ISDIN USA Privacy Policy

Last updated and effective as of as of: November, 2023

ISDIN Corp. (“ISDIN,” “Company,” “we”, “our” or “us”) understands that privacy is important to you. We created this Privacy Policy to show our commitment to your privacy. This Privacy Policy discloses our practices regarding information collection and usage for the website located at www.isdin.com/en-US(the “Website”) and any services offered on the Website (collectively, the “Service”). This Privacy Policy does not apply to any other websites, apps, or services provided by us, our affiliates, or our clients unless it appears on those websites, apps, or services.

By using or accessing the Service, you agree to be bound by our Privacy Policy. If you do not agree to this Privacy Policy you may not access or otherwise use the Service.

ACCESSIBILITY—IF YOU ARE HAVING ANY TROUBLE ACCESSING THIS PRIVACY POLICY OR THE WEBSITE OR SERVICE, PLEASE CONTACT US TOLL FREE AT +1 862-242-8129, 24 HOURS A DAY, 7 DAYS A WEEK.

If you are a resident of California, Virginia, Colorado, or Connecticut, please see our California Privacy Notice and Virginia, Colorado, and Connecticut Privacy Notice for specific disclosures with respect to our collection, use, and disclosure of your information and additional rights you have under applicable law.

The following links will take you directly to the corresponding sections of this Privacy Policy:

• What Our Privacy Policy Covers

• Personal Information We Collect from You

• How We Collect Your Personal Information

• How We Use Your Personal Information

• How We Disclose or Share Your Personal Information

• Love ISDIN Loyalty Program

• Links to Other Sites and Social Media Services

• Interest-based Advertising

• How We Protect Your Personal Information

• Data Retention

• Your Choices

• Nevada Privacy Rights

• Data Processed in the United States

• Children’s Privacy

• Changes to This Policy

• Contacting Us

WHAT OUR PRIVACY POLICY COVERS

This privacy policy applies to personal information that we collect in different situations, including when you:

Access or use the Service;

Communicate with us over email or Website chat, or otherwise via the Service;

Engage with us on social media; or

Participate in any of our programs or events, including sweepstakes, contests, or surveys.

We may provide different or additional privacy notices in connection with certain activities, programs, and offerings. Additionally, we may provide additional “just-in-time” notices or notices at collection that may supplement or clarify our privacy practices or provide you with additional choices regarding your personal information.

This Privacy Policy is a layered privacy notice. This means that, where possible, we give you short summaries of the most important takeaways, with more detailed information available if you choose. We do this to save you the trouble of reading through a long, wordy document to get the information you need. When you interact with a sentence that reads “click here for more information,” we will provide you with additional detail about that particular topic.

PERSONAL INFORMATION WE COLLECT FROM YOU

We collect your personal information when you interact with the Service. “Personal information” is information that identifies, relates to, describes, or can be associated with you.

We use the term “personal information” – also called “personal data” or “personally identifiable information” in the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been deidentified or that otherwise cannot reasonably be related back to a specific person is not considered personal information. The precise definition of personal information may vary depending on your place of residence, but we take the same general approach to protecting your privacy, subject to any additional measures that may be required by applicable laws.

The personal information we collect may include:

• Identifiers, such as your name, email address, and account name and password;

• Contact information, such as your phone number, mailing address, and billing address;

• Characteristics, such as your age and date of birth, and your gender;

• Commercial information, such as products or services purchased, your purchasing or consuming interests, or histories or tendencies relating to purchases.

• Device and online identifiers and related information, including internet protocol (IP) address, mobile ad identifiers, data collected from cookies, beacons, and pixel tags, and similar unique identifiers;

• Internet or other electronic network activity information, including, but not limited to browsing history, search history, and information regarding your interaction with an internet website, application, mobile app, or advertisement;

• Geolocation or other information that permits us to determine your location;

• Any other personal information that you voluntarily provide us.

Additionally, you may choose to provide us with the information of your doctor or healthcare provider when you participate in our Love ISDIN loyalty program. We use this information solely to to know at a statistical level the specialties most consulted by users and will not use this information to infer any health conditions or diagnoses.

HOW WE COLLECT YOUR PERSONAL INFORMATION

Personal Information You Provide

We collect personal information that you provide to us directly, such as when you contact us, create an account, sign up for a subscription, complete a survey, or make purchases or transactions.

Personal information you provide to us directly may include, but is not limited to:

• Information you provide when you create a profile or account, or subscribe to one of our services;

• Information you provide when you contact us via email or text message, or through other Internet-enabled communications;

• Your responses to surveys or beauty guides that you choose to complete for us;

• Information you provide when you enter a contest or other promotion sponsored by us;

• Details relating to transactions that you carry out through our Service, including any orders that you ask us to fulfill, and any information you provide to us relating to such orders;

• Your search queries on the Service;

• Any other information that you provide us on or through the Service.

Personal Information We Collect Automatically

When you visit our Service, open or click on emails we send you, or interact with our advertisements, we or third parties we work with may automatically collect certain data (some of which may be personal information) using technologies such as cookies and other tracking technologies, including the following:

Cookies and Similar Technology—we or third parties that we partner with may store information on your device to collect data about your use of the Service, subject to our Cookie Policy.

"Cookies" are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Such data may include, for example, the address of the websites you visited before and after you visited our Service, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Service you visited and what links you clicked on, the region where your device is located, and geographic information based on your IP data. We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Service. We may also use cookies to customize your visit to the Service and for other purposes to make your visit more convenient or to enable us to enhance the Service. For additional information about our use of cookies, please see our Cookie Policy.

Clickstream Data—we collect information about your browsing activity across different websites.

As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as "clickstream data," can be collected and stored by a website's server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Service. We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our Website, how visitors navigate throughout the Service, and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Service.

Analytics—we use third-party analytics vendors to help us track and understand how visitors use our Service.

We may work with third-party vendors who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Service. One such provider is Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help analyze how users use the Website. The information generated by these cookies about your use (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on activity for its staff, and providing other services relating to web page activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may refuse the use of cookies by selecting the appropriate settings in your browser. By using the Website and accepting cookies, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Please refer to the currently available opt-outs for Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.

We may also obtain information about you from other sources, such as data analytics providers, marketing or advertising vendors, fraud prevention vendors, vendors that provide other services on our behalf, or publicly available sources.

If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms or networks in connection with our Service, we may collect information that you share with us on social media or that such platforms share with us. Please review the privacy policies and settings of the social media platforms and networks that you use for more information about their privacy practices.

HOW WE USE YOUR PERSONAL INFORMATION

We collect and use personal information for the following purposes:

To communicate with you.

This may include: contacting you about and providing you and our clients with our Service; enabling our website chat function; responding to your direct inquiries, requests, issues or feedback, and providing customer service; and adding you to our mailing lists and sending you emails from time to time.

To provide our products and services.

This may include: operating the Service, and providing you with any specific services that you have requested; creating, maintaining, and otherwise managing your account, profile, or subscription; delivering content and product and service offerings relevant to your interests; fulfilling your orders and/or completing the transactions you have requested, processing your payments, and providing you receipts and order updates; to remind you of items you have left in your cart; and providing a forum for discussion, asking questions, posting photos and reviews, and sharing experiences.

For marketing and promotional purposes

This may include: marketing our goods and services or goods and services of those of our affiliates, business partners, and other third parties; providing you advertising for products and services that may be of interest to you; providing and administering our Love ISDIN loyalty program; and administering sweepstakes, contests, and other similar promotions.

For analytics and personalization.

This may include: identifying trends and making inferences about you and your interactions with us or our affiliates or our business partners; conducting research and analytics to improve our services and product offerings or those of our affiliates and business partners; understanding how you interact with our Service, advertisements, and communications with you to determine which of our products or services are the most popular, and to improve the Service and marketing campaigns; personalizing your experience to save you time when you visit our Service, and to customize the marketing and advertising that we show you; better understanding our customers’ needs; and providing personalized recommendations about our products and services.

For security and fraud prevention.

This may include: helping maintain the safety, security, and integrity of our Service, databases and other technology assets, and business; internal research; technological development and demonstration; and improving, upgrading, or enhancing our Service; detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity; and investigating suspected fraud, harassment, or other violations of any law, rule, or regulation, or the policies for our Service.

To comply with legal obligations.This may include: compliance with legal or regulatory obligations, establishing or exercising our rights, and to defending against a legal claim; responding to law enforcement requests and as required by applicable law, court order, legal process, or governmental regulation.

To support core business functions.

This may include: maintaining records related to business process management, loss and fraud prevention, and to collect amounts owing to us; and providing and maintaining the functionality of our Properties, including identifying and repairing errors or problems.

For any additional purposes that you specifically consent to.

If you participate in our referral programs and want to tell your friends about our Service or products, we may ask that you provide us with your friend’s name and email address. We will only use the information you provide us to send communications to your friend containing further information about our Service or products as you requested. If you have received a referral communication from us and would like us to delete your information from our records, please contact us at privacy.us@isdin.com.

We reserve the right to supplement your personal information with information we gather from other sources which may include online and offline sources, including information that does not identify you (“non-personal information”).

