Date last updated:
We work hard to build and maintain a relationship of trust with you. So, when it comes to handling your information, we do so carefully and sensibly, and in ways that live up to that trust. This policy lets you know how we do that, including what information we collect, how we use and protect it, and how you can decide what we do with it. Our goal is to help you understand how we use your information to improve our content, products, advertisements, and services.
What We Collect
What We Use
How We Safeguard Your Information
What We Share
Your Rights and Choices
Cookies and Other Technologies
EU Processing, Retention, and Transfer
Site and App Content
Here’s a short introduction to our privacy practices
what we collect
Information you give us
Information we collect when you contact us, visit our sites, use our mobile applications or services, use our products or devices, or view our advertisements.
Information we get from other companies who have obtained your consent to share or sell it or have ensured that other companies from whom they have received your information can share it with them and, in turn, with us and/or other companies.
Information we get from other companies when you visit their websites
We may combine any and all of this information to help create better products, services, and consumer experiences.
How we use your information:
Send you the products and services you ask for
Tell you about our and our marketing partners’ products and services
Help us run our sites and services
How and when we share your information:
When we have your consent, with our carefully selected partners so that they can send you offers, promotions, or ads about their products and services we believe you may be interested in
With other companies we hire to help us run our business
As part of a sale of a Acnecide brand or business to another company
To help us protect our rights or property, e.g., fraud prevention or information security
When required by law or government authorities your choices
You can tell us how we can use your information by clicking on the links below:
If you live in the EU, you have certain personal data rights, including to access what personal information we have about you, make corrections or updates to it, tell us to delete that data, or receive a portable copy of that information. These rights don’t apply in all situations. Please click the links below to:
Access or update personal information
Request correction, deletion, or transfer of your personal information
If you live in California, you may also have certain privacy rights, including to access what personal information we have about you, ask us to delete the personal information we collected from you, or request for us to not “sell” that data. These rights also don’t apply in all situations. To learn more about your rights and how to exercise them, please click the link below:
California Consumer Privacy Rights
What we collect
We collect information when you give it to us, when you contact us, visit our sites, use our mobile applications or services, use our products or devices, or view our advertisements. We also receive information from other companies who have obtained your consent to share or sell it, have ensured that other companies from whom they have received your information can share it with them and, in turn, with us and/or other companies or have collected the information when you visit their websites.
Data elements in this category include names (including nicknames and previous names), titles, mailing address, email address, telephone/mobile number and contact information for related persons (such as authorized users of your account).
Data elements in this category include unique ID number (such as customer number, account number, subscription number, rewards program number), system identifiers (including username or online credentials), device advertisers, advertising IDs and IP address.
Government‐issued identification information numbers
Data elements in this category include social security number, driver’s license number and passport number.
Data elements in this category include bank account number and details and payment card information.
Data elements in this category include facial recognition data, voiceprint, fingerprint and a mathematical representation of your biometric identifier, such as the template maintained for comparison.
Demographic Information and Preferences
Data elements in this category include personal characteristics and preferences, such as age range, marital and family status, shopping preferences, languages spoken, loyalty and rewards program data, household demographic data, data from social media platforms, education and professional information, hobbies and interests and propensity scores from third parties (likelihood of purchase, experiencing a life event, etc.).
Transaction and Commercial Information
Data elements in this category include customer account information, qualification data, purchase history and related records (returns, product service records, records of payments, credits etc.), records related to downloads and purchases of products and applications, non‐biometric data collected for consumer authentication (passwords, account security questions), customer service records.
Inferred Information derived from other information listed in this section
We create inferred and derived data elements by analyzing our relationship and transactional information. Data elements in this category include propensities, attributes and/or scores generated by internal analytics programs. Online & Technical Information, including internet or other electronic network activity information Data elements in this category include: IP address, MAC address, SSIDs or other device identifiers or persistent identifiers, online user ID, encrypted password, device characteristics (such as browser information), web server logs, application logs, browsing data, viewing data (TV, streaming), website and app usage, first party cookies, third party cookies, flash cookies, Silverlight cookies, web beacons, clear gifs and pixel tags.
