Privacy Policy 

This Privacy Policy governs the processing of your personal data on the basis of the European General Data Protection Regulation (GDPR) by LifeStyles Healthcare Pte. Ltd. as part of your visit to our website https://skyn.com (hereinafter: “Website”), or your communication with us via e-mail, telephone, fax and our social media channels (such as Facebook, Twitter, and Instagram).

1. Who are we?

1.1 Your personal data are processed on the basis of applicable data protection legislation by LifeStyles Healthcare Pte. Ltd. of 30 Cecil Street, #19-08 Prudential Tower, Singapore 049712 (hereinafter: “LifeStyles”, “we”, “us”, “our”). You can contact us via e-mail at privacy@lifestyles.com.

1.2 Where reference is made in this Privacy Policy to laws or regulations, possible amendments to these laws or regulations are implicitly included.

1.3 We reserve the right to change and adapt this Privacy Policy on our own initiative. In that case, those changes and adaptations will be communicated to you via our Website. Any further use of our Website will be subject to the amended Privacy Policy.

2. Which of your personal data do we process?

2.1 When you use our Website or our social media channels, we process:

• Technical information, such as information concerning your device, IP-address, browser type, geographical location, operating system, page response times, download errors;
• Browsing information, such as full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), products you viewed or searched for, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
• Other information you provide us with, such as when you register to use our Website, subscribe to our service, search for a product, place an order on our Website, participate in discussion boards or other social media functions on our Website, enter a competition, promotion or survey and when you report a problem with our Website.

2.2 When you communicate with us by filling out a contact form on our Website, or via e-mail, telephone, fax or social media channels, we process:

• Identity information you provide us with, such as your first name, last name, birthdate, preferences and interests;
• Contact details you provide us with, such as your e-mail address, postal address, country and (mobile) telephone number;
• Content of the communication, such as your question or complaint;
• Technical information of the communication, such as with whom you communicate at our end, date and time of the communication, or the phone number used to call our customer service number;
• Any other personal data you provide us with.

2.3 When you take a survey or questionnaire or enter a contest:

• Identity information you provide us with, such as your first name, last name, birthdate, preferences and interests;
• Contact details you provide us with, such as your e-mail address, postal address, country and (mobile) telephone number;
• Other information you provide us with or that we can derive from the answers to the questions you provide us with.

2.4. When you place an order or request a sample via our webshop:

• Identity information you provide us with, such as your first name, last name, preferences and interests;
• Contact details you provide us with, such as your e-mail address, postal address, country and (mobile) telephone number;
• Order details, such as the products you purchased;
• Payment details, such as credit card or bank account numbers and the amount you paid for your purchase, unless you request a free sample.

2.5 We receive most of your personal data directly from you, but it may happen that we receive additional information about your preferences and browsing behavior from partners such as Google. If you require more information about the personal data these parties process about you and make available to others, you are kindly requested to consult their respective privacy policies.

2.6 Our Website may also contain links to non-LifeStyles websites. LifeStyles is not responsible for the privacy policies of third party websites and recommends you review the privacy policies of each website you visit.

3. For what purposes do we process your personal data and what is the legal basis for this?

3.1 In the table below, we explain the purposes for which we process your personal data and on the basis of which legal basis we do so. We rely on the following legal bases:

• Your consent, in which you are informed of what this consent means before you freely give your consent;• A contract with you, in order to perform that contract or in order to take steps prior to entering into a contract with you;
• A legal obligation that we have to comply with;
• Our legitimate interest, such as continuous improvements of our Website, social media channels, products and services to ensure that you have the best experience possible, to keep them safe from misuse and illegal activity, to promote them and to make them available to you.

4. To whom do we send your personal data?

4.1 We may share your personal data with our related LifeStyles entities and we may also rely on third parties in order to process your personal data for the purposes outlined in Article 3 above, for example:

• To provide you our Website or webshop (such as a hosting provider); or
• To target our advertising (such as a marketing company); or
• To process your order (such as a transport company to deliver you the products); or
• To process your payment (such as a payment service provider or a credit checking agency).

These third parties are only allowed to process your personal data on our behalf and upon our explicit written instruction. We also warrant that all those third parties are selected with due care and are committed to observing the safety and integrity of your personal data.

4.2. We may be legally obliged to share your personal data with competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities, to comply with a legal obligation as set out in Article 3 above.

4.3. We do not send your personal data in an identifiable manner to any other third party than the ones mentioned in Articles 4.1 and 4.2 without your explicit consent to do so. However, we may send anonymised data to other organizations that may use those data for improving products and services as well as to tailor the marketing, displaying and selling of those products and services.

