Privacy Policy

SKIN GROWS BACK™ Privacy Policy

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This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from skingrowsback.com (the “Site”).

PERSONAL INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number. We refer to this information as “Order Information”.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

- Communicate with you;

- Screen our orders for potential risk or fraud; and

- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

[We use device and order information in ADVERTISING/RETARGETING campaigns only if you opt-in or sign up for an account.

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store -- you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

BEHAVIOURAL ADVERTISING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

- Facebook: https://www.facebook.com/settings/?tab=ads

- Google: https://www.google.com/settings/ads/anonymous

- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada, Australia and the United States.

GDPR COMPLIANCE

If you are a resident of the European Union your personal information is protected by GDPR (General Data Protection Regulation). Part of the GDPR compliance policy is up to the merchant (SKIN GROWS BACK) and part is covered by Shopify and how they handle your personal information. You can read Shopify’s white paper on GDPR compliance here: https://help.shopify.com/assets/pdfs/gdpr-whitepaper.pdf

ERASURE

Data subjects have the right to request that their personal data be erased in certain circumstances.

If SKIN GROWS BACK receives a request from a customer to delete their personal data, before doing this we need to:

• ●  Verify that the requester is the same as the data subject (that is, the requester is not asking to erase someone else’s personal data)
• ●  Confirm there is no legal reason to preserve this data
  If both conditions are satisfied, SKIN GROWS BACK will forward the request to Shopify, either through Shopify's support system, or by email.
  After a request is received, Shopify will ensure that the relevant personal data is erased. If erasing it is impossible, Shopify will let SKIN GROWS BACK know to what degree it is impossible, and why.
  In addition to contacting Shopify, SKIN GROWS BACK will contact any relevant third parties to make sure that they delete or anonymise the relevant personal data.
• TIMING
  Personal data cannot be erased from Shopify while it is:

• ●  Associated with a pending order
• ●  Associated with an order made fewer than 180 days before the
  request (the usual window in which a buyer can make a chargeback).
  

If the buyer’s personal data cannot be erased for this reason, SKIN GROWS BACK will re-submit the deletion request after the appropriate time has passed.

SCOPE

When processing a request for erasure, Shopify will anonymise the personal data of the buyer, but keep non-personal data such as revenue information and order details. Order details that are retained include the gateway used to process payment, time of sale, amount paid, currency, subtotal, shipping cost, taxes added, shipping method, item quantity, item name, SKU, and payment method.

If no data erasure requests are received, Shopify will keep data for the lifetime of a store, and purge personal data within 90 days after a store is closed.

ACCESS

SKIN GROWS BACK will upon request only, explain to data subjects how their personal data is processed and provide access to this personal data.

If SKIN GROWS BACK cannot export data sufficient to fulfill the request from their admin, We will forward the request to Shopify. Similar to a request for erasure, if a buyer requests access to their personal data, SKIN GROWS BACK must first validate the identity of the requester.

Once the identity of the data subject has been verified SKIN GROWS BACK will contact Shopify, either through Shopify's support system, or by email

When Shopify receives the request, it will:

● Confirm whether personal data about a buyer is being processed by Shopify

• ●  Confirm what categories of data are being processed by Shopify
• ●  Provide the buyer with the relevant information from Shopify
  systems.
• DATA PORTABILITY
  When SKIN GROWS BACK process data using automation we will, in limited circumstances, provide data subjects with their personal data upon request. This data will be provided in a commonly used and machine-readable format.
  SKIN GROWS BACK may export some data directly from their store’s admin page. Many data types can be exported to common formats such as Excel or CSV with one click:
  ●  Transaction histories
  ●  Payouts
  ●  Product lists
  ●  Customer lists
  In addition, if SKIN GROWS BACK contacts Shopify to request copies of processed data, Shopify will make the data available in a common format.
  
• RECTIFICATION
  Data subjects have the right to correct incomplete or inaccurate personal data held or processed SKIN GROWS BACK.
  Shopify’s platform allows SKIN GROWS BACK to change customer records directly from their store admin.
  

AUTOMATED DECISION-MAKING

Data subjects have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision making has a legal effect on the data subject or otherwise significantly affects them. An example of a legal effect is a decision that impacts an individual’s legal or civil rights, or their rights under a contract. Examples of significant effects include decisions that have a financial impact on individuals, or impact their employment.

SKIN GROWS BACK and Shopify does not currently engage in fully automated decision-making that has a legal or otherwise significant effect using buyer data.

Services that include elements of automated decision-making are highlighted in the table below:

Under the GDPR, SKIN GROWS BACK and SHOPIFY are required to implement appropriate technical and organisational measures.

DATA RETENTION

When you place an order through the site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

THIRD PARTIES

SKIN GROWS BACK shares your personal information with Shopify, Paypal and Mail Chimp for order processing, payment and marketing purposes only. You can select if you want to opt-in or opt-out of our marketing campaigns it is no longer automatic. We are required to pass on relevant shipping information to the various carrier services that we use so they can fulfil your order.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

[[18]]

MINORS

The Site is not intended for individuals under the age of [[18]]  .

We use Google Analytics to monitor users of this site ( https://skingrowsback.com/ )

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at hello@skingrowsback.com or by mail using the details provided below:

SKIN GROWS BACK

[Re: Privacy Compliance Officer]

Unit 9 / 1B Dunmore Drive, Truganina, VIC, 3029 Australia

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