Privacy Policy

1.  Scope and updates of this User Privacy Notice

This User Privacy Notice applies to your use of this website and all Skinholy applications, services (including payment services), products and tools (collectively the "Services"), regardless of how you access or use these Services, including access via mobile devices and apps.

We may change this User Privacy Notice at any time by posting the revised User Privacy Notice on this website and indicating the effective date of the revised User Privacy Notice. You will be notified of any material changes to this User Privacy Notice via email.

2. Controller

Which Skinholy group company is responsible for the collection and processing of your personal data in connection with the provision of the Services depends on how you use our Services.

2.1 Use of the Services

Depending on the region in which you are located, one of the following Skinholy group companies is responsible for the collection and processing of your personal data in connection with the provision of our Services (except payment services for sellers):

• Skinholy LLC, 1151 Walker Rd #407 Dover, DE 19904

2.2 Use of the payment services for sellers

Depending on the region in which you are located and whether we provide our payment services there, the following Skinholy group companies are responsible for the collection and processing of your personal data in connection with the provision of our payment services to sellers:

• Skinholy, 1151 Walker Rd #407 Dover, DE 19904

 As described in our Payments Terms of Use, your personal data may be processed by one or more of these companies depending on your location and the location of the Skinholy website on which a user completes a transaction with you.

3.  Data protection officer and contact

If you have any questions about this User Privacy Notice or about data protection at Skinholy in general, you can contact the data protection officer responsible at any time. 

 Furthermore, if you have any questions or complaints regarding this User Privacy Notice, our data protection principles or our handling of personal data, you can also contact the Skinholy Privacy Team.

4.  What personal data we collect and process

We collect your personal data when you use our Services, create a new Skinholy account, provide us with information via a web form, add or update information in your Skinholy account, participate in online community discussions or otherwise interact with us. We also collect personal data from other sources (such as other Skinholy corporate family members, credit agencies or bureaus, and other data brokers).

We collect the following personal data:

4.1 Personal data you provide when using our Services or creating an Skinholy account

• Data that identifies you, such as your name, address, telephone numbers, email addresses, your user name or your tax identification number that you provide when setting up your Skinholy account or at a later date.
• If you use our payment services as a seller, additional identification data (such as social security number or date of birth), tax identification numbers and other information (such as bank account number) that you provide when using our payment services as a seller.
• Data regarding purchases, or sales that you provide in a transaction.
• Content that you share with other users through our messaging tools
• Financial information (e.g. credit card and account numbers, transaction details, and form of payment).
• Shipping, billing, and other information you provide, as well as information required for customs clearance (such as tax identification numbers or other identification numbers) and relevant shipping information (such as shipment numbers and tracking information) if shipped through one of our programs.
• In some cases: age, gender, country of birth, nationality, employment status, family status, interests and preferences.
• You may provide us with additional information through a web form or by updating or adding information to your Skinholy account, by participating in community discussions, member chats, inquiries, dispute resolution, customer service calls recorded with your consent, or if you contact us for any other reason regarding our Services.
• Other data that we are required or entitled by applicable law to collect and process and that we need for your authentication or identification, or for the verification of the data we collect.

4.2 Personal data we collect automatically when you use our Services or create an Skinholy account

• Data that is generated as part of one of your transactions (bids, purchases, sales) or that is linked to your Skinholy account as a result of a transaction in which you are involved, such as transaction amounts, time and location of transactions and form of payment or payout method.
• Data that is generated through your other actions when you use our Services and which is linked to your Skinholy account, e.g. when you place items in your shopping cart, place items on the watch list, save sellers, searches or interests, or follow users.
• Data regarding all other interactions with our Services, your advertising preferences, and your communications with us.
• Location data, including your general location data (e.g., IP address) and the precise location data of your mobile device. Please note that for most mobile devices, you can manage or disable the use of location services for all applications in the settings menu of your mobile device.
• Computer and connection information, such as statistics regarding your use of services from Skinholy, information on data traffic to and from websites, referral URL, information on advertisements, your IP address, your access times, your browser history data, your language settings and your weblog information.

4.3 Personal data we collect in connection with the use of cookies and similar technologies

We use cookies, web beacons and similar technologies to collect data while you use our Services. We collect this data from the devices (including mobile devices) that you use our Services with. The data collected includes the following usage- and device-related information:

• Data about the pages you visit, the access time, frequency and duration of visits, the links on which you click and other actions you take as part of your use of our Services and in advertising and email content.
• Data about your activities and interactions with our advertising partners including data about the advertisements you were shown, how often they were shown, when and where they were shown, and whether you took any action, such as clicking on an advertisement or making a purchase.
• The user segment or category into which you as a user fall, for example: male, 20-49 years old, interested in cars.
• Model or device type, operating system and version, browser type and settings, device ID or individual device identifier, advertisement ID, individual device token, and cookie-related data (e.g. cookie ID).
• The IP address from which your device accesses the Services.
• Location data, including your general location data (e.g., IP address) and the precise location data of your mobile device. Please note that most mobile devices allow you to manage or disable the use of location services for all applications in the settings menu.