Audio Visual Information
Data elements in this category include photographs, video images, CCTV recordings, Call Center recordings and call monitoring records, and voicemails.
Data elements based on how it is collected include:
Information collected from consumer programs
General health and symptom information or product interest
Pregnancy related information, such as due date
Consumer Research Studies where you have provided your informed consent
Information about physical or mental health, disease state, medical history or medical treatment or diagnosis, medicines taken and related information
Internet of Things and Sensor data
Data elements in this category include smart device records, IoT products.
Data elements in this category include precise location (such as latitude/longitude)
We do not knowingly collect personal information directly from children under 16, except where we have the consent of the parents or guardians. We receive children’s data from parents and guardians.
How We Collect Your Information
We collect information about you in many ways from many places. Some of the information we collect may include personal information that can be used to identify you; for example, your name, email address, telephone number, or postal address. In some countries like those in the EU or in states like California, things like IP address or cookie and mobile device identifiers may also be considered personal information.
Here are the ways we collect your information:
Please note: We may combine all of the information we collect about you to give you better products, services, and user experiences, you provide it to us directly.
You give us your information when signing up for an account on our websites or mobile apps or by calling or emailing us. We may ask for things like your name, email or home address, date of birth, payment information, your age, gender, the number of people in your family, and the way you want us to send you information about our products and services—for example, to your home address, email address, or by texting you.
From other places. We may get information that other companies share with or sell to us. For example, you may have given consent for another company to share your personal information with us when you signed up for telecom services or a retailer loyalty points program. We may also collect information from places that you know everyone can see, such as from internet postings, blog entries, videos, or social media sites. We may also receive information from other companies, such as consumer data resellers, who are in the business of collecting or aggregating information about you sourced from publicly available databases (in line with local legal requirements as applicable) or from consent you have given to their use and subsequently our use of your information. This might be information about your income level, age, gender, number of people in your family, and products you have bought on the internet or from stores in your neighbourhood.
How We Use Your Information
We use your information to help us meet our purpose of touching and improving the lives of people like you every day around the world. For example, we use your information to:
Perform Services Identify and authenticate you to our different marketing programs and websites
Respond to your questions or requests for information,
Provide customer service
Send transactional messages (such as account statements or confirmations),
Send marketing communications, survey and invitations
Process your payment for the products you buy from us
Process and issue refunds and collections
Send you products or samples you have requested
Help you manage your Acnecide site or app preferences
Allow you to enter our contests or sweepstakes
Interact with you on social media
We also use your information for internal business purposes, such as:
Quality control, training and analytics
Safety Maintenance and verification
System administration and technology management, including optimizing our websites and applications
Security purposes, including detecting threats and protecting against malicious or fraudulent activity
Recordkeeping and auditing interactions with consumers, including logs and records maintained as part of transaction information
Risk management, audit, investigations, reporting and other legal and compliance reasons
We may also use your personal information to better understand you and our customers generally, including:
For internal research
To design and develop products, services and programs that delight our consumers
To identify prospective consumers
Another way we use your information is to track your use of products, services and websites to make sure that what you hear from us is relevant and useful to you as an individual. For example, we may send you information about Acnecide products if you have shown interest in our shaving products by visiting Acnecide.com. When we do this, we may identify you or your device and associate you with different devices you may use in order to deliver more relevant advertising to you. We will use your information – a cookie ID or device ID ‐‐ to limit the number of times you see the same advertisement from Acnecide. We want you to hear from us about the products you use and love without you hearing the same message We may also use your personal information to learn more about what consumers want so that we can make new products or improve the ones we already have.
How We Safeguard Your Information
We respect your personal information and take steps to protect it from loss, misuse, or alteration. Where appropriate, these steps can include technical measures like firewalls, intrusion detection and prevention systems, unique and complex passwords, and encryption. We also use organizational and physical measures such as training staff on data processing obligations, identification of data incidents and risks, restricting staff access to your personal information, and ensuring physical security including appropriately securing documents when not being used
What We Share with other companies.
