1. Our relationship to you

To fully understand our obligations and your rights regarding your personal information under this policy, it's important to identify which relationship(s) you have with us. You as a "user" means the individual accessing or using the service, or the company, or other legal entity on behalf of which such individual is accessing or using the service, as applicable. Under GDPR (General Data Protection Regulation), you can be referred to as the data subject or as the user as you are the individual using the service. We may refer to customers and user collectively as "you".

The data controller who processes all of the personal data: Routinely, located at Overhoeksplein 1, 1031 KS, Amsterdam, The Netherlands and registered at the Chamber of Commerce in the Netherlands with the number 78091640.

2. Notice

We provide notice to you through the posted privacy policy and may provide additional "just-in-time" disclosures about the data collection, use, and sharing practices of specific services. If you have any questions about notices, please contact our Data Protection Officer via dpo@routinely.com. If you do not understand a notice or this privacy policy, you should not continue using our services.

3. Data collected

3.1 Types of data

While using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you and/or fulfill orders. Personally identifiable information may include, but is not limited to: email address, first name and last name, phone number, location, address, state, province, postal code, city, country, date of birth, payment details, social media details, health (e.g. menstrual cycle) and activity (e.g. amount of steps taken) information, product feedback answers and/or medical data (e.g. your skin ID test results, current and preferred skin condition information). You may contact us at any time through email to request information or support. If you send us such an email, we may process the personal data and information provided in your email. If you provide us with personal data about another person, you hereby declare that you are authorized to do so and that you allow us to use that information in accordance with this privacy policy.

Usage data is collected automatically when using the service. Usage data may include information such as your device's internet protocol address (e.g. IP address), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, your behavior on those pages, unique device identifiers and other diagnostic data. When you access the service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, unique device identifiers and other diagnostic data. We may also collect information that your browser sends whenever you visit our service or when you access the service by or through a mobile device. We aim to to anonymize data as much as possible.

Any information you disclose in our forums, blog or review section becomes public information. This means that your posts are available to the general public and may appear in search engines or other publicly available platforms, and may be "crawled" or searched by third parties. You should not share information there that you're not comfortable sharing publicly.

We use the information mentioned above to provide features of our service, to improve and customize our service. The information may be uploaded to our servers and/or a service provider's server or it may be simply stored on your device.

3.2 Social media services

We allow you to create an account and log in to use the service through the social media services such as Google, Facebook, Twitter and Sign in with Apple. If you decide to register through or otherwise grant us access to a third-party social media service, we may collect personal data that is already associated with your third-party social media service's account, such as your name, your email address, your activities or your contact list associated with that account. You may also have the option of sharing additional information with the company through your third-party social media service's account. If you choose to provide such information and personal data, during registration or otherwise, you are giving the company permission to use, share, and store it in a manner consistent with this privacy policy.

3.3 Cookies and tracking

We and our service providers use cookies and similar tracking technologies (hereinafter referred to as "cookies") to track the activity on our service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our service. The technologies we use may include:

• Cookies. A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use certain parts of our service. Unless you have adjusted your browser setting so that it will refuse cookies, our service may use cookies. Cookies can be "persistent" or "session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser. Some cookies are essential (such as keeping track of the products in your shopping cart) and some cookies are there to improve your experience. We may also use cookies to test new pages, features or new functionality of the website to see how our users react to them.
• Web beacons. Certain sections of our service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Please read our cookie policy for more information.

3.4 Behavioral remarketing

We use re-marketing services to advertise to you after you have accessed or visited our service. We and our third-party vendors use cookies and non-cookie technologies to help us recognize your device and understand how you use our service so that we can improve our service to reflect your interests and serve you advertisements that are likely to be of more interest to you. These third-party vendors collect, store, use, process and transfer information about your activity on our service in accordance with their privacy policies and to enable us to (1) measure and analyze traffic and browsing activity on our service, (2) show advertisements for our products and/or services to you on third-party websites or apps and (3) measure and analyze the performance of our advertising campaigns.

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest-based advertising: the NAI's opt-out platform, the EDAA's opt-out platform and the DAA's opt-out platform. You may opt-out of all personalized advertising by enabling privacy features on your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See your mobile device help system for more information.

We may share (pseudonymous) information, such as hashed email addresses (if available) or other online identifiers collected on our service with these third-party vendors. This allows our third-party vendors to recognize and deliver you ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities, please refer to the privacy policy of each vendor in section 4.1.

Google also recommends installing the Google Analytics Opt-out Browser Add-on - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

4. Data processing

We may process personal data under the following conditions:

• Consent: You have given your consent for processing personal data for one or more specific purposes.
• Performance of a contract: provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
• Legal obligations: processing personal data is necessary for compliance with a legal obligation to which the company is subject.
• Vital interests: processing personal data is necessary in order to protect your vital interests or those of another natural person.
• Public interests: processing personal data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the company.
• Legitimate interests: processing personal data is necessary for the purposes of the legitimate interests pursued by the company.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

We may use personal data for the following purposes:

• To provide and maintain our service, including to monitor the usage of our service.
• To manage your account: to manage your registration as a user of the service. The personal data you provide can give you access to different functionalities of the service that are available to you as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the service.
• To contact you: to contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To process payments: we will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
• To provide "direct marketing": news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you haven't opted in to receive such information. Transactional communications about your account or our services are not considered "direct marketing" communications. You can opt-out, by clicking an unsubscribe link in these emails.
• To manage your requests: to attend and manage your requests to us.
• To deliver targeted advertising to you: we may use your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to your interests and/or location and to measure its effectiveness.
• For business transfers: we may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our service users is among the assets transferred.
• To comply with various legal obligations, including tax obligations and to protect our property rights.
• For statistical and strategic use: we use the personal and usage data, as described in section 3.1, to conduct aggregated analyses for internal research and statistical and strategic purposes ("aggregated information"). This aggregated information does not identify you. We use the aggregated information to optimize our website, services and products and learn more about the use of our website and products so we can improve them.
• For other purposes: we may use your information for other purposes, such as data analysis, fraud prevention, improving security, identifying usage trends, generating recommender systems, determining the effectiveness of our promotional campaigns and to evaluate and improve our service, products, services, marketing and your experience.