Non-personal information may include anonymous or aggregate data, or information lawfully made available from federal, state, or local government records. Because non-personal information does not personally identify you, we may collect, use, and disclose such information for any purpose permitted by law. In some instances, we may combine non-personal Information with personal information. If we combine any non-personal information with personal information, the combined information will be treated by us as personal information to the extent that it is capable of personally identifying you. We reserve the right to develop and derive aggregate data (meaning information that relates to a group or category of individuals, from which individual identities have been removed) from personal information in order to enhance and maintain the Service, and such aggregate data will be treated as non-personal information.


HOW WE DISCLOSE OR SHARE YOUR INFORMATION

Besides using your information ourselves, from time to time, we may share your information with our affiliates, subsidiaries, retail partners, third party service providers and the authorities in the following circumstances:

Service Providers—We may share your personal information with third-party vendors who perform services on our behalf. These vendors are not allowed to use your personal information for their own benefit.

Third-party service providers may include vendors who perform services for us, including, but not limited to: website hosting, data analysis, infrastructure provision, information technology services, customer service, email delivery services, payment processing, auditing, and anti-fraud monitoring. These service providers may have access to personal information that is necessary to perform their functions, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit. We require these entities to maintain appropriate security to protect your information from unauthorized access or processing.   

ISDIN Affiliates, Subsidiaries and Retail Partners—We may share your information with our affiliates, subsidiaries, and retail partners worldwide so that such parties can contact you for their own purposes. By visiting our website or otherwise providing us with your information, you consent to this transfer of your information throughout the ISDIN network of entities.

Business and Advertising Partners—We may share your personal information with third parties who partner with us to promote our products, provide marketing and advertisements, conduct data analytics, or for other commercial purposes. We do not control how these third parties use and share your personal information once they receive it. You will need to contact such third parties directly for information about their privacy practices or to exercise any rights (including opt-out rights) you may have.

Legal Compliance and to Defend Our Rights—We may disclose personal information and other information as we believe necessary or appropriate to comply with laws and defend our legal rights.

This may include disclosures to other parties: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms and Conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Business Transfers—We may share your personal information and other information with third parties in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of the Company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the assets transferred may include information about the users of our Service.

Non-Personal Information—We may share non-personal information with unaffiliated third parties, such as business and advertising partners, manufacturers, distributors, and retailers, to improve and enhance your experience using the Service, and for our own market research activities. We publicly commit to maintain and use the information in de-identified or aggregate form, and not to attempt to re-identify the information.

Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.

LOVE ISDIN LOYALTY PROGRAM

We offer our customers the opportunity to sign up for our Love ISDIN loyalty program when they register for an ISDIN account. As part of your participation in Love ISDIN, you may receive points that can be used as a method of payment to purchase products on the ISDIN.com website. Points are earned by scanning the QR codes on our various products. When you sign up for Love ISDIN, we require you to provide your name and email address. We also give you the option to voluntarily provide your date of birth in order to receive a gift every year, and the information of your medical provider in order to to know at a statistical level the specialties most consulted by users. When you scan QR codes, we automatically collect identifiers (such as IP address), device information, internet or similar network activity, and non-precise geolocation information.

Because Love ISDIN involves the collection of personal information, it may be interpreted as a “financial incentive” under California law or a “bona fide loyalty program” under Colorado law. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of Love ISDIN, less the expense related to offering those products, services, and benefits to you.

You may withdraw from participating in Love ISDIN at any time by contacting us using the designated method set forth in the Love ISDIN Terms and Conditions, or by contacting us at privacy.us@isdin.com.

LINKS TO OTHER SITES AND SOCIAL NETWORKING SERVICES

As a convenience to you, we may provide links to third party web sites, apps or services from within the Service. The Service may integrate with social networking services. We are not responsible for the privacy practices or content of these third party sites or social networking services, and do not control them. By providing a link or integrating with them, we are not endorsing or promoting them, but are merely doing so as an accommodation.  When use other websites, apps, services, or social media platforms outside of the Service, you do so at your own risk. We encourage you to read the policies and terms of every web site, app, service, or platform that you visit or use.

You should be aware that personal information which you voluntarily include and transmit online in a publicly accessible blog, social network, or otherwise online may be viewed and used by others, and you assume the risk that the personal information provided by you may be viewed and used by third parties.

INTEREST-BASED ADVERTISING

Targeted Advertising / Behavioral Advertising

We ourselves, or with third-party vendors, may use your data to deliver targeted advertising to you when you visit our Service or other websites.

For example, if you are searching for information on a particular product, we or our vendors may cause an advertisement to appear on other websites you view with information on that product. This form of advertising—sometimes called “targeted advertising,” “behavioral advertising,” or “cross-context behavioral advertising”—enables us and our vendors to know about your interests in connection with the delivery of a specific ad. We believe that such advertising is helpful because it allows you to see advertisements that are relevant to your interests. Cookies, clickstream data, and other similar technologies described in this Privacy Policy may be used in this process.