 

4.4 Personal data from other sources

We also collect personal data about you from other sources and from third parties to the extent permitted by applicable law. In particular, this includes the following data:

• Data from public sources (e.g. demographic data)
• Data from credit agencies or bureaus (e.g. credit reports/checks, identity confirmation, data for risk modeling and setting of credit limits)
• Data from data providers (e.g. "Know Your Customer"/identity verification, demographic, interest-based and online advertising related data)
• With regard to our payment services for sellers: data from government or other sources concerning any previous convictions of the respective seller, to the extent permitted by applicable law

 

We combine or connect the personal data we collect from you with data from these other sources. Where personal data is disclosed to us by third parties that these third parties are legally permitted to disclose your personal data to us. We also receive access to personal data about you from other members of the Skinholy LLC corporate family.

4.5 Social network data you share with us

• We allow you to use social networks (such as Facebook) or other providers of single sign-on services (such as Google or Apple) with whom you already have an account to create an Skinholy account or to link your Skinholy account to such single sign-on services.  You can determine the personal data that we can access when authorizing the connection with the single sign-on service.
• We allow you to share personal data with social networks (such as Facebook) or to link your Skinholy account to a social network. These social networks may automatically provide us with access to certain personal data they have stored about you (e.g. content you have viewed or enjoyed, information about the advertisements you have been shown or clicked on, etc.). You can determine the personal data that we can access through the privacy settings of each social network.
• If you give us access to video content pages, your grant of access is your consent that we may, for at least two years, or until you withdraw your consent or are no longer connected to the social network, share with and collect from social networks information regarding your viewing of videos.
• We may also use plug-ins or other technologies from various social networks. If you click on a link displayed through a social network plug-in, you voluntarily connect to that social network.

5. Purposes and legal basis for data processing and categories of recipients

We process your personal data for various purposes and based on several different legal bases that allow this processing. For example, we process your personal data to provide and improve our Services, to provide you with a personalized user experience on this website, to contact you about your Skinholy account and our Services, to provide customer service, to provide you with personalized advertising and marketing communications, and to detect, prevent, mitigate and investigate fraudulent or illegal activity. We also share your information with third parties, including service providers acting on our behalf, for these purposes. In addition, we may share your personal data among Skinholy group companies in order to fulfil our contract with you under the User Agreement and, if applicable, the Payments Terms of Use.

5.1 We process your personal data in order to fulfil our contract with you and to provide you with our Services. This includes the following purposes:

• Processing of data relating to you or your company for the purpose of entering into a contract with you and executing it.
• Provision of our Services, including but not limited to enabling and performing transactions with other users (including the transmission of your personal data to other users where necessary to perform the transaction, including in cases of terminated, failed or subsequently voided transactions, e.g. by sharing your return address so a buyer may return an item), displaying your transaction and feedback history to you, providing and enhancing features such as payment processing, ratings and Skinholy account management, providing other services you may use (as described in connection with such services), and ensuring the functionality of our Services. In connection with the provision of our Services, we will send you notifications relating to the execution of transactions and the use of our Services in accordance with the communication preferences in your Skinholy account.
• Enabling the delivery of purchased items by logistics/shipping service providers including notifications in connection with the delivery (such as tracking information), the latter to the extent permitted by applicable law without your consent.
• Provision of our payment services in accordance with the Payments Terms of Use.
• Providing general customer support including the solution of problems with your Skinholy account, arbitration of disputes, providing other services within the scope of customer service as well as enforcement of fee claims. For these purposes, we may contact you via notification in My Skinholy, email, telephone, SMS, push notification on your mobile device or by mail. If we contact you by telephone, in order to ensure efficiency, we may use automatically dialed calls with tape announcements or automated text messages in accordance with our User Agreement and Payments Terms of Use, to the extent permitted by applicable law.
• Processing of general location data (such as IP address or postal code) in order to provide you with location-based services (such as radius search and other content that is personalized on the basis of your general location data).
• Enforcement of our User Agreement, Payments Terms of Use, this User Privacy Notice and other rules and policies.

Publication and promotion of your listings and related content on the websites or in the applications, services and tools of other Skinholy LLC corporate family members or cooperating third party operators of websites, applications, services and tools. When we share the content of your listings and any related personal data with third parties, we do so only on the basis of an agreement that limits the use of such personal data by the third party to the purposes necessary to fulfil its contractual obligations to us. Third party providers are contractually obliged to take appropriate security measures with regard to this data. Third party providers are strictly forbidden to pass on personal data contained in your listings to other third parties. 

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

• Other Skinholy users
• Skinholy LLC. corporate family members
• External service providers and shipping companies (such as DHL, UPS, etc.)
• Payment service providers including the PayPal Inc., Shopify Payments and Stripe. group of companies
• External operators of websites, applications, services and tools

5.2 We process your personal data in order to comply with legal obligations to which we are subject. This includes the following purposes:

• Participation in investigations and proceedings (including judicial proceedings) conducted by public authorities or government agencies, in particular, for the purpose of detecting, investigating and prosecuting illegal acts.
• Prevention, detection and mitigation of illegal activities (e.g. fraud, money laundering and terrorist financing).
• Complying with information requests from third parties based on any statutory information rights they have against us (e.g. in the event of an intellectual property infringement, product piracy, or other unlawful activity).
• Ensuring the information security of our Services.
• Retention and storage of your personal data to comply with specific legal retention requirements.

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

• Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or supranational bodies (in connection with our payment services provided in the EU for sellers in particular with regard to compliance with Luxembourg laws concerning FATCA dated July 7, 2015 and concerning the OECD Common Reporting Standard dated December 18, 2015).
• Third parties based on statutory information claims against us
• Third party service providers
• Third parties who are involved in judicial proceedings, in particular, if they submit a legal order, court order or equivalent legal order to us.
• Credit agencies, bureaus, or associations, if required by applicable law (e.g. information on payment delays, payment defaults or other irregularities that may be relevant to your credit report).
• Skinholy LLC. corporate family members

5.3 We process your personal data in order to protect your vital interests or the vital interests of another natural person. This includes the following purposes:

• Prevention, detection, mitigation and investigation of unlawful activities that may result in impairment of your vital interests or the vital interests of another natural person, unless there is a statutory obligation to this effect.

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

• Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or supranational bodies
• Third parties who are involved in judicial proceedings
• Skinholy LLC corporate family members
• External service providers

5.4 We process your personal data where necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. In order to reconcile our legitimate interests with your rights, we have introduced appropriate control mechanisms. On this basis, we process your data for the following purposes:

• Participation in proceedings (including judicial proceedings) conducted by courts, law enforcement agencies, government agencies or public authorities, intergovernmental or supranational bodies, in particular for the purpose of detecting, investigating and prosecuting illegal acts, unless there is a statutory obligation to this effect, and we may legitimately assume that the disclosure of the data is necessary to avert imminent disadvantages or to report a suspicion of an illegal act. In such cases, we will only disclose what we believe is necessary, such as your name, city, zip code, telephone number, email address, (previous) user names, IP address, fraud complaints, bidding and listing history.
• Protection of the legitimate interests of third parties in connection with civil law disputes, unless there is a statutory obligation to this effect, if we may legitimately assume that it is necessary to disclose the data to such third parties in order to avert imminent disadvantages.
• Prevention, detection, mitigation and investigation of fraud, security breaches and other prohibited or unlawful activities, including the assessment of corresponding risks (e.g. through the use of captchas or the telephone number stored in your Skinholy account for two-factor authentication), unless there is a statutory obligation to this effect.
• Monitoring and improvement of the information security of our Services, unless there is a statutory obligation to this effect.
• Performance of identity checks, creditworthiness and other financial standing checks, evaluation of applications and comparison of information for accuracy and verification purposes.
• Automatic filtering and, where necessary, manual review of messages sent through our messaging tools to prevent fraudulent or suspicious activity or violations of our User Agreement
• Provision of functions for users that make the processing of transactions easier or more convenient (e.g. administration of several delivery addresses).
• Analysis and improvement of the Services from Skinholy LLC corporate family members, e.g. by reviewing site usage data or information from users about blocked or crashed pages in order to identify and solve problems and to provide you with an improved user experience, including as part of product development.
• Analysis of telephone conversations with our customer service that we recorded with your consent.
• Advertisements by mail (according to your communication preferences in your Skinholy account).
• To the extent permitted by applicable law without your consent, communications with you via electronic mail (e.g. email or text message) or telephone to offer you vouchers, discounts and special offers, to conduct opinion polls and surveys, and to inform you about our Services (according to your communication preferences in your Skinholy account). If you do not wish to receive marketing communications from us, you can also unsubscribe by clicking on the link in the email you received. For technical reasons, the implementation may take a few days.
• Notifications regarding promotions and information about our Services after logging into your account (according to your communication preferences in your Skinholy account).
• Personalization, measurement and improvement of our and third party advertisements in our online offerings, the online offerings of other Skinholy LLC corporate family members or third parties.
• Customization of page content to display the items and services you may like based on the actions you take.
• Evaluation of the quality and success of our email marketing campaigns (e.g. through analysis of opening and click rates).
• Assessment of the service status (e.g. on the basis of tracking information if sellers use shipping labels from shipping providers via Skinholy or provide tracking numbers).
• Offering of partner and bonus programs and other co-branded marketing efforts, e.g. co-branded credit cards in collaboration with a third party credit card issuer.
• Provision of shared content and services (such as registration for services, transaction processing and customer service) with Skinholy LLC corporate family members or cooperating payment service providers.
• Initiation, preparation and execution of a company acquisition, e.g. in the event of a merger with another company or takeover by another company. If such an event occurs, we will require the merged entity to comply with this User Privacy Notice with respect to your personal data. Should your personal data be processed for any purpose not specified in this User Privacy Notice, you will be informed in advance of the processing of your data for this new purpose.
• Assertion of or defense against legal claims, including those asserted by one Skinholy user against another Skinholy user.

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

• Skinholy LLC corporate family members
• External service providers
• Other Skinholy users
• Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or supranational bodies
• Third parties who are involved in judicial proceedings
• Payment service providers including the PayPal Inc., Shopify Payments and Stripe Inc. group of companies
• Credit agencies or bureaus, data verification services, risk assessment vendors and collections agencies (e.g. information about payment delays, payment defaults, or other irregularities that may be relevant to your credit report, or that we use to confirm your identity, model risk, establish credit limits, or collect unpaid debts)
• Other companies in the context of a company acquisition
• In the event of an investigation for fraud, intellectual property infringement, retail crime, stolen goods, product piracy or other unlawful activity, if we, in our sole discretion, deem the investigation of such incident necessary or useful. In such cases, we will disclose the seller's name, address, city, zip code, country, telephone number, email address and company name to the third party and bind the third party by a worldwide non-disclosure agreement to treat the data as confidential.

5.5 With your consent, we process your personal data for the following purposes:

• Marketing communications by telephone or electronic mail (such as email or SMS), including communications by other Skinholy LLC corporate family members or by third parties, unless these communications are permitted without your consent under applicable law. We may engage third parties to send marketing communications on our behalf
• Processing of your precise location data to provide location-based services
• Provision of a single sign-on service allowing you to register or log-in to third party services using your Skinholy log-in credentials
• Processing of your personal data on the basis of your consent, which you have given so that we or third parties can enable you to use certain services or make them available to you
• You can opt out of sales of personal information at any time

 Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

• Skinholy LLC corporate family members
• External service providers
• Third parties using our single sign-on service (as authorized by you in each single case)
• Other third parties with whom we partner to offer you specific services (as described at the collection of the respective user consent)
• Third party financial institutions with whom we partner to offer financial products to you, for them to provide joint content and services (such as, registration, transactions and customer support). These third party financial institution partners will use your personal data to send you marketing communications only if you have requested their services

5.6 Data Sharing between Skinholy LLC Corporate Family Members

As set out above under "Personal data from other sources", we also receive access to personal data about you from other Skinholy LLC corporate family members. This enables us, in particular, to provide you, with your consent as legally required, with information about products and services, which we believe might interest you, and improve our products, services, content, and advertising by analyzing your use of the services of other Skinholy LLC corporate family members, in particular through the matching of certain data (e.g. cookie IDs). Furthermore, this allows us to better prevent, detect, mitigate and investigate fraud, security breaches and other prohibited or unlawful activities, including the assessment of corresponding risks. We will also grant access to personal data about you to other Skinholy LLC corporate family members for the aforementioned purposes. To the extent that other Skinholy LLC corporate family members have access to your personal data, they will follow practices that are at least as restrictive as the practices described in this User Privacy Notice.

5.7 Additional information regarding our payment services for sellers

With regard to our payment services for sellers in the EU, we additionally point out that Skinholy is subject to professional secrecy, which requires special transparency with regard to the processing and, in particular, the transmission of your personal data. We therefore expressly draw your attention to the fact that Skinholy may pass on your personal data to trustworthy third parties and business partners where necessary to provide our payment services for sellers, as described above in this Section 5 of the User Privacy Notice. This includes in particular the following third parties and business partners:

• Other payment service providers, including financial institutions
• Companies offering financial products, analyses and scoring (e.g. credit agencies or bureaus)
• Authorities, agencies and other governmental bodies (e.g. to combat fraud)
• Auditors and other professional advisors

You can request a complete list of all third party providers and business partners for our payment services for sellers outside of US by contacting us.