We may share your personal information in the following situations:

• For business transfers: we may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• For retail purposes: we may transfer your personal data and the information to our retail stores
• With service providers, affiliates and/or business partners: we may share your information with our service providers, affiliates and/or, partners, in which case we will require those to honor this privacy policy and any such third parties are also made parties to data processing agreements. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us. We may share your personal information with service providers to, including but not limited to, monitor and analyze the use of our service, prevent fraud, to advertise on third party websites to you after you visited our service, for payment processing, and/or to contact you. Please see our record of processing activities for a breakdown.
• With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a third-party social media service, your contacts on the third-party social media service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.
• With your consent: we may disclose your personal information for any other purpose with your consent if required by law.

4.1 Processing activities

We've created an overview of all or processing activities, including the reason why we process certain data and for how long.

5. Retention

We retain your personal data as long as we are providing the services to you. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain aggregated usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time (e.g. so-called server debug log entries are removed within one month), except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods. If you unsubscribe from our marketing communications we will add your contact information to our suppression list indefinitely to respect your unsubscribe request.

You have the right to ask us to delete or remove personal data when there is no good reason for us to continue processing it.

If you have questions about retention periods that apply to any other data, please contact us at dpo@routinely.com.

6. Transfers

Your information, including personal data, is processed at the company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. Your consent to this privacy policy followed by your submission of such information represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place (e.g. EU-US Privacy Shield certification or an EU-approved code of conduct or certification) including the security of your data and other personal information. Some countries outside the European Economic Area (EEA) are recognized by the European Commission as countries where an appropriate level of data protection applies conforming to the EEA standards (see full list here).

If we are involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different privacy policy.

We will never sell your data.

7. Disclosure

Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). We may disclose your personal data in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of the company, prevent or investigate possible wrongdoing in connection with the service, protect the personal safety of users of the service or the public and protect against legal liability.

8. Security

Personal information we process is treated as confidential. The security of your personal data is important to us, but remember that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means (i.e. reasonable and appropriate physical, electronic, and administrative safeguards) to protect your personal data, we cannot guarantee its absolute security (i.e. accidental or unlawful destruction, alteration, loss, unauthorized disclosure or access or against any other unlawful or unauthorized processing of such personal data).

9. Use by minors

We recognize that some data protection laws vary based on the age of consent. Depending on the jurisdiction, the age of consent can be between 13 to 16 years old. Our services are not intended for use by persons under the age of 16. If you are younger than 16 years of age, you cannot make use of the services and you must refrain from providing personal data. If we are aware of or suspect that a data subject is under the age of consent, we will require the data subject to terminate their account and we will take steps to delete the data as soon as possible. Please notify us if you know of any individuals under the age of consent using our services.

10. Changes to this policy

We may change our privacy policy at any time and the changes will apply to any personal information we already hold and to any new personal information collected after the change happens. If we make any material changes to this policy, we will endeavor to notify you by email or by posting a prominent notice on the services prior to the change becoming effective. We recommend you to periodically review this page for the latest information on our privacy practices. Your continued use of our services after the effective date of this policy constitutes an acceptance of the amended terms. You may refer to the "Last Updated" date of this Policy to determine if the policy has changed since your last visit.

11. Your rights

You have the right under this privacy policy, and by law if you are within the EU, to:

• Request access to your personal data. The right to access, update or delete the information we have on you. Whenever possible, you can access, update or request deletion of your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the personal data we hold about you.
• Request correction of the personal data that we hold about you. You have the right to to have any incomplete or inaccurate information we hold about you corrected.
• Object to processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your personal data on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request erasure of your personal data. You have the right to ask us to delete or remove personal data when there is no good reason for us to continue processing it. We follow the Notice And Takedown code of conduct for removal requests.
• Request the transfer of your personal data. We will provide to you, or to a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw your consent. You have the right to withdraw your consent on using your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the service.

Your rights to your personal data are not without limits. Access may be denied when required by law, granting access would have a negative impact on other's privacy, to protect our rights and properties, and when the request is frivolous or vexatious.

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible. You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA. To exercise your rights, please contact our data protection officer (DPO) via the details below.

12. Links to other websites

Our service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

13. Data protection officer

We have voluntary appointed a data protection officer (Dutch: 'functionaris gegevensbescherming') at the Dutch privacy authority (https://autoriteitpersoonsgegevens.nl) with registration number FG012537.

14. Data breach

In case of a data breach, we follow the guidelines set forth by the Dutch privacy authority at https://autoriteitpersoonsgegevens.nl/nl/onderwerpen/beveiliging/meldplicht-datalekken. This means we will notice affected users and inform the privacy authority within 72 hours depending on whether their guidelines indicate a high risk. Data breached are filed in a data breach register.

15. Contact us

If you have any questions about this privacy policy, you can contact us via email at dpo@routinely.com, or at:

Skin Faculty B.V.
Keizersgracht 316-bel
1016 EZ Amsterdam
The Netherlands