1. Collected Information.
The information collected during your use of the Services includes the following:
a. Submitted Information. As part of using the Services, you may submit certain information to us. For example, when you register for an account on the Services we will collect information from you, including Personal Information such as your name and e-mail address. To the extent you provide your permission through our service, we may also collect certain information from other apps on your mobile device, such as fitness tracking and weather applications.
b. Personal Information. This means information such as gender, location, birth date, name and e-mail address that we can directly associate with a specific person or entity without additional information.
c. Skincare information. This means information that you report to us regarding your skin routines, your skin profile, skin health, skin condition, whether your skin condition has been diagnosed, your product use, as well as your opinions and ratings on skincare products and treatments, cosmetics and medications and how you are feeling,. To the extent you decline to share certain information with us, we may not be able to provide some or all of the features and functionalities found on the Services.
d. Automatically Collected Information. When you use the Services, we gather certain non-personally identifiable information from you, and this information can be associated with your user account. This includes usage information, such as information on when, how often and for how long you use the Services, as well as server log data such as a computer’s IP address, browser type or the webpage you were visiting before you came to the Services.
e. Tracking and Cookies. The Services may use both web beacons and cookies to collect information. ‘Beacons’ (also often referred to as ‘pixels’) are tiny graphics on a web page designed to track when a page is viewed. ‘Cookies’ are small text files containing a string of alphanumeric characters that are downloaded by your web browser or mobile device when you visit a website. We may use both session cookies and persistent cookies when you access and use the Services. Cookies may be used, for example, to remember your user account information and your preferences, to customize the interface of the Services for you and to assist us in measuring and analyzing Service traffic. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. Persistent cookies can be removed. Please review your browser’s documentation to learn the best way to modify your cookie settings. Like many websites, the Services does not currently respond to ‘do not track’ browser headers. However, you can take steps to limit tracking by erasing cookies from your computer’s hard drive and by setting your browser to block all cookies or warn you before a cookie is stored.
f. Analytics. We use certain third-party services to assist us in analysis, auditing, research, and reporting regarding the Services. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular we use Google Analytics to help collect and analyze certain information for the purposes discussed in this Policy. For more information about Google’s privacy practices relating to Google Analytics, please visit www.google.com/policies/privacy/partners/.
g. Location. We may ask for your address so we may send you product samples that match your skin profile. With your permission, we will obtain your precise physical location when you are using the Services, in order to provide the features and functionality of the Services.
2. Use of Information.
We collect this information, so we can help you find products and treatments for your personal skin problem, via the power of crowdsourcing insights from others like you. The information is collected via self-reporting by users through Cocoon service. We internally use the information we collect as follows.
a. Provision of Services. We may use collected information for the purposes for which you provided the information including, for example, to generate skincare and cosmetic product recommendations for you, and for the benefit of other users to share your results and other information anonymously with other users with a matching skin profile and skin condition (your ‘Skin Peers’). We call this the democratization of skincare information and it is an important part of our value to the skincare community and to you. We may use collected information to create and maintain an account for you or to respond to a question that you may submit to us. We also use the collected information as necessary to provide the features and functionality of the Services to you and as reasonably necessary for our business operations.
b. Updates and Troubleshooting. We may also use the collected information to contact you regarding updates or modifications to the Services or to help troubleshoot problems, provide you with required notices in connection with disputes between you and another user or alert you to changes in our policies or agreements that may affect your use of the Services.
c. Personalized Content. We may use the collected information to personalize the content that you and others see based on personal characteristics or preferences.
d. Analytics and Improvements. We may also analyze collected information relating to your use of the Services to help us improve the Services and develop and improve other products and services.
e. Promotional Offers. We may use the collected information to provide you with promotional materials and offers. However, we will give you the ability to opt out of receiving such e-mails or other correspondence in accordance with applicable law. We will not provide your personally identifiable information to third parties for their own marketing purposes without your consent.f. Combination. We may combine personal information collected through the Services with other information that we or third parties collect about you in other contexts such as our communications with you via e-mail, phone, or your customer service records.
f. Notifications. We may send you Service related updates and notifications via e-mail, including peer-recommendations, weekly statistics, etc.