5.8 Automated decision-making

We use technologies that are considered automated decision making or profiling. We will not make any automated decisions about you that would significantly affect you unless such a decision is necessary for entering into, or the performance of, a contract with you, we have obtained your consent, or we are required by applicable law to use such technology. You will find information on your right to object to this processing of your data below under Rights as a data subject.

6.  International data transfers

Some recipients of your personal data are located outside your country or have offices in countries where data protection laws may provide a different level of protection than the laws in your country. When transferring personal data to such recipients, we provide appropriate safeguards.

6.1 Data transfers to Skinholy LLC corporate family members

The transmission of personal data between different Skinholy LLC corporate family members (e.g. to enable cross border transactions and for other legally permitted purposes) is based on our worldwide data protection principles, which are binding internal data protection regulations (Binding Corporate Rules, BCRs), or on the basis of other appropriate safeguards (e.g. standard data protection clauses issued or approved by the European Commission (2010/87/EU, 2001/497/EC or 2004/915/EC)). Through our Binding Corporate Rules, the Skinholy LLC corporate family members undertake to protect your personal data and to comply with data protection obligations. Further information on our binding company-wide guidelines and our worldwide data protection principles can be found in the Skinholy Privacy section. 

6.2 Other data transfers (from the European Economic Area to third countries)

We will only transfer your personal data from the European Economic Area (EEA) to third countries, i.e. countries outside the EEA, on the basis of appropriate safeguards.

7.  Storage duration and erasure 

Your personal data will be stored by us and our service providers in accordance with applicable data protection laws to the extent necessary for the processing purposes set out in this User Privacy Notice. Subsequently, we will delete your personal data in accordance with our data retention and deletion policy or take steps to properly render the data anonymous, unless we are legally obliged to keep your personal data longer (e.g. for legal compliance, tax, accounting or auditing purposes). As far as legally permissible or required, we restrict the processing of your data instead of deleting it (e.g. by restricting access to it). This applies in particular to cases where we may still need the data for the execution of the contract or for the assertion of or defense against legal claims, or where such retention is otherwise required or permitted by law. In these cases, the duration of the restriction of processing depends on the respective statutory limitation or retention periods. The data will be deleted after the relevant limitation or retention periods have expired.

The specific retention periods for personal data are documented in our regional data retention guidelines. How long we retain personal data may vary depending on the Services we provide and our legal obligations under applicable national law. The following factors typically affect the retention period:

• Necessity for the provision of our Services
  This includes such things as executing the User Agreement with you, maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. Most of our retention periods are determined on the basis of this general rule.
• Special categories of personal data
  If we store special categories of personal data (i.e., personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data which is being processed for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation), a shorter retention period is usually appropriate.
• Consent-based processing of personal data
  If we process personal data on the basis of consent (including consent to the extended storage), we store the data for as long as necessary in order to process it according to your consent.
• Statutory, contractual or other similar obligations
  Corresponding storage obligations may arise, for example, from laws or official orders. It may also be necessary to store personal data with regard to pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law.

8.  Rights as a data subject

Subject to possible restrictions under national law, as a data subject, you have the right to access, rectification, erasure, restriction of processing and data portability with regard to your personal data. In addition, you can withdraw your consent and object to our processing of your personal data on the basis of our legitimate interests. You can also lodge a complaint with a supervisory authority.

Your rights in detail:

• You can withdraw your consent to the processing of your personal data by us at any time. As a result, we may no longer process your personal data based on this consent in the future. The withdrawal of consent has no effect on the lawfulness of processing based on consent before its withdrawal.
• You have the right to obtain access to your personal data that is being processed by us. In particular, you may request information on the purposes of the processing, the categories of personal data concerned, the categories of recipients to whom the personal data have been or will be disclosed, the envisaged period for which the personal data will be stored, the existence of the right to request rectification or erasure of personal data or restriction of processing of personal data or to object to such processing, the right to lodge a complaint with a supervisory authority, any available information as to the personal data’s source (where they are not collected from you), the existence of automated decision-making, including profiling and, where appropriate, meaningful information on its details. Your right to access may be limited by national law.
• You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
• You have the right to obtain from us the erasure of personal data concerning you, unless processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims. The right to erasure may be limited by national law.
• You have the right to obtain from us restriction of processing to the extent that
• the accuracy of the data is disputed by you,
• the processing is unlawful, but you oppose the erasure of the personal data,
• we no longer need the data, but you need it to assert, exercise or defend legal claims or
• you have objected to the processing.
• You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller ("right to data portability").
• You have the right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence, your place of work or the registered office of the controller.

The exercise of the above data subjects' rights (e.g. right to access or erasure) is generally free of charge. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge an appropriate fee (at most our actual costs) in accordance with the applicable statutory regulations or refuse to process the application.

