Your Privacy

Effective Date: March 11, 2021

Galderma Laboratories, L.P. (hereinafter referred to as “Galderma,” “we,” “our,” or “us”) is committed to safeguarding your privacy. We ask that you carefully review this Privacy Policy, as it applies to all information Galderma collects from and about you, whether in writing, verbally, or electronically. This includes information we collect when you: (a) visit our website (“acne.com”), (b) signup for acne.com newsletter, (c) complete acne.com skin quiz or (d) otherwise choose to contact us (collectively, the “Services”). By using the Services, you agree to the collection, use, and disclosure of your information, as described in this Privacy Policy. If you do not agree, please do not access or use the Services.

California Notice of Collection of Personal Information: Galderma collects personal information listed below under “Information We Collect” for the purposes described below under “Information Use.” To learn more about your California privacy rights, please scroll down to “Your California Privacy Rights.”

1. INFORMATION WE COLLECT

A. Types of Information We Collect

Galderma collects information from you when you use the Services and when you choose to share information with us. This may include “Personal Information” such as: your biographical information (e.g., name, , email address, ,age group ); user-generated content (e.g., ratings, reviews, comments, photos containing your image); geo-location information; unique user identifiers (e.g. VoIP identifier, instant messaging ID, video chat identifier, or social networking login information, third party platform login information); medical or other health related information; and aesthetic information (e.g. treatment history, loyalty program history, treatment date, treatment type, treating healthcare professional).

B. Information Automatically Collected

Additionally, whenever you visit or interact with the Services, Galderma or its third-party advertisers and/or service providers, may use a variety of technologies such as cookies, web beacons, pixel tags, log files, local shared objects (Flash cookies), HTML5 cookies, or other technologies to automatically or passively collect information about your online activity. We may automatically collect the following information about you:

Computer or Device Information. We may automatically collect your Internet Protocol (“IP”) address or other unique identifiers or information from the computer, mobile device, tablet, or other device you use to access the Services, including but not limited to your browser type, device type, operating system, software version, phone model, phone operating system, carrier information, and the domain name from which you accessed the Services.
Usage Information. We may collect information about your use of the Services, including the date and time you visