Privacy Policy
1. Introduction
1.1 Skinrun (SEA) Pte. Ltd. (hereinafter referred to as “we” or “Skinrun”) respect and protect the privacy of all users who use the Skinrun platform service (“Skinrun App”). This Privacy Policy is provided by Skinrun pursuant to the Personal Data Protection Act 2010 and the relevant regulations governing the same (“PDPA”).
1.2 This Privacy Policy explains how we collect, process, manage and protect your personal data (“Personal Data”) collected by Skinrun in the course of your dealings with us.
1.3 This Privacy Policy shall be incorporated as part of the Skinrun’s Terms. Your use of the Skinrun App and/or Service is subject to the Terms and this Privacy Policy. Unless specifically defined in this Privacy Policy, the defined terms shall have the same meaning as defined in the Terms.
1.4 If you are a company, an entity or an organisation, references to the term “you” and “your” shall also include your employees, representatives and agents.
1.5 This policy is closely related to the products and/or services you use. We will adhere to this policy when you register, log in, and use our products and/or services (collectively, “the use of our products and/or services”), in order to process and protect your personal information. We are committed to present to you, in a brief and concise way, the technical terms involved in this policy so that you could understand them. Terms of this policy which are (possibly) of utmost importance to your interest are written in bold letters to highlight them. Please pay extra attention to those terms.
1.6 Skinrun specifically calls the attention of minors under the age of 18. For minors who wish to register with Skinrun App, the registration and the acceptance of this Privacy Policy shall be completed by his/her guardian who shall be eighteen (18) years or older.
1.7 Please read and understand fully this policy before using/continuing to use our products and services, and to make appropriate choices in accordance with the guidelines set out in this policy should the need arise. Your use or continued use of the products and/or services provided by us constitutes your full understanding and acceptance,agreement and consent to us processing your Personal Data in accordance with the manner as set out in this Privacy Policy, as amended from time to time.
1.8 We may revise or update this Privacy Policy at any time by posting a revised/an updated version on the Skinrun App. Unless stated otherwise, any revision or update takes effect immediately. Your continued access and/or use of our Skinrun App and/or Service or dealing with us after a revision or update to this Privacy Policy constitutes your binding acceptance of the revised or updated Privacy Policy.
1.9 It is necessary for us to collect and process your Personal Data.If you do not agree with the content of this policy, it may interrupt the proper operation of our products and/or services or may affect the intended performance of the service. In such a case, you should immediately stop accessing/using our products and/or services.
2. Scope of Information Collection
2.1 Based on the principles of fairness, lawfulness, and necessity, we will collect and use the personal information that you voluntarily provide to us while using our services or personal information generated as a result of you using our products and/or services, for the purposes as stated herein. If we use your personal information for any other purpose which is not covered under this policy, or for any purpose other than the purpose for which the collected information is intended for, we shall give reasonablenotice and request for your consent before using it.During your course of dealing with us, we will collect and process your Personal Data for purposes, which shall include, without limitation, the followings (collectively referred to as “Purposes”):
2.1.1 Where you are a Skinrun App User:
2.1.1.1 your gender, date of birth, email, personal mobile number and skin type according to your needs. Filling in the abovementioned information will increase the accuracy of your skin analysis resultsprocessing, managing or verifying your identity;
2.1.1.2 the images which you submit for skin analysis for machine learning and algorithm training purposes. At the same time, we will store the value for each of your analysis. The accurate recording of all the values allows you to observe the subtle changes in your skin at any time;
2.1.1.3 fulfilling and validating your purchases;
2.1.1.4 processing payment from you, collection of payment and/or outstanding payment(s), liaising with you and keeping and enhancing customer relationship;
2.1.1.5 personalising and enhancing your user experience with the Skinrun App and/or Service;
2.1.1.6 providing you with support and handling enquiries and complaints;
2.1.1.7 facilitating your participation in, and our administration of, any of our activities including contests, promotions, campaigns, polls or surveys;
2.1.1.8 protecting and/or enforcing our legal rights and interests, including defending any claim; detecting, investigating and preventing any fraudulent, prohibited or illegal activities or misusing of the Skinrun App and/or Service;
2.1.1.9 the delivery to you of our Services, notices, information in connection with our services;
2.1.1.10 preparing and executing all necessary documents for the performance of our contractual obligations with you;
2.1.1.11 manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management;
2.1.1.12 complying with any legal or regulatory requirements and to make the necessary disclosures under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular and/or code which are applicable to us and for the prevention of crime; and/or
2.1.1.13. any other purposes incidental/related to any of the above Purposes.
