Effective Date: May 23, 2023

This Privacy Policy describes information Skims Foundations, Inc. (“Skims”, “us”, or “we”) may collect when you visit a website owned by Skims (the “Site”) or when you direct an inquiry to Skims through electronic means, telephonically, or otherwise. This Site is located at www.Skims.com and is owned and operated by Skims. This Privacy Policy also describes information we may otherwise collect in the course of our business and discusses how Skims stores, uses, discloses or shares information collected. This Privacy Policy forms part of the Terms and Conditions of Use that govern your use of the Site.

Please read this Privacy Policy carefully. If you do not agree, please do not access or use the Site. By accessing or using the Site, or by clicking “I agree,” you agree to this Privacy Policy. This Privacy Policy may change from time to time. Skims will post the modified version at this link. Your continued use of the Site after the Privacy Policy is modified is deemed to be acceptance of those modifications, so please check periodically for updates.

The Skims Site is powered by Shopify Inc. (“Shopify”). Information collected through the Site is collected by Shopify, and Shopify’s privacy policy applies to the collection of data by Shopify. Shopify’s privacy policy can be found here: https://www.shopify.com/legal/privacy.

1. Scope.
1. This Privacy Policy tells you about our information gathering, use, storing, and disclosure practices and applies to information collected through your use of this Site and your electronic communications through this Site. This Privacy Policy also applies to our collection and processing of information provided to us or collected by us offline.
2. This Privacy Policy does not apply to information collected by third parties, including via websites that may be accessible from, link to, or are linked from this Site. This Privacy Policy does not apply to information collected by third parties, even if the Site is accessed through a third party website or app.  Skims is not responsible for the content or privacy practices of any company other than Skims, and Skims is not responsible for the content or privacy practices of any non-Skims Site to which this Site links or which link to a Skims Site.
2. Information We Collect. Skims collects personal information and non-personal information.
   1. Registration information you submit when you create an account on the Site or update your account, including your name, email address, phone number, and mailing information or sign up to receive email correspondence from the Site;
   2. Information we obtain when you make a purchase or conduct another transaction, including your name, bra size, mailing address, email address, phone number, and credit card information;
   3. Information you submit when you subscribe to the Site, provide us feedback, use our “submit a request” form or otherwise correspond with Skims, which may include copies of the correspondence;
   4. Information you post on the Community page, which may include copies of the content posted;
   5. Information we obtain from a third party, such as a third party site, vendor, service provider, analytics partner, marketing or remarketing partner, or other platform provider;
   6. Location information, including location information provided by a mobile device or other device as you navigate the Site;
   7. Activity information about your use of the Site;
   8. Usage, viewing, technical, and device data when you visit the Site or interact with communications from our Site.
1. “Non-personal Information” is any information that does not identify you individually or does not permit a direct association with an individual. Non-personal Information may include information derived from Personal Information that has been de-personalized by removing unique identifiers and/or combining it with information about other users to form aggregated data.
2. “Personal Information” is information that is reasonably capable of being associated or could be linked, directly or indirectly, with a particular consumer or household. Skims collects some information that is about you individually, but does not identify you, and collects information about your internet connection, your device used to access the Site, and your use of the Site. If Skims combines that information with personal information, it will treat it as personal information.
3. Examples of information Skims collects include:
