Information we collected about you;
The business or commercial purpose for collecting or selling (if applicable) Personal Information about you;
The categories of Personal Information about you that we sold and the categories of third parties to whom we sold such Personal Information (if applicable);
The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
Delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please email us at data_privacy@cotyinc.com or you can fill out the contact form We will respond to your request consistent with applicable law.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.