Atolla Privacy Policy

1. Introduction

Here at Atolla Skin Health, Inc. ("Atolla" or "we" or "us" or "our"), we are committed to preserving your privacy and being transparent about how Atolla uses information collected through its website and related services (collectively, the "Services"). The following privacy policy (the "Policy") is intended to inform you of our policies and procedures regarding the information that we collect and use when you use the Services. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

2. Information Collected

When you use the Services, you will have the opportunity to provide us with some information directly. For example, some functions of the Services may require you to provide us with information such as your name, email address, demographic information, phone number and/or other information specific to you. As another example, we may ask or gather additional information related to your skin through an online survey.

In addition, we may get information about you from other sources. For example, we may supplement address information you provide to us with information we obtain from the US Postal Service, or we may have obtained information about you from another user who referred you to our Services. We may add this information to information we collect directly from you.

In order to use our Services, you will be asked to provide certain financial information so that you can be charged for the Services that you have purchased. Please note that your financial information will be collected by a third party payment processor that we have engaged to handle our financial transactions, and we will not have access to your financial information.

3. Use of Information

Information collected by us is used for five main purposes. First, we use the information collected to improve the Services by determining which of our areas, features and forums are most popular.  Second, we use your information to personalize the experience of the users of the Services.  For example, users of some of the Services are required to create an account, UserID and password in order to access those Services.  Third, we use your information to enable you to participate in features, services, programs and/or other activities from time to time. Fourth, we may use your information to communicate with you about promotions, upcoming events, and other news about products and services offered by us and our selected partners.  Finally, we use your financial information to enable you to purchase Services from us directly.  

4. Disclosure of Information

Information collected through cookies: Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, "cookie" information, the type of browser and/or device you're using to access our Services, and the page or feature you requested. "Cookies" are identifiers that we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people.  You may be able to change the preferences on your browser or device to prevent or limit your device's acceptance of cookies, but this may prevent you from taking advantage of some of our features.  

Sharing information with our service providers: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing company to receive and process your credit card transactions for us. As another example, Atolla uses Google Cloud Platform as a third party service provider to host our web services. As such, Google Cloud Platform may collect and use your information as described in Google Cloud Platforms's Privacy Policy.  Unless we tell you differently, our agents do not have any right to use the personally identifiable information that we share with them beyond what is necessary to assist us.

Sharing information as part of a corporate restructuring or liquidation: We reserve the right to transfer your personally identifiable information, as well as any other information, in connection with the sale or other disposition of all or part of the Atolla business and/or assets. We also cannot make any representations regarding the use or transfer or your personally identifiable information or other information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership or an assignment for the benefit of creditors, and you expressly agree and consent to the use and/or transfer of your personally identifiable information or other information in connection with a sale or transfer of some or all of our assets in any of the above described proceeding.

Sharing information for legal purpose: We reserve the right to access, read, preserve and disclose any information that we believe is necessary to comply with law or court order; enforce or apply this Policy, our Terms of Service, or other agreements; respond to claims concerning the Services; or protect the rights, property, or safety of Atolla, our employees, our users, or others.

Sharing aggregated information: We aggregate information about the use and effectiveness of our services for benchmarking purposes and share this aggregated de-identified information for research or marketing purposes and in order to provide our customers with skincare insights and trends. An example of the information we would share is: "60% of 35-45 year old females using our product experienced an improvement in skin tone within x months."

5. Security

For certain features available through the Services, we may now, or in the future, require the use of encryption technologies provided for your protection and/or your use of a UserID and password after setting up an account.  We will use reasonable precautions to protect the privacy of your account information and other personally identifiable information that we hold in our records.  You, however, are ultimately responsible for protecting your UserID, password and account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies.  You agree to:  (a) immediately notify Atolla of any unauthorized use of your UserID, password and/or account, and/or any other breach of security, and (b) ensure that you exit from your account at the end of each session.  While we may provide certain encryption technologies and use other reasonable precautions to protect your confidential information and provide suitable security, we do not and cannot guarantee or warrant that information transmitted through the internet is secure, or that such transmissions are free from delay, interruption, interception or error. In addition, unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

6. Modification or Deletion of Information

Please email us at [email protected] to edit or delete any of the following information that you provided to us:

l     Name;

l     Email address;

l     Location; or

l     Demographic information.

The information you can view, update, and delete may change as the Services change over time and from time to time.  If you have any questions about viewing or updating the information that we have on file about you, please contact us at [email protected]

Finally, if you request, we will remove your name and all other personally identifiable information that you have provided from the Services.  Please understand, however, that it may be impossible to delete this information completely, due to backups and records of deletions. In addition, please understand that, if you request removal of your information, you will be unable to utilize associated features of the Services.  You may not request the removal of de-identified, anonymous, or aggregate data from our databases.

7. Information from Children

The Services are not intended or designed to attract children under the age of thirteen (13).  Children under the age of 13 are not permitted to use, access or register for the Services in any way. We do not knowingly collect or solicit information from anyone under the age of 13. If we learn that we have collected personally identifiable information from a child under the age of 13, we will delete that information as quickly as possible and use commercially reasonable measures to block that user from using the Services.

8. Your California Privacy Rights

Under California's "Shine the Light" law, California residents who provide personal information in connection with obtaining products or services for personal, family or household use are entitled to request and obtain from us once per calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses.  If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities).

To obtain this information with respect to Atolla, please send an e-mail to [email protected], with "Request for California Privacy Information" in the subject line and in the body of your message.  In response, we will provide the requested information to you at the e-mail address that you provide.

Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.  

9. Do Not Track Requests

Additionally, because we may collect your personal information from time to time, California's Online Privacy Protection Act requires us to disclose how we respond to "do not track" requests and other similar mechanisms. Currently, our policy is that we do not recognize "do not track" requests from internet browsers and similar devices.

10. European Union Customers

Because our Services are accessible globally, the information that we collect may be made available to third parties anywhere in the world.  For those users visiting us from the European Union, please note that Atolla may transfer your personally identifiable data outside the European Union for use for any of the purposes described above. By using the Services and providing Atolla with your personal data, you consent to such transfer of your personal data.

11. Terms of Service  

Your use of the Services will also be governed by the Atolla Terms of Service at atolla.co/terms.

12. Governing Law  

This Policy will be governed by the laws of the State of New York, without giving effect to any principles of conflicts of laws.  By using or accessing the Services, you agree that any action at law or in equity arising out of or relating to your use of the Services or this Policy will be filed only in the state or federal courts sitting in New York, New York, and you hereby consent and submit to the personal jurisdiction of such courts for the purpose of litigating any such action.

13. Changes to Policy

Atolla reserves the right, in its sole discretion, to modify this Policy at any time and without prior notice. If we modify this Policy, we will either post a notification of the modification on our website or otherwise provide you with notice of the change. The date of the last modification will also be posted at the beginning of this Policy. It is your responsibility to check from time to time for updates. By continuing to access or use the Services, you are indicating that you agree to be bound by any modified Policy.

14. Contact Us

If you have any questions about the Services or this Policy, please do not hesitate to contact us by email at [email protected], or by mail at:

                       Atolla Skin Health, Inc.

                       

                       19 Morris Ave, Building 128

                       Brooklyn, NY 11205

Attn: Customer Service

Copyright © 2019.  Atolla Skin Health, Inc.  All Rights Reserved.