3. How We Collect. Skims collects information from and about you directly when you provide such information to Skims and automatically when you use the Site. 
1. Voluntarily and/or Directly Provided. In the course of visiting and using the Site, you may provide information to us voluntarily. For example, you provide information to Skims voluntarily when you register an account, fill out the “submit a request” form, complete a transaction, or post on the Community page. If you voluntarily provide your Personal Information to us, we collect it. You choose whether to disclose Personal Information, but you may not be able to use certain portions or features of the Site or conduct certain transactions without doing so.
2. Technologically Gathered. We collect some information automatically as you navigate the Site. For example, we collect traffic data (such as information about how much time visitors spend on the Site or each page, etc.), collect and log “clickstream data” (such as internet protocol addresses, pages visited, clicks made, and similar information) and information about your computer and internet connection (such as operating system and browser type) for all visitors. This sort of information is generally considered Non-personal Information (unless it is combined with Personal Information). We may combine information about your use with information about others’ use to generate aggregated Non-personal Information about visitors as a group. Some of the technology used to collect information is explained further in Skims’s Cookie Policy.
4. Cookies and Related Technology. Skims may use the following technologies to collect data as you visit the Site. To learn more about Skims’ use of cookies and your choices, please see Skims’s Cookie Policy.
1. “Cookies” are small pieces of data that a website, when visited by a user, asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Cookies can be either persistent or temporary. A persistent cookie retains user preferences for a particular website, allowing those preferences to be used in future sessions and remains valid until its set expiry date (unless deleted by the user before the expiry date). Temporary cookies expire at the end of a user session when the browser is closed.
2. Most internet browsers are initially set to accept cookies.  Cookies are classified in the following categories: Necessary Cookies, Performance Cookies, Functional Cookies, and Targeting Cookies. You cannot opt-out of Necessary Cookies, but you can opt out of the other cookie categories by clicking on the “cookie settings” button in your browser, in this policy, or in the applicable website cookie notice.  If you decline the use of cookies or set your browser to refuse cookies, then you may not be able to access or use portions of this Site.
3. “Web beacons” and “pixels” are small bits of code embedded in web pages or emails that assist in delivering cookies and measuring statistics. Web beacons and pixels help Skims determine whether a page on this Site has been viewed and, if so, how many times. Skims may also use web beacons and pixels in email messages to determine what the recipient has done with the message. Although you cannot decline to receive web beacons and pixels when visiting a web page, you can choose not to receive them by email if you disable HTML images or refuse HTML email messages. 
5. How We Use the Information. Skims uses information that you provide and/or that Skims collects to present the Site to you, improve the Site, deliver a more personalized experience to you, to provide you with information, products, and/or services that you request from Skims, to market Skims’s products to you, to fulfill any other purpose for which you provide such information, to provide you with other information you requested, in any other way Skims may describe when you provide the information, and for any other purpose with your consent. The way Skims uses such information is described in more detail in the chart below. Skims may aggregate the information you provide or that Skims collects from you with information collected from other users to allow Skims to evaluate its products, solutions, and services. Skims may use the information it collects to contact you about Skims’s products that may interest you; if required by law, we will obtain your approval to do so. If you do not want Skims to use your information this way, please see Section 7 below.
   