3. Disclosure and Use of Information.
We share and disclose the information we collect about you as follows:
a. Insights reporting. We may analyze and share your Skincare Information with brands and our business partners to allow them to understand consumer behavior. However, such sharing is always on anonymous cohort basis meaning your information is presented as an anonymous datapoint as part of a cohort of other users. It is important to understand that we never share your individual information with brands. Your Skincare Information is combined with the skincare data of other users and the reported cohort analytics are stripped of any individually identifiable information. We will never share your personal information with brands to allow them to contact you directly. All brand communication towards you is always through Cocoon platform. Your privacy is important to us.
c. Cocoon community. In order to provide you with personalized suggestions on products and treatments that have worked for others like you, we may compare your SkincareInformation with that of other users in the Cocoon Community. By being part of the Cocoon Community, you will help yourself and others struggling with the same condition find the products and treatments that improve everyone’s quality of life through better skincare
d. Third-Party Service Providers. We use contractors and third-party service providers to assist us in making the Services available. Such third-party contractors or service providers may obtain access to the information you provide, including Personal Information.
e. Advertising. We may provide advertisers and other third parties with aggregated, non-personally identifiable information about our user base and its interests and usage patterns. We may also partner with third party advertising companies in order to serve online advertising regarding our products and services to users after they visit the Services. This is a common practice called retargeting. For more information on such practices and the ability to opt-out, you may visit www.aboutads.info.
f. Aggregated Data. We may report aggregated, anonymous data relating to activity on the Services to third parties or the general public. By way of example only, this may include the provision or publication of reports regarding the geographical distribution of our user base.
g. Business Arrangements. We may disclose non-personally identifiable information to third-party partners in furtherance of our business arrangements with them, including without limitation to jointly offer a product or service to you or create interoperability between our products and services and the products and services of such partners.
h. Transfer as Corporate Assets. In the event of a merger, sale of capital stock or assets, reorganization, consolidation or similar transaction involving Company, the information we possess, including personally identifiable information, shall be transferred as a corporate asset to the acquiring entity.
i. Legal Requirement. We will use and disclose information where we, in good faith, believe that the law or legal process (such as a court order, search warrant or subpoena) requires us to do so or in other circumstances where we believe it is necessary to protect the rights or property of Company, our users and/or third parties.
j. Affiliates. We may disclose this information to our affiliates for use as described in this Policy.
k. Sharing. Our Services may include features that by their nature support sharing certain information with other users.
4. Effective Date; Changes.
When we make any changes to our practices under this Policy, we will change the Effective Date. We will treat your continued use of the Services following such change as your acceptance of the changes.
The Services may contain offers from third parties or links to third-party websites. This Policy does not apply to information that you may provide to or that may be collected by third parties.
6. Viewing, Amending, and Deleting Information.
The personally identifiable information we collect about you is stored in limited access servers. We will maintain reasonable safeguards to protect the security of these servers and your personally identifiable information. However, no security measures are 100% effective and we cannot guarantee the security of your personally identifiable information. We expressly disclaim any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing or otherwise offering any definitive promise of security in connection with your personal information or usage information.
8. Children Under 14.
We do not knowingly collect information from children under 14 and the Services are not directed at children under 18. If you are a parent and believe your child under the age of 14 has used the Services and provided personally identifiable information to us through the Services, please contact us at the phone number and address provided in Section 10 of this Policy and we will work to delete that Service account and any such personally identifiable information.
9. Transfer to the U.S. or Other Countries.
We use facilities in the United States. Your information will be stored and processed in the United States or other countries where Company has facilities. By using the Services, you consent to the transfer of information outside of your country, even if your country has more rigorous data protection standards.
10. Mergers, Acquisitions and Similar Business Transactions.
11. Sharing Information with the Government or As Otherwise Required by Law.
Cocoon cooperates with government and law enforcement officials to enforce and comply with the law. We may therefore disclose your information as listed above, if we have a good faith belief that it is reasonably necessary to: (a) satisfy any applicable law, regulation, legal process or enforceable governmental request; (b) enforce our Terms of Service, including investigation of potential violations thereof; (c) detect, prevent, or otherwise address fraud, security or technical issues; or (d) protect against harm to the rights, property or safety of Cocoon, its users or the public as required or permitted by law.
12. Your California Privacy Rights.
Cocoon Holdings, Inc.
Attn. Privacy Questions
1330 Avenue of the Americas, 14th Fl
New York, NY 10019
Effective Date: December 14, 2018