If you would like to opt out of these interest-based advertisements, please follow the opt-out process described in the section titled Your Choices below.

Cross-Device Matching

We may use your information to help us, or our third-party vendors, determine if you have interacted with our Properties across multiple devices and to match such devices. This is known as “cross-device matching.”

To accomplish this, we may rely on information (including demographic, geographic and interest-based data) from third parties such as data vendors, pursuant to their own privacy policies, or we may use information we collect in conjunction with such third-party data. Based on this data, we may then display targeted advertisements across devices that we believe are associated with each other, and may further provide services to our advertisers to better enable cross-device targeting and analysis.

To opt-out of or restrict our use of certain cross-device data, please see the section titled Your Choices below.

HOW WE PROTECT YOUR PERSONAL INFORMATION

We make commercially reasonable efforts designed to protect your data. Personal information is maintained on our servers or those of our vendors, and is accessible by authorized employees, independent contractors, representatives, and agents as necessary for the purposes described in this Privacy Policy. We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal information. However, no method of safeguarding information is completely secure, and we cannot guarantee that our safeguards will be effective or sufficient.

If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us at privacy.us@isdin.com.

DATA RETENTION

We will retain your personal information for as long as your inquiry is active or as needed to provide you with the Service, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregate data, or any other data that constitutes non-personal information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

YOUR CHOICES

Consistent with applicable law, you may exercise the choices described in this section regarding your personal information and communications from us. You may also have certain additional rights available depending on laws in your state or country of residence, as described further below in the Privacy Policy.

Opting Out of Messages or Services

To opt out of any future promotional messages from us, you should send an unsubscribe request to us at privacy.us@isdin.com.  We will process your request within a reasonable time after receipt.  However, we are not responsible for removing your personal information from the lists of any third party who has previously been provided with your information in accordance with this Privacy Policy or your consent. Please note that if you opt out in this manner, certain aspects of the Service may no longer be available to you.

If you do not want us to retain or use your personal information, you may contact us at privacy.us@isdin.com and we will do our best to accommodate your request.

Cookies and Tracking Technologies

As noted above, you may opt out of or restrict the placement of cookies on your device or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on many mobile devices. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. Further information on cookies is available at www.allaboutcookies.org.

Some browsers have a Do Not Track (“DNT”) feature that lets users signal to websites that they do not want to have their online activities tracked. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. However, if you are a resident of California, Colorado, or Connecticut, we treat opt-out preference signals as a means of opting out of the sale or sharing of personal information, or of opting out of the processing of personal information for targeted advertising, as applicable. Please see the California Privacy Notice and the Virginia, Colorado, and Connecticut Privacy Notice for more information.

Interest-Based Advertising

You may opt out of receiving targeted ads from certain data and advertising partners that participate in certain industry self-regulatory programs. The DAA provides a website at www.aboutads.info/consumers with information about how to opt out of targeted advertising from some or all of the DAA’s participating companies. We comply with the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance (“DAA”). Additionally, the Network Advertising Initiative (“NAI”) offers a website at http://optout.networkadvertising.org/, where you can opt out of interest-based advertising from some or all of the NAI’s members. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. In the event that we perform cross-device matching (as described above), once you have opted out on one device (“Opted-Out Device”), we will not use any new data from the Opted-Out Device to identify you on another device for interest-based advertising purposes, and we will not use data from another device for interest-based advertising purposes on the Opted-Out Device.

NEVADA PRIVACY RIGHTS

If you are a Nevada resident, you have the right to request that we do not sell your covered information (as those terms are defined in N.R.S. 603A) that we have collected, or may collect, from you.  We do not sell your covered information; however, if you would like to make such a request you may do so by contacting us at privacy.us@isdin.com.

DATA PROCESSED IN THE UNITED STATES

Our Service is maintained in the United States of America.  By using the Service, you freely and specifically give us your consent to export your personal information to the USA and to store and use it in the USA as specified in this Privacy Policy. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA.

CHILDREN’S PRIVACY

Our Service is designed for those 18 years of age and older. We do not knowingly collect information from anyone under the age of 18. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

CHANGES TO THIS POLICY

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time.  However, if at any time in the future we plan to use personal information in a way that materially differs from this Privacy Policy, we will post such changes here or email you. We encourage you to periodically review the Service for the latest information on our privacy practices.  You are bound by any changes to the Privacy Policy when you use the Service after such changes have been first posted.

CONTACTING US

For questions or concerns relating to this Privacy Policy or your information, we can be contacted at: privacy.us@isdin.com.