Last updated: May 18, 2021
At Routinely, a Skin Faculty B.V. brand (hereinafter, "Routinely", "company", "us", "our", or "we"), we respect and protect the privacy of visitors to our website, users of our mobile app, www.routinely.com (https://www.routinely.com/), and the other websites under the routinely.com (https://routinely.com/) domain (collectively, the "sites"), and our customers who use our website, mobile app and related services (together with the sites, the "service"). This privacy policy describes our policies and procedures on the collection, use and disclosure of your information when you use the service and tells you about your privacy rights and how the law protects you. We use your personal data to provide and improve the service.
Terms that are not defined in this policy are given meaning in our terms of service.
By using the service, you agree to the collection and use of information in accordance with this privacy policy. If you do not agree with or you are not comfortable with any aspect of this privacy policy, you should immediately discontinue access or use of our services.
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 Keizersgracht 316-bel, 1016 EZ, Amsterdam, The Netherlands and registered at the Chamber of Commerce in the Netherlands with the number 78091640.
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.
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.
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.
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:
Please read our cookie policy for more information.
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.
We may process personal data under the following conditions:
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:
We may share your personal information in the following situations:
We've created an overview of all or processing activities, including the reason why we process certain data and for how long.
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.
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.
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.
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).
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.
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.
You have the right under this privacy policy, and by law if you are within the EU, to:
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.
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.
We have voluntary appointed a data protection officer (Dutch: 'functionaris gegevensbescherming') at the Dutch privacy authority (https://autoriteitpersoonsgegevens.nl) with registration number FG012537.
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.
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