2.2 During the course of your dealings with us, we will from time to time request that you provide your Personal Data, to enable us to enter into transactions with you or to communicate with you for the performance of any Services offered by us. Your Personal Data may be collected by us through various means, including but not limited to the followings:
2.2.1 directly from you or indirectly from your representatives, agents and/or employer when you, your representatives, agents and/or employer send us a completed enquiry, application and/or registration forms via various means, including online and physical hardcopies at public venues or in any of our premises.
2.2.2 our forms whether in electronic or hardcopy format;
2.2.3 any correspondence that we have received from you requesting for information or making any inquiries;
2.2.4 business cards or other information provided to us or that were dropped at our premises or given to our employees or other agents; and/or
2.2.5 a variety of sources, including without limitation, at any meetings, events, activities, contests, customer satisfaction surveys organised and/or sponsored by us, as well as from publicly available sources such as directories and Skinrun App’s social media pages, if you follow, like or are a fan of such pages. Further information may also be collected when we exchange communications with you, for example, if you file a complaint or contact our support team.
2.3 Exceptions to authorisation and consent: Pursuant to the relevant laws and regulations, we may collect and use the necessary personal information without authorisation and consent from you in any of the following circumstances:
2.3.1 When the information is directly related to national security or national defence;
2.3.2 When the information directly concerns public security, public health, and is of significant public interests;
2.3.3 When the information is directly related to criminal investigation, prosecution, trial, and enforcement of judgment;
2.3.4 When the information is critical for protecting your vital interests or other individual’s vital interests (in relation to life and property), and consent is difficult to obtain;
2.3.5 When you voluntarily disclose the personal information to the general public;
2.3.6 When the personal information is collected legitimately from public information channels, such as from legitimate news reports and open government information and so forth;
2.3.7 When it is necessary according to the online agreements or contracts you sign with the platform;
2.3.8 When it is necessary to maintain the safe and stable operation of our products and/or services, such as to detect and manage product or service malfunctions;
2.3.9 Other circumstances as stipulated by the laws and regulations.
2.4 By providing yourPersonal Data to us, you have agreed to give your consent to the processing of your Personal Data by us for the Purposes as listed above when your Personal Data was collected.
2.5 If you fail to provide us with such Personal Data, we may not be able to process and/or disclose your Personal Data for any of the above Purposes and consequently we may not be able to continue to provide you with our services.
3. Marketing and promotional purposes
3.1 We may also use and process your Personal Data for the following marketing and promotional purposes (“Marketing and Promotional Purposes”):
3.1.1 to send you information, alerts, newsletters, updates, promotional materials,special privileges announcements on products, services, upcoming contests, events, activities, promotions, campaigns, polls or surveys offered/organised by us and/or our selected third parties (business/marketing partners, sponsors, advertisers) which may be of interest to you;
3.1.2 to send you seasonal/festive greetings or messages;
3.1.3 to notify and invite you to events or activities organised by us and/or ourselected third parties (business/marketing partners, sponsors, advertisers) which may be of interest to you;
3.1.4 to process your registration to participate in or attend an event or activityand to communicate with you regarding your attendance at the event or activity; and/or
3.1.5 to share your Personal Data within our organisation and our selected thirdparties (business/marketing partners, sponsors, advertisers) who may communicate with you to market their products, services, events or promotions, from time to time by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels.
3.2 You have the right at any time to request us to stop sending you any marketing and promotional materials or contacting you for Marketing andPromotional Purposes. You may also click on the “Unsubscribe” link embedded in the relevant marketing and promotional email in order not to receive any marketing and promotional email in the future. If you unsubscribe, we may still send you non-marketing and promotional communications, such as those about your Account, about the Skinrun App and/or Service or our ongoing business relations.
3.3 If you are a Skinrun App User, your user profile information such as your username will be used to identify you when you use the Skinrun App and/or Service.Your username may be displayed to other users when you submit your rating and/or review. We will not directly disclose or share your user email address and other information without your consent.
3.4 We may also use, process and share non-personally identifiable, aggregated, statistical and/or anonymous data with third parties for data analytics and to analyse and develop our marketing strategy and further improve and enhance the Skinrun App and/or Service.
3.5 You agree and consent to us using and processing your Personal Data for the Purposes as identified in this Privacy Policy.