Exercising your rights and managing your settings

You can exercise your rights as a data subject via our Privacy Contact page. In addition, you are of course free to contact us. If you would like to change your preferences regarding Skinholy notifications (including marketing communications), you can do so at any time via Skinholy website. If you do not wish to receive marketing communications from us, you can also unsubscribe by clicking on the link in the email you received. For technical reasons, the implementation may take a few days. 

9.  Cookies & similar technologies

When you use our Services, we and selected third parties may use cookies and similar technologies to provide you with a better, faster and safer user experience or to show you personalized advertising. Cookies are small text files that are automatically created by your browser and stored on your device when you use the Services.

Our cookies and similar technologies have different functions:

• They may be technically necessary for the provision of our Services
• They help us optimize our Services technically (e.g. monitoring of error messages and loading times)
• They help us improve your user experience (e.g. save font size and form data entered)
• They allow us to show you more relevant advertisements

We use cookies and similar technologies that remain on your device only as long as your browser is active (session cookies), as well as cookies and similar technologies that remain on your device longer (persistent cookies). Where possible, we take appropriate security measures to prevent unauthorized access to our cookies and similar technologies. A unique ID ensures that only we and/or selected third parties have access to cookie data.

Your choices regarding cookies

You are free to disable the use of cookies and similar technologies if this is supported by your device. You can manage your cookie settings in your browser or device settings. In addition, you can decide whether we may use cookies and similar technologies to show you personalized advertisements:

• To manage the settings regarding the use of first-party cookies (and similar technologies) for advertising-related purposes, please go to Advertising Preferences
• You can find information about third-party cookies (and similar technologies) related to advertising and how to prevent their use on the following websites:
• www.youronlinechoices.eu
• www.aboutads.info/choices (only available in English)
• www.networkadvertising.org/choices (only available in English)
• Users in the European Economic Area (EEA) can also use Advertising and related preferences to determine to what extent they consent to the processing of their personal data for advertising purposes via cookies (and similar technologies)

If you decide not to have your personal data processed by us for advertising purposes via cookies (and similar technologies), this does not mean that we will not show you advertisements. It simply means that these advertisements will not be personalized for you using first-party or third-party cookies, web beacons, or similar technologies.

10.  Data security

We protect your personal data through technical and organizational security measures to minimize risks associated with data loss, misuse, unauthorized access and unauthorized disclosure and alteration. To this end we use firewalls and data encryption, for example, as well as physical access restrictions for our data centers and authorization controls for data access.  

Keeping you and your personal information secure is very important to us. We take a number of reasonable steps to try to protect the personal information that you provide, including:

- • Using a Transport Layer Secure (TLS) to encrypt the personal data that you send us during the order process (including any financial information such as credit or debit card details).

- • Requiring you to establish a unique username and password to access your account on our website.

- • Not keeping details of your credit or debit card that would enable any third party to transact using that credit or debit card (such as your CVV number).

- • Regularly monitoring our servers and IT systems for possible vulnerabilities and attacks. Unfortunately, despite this, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your personal data transmitted to or through our website, and any such transmission is at your own risk. In particular, please keep in mind that if you voluntarily disclose personal information through other means of communication than the website in a non-protected environment (such as through email, sms, online messages) then that information can be collected and used by others outside of our or your control.

11.  Other important information regarding data protection

This section contains important additional information about the protection of personal data in connection with the use of our Services, including whether you are required to provide personal data.

What happens when you share your personal data on our sites or applications?

Other users have access to the information you share on Skinholy or disclose to other users. For example, other users can see your bids, purchases, items for sale, saved interests, sellers and searches, storefronts, feedback, ratings, product reviews and associated comments. Other users can also see any information you chose to share in your profile.

When you use our Services, your public user ID may be displayed and available to the public and associated with all of your public Skinholy activity. Notices sent to other users about suspicious activity and notice violations on our sites may refer to your public user ID and specific items. Accordingly, if you use a username that allows others to identify you, these others may be able to identify your Skinholy activities.

To help protect your personal data, we allow only limited access to other users' contact, shipping and financial information as necessary to facilitate your transactions and collect payments. However, when users are involved in a transaction, they have access to each other's name, user ID, email address and other contact and shipping information. For example, we may allow users to exchange telephone numbers in order to contact each other prior to completing a transaction (e.g. a seller may opt to share their telephone number with a buyer so that the buyer may call with questions about a listed item). In this case, sellers are prohibited from using a buyer's telephone number for other purposes (e.g. completing a transaction off Skinholy or adding the buyer to a marketing list).