5. Where do we process your personal data?

5.1. We process your personal data both within and outside the European Economic Area (EEA). In order to process your personal data for the purposes outlined in Article 3 above, we may also transfer your personal data to third parties who process on our behalf outside the EEA. Each entity outside the EEA that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data. Such safeguards may be the consequence of:

• The recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or
• A contractual arrangement between us and that entity; or
• An approved certification mechanism, such as the EU-US Privacy Shield decision adopted by the European Commission on 12 July 2016.

5.2. We may transfer anonymised and/or aggregated data to organizations outside the EEA. Should such transfer take place, we will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data you might enjoy under applicable mandatory law.

6. What quality assurances do we comply with?

6.1. We do our utmost best to process only those personal data which are necessary to achieve the purposes listed under Article 3 above.

6.2. Your personal data are only processed for as long as needed to achieve the purposes listed under Article 3 above or up until such time where you withdraw your consent for processing them. Your withdrawal of consent may imply that you can no longer use the whole or part of our Website. We will de-identify your personal data when they are no longer necessary for the purposes outlined in Article 3 above, unless there is:

• An overriding interest of LifeStyles, or any other third party, in keeping your personal data identifiable; or
• A legal or regulatory obligation or a judicial or administrative order that prevents us from de-identifying them.

6.3. You understand that an essential aspect of our marketing efforts pertains to making our marketing materials more relevant to you. We do this by customizing your unique profile based on relevant characteristics and then use this profile to provide you with communications, promotions, offerings, newsletters and other advertising about products and services that may interest you.

6.4. We will take appropriate technical and organizational measures to keep your personal data safe from unauthorised access or theft as well as accidental loss tampering or destruction. Access by our personnel or third parties’ personnel will only be on a need-to-know basis and be subject to confidentiality obligations. You understand, however, that safety and security are best efforts obligations which can never be guaranteed.

6.5. If you are registered to receive advertising, such as communications, promotions, offerings and newsletters, via e-mail or other person-to-person electronic communication channels, you can change your preferences for receiving such advertising by clicking the opt-out link provided in such advertising.

7. What are your rights?

7.1. You have the right to request access to all personal data processed by us pertaining to you. We reserve the right to charge a reasonable administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to us. Each request must specify for which processing activity you wish to exercise your right to access and must specify to which data categories you wish to gain access to.

7.2. You have the right to rectification, i.e. to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If you submit a request for correction, your request needs to be accompanied of proof of the flawed nature of the data for which correction is asked.

7.3. You have the right to withdraw your earlier given consent for processing of your personal data.

7.4. You have the right to erasure, i.e. to request that personal data pertaining to you be deleted if these data are no longer required in the light of the purposes outlined in Article 3 above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by us against:

• Our and a third parties’ interests which may override your interests; or

• Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

7.5. You have the right to restriction instead of deletion, i.e. to request that we limit the processing of your personal data if:

• We are verifying the accuracy of your personal data; or

• The processing is unlawful and you oppose the deletion of your personal data; or

• You require your personal data to establish, exercise or defend a legal claim, while we do no longer need your personal data for the purposes listed under Article 3 above; or

• We are verifying whether our legitimate interests override your interests if you exercise your right to object in accordance with Article 7.6.

7.6 You have the right to object to the processing of personal data if:

• The processing is based on our legitimate interest under Article 3 above; and
• You are able to prove that there are serious and justified reasons connected with your particular situation that warrant such objection; and
• Our legitimate interests do not override your interests.

However, if the intended processing qualifies as direct marketing, you have the right to object to such processing free of charge and without justification.

7.7 You have the right to data portability, i.e. to receive from us in a structured, commonly-used and machine-readable format all personal data you have provided to us if the processing is based on your consent or a contract with you under Article 3 above.

7.8 If you wish to submit a request to exercise one or more of the rights listed above, you can contact our Privacy Officer by sending an e-mail to privacy@lifestyles.com. An e-mail requesting to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should meet the following conditions:

• State clearly which right you wish to exercise; and
• State clearly the reasons for exercising your right if such is required; and
• Your request should be dated and signed; and
• Your request should be accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form, we may ask you for your signed confirmation and proof of identity.

We will promptly inform you of having received your request. If the request meets the conditions above and proves valid, we will honor it as soon as reasonably possible and at the latest thirty (30) days after having received your request.

If you have any complaints regarding the processing of your personal data by us, you may always contact our Privacy Officer by sending an e-mail to privacy@lifestyles.com. If you remain unsatisfied with our response, you are free to file a complaint with the competent data protection authority.

8. About children

This website is not intended for, nor do we believe it is appealing to, children under the age of 13. We do not knowingly solicit or collect information from children under the age of 13. If We learn that it has been provided with information from someone under 13, We will destroy that information. We encourage parents to take an active role in ensuring that their children do not send information about themselves anywhere on the Internet unknowingly, and suggest that they use software tools or online services to ensure a safe Internet experience for their children.