4. Consent to disclosure for reasons relating to the Purposes
4.1 By providing your Personal Data to us, you have agreed to give your consent to the following disclosures of the Personal Data by us to these classes of third parties (which may be located or operating out of Malaysia) for reasons relating to the Purposes:
4.1.1 our collaborative partners related and associated firms including but not limited to Skinrun’s software and hardware purchasers and/or subscribers who undertake to keep your Personal Data confidential;
4.1.2 third parties appointed by us to provide services to us or on our behalf (including but not limited to auditors, lawyers, consultants, contractors, professional advisors, service providers, merchants, printing companies, advisers);
4.1.3 to the extent permitted by law, to any third-party credit search agency including but not limited to the Insolvency Department of Malaysia, Central Credit Reference System (“CCRIS”) and Credit Tip Off Service (“CTOS”), CTOS Sdn. Bhd;
4.1.4 as required or requested by Bank Negara Malaysia, Securities Commission of Malaysia, Companies Commission Malaysia, Inland Revenue Department or any other regulatory or competent authorities;
4.1.5 government agencies, statutory authorities, local councils and/or industry regulators, as well as to any other third party pursuant to any order or judgment of a court of law;
4.1.6 law enforcement agencies where it is required for the purposes of prevention of crime, illegal/unlawful activities or fraud or for the apprehension or prosecution of offenders or for an investigation relating to any of these;
4.1.7 any party in relation to legal proceedings or prospective legal proceedings;
4.1.8 When the information directly concerns public security, public health, and is of significant public interests;
4.1.9 When the information is directly related to criminal investigation, prosecution, trial, and enforcement of judgment;
4.1.10 When the information is critical for protecting your vital interests or other individuals’ vital interests (in relation to life and property), and consent could not be possibly obtained;
4.1.11 such other third parties as are necessary to carry out the Purposes stated herein (including but not limited to banks and financial institutions; insurance providers; housing/commercial/land developers; property surveyors & valuers; real estate agents/negotiators);
4.1.12 in the event of merger, acquisition, or liquidation, where we shall request the new company, organisation, or individual which holds your personal information to abide by this policy;
4.1.13 When you voluntarily disclose the personal information to the general public; and/or
4.1.14 When the personal information is collected legitimately from public information channels, such as from legitimate news reports and open government information and so forth.
4.2 Save as otherwise provided above, we do not discloseyour personal information with any other company, organisation or individual unless one or more of the following circumstances occur:
4.2.1 We have obtained your prior authorisation; or
4.2.2 You request for it.
5. Effect of Not Consenting to This Privacy Policy/Not Providing Your Personal Data
5.1 The collection of your Personal Data by us may be mandatory or voluntary in nature depending on the Purposes for which your Personal Data is collected. Where it is mandatory for you to provide us with your Personal Data, and you fail or choose not to provide us with such data, or do not consent to the above or this Privacy Policy, we will not be able to provide our Skinrun App and/or Service to you (if you are a Skinrun AppUser) or engage you to provide products and/or services to us or on our behalf or issue payments to you for products and/or services provided (if you are Skinrun’s business/marketing partner, agent, vendor, distributor, supplier, contractor or service provider).
6. Accuracy of Your Personal Data
6.1 AllPersonal Data provided by you to us will be treated as complete and accurate, and not misleading or obsolete. If there is any change to your Personal Data, please notify us. Please also be reminded that you may not access or use the Skinrun App and/or Service if you fail to keep complete, accurate and up-to-date Personal Data (including having an invalid or expired payment method).
7. Your Rights
7.1 To the extent that the prevailing Personal Data protection and privacy laws of the countries we operate in allow, you have the right to request for access to, request for a copy of, request to update or correct, your Personal Data held by us. We may charge a small fee (such amount as permitted under the applicable law) to cover the administration costs involved in processing your request to access your Personal Data. Notwithstanding the foregoing, we reserve our rights to rely on any statutory exemptions and/or exceptions to collect, use and disclose your Personal Data.
7.2 In addition, you also have the right, by notice in writing, to inform us on your withdrawal (in full or in part) of your consent given previously to us subject to any applicable legal restrictions, contractual conditions and a reasonable duration of time for the withdrawal of consent to be effected. We will use our best endeavour to cease the processing of your Personal Data upon receiving your notice in writing to us on the withdrawal. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we will not be able to continue with your existing relationship with us or the contract that you have with us will have to be terminated.
7.3 You may correct, update or delete your Personal Data at any time by editing your profile on the “Account Settings” page on the Skinrun App. However, please note that your Personal Data may be retained on our back-up systems for some time. In addition, you cannot delete information associated with past transactions as we keep track of these records.