Your responsibilities over transactional information you receive through Skinholy

When you complete a transaction with another user (or a transaction has been cancelled, failed, or subsequently invalidated), we will provide you with the other user's personal data (such as name, username, email address, contact information, shipping and billing information, or return address). Independent from us, you are the controller of such data and responsible for any processing that you perform after we have shared this data with you, including compliance with any limitations imposed by this User Privacy Notice and our User Agreement.

Unless you act for purely personal purposes, we recommend that you explain your data processing activities in your own privacy notice and protect the privacy of other users. As a seller, you must in any case comply with the applicable data protection laws and in particular protect the rights of other users as data subjects, e.g. give them the opportunity to access the personal data collected by you and demand that it be erased.

You may only use the personal data that you have access to for Skinholy transaction-related purposes, or for other Services offered through Skinholy (such as shipping, fraud complaints, and member-to-member communications), and for purposes expressly consented by the user to whom the data relates. Using personal data of other users that you have access to for any other purpose, such as adding them to a mailing list without their express consent, constitutes a violation of our User Agreement.

Personal data relating to third parties

If you provide us with personal data relating to another person, you must obtain the consent of this person or the disclosure of the data to us must be otherwise legally permissible. You must inform the other person of how we process personal data in accordance with our User Privacy Notice.

Filtering of messages sent via our messaging tools

All messages sent via our messaging tools are first received by us and then forwarded to the recipient. All messages are automatically filtered according to certain criteria. 

 

This is to protect our legitimate interests such as protecting against fraudulent or suspicious activities (e.g. spam, viruses, phishing, or other illegal activities) or enforcing our User Agreement and our other rules and policies (e.g. illegal and other prohibited content), including but not limited to enforcing the prohibition of purchases and sales outside of Skinholy.

 

Are you obliged to provide your personal data to us?

Some of the personal data that you provide to us (e.g. data by which we can identify you) are required to enter into the User Agreement and the Payments Terms of Use. For example, under the Payments Terms of Use you must provide us with certain identification information including legal name, date of birth, and tax identification number or social security number so that we may fulfil our legal "Know Your Customer" (KYC) obligations. As described elsewhere in our User Privacy Notice and in the Payments Terms of Use, we may share this data with other Skinholy group companies in order to facilitate transactions and with service providers, including payment processors, credit agencies and bureaus. Although the provision of any other personal data (e.g. address and shipping data) is voluntary, it may be necessary for the use of our Services, such as bidding, purchase and sales data to complete a transaction.

Children's Privacy

Our services are not intended for the use by children. We do not knowingly collect personal data from users who are considered children under applicable national laws. Under our User Agreement, children are not permitted to use our Services.

Staying Signed in

When you sign in to your account on our Services, we give you the option to stay signed in to your account for certain amount of time. If you are using a public or shared computer, we encourage you to decline. You or any other user of the computer/browser you signed in on will be able to view and access most parts of your account and take certain specific actions during this signed in period without any further authorization. The specific actions and account activities that you or any other user of this computer/browser may take include:

• Bid, buy or make an offer on an item
• Check out or add items to your cart
• Purchase an item with PayPal Inc., Shopify Payments and Stripe using Faster Checkout (if enabled in your account)
• View the activity header
• View the Skinholy page
• View or edit the Watch List or order details
• View the profile page
• Send member-to-member messages
• Conduct after-sale activities, like leaving feedback, canceling orders, requesting returns or submitting claims

If you attempt to change your password or user ID, update any other account information or attempt other account activity beyond those listed above, you may be required to enter your password.

You can typically end your signed in session by either signing out and/or clearing your cookies. If you have certain browser privacy settings enabled, simply closing your browser may also end your signed in session. If you are using a public or shared computer, you should sign out and/or clear your cookies when you are done using our Services to protect your account and your personal data.

12. UPDATES TO THIS POLICY

Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to keep informed of updates or changes to this Privacy Policy.

 

PRIVACY POLICY ADDENDUM FOR CALIFORNIA RESIDENTS

Under the California Consumer Privacy Act (“CCPA”), California residents are afforded certain rights regarding the personal information we collect about them. California residents request any of the following:

• The categories of information that we collected.
• The categories of sources from which the information is collected.
• The purpose for collecting information.
• The categories of third parties to whom we disclosed information, the categories of such information that was disclosed (if applicable), and the purpose for disclosing information.
• The specific pieces of information we collected.

You may also request the deletion of information we have collected, as well as the right to opt-out of the sale of your personal information. Consistent with the California Consumer Protection Act, we will consider and timely process data access and deletion requests. We will not unlawfully discriminate against you for making any such requests. To initiate access or deletion requests, you can contact us at our address.