Other situations. If a brand or one of our businesses with which you’ve shared personal data is sold to another company, your data will be shared with that company. As a result, your account and the personal data in it will not be deleted unless you tell the brand or new company that you want it deleted. We may also share your information with companies who help us protect our rights and property, or when required by law or government authorities.
Your Rights and Choices
Marketing; You can tell us to stop sending you email and text messages by following the opt‐out instructions sent with these communications. You can also choose to stop receiving marketing email, SMS, or postal mailings by clicking here. While we will honour your choices, we may need to keep information to do so. For example, if you tell us to stop sending marketing emails, we will need your email address on file so that our systems remember that you no longer wish to receive marketing communications to that email address.
Accounts; Depending upon the country where you registered, your Acnecide account may offer the ability to access your information and make updates to or delete your data. If not, you can contact us through your account to make a request.
California residents. If you live in California, you may access the personal information we hold about you, request details about how we process your personal information, ask us to delete your data or request that we no longer “sell” your personal information (as “sell” is defined in the CCPA). To learn more and to exercise such rights, please contact us through Live chat or your account.
European union residents. If you live in the EU/EEA, or are physically in the EU/EEA, you may access the personal data we hold about you, request that inaccurate, outdated, or no longer necessary information be corrected, erased, or restricted, and ask us to provide your data in a format that allows you to transfer it to another service provider. You also may withdraw your consent at any time where we are relying on your consent for the processing of your personal data. And you may object to our processing of your personal data (this means ask us to stop using it) where that processing is based on our legitimate interest (this means we have a reason for using the data). If you would like more information about data protection and your personal data rights in general, please visit the European Data Protection Supervisor’s site at https://edps.europa.eu/data‐ protection/ . If you are not happy with our response to your requests, you may lodge a complaint with the data protection authority in your country. Please select from the following options to make your request:
General requests . To make a request with respect to personal data used for marketing, which would include for example information you provided us as you registered through one of our websites or apps, please contact us here .
Media advertising . To make a request with respect to personal data used for advertising, which would include for example information we may have about you at a cookie or device ID level and which we use to provide you with relevant ads, please contact us here . There may also be data associated with your cookie or device ID in our demand‐side (or ad‐serving) and ad verification partner platforms. For that data, please see here and here.
Consumer research . To make a request with respect to personal data we may have as part of your participation in one of our research studies, please see the contact information provided on your consent form or call or visit your research center.
See our Cookie Information.
Proximity‐based beacons. Beacons send one‐way signals to mobile apps you install on your phone over very short distances to tell you, for example, what products are on‐sale as you walk through a store. Beacons only talk to your device when you get close enough and after you have given consent within the mobile application associated with a particular beacon. In turn, apps may provide us location information to help customize advertising and offers to you. For example, when you are near a beacon in the skin care section of a supermarket, we may send you a $4 off coupon.
Pixels. These are small objects embedded into a web page, but are not visible. They are also known as "tags,” “web bugs,” or "pixel gifs." We use pixels to deliver cookies to your computer, monitor our website activity, make logging into our sites easier, and for online marketing activity. We also include pixels in our promotional email messages or newsletters to determine whether you open and act on them.
Mobile device identifiers and SDKs. We use software code in our mobile apps to collect information similar to what cookies collect on the internet. This will be information like your mobile phone identifiers (iOS IDFAs and Android Advertising IDs) and the way you use our apps. Similar to cookies, the device information we collect automatically as you use our apps will never identify you as a person. We only know a mobile device as randomly assigned numbers and letters (e.g., advertising ID EFG4567) and never as, for example, John E. Smith.
Precise geolocation. We may receive information about your exact location from things like global positioning system (GPS) coordinates (longitude and latitude) when you use our mobile apps. You will always get a pop‐up notice on your phone or device asking for you to accept or reject allowing us to know exactly where you are in the world. You should understand that we will not always ask for consent to know generally that you are in a broader city, postal code, or province. For example, we do not consider it to be precise location if all we know is that you are somewhere in Manila, Philippines.