8. How do we store and protect your personal information
8.1 Storage:
8.1.1 The information we obtained from users in Malaysia is stored in Southeast Asia data server or such other servers which may be situated in other countries outside of your country. This may include, but not limited to, instances where your Personal Data may be stored on servers located outside of your country. In addition, your Personal Data may be disclosed or transferred to entities located outside your country. Please note that these foreign entities may be established in countries that might not offer a level of data protection that is equivalent to that offered in your country under the applicable laws in your country. You hereby expressly consent to us transferring your Personal Data outside of your country for such purpose.We shall strictly abide by the laws and regulations of Malaysia and ensure that the recipient of data has sufficient data protection capacity to protect your personal information;
8.1.2 We will not keep your Personal Data longer than is necessary for the fulfillment of the purpose(s) for which it was to be processed unless such retention is necessary for us to discharge any regulatory function, under any law or in relation to any order or judgment of a court.
8.1.3 We will take all reasonable steps to ensure that all Personal Data are destroyed or permanently deleted if they are no longer required for the purpose(s) for which they were to be processed.
8.2 Protection:
8.2.1 In order to protect the security of your personal information, we shall endeavour to employ various industry-standard security measures to protect your personal information to minimise the risk of destruction, misappropriation, leakage, unauthorised access, use, disclosure, and alteration of your information.
8.2.2 We will make reasonable updates to our security measures from time to time and ensure the authorised third parties only use your Personal Data for the Purposes set out in this Privacy Policy.
8.2.3 Despite the aforementioned security measures, please take note that there are no absolute security measures on the information network. In order to prevent security incidents, we have set up an early warning mechanisms and emergency plans in accordance with the provisions of the laws and regulations. Besides that, in accordance with the requirements of the regulatory authorities, we shall report the security incidents together with the measures taken to cooperate closely with the government agencies.
8.2.4 All our employees and data processors, who have access to, and are associated with the processing of your Personal Data, are obliged to respect the confidentiality of your Personal Data.
8.2.5 Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be completelysecure. While we take commercially practical steps to protect your Personal Data, we cannot and do not accept responsibility for any unauthorised access, unlawful interceptions or loss of Personal Data transmitted to or from Skinrun App, and are not responsible for the actions of any third parties that may receive any such Personal Data.
9. Cookies and Other Types of Similar Technologies
9.1 Cookies are small files that are placed on your browser or device by the particular website(s) or application(s) you use or view. Cookies and similar technologies are utilised by Skinrun App to enable essential parts of Skinrun App to operate, recognise you when you visit Skinrun App, to track site usage and trends, to customise your experience on Skinrun App and to help keep Skinrun App safe, secure and easy to use; and
9.2 By using Skinrun App, you consent to the use of cookies placed in your computer. Notwithstanding, we may require your active consent to the use of cookies and similar technologies by clicking on the relevant acceptance box. In the event that you do not accept or block the use of cookies and similar technologies by adjusting the settings on your browser, parts of Skinrun App and the Services may not work and may impact your ability to use Skinrun App.
10. Right to Access and Correct Personal Data
10.1 Subject to the exceptions provided under the laws of Malaysia, you can obtain information about your Personal Data stored by us and may request access to see any information stored about you and request correction, updating, deletion or disabling of the same at any time. Kindly contact us in writing using the contact details provided below for this purpose. For avoidance of doubt, we may refuse to comply with your request if we are not supplied with information as may reasonably require in order to satisfy us as to your identity as the requestor and such other circumstances as provided under the relevant laws and regulations.
10.2 You may also contact us in writing using the contact details provided below should you have any queries, objections or complaints about the processing of your Personal Data or if you wish to limit the processing of your Personal Data or if you wish to withdraw consents which you have provided voluntarily.
10.3 We reserve the right to impose a fee for access of your Personal Data in the amounts as permitted under law. In respect of your right to access and/or correct your Personal Data, we have the right to refuse your request to access and/or make any correction to your Personal Data for the any reasons as permitted under laws of Malaysia.
10.4 We can be contacted through our email at infoms@skinrun.me during office hours between 9:30am to 5:30pm, Mondays to Fridays (besides public holidays).
11. How do we update our privacy policy
11.1 We reserve the right to update or revise this privacy policy from time to time and the updated version shall apply and supersede any and all previous versions.
11.2 In the event that this Privacy Policy is updated, it will be posted on the Skinrun App and we maynotify you via WeChat public accounts push notification or otherwise by any other reasonable means, that you may be informed at the earliest of any changes made to this privacy policy.
11.3 You may alsorequest for a copy of our latest Privacy Policy by contacting us through the contact details as provided for in this Privacy Policy.
12. How to contact us
12.1 If you have any questions about this policy, please contact us at +86 4000037993or add our WeChat customer service SKINRUN.