   

   Why Skims processes your information	Legal basis for the processing purpose
   To respond to your request or to fulfill the purpose for which you provide the information	Performance of a contract Your consent
   To personalize and improve your experience with the Site	Legitimate interest
   To ensure technical functionality and proper operation of the Site	Legitimate interest
   To improve our products and services or to develop new products and services	Legitimate interest
   To communicate with you for product or services-related purposes, such as regarding support issues and customer service inquiries	Performance of a contract Legitimate interest Consent
   To communicate with you for the following purposes: to respond to a request, marketing, remarketing, research, or other promotional purposes, via email, notifications or other messages, consistent with any permissions you may have communicated to us	Consent Legitimate Interest
   To comply with our legal obligations	Legitimate Interest
   To carry out our obligations and enforce our rights	Legitimate Interest Contract
   In any other way described when the information is collected	Legitimate interest Consent

   
   
   
6. To Whom We Disclose.
   1. General. Skims may disclose aggregated information about its users and information that does not identify any individual without restriction. Skims may disclose personal information that it collects or you provide as described in this Privacy Policy to Skims’s business partners, affiliates, contractors, distributors, or service providers, and other third parties Skims uses to support its business, including but not limited to customer support, web hosting, information technology, payment processing, product fulfillment, fraud control, legal services, marketing, and remarketing, advertising and analytics providers. Skims requires such processors to agree in writing to maintain safeguards for protection of your Personal Information Skims may also disclose personal information that it collects or you provide to a purchaser or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Skims’s assets; to fulfill the purpose for which you provided the personal information; for any other purpose when you consent to such disclosure at the time you provide the information. Skims may also disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request, to enforce Skims’s terms of use and other agreements, and if Skims believes disclosure is necessary or appropriate to protect the rights, property, or safety of Skims, its customers, or others.
   2. Disclosure for Third Party Direct Marketing. Skims does not share personal information it receives or collects from you with its business partners for their direct marketing purposes (to market their own goods or services directly to you). Skims will not do so in the future unless you have first consented and then only unless or until you withdraw your consent.
   3. Google Analytics and Google Analytics Advertising. The Site uses Google Analytics. Google Analytics assists Skims with collecting and monitoring data about traffic to the Site. Google Analytics collects visitation information via Google advertising cookies and identifiers. You can learn how Google collects and processes data by visiting the following website: www.google.com/policies/privacy/partners/. This Site also uses Google Analytics Advertising, including Google Demographics and Interest Reporting, Google Display and Search Remarketing, and Google Display Impression Reporting. Google Analytics Remarketing uses cookies to track users who visit the Site and display ads when users are on other websites. If you would like opt-out of the Google Analytics Advertising Features, you can adjust your Ad Settings and Ad Settings for mobile apps. For information on how to adjust your Ad Settings, visit the following website: https://support.google.com/accounts/answer/2662856?co=GENIE.Platform%3DAndroid&hl=en. For more information about Google Analytics’ currently available opt-outs or to opt-out of the collection of data by Google Analytics, visit the following website: https://tools.google.com/dlpage/gaoptout/. For information about how to opt out of Google Marketing Platform’s use of cookies, visit https://optout.networkadvertising.org/?c=1.  For more information about targeting and advertising cookies and how to opt out of those, visit optout.aboutads.info.
   4. Third Party Analytics. Skims also engages Facebook, LinkedIn, and Instagram, as well as engage other third party service providers to assist with collecting and monitoring data about traffic to the Site, as well as to display ads to users when users are on other websites. These third parties use cookies, web beacons, and other tracking technologies to collect or receive information from Skims, the Site, or elsewhere on the internet, as discussed in Section 4 above, and will use that information to provide measurement services and targeted advertisements. You have the ability to opt-out of the collection or use of your data for remarketing, retargeting, online behavioral advertising, and interest-based advertising. You may do so by visiting the following websites: www.networkadvertising.org/choices, www.aboutads.info/choices, or http://www.youronlinechoices.eu/.
7. Your Choices. You have some choices about how personal information you provide to us or that we collect is used.
   1. Do Not Track. The Site does not respond to web browser Do Not Track (DNT) signals.
   2. Tracking Technologies. You may set your browser to refuse some or all browser cookies, or to alert you when cookies are being sent. To learn how to manage or delete cookies on your browser, visit the browser developer’s website. To learn how to manage Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that parts of the Site may not be accessible or may not function properly.
   3. Updating Information. You may contact Skims at the contact information set forth below to request access to, correct, or delete certain personal information that you have provided to Skims. Skims may not accommodate a request to change information if Skims believes the change would violate any law or legal requirement or cause the information to be incorrect. 
   4. California Residents. You may review the Supplemental Notice applicable to California residents.
8. For Residents of EEA. If you reside in the European Economic Area (the “EEA”), the following provisions apply to you: 
   1. Access. You may request access to your personal information and the following information regarding our use of it: (i) purpose of the use, (ii) categories of personal information used, and (iii) to whom we have disclosed your personal information.
   2. Correction. You may request that Skims correct any inaccurate personal information we have.
   3. Right to Be Forgotten. You may request that Skims erase your personal information when Skims no longer needs such data.
   4. Withdraw Consent. If Skims’s ability to use your personal information depends on consent you have given, you may withdraw such consent.
   5. Restriction. You may request that Skims restrict (or suspend) use of your personal information.
   6. Object. You may object to Skims’s use of your personal information to perform services you have not requested.
   7. Copies and Portability. You may request copies of your personal information that Skims possesses in a structured, commonly used, and machine readable format and you may request that this be transmitted to another controller.
   8. Complaint. You may lodge a complaint with the supervising authority of your country.
9. Data Transfer. Skims stores your personal information in the United States. The privacy protections in the United States may not be the same as in your home country. If you are located in a country outside the United States and submit personal information to Skims, you consent to the general use and disclosure of such information as provided in this Privacy Policy and to the transfer and/or storage of that information to the United States.
   