When you visit our partner sites, we can show you ads or other content we believe you would like to see. For example, you may receive advertisements for Tide® laundry detergent if we notice that you are visiting sites that sell children’s clothing or school supplies. And from that information we may conclude that you have children and therefore could well be interested in a powerful laundry‐ cleaning product. In this way, we intend to send you relevant information about our products that might be of benefit to you.
We learn from groups of consumers sharing similar interests. We may place you into a particular group of consumers who show the same interests. For example, we may put you in the group of “razor aficionados” if we see you frequently purchase razors online or you could be a “bargain‐ shopper” if we notice you use online coupons or look for discounts or sales. We notice these things about you as you look at web pages, links you click on our websites and other websites you visit, mobile applications you use, or our brand emails you view and links you click in the emails. We group together cookie and device IDs to help us learn about general trends, habits, or characteristics from a group of consumers who all act similarly online and/or offline. By doing this, we can find and serve many others who “look like” those already in the group and thereby send them what we believe will be relevant and beneficial product offers and information.
We link other information to your cookie and device IDs. Your cookie and device IDs may be supplemented with other information, such as information about the products you buy offline or information that you provide directly to us when creating an account on our sites. We generally do this in ways that will not directly personally identify you. For example, we could know that cookie ID ABC12345 belongs to the razor aficionado group based on person’s web site visits, age, gender, and shopping habits, but we would not know that person’s name or address or other information that would identify him or her as a person. Should we ever want to personally identify your cookie or device information (web and app viewing history), we will always ask you before doing so.
We may know you across all of your computers, tablets, phones, and devices. We may know that cookie ID ABC12345 is from a computer that that may be connected to the same person or household owning the mobile phone with device ID EFG15647. This means that you may search for shave cream on your laptop, click on a Google search result link which we have sponsored, and then later see an ad for Acnecide on your mobile phone. We might assume or deduce that the same person owns the computer and phone because, for example, they sign on to the same WiFi network every day at the same time. Understanding what devices seem to be used by a person or household helps us limit the number of times you see the same ad across all of your devices. And this is important because that way you don’t get annoyed at us for spamming you with the same ad and we don’t pay for such repetitive ads that we don’t want you to receive.
How you can stop receiving interest‐based ads. To stop receiving Acnecide interest‐based advertising, you can click on the AdChoices icon on one of our sites. You can also prevent getting interest‐based ads on websites by declining cookies in your browser(s), declining the “access to data” requests that apps usually present when you install them, or by adjusting the ad tracking settings on your device.
You will still see “contextual” ads even if you opt out of interest‐based ads. Even if we stop sending you interest‐based ads, you will still get ads from our brands on your computer or mobile devices. These ads, however, are based on the context of the sites you visit and are called contextual ads. Unlike interest‐based ads which are based on pages you visit on your mobile phone or computer viewing activities, contextual ads are ads shown to you based on the context of the specific site you are visiting. For example, you still may see an ad for one of our baby care brands while looking at nursery products online because these sites traditionally have had mostly new or expecting parents as visitors. You should also know that we may still collect information from your computer or devices and use it for other purposes like evaluating how our websites work, for consumer research, or detecting fraud.
Deleting cookies also deletes your opt out. When you opt out of interest‐based advertising, we send an opt‐out cookie to your browser that tells us that you no longer want to receive interest‐based ads from us. Your opt‐out cookie will be deleted if you decide to delete all cookies. This means that you will need to opt‐out again if you still do not want to receive interest‐based ads.
European Union Data Processing, Retention, and Transfers
This section applies only to our processing of personal data of EU country residents. It aims to provide increased transparency into our processing, retention, and transfer of EU resident personal data that is in line with the letter and spirit of the General Data Protection Regulation. entities.