SALES OF PERSONAL INFORMATION

We allow companies to use cookies and other tracking technologies on our sites that allow those companies to collect information about your website activity and use that information to target advertisements to you online. You can exercise control over the use of these technologies. See the section on Cookies above in the Privacy Policy in order to opt-out of the “sale” of personal information.

HOW WE COLLECT AND SHARE CALIFORNIA RESIDENTS’ INFORMATION

Over the last 12 months, personal information we have collected and shared includes the following:

Category of Information Collected - Identifiers, including your name, account nickname, IP address, cookie identifiers, mailing address, phone number, email address, date of birth, government-issued forms of identification (like a driver’s license), internal identifiers Skinholy assigns to you, and email addresses or social media information about your friends.

• Sources. We collect this information directly from you, except with respect to: your IP address, which we automatically collect from your device through our use of cookies and similar technologies; your cookie identifier, which is assigned to your device; and your Skinholy internal identifier, which we assign to you.
• Uses. We use this information to: provide, maintain, and improve our Services; perform fraud and credit checks; manage our loyalty programs; fulfil your orders and deliver products to you; respond to customer inquiries; manage your online account; personalize your online experience; and process and deliver promotional offers.
• Sharing. We share this information with service providers who to help us to: provide, maintain, and improve our Services; perform fraud and credit checks; manage our loyalty programs; deliver products to you; respond to customer inquiries; manage your online account; personalize your online experience; and process and deliver promotional offers.

Category of Information Collected – Personal information as defined by Cal. Civ. Code 1798.80, including your name, phone number, mailing address, gender (collected from our consumers), and payment card information.

• Sources. We collect this information directly from you.
• Uses. We use this information to: provide, maintain, and improve our Services; perform fraud and credit checks; manage our loyalty programs; deliver products to you; respond to customer inquiries; manage your online account; better understand our customer audience; personalize your online experience; and process and deliver promotional offers.
• Sharing. We share this information with service providers who to help us to: provide, maintain, and improve our Services; perform fraud and credit checks; manage our loyalty programs; deliver products to you; respond to customer inquiries; manage your online account; better understand our customer audience; personalize your online experience; and process and deliver promotional offers.

Category of Information Collected – Commercial information like information about a transaction, including your credit or debit card details, spending history on the Website, and order details.

• Sources. Our third-party payment vendors collect this information directly from you on our behalf.
• Uses. We use this information to: process your transactions and deliver our products to you; manage our loyalty programs; personalize your online experience; and to perform fraud and credit checks.
• Sharing. We share this information with service providers who help us to: process your transactions and deliver our products to you; manage our loyalty programs; personalize your online experience; and to perform fraud and credit checks.

Category of Information Collected – Internet or other electronic network activity information like the information derived from our use of cookies and similar technologies – including the type of device you have, the device identifier/media access control (MAC) address, the proximity of the device from the Wi-Fi access point, the browser you are using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location, crash or download error reports, your language preferences, and where relevant, when and for how long the device is connected to the Wi-Fi network.

We will also collect information about your browsing history, your purchasing preference history, your shopping cart status, and your contact history with us (including phone records of our conversations).

• Sources. We collect this information directly from you and from cookies and similar technologies that automatically collect this information from your device. We also collect this information – such as social graph data – from our select partners.
• Uses. We will share this information with service providers to provide, maintain, and improve our Services, respond to customer inquiries; manage your online account; personalize your online experience; and process and deliver promotional offers. To this end, we will append this information to our existing customer account information to better understand customers’ interests and to provide more relevant product recommendations and advertising, to increase our customer’s security when using our Website, and to comply with our legal obligations, such as sanctions laws.
• Sharing. We will share this information with service providers to: provide, maintain, and improve our Services; respond to customer inquiries; manage your online account; personalize your online experience; and process and deliver promotional offers. And we will share this information with our advertising partners, which may inform which individuals they help other companies to target with third-party advertising.

Category of Information Collected – Geolocation data, including the location of the device.

• Sources. We automatically collect this information from your device, depending on your settings, and we collect location information when you share it directly with us.
• Uses. We use this information to: provide, maintain, and improve our Services; manage your online account; personalize your online experience; and process and deliver promotional offers.
• Sharing. We share this information with our service providers who help us to: provide, maintain, and improve our Services; manage your online account; personalize your online experience; and process and deliver promotional offers.

Category of Information Collected – Inferences derived from personal information.

• Sources. We analyse your behaviour and purchase on our website as well as public or social graph data provided by our partners to determine shopping preferences and improve your experience.
• Uses. We us this category of information to tailor and improve your shopping experience on our website.
• Sharing. We do not share this information.

CALIFORNIA DO NOT TRACK

Our website does not follow the direction of “do not track” or “DNT” settings that are available in some browsers.