   
10. For Residents of Canada. If you reside in Canada, the following provisions apply to you: 
    1. Types of Personal Information Collected, Used, and Disclosed. Skims collects various types of personal information directly from you, as well as from third parties and automatically through the use of analytics tools, as described in Section 2 above.  The following chart identifies the categories of personal information collected by Skims, the source of such personal information, how Skims uses such personal information, and to whom Skims discloses such personal information:
       
       

       Category of Personal Information	Source	Business Purpose	To Whom Disclosed (categories)
       Identifiers: Name, postal address, IP address, email address, driver’s license number, telephone number	-you -technologically gathered from you -service providers -business partners	-facilitate transactions -marketing/ communications -fulfill requests -provide support -provide goods/services	-service providers -business partners -data analytics providers -advertising and remarketing partners -fulfilment partners -payment processors -customer support partners -internet service providers
       Name, address, bank account number, credit card number, debit card number, or any other financial information	-you -service providers -business partners	-facilitate transactions -marketing/ communications -fulfill requests -provide support -respond to inquiries	-service providers -business partners -data analytics providers -advertising and remarketing partners -fulfilment partners -payment processors -customer support partners -internet service providers
       Purchasing or consuming histories, tendencies, or preferences	-you -service providers -business partners	-facilitate transactions -provide goods and services to customers - improve goods and services -fulfill contractual obligations -respond to inquiries	-service providers -business partners -data analytics providers -advertising and remarketing partners -fulfilment partners -payment processors -customer support partners -internet service providers
       Internet/network activity	-you/your device -service providers	-improve Site -personalize Site -improve Site experience -marketing and remarketing	-service providers -business partners -data analytics providers -advertising and remarketing partners -fulfilment partners -payment processors -customer support partners -internet service providers
       Geolocation data	-you/your device -service providers	-improve Site -personalize Site -improve Site experience -improve customer experience -marketing and remarketing	-service providers -business partners -data analytics providers -advertising and remarketing partners -fulfilment partners -payment processors -customer support partners -internet service providers
       Inferences drawn from other personal information	-business partners -service providers	-provide goods and services -marketing and remarketing -improve customer experience -improve product and service offerings -respond to inquiries	-service providers -business partners -data analytics providers -advertising and remarketing partners -fulfilment partners -payment processors -customer support partners -internet service providers

       
       