Processing and retention. As a general rule, we keep your data for only as long as it is needed to complete the purpose for which it was collected or as required by law. We may need to keep your data for longer than our specified retention periods to honour your requests, including to continue keeping you opted out of marketing emails, or to comply with legal or other obligations. This chart tells you the type of data we collect, the purposes for which we use it, why such uses comply with the law (legal basis), and how long we usually keep it (retention period).
Type of Data Why We Collect This Data Legal Basis Retention Period
Email, name, phone number, postal address, your affinities, your interests, your profession, your habits, what you bought, the photos or videos you upload, information about your children and your home, your family composition, the number of people in your household, your hair type, your skin type, your favorite scent, whether you have a pet, etc. To send you materials, including advertisements, marketing our products or services or the products or services of our partners
Your consent for email and SMS and, where we obtain it, consent for postal. Legitimate interests for everything else. Until you request to delete the personal data or withdraw your consent. If you do not make such a request, the personal data will be deleted on the following schedule:
email: after <50 months of all‐channel inactivity. We define inactivity through several internal criteria.
SMS: after <50 months of all‐channel inactivity. We define inactivity through several internal criteria.
postal address: after <50 months of all‐channel inactivity. We define inactivity through several internal criteria.
Email, name, phone number, sometimes other data. To provide contest participants with information about the contest, including announcing the winner(s) of the contest. Your consent. For 24 months unless local law requires us to retain it longer.
Email, name, phone number, payment information (including bank account IBAN or Paypal details), sometimes other data. To process your purchases of our products, cashback offers, or warranties and to send you relevant communications related to that purchase. Your consent. As long as necessary to fulfil your order and follow up with communications about your order unless local law requires us to retain it longer. We also generally retain data for 24 months for cashback offers and 10 years for warranties.
Email, name, phone number, sometimes other data. To address your inquiries and make sure we follow up appropriately or as may be required by law or Acnecide policy. Our legitimate business interest in managing consumer inquiries, as well as your consent for special category data which may be collected in some adverse event cases. From 0 to 10 years, depending on the nature of the inquiry, our legitimate interests for processing the data, and our legal obligations.
Email, name, phone number, address, identifiable photos or videos, sometimes other data. To test our product ideas and learn about your preferences and practices so that we can improve our products and the lives of our consumers. Your consent. We will retain the personal data collected as part of substantive clinical research for as long as we need it for the purpose for which it was collected, and/or for as long as may be required to retain it by local law or regulation, which may be up to 25 years. For non‐clinical research, we will retain your substantive personal data for a maximum of 5 years. We will retain your signed informed consent documents
Advertising cookies, device ID, demographic information such as gender and age, behavioral data such as page views, and sometimes other data. To learn about your Internet interests and customize the ads we send you. Our legitimate business interests in serving you with relevant advertising in all EU/EEA countries, except for France and United Kingdom, where we rely on consent. We will obtain your consent for the deployment of cookies on our own websites in accordance with ePrivacy requirements. We will retain this data for thirteen months from the date we collect it or until you opt out, whichever is earlier.
Transfers of your data to other countries. Your personal information may be transferred to, stored, and processed in a country other than the one in which it was collected, including the United States. For example, we may store your data on a server in the United States because that is where a particular database is hosted; and that data may be “transferred” again when one of our marketers accesses that data from Switzerland to send you a product sample. We perform such transfers, both between Acnecide entities and between Acnecide and our service providers, using contractual protections that EU regulators have pre‐approved to ensure your data is protected (known as model contract clauses). If you would like a copy of a transfer agreement, contact us. We may also for certain vendors, e.g., online platform service providers, rely on these vendors’ participation in the U.S./EU Privacy Shield Framework.
Site and App Content
Logins. Our websites may allow you to log in using your account with another company such as, for example, “Login with Facebook.” When you do this, we will have access only to the information that you have given us consent to receive from your account settings in the other company’s account you’re using to log in with.
Children’s online privacy laws. We follow all applicable data protection laws when collecting personal information online from children. For example, in the EU we do not collect personal information from children under 16 years of age unless we get consent from a parent. Similarly, in the U.S., we obtain verified parental consent when collecting personal information from children younger than 13.