       
    2. Risk of Harm and Other Consequences. You choose whether to provide Personal Information to Skims and whether to allow Skims to collect Personal Information about you. You may not be able to use certain portions or features of the Site or conduct certain transactions without doing so. Skims has implemented some measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, however, the transmission of information via the internet is not completely secure. Skims cannot guarantee the security of your personal information transmitted to or through the Site, and there is a risk that your personal information will be compromised.
    3. Methods of Collection and Obtaining Consent. We may process your Personal Information in accordance with your consent or other instructions. We share Personal Information with third parties when we have your consent to do so. For example, if you decide to register an account, complete a transaction, or use our Site, you consent to our privacy policy and the use of your Personal Information as disclosed herein. We may also share your Personal Information with third parties, including our service providers.
    4. Choices and Withdrawal of Consent. Consistent with applicable law, you may request access to or copies of your Personal Information stored or retained by Skims. Applicable law may also entitled you to request deletion of your Personal Information stored or retailed by Skims. Please note that if you request the erasure of your Personal Information, Skims may retain and/or use your Personal Information as permitted under applicable law and to exercise legitimate business interests and complying with applicable law.
    5. Account Closing and Deletion of Information. Subject to certain exceptions, you may request that Skims close your account and delete Personal Information about you that it has collected and retained. 
    6. Use of Third Parties. As described in this Privacy Policy, Skims relies on its business partners, affiliates, contractors, distributors, or service providers as well as to other third parties to support its business and may receive Personal Information from or disclose information to these third parties in the course of receiving support from these third parties. More information about Skims’s use of third parties is described above in Section 10(c).
    7. Disclosure of Data for Third Party Use. Other than as disclosed herein, Skims does not disclose or sell Personal Information for third party use.
    8. Cross-Border Transfers. For the reasons and purposes set forth in this Privacy Policy, the Personal Information and other data that Skims collects may be transferred to and stored or otherwise processed in the United States or other locations. While in another jurisdiction for processing, your Personal Information may be accessed by the courts, law enforcement, and national security authorities of that jurisdiction. These jurisdictions may not provide the same level of data protection as your home jurisdiction.
    9. Law Enforcement Requests. We disclose Personal Information when we believe doing so is reasonably necessary to comply with applicable law or legal process, including an enforceable request from law enforcement, to respond to claims, to enforce or apply our Terms of Use, or to protect the rights, property, or personal safety of Skims, our users, employees, or others.
    10. Access and Correction Requests. Subject to certain exceptions, you have the right to request certain information about Skims’s collection, use, and/or disclosure of your personal information. After receipt of an access request from you, Skims will disclose to you the categories of personal information collected, categories of sources for the categories of personal information collected, business or commercial purpose for collecting such personal information, categories of third parties with whom Skims shared such personal information, and specific pieces of personal information collected about you. If any of the information Skims maintains about you is incorrect, you may also request that Skims correct such information about you.
11. Data Retention and Security.
    1. Data Retention. Skims retains personal data in accordance with applicable law. Skims may store your personal information to the extent required to comply with Skims’s legal, accounting, and/or reporting requirements. Additionally, Skims may continue to store your personal information contained in standard backups. Upon your request, Skims will delete or permanently de-identify your personal information, unless Skims is legally required or permitted to maintain such personal information.
    2. Data Security. Skims has implemented some measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Skims cannot guarantee the security of your personal information transmitted to or through the Site. Any transmission of personal information is at your own risk. Skims is not responsible for circumvention of any privacy settings or security measures contained in the Site.
12. Changes to Privacy Policy. Changes to the Privacy Policy will be posted on this page. If Skims makes material changes to the way it treats users personal information, Skims may choose notify you by email or through a notice in addition to posting. The date the Privacy Policy was last revised appears at the top of the Privacy Policy. You are responsible for ensuring Skims has a current email address for you and for periodically visiting the Site and the Privacy Policy to check for any changes.
13. Children. The Site is not for children. Skims does not knowingly collect personal information from children under the age of 18 through the Site. If Skims learns that it has collected or received such information, it will delete that information. If you believe we might have information from or about a child under the age of 18, please let us know by contacting us using the information set forth in Section 17.
14. Nevada Residents.  Under Nevada law, Nevada residents may submit a request directing Skims not to make certain disclosures of personal information we maintain about them. If you are a Nevada resident and wish to exercise this right, you may contact us by email at info@skimss.com.
15. Additional State Privacy Rights.  Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
    1. Confirm whether we process their personal information.
    2. Access and delete certain personal information.
    3. Data portability.
    4. Opt-out of personal data processing for targeted advertising and sales.
       Colorado, Connecticut, and Virginia also provide their state residents with rights to:
       1. Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
       2. Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
          
          To exercise any of these rights or to appeal a decision regarding a consumer rights request, please contact us in listed in Section 17 below.  Skims will respond to all appeal requests as soon as we reasonably can, and no later than legally required.
16. Links. This Site contains links to third party websites that Skims does not control. Skims cannot be held responsible for third parties’ privacy practices or content provided on such websites. If you click on one of these links, please understand that you are leaving the  Site and any information you provide will not be covered by this Privacy Policy. Please read that website’s privacy policy before providing any information.
17. Contact Information. If you have any questions or comments about this Privacy Policy and Skims’s privacy practices, please contact Skims at:

TSALELHSCH LTD - 3346312
2301 Bayfield - Building 99
Hennessy Road - WAN CHAI - HONG KONG
Email: info@skimss.com