California Consumer Privacy Rights
For more information about the categories of personal information we collect, business and commercial purposes for the collection of the personal information and categories of third parties with whom we share the personal information, please see the disclosures above. As a California resident, you may have the right to request, twice in a 12‐month period, the following information about the personal information we have collected about you during the past 12 months:
the categories and specific pieces of personal information we have collected about you;
the categories of sources from which we collected the personal information;
the business or commercial purpose for which we collected or sold the personal information;
the categories of third parties with whom we shared the personal information; and
the categories of personal information about you that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.
In addition, you have the right to request that we delete certain personal information we have collected from you. To submit a request for general disclosure contact us here, to access all the information we have about you contact us here or to ask to delete your data as described above you can contact us through Live Chat or your account in any case. To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or considering your deletion request. Upon receipt of your request, we will send you a verification form by email or postal mail. To complete your request, please respond to the verification form when you receive it. To verify your identity, we may require you to provide any of the following information: Name, email address, postal address, or date of birth. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Please understand that Acnecide cannot delete personal information in those situations where our retention is required for our own internal business purposes or otherwise permitted by the CCPA (such as fraud prevention or legal compliance). In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.
Finally, you also have the right to opt out of the sale of your personal information. To exercise that right, please complete the process by contacting us through Live chat or your account.
“Sales” of Personal Information How to Opt Out
Unique Identifiers, Inferred and Derived Information, Online & Technical Information, Geolocation Data
To opt out of sales of your data, contact us through Live Chat or opt-out through cookie selection
If you want us to update our internal records so we do not share your personal information from our brand programs with a third party in a way that may be defined as a “sale,” contact us through Live chat or your account.
Please note that Acnecide may also transfer your personal information to third parties through cookies or tracking technologies for advertising and joint marketing purposes. To exercise your “Do Not Sell” right related to website cookies and tracking technologies, please go to the applicable brand website, access our California Do Not “Sell” Request Center available at the bottom of the page and set your preferences. Because some of these third parties operate differently by website and device, you may need to take this step for each Acnecide website you use.
Demographic Information and Preferences
Any other information with your consent Under the CCPA, you may designate an authorized agent to make a request on your behalf but the agent will need to complete the verification process, including the submission of proof that it has been designated to act on your behalf. For access and deletion requests made by an authorized agent on your behalf, we also may require you to verify your own identity directly with us (as described above). We will not deny, charge different prices for, or provide a different level or quality of goods or services if you choose to exercise your rights under the CCPA.
Rewards Programs calculation. Under the CCPA, you may be entitled to be informed as to why financial incentive programs, or price or service differences, are permitted under the law, including (i) a good‐faith estimate of the value of your personal information that forms the basis for offering the financial incentive or price or service difference, and (ii) a description of the method we used to calculate the value of your personally identifiable information. Generally, we do not assign monetary or other value to personal information. However, in the event we are required by law to assign such value in the context of Rewards Programs, or price or service differences, we have valued the personal information collected and used as being equal to the value of the discount or financial incentive provided, and the calculation of the value is based upon a practical and good‐faith effort often involving the (i) categories of personal information collected (e.g., names, email addresses), (ii) the transferability of such personal information for us and our Rewards Programs, (iii) the discounted price offered, (iv) the volume of consumers enrolled in our Rewards Programs, and (v) the product or service to which the Rewards Programs, or price or service differences, applies. The disclosure of the value described herein is not intended to waive, nor should be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.
California notice for minors. We may offer interactive services which allow teens under the age of 18 to upload their own content (e.g., videos, comments, status updates, or pictures). This content can be removed or deleted any time by following the instructions on our sites. If you have questions about how to do this, contact us . Be aware that such posts may have been copied, forwarded, or posted elsewhere by others and we are not responsible for any such actions. You will, in such cases, have to contact other site owners to request removal of your content.
Please contact us directly with any questions or concerns you may have about your privacy and our data protection practices or if you are a consumer with a disability and need a copy of this notice in an alternative format.
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GB-ACC-2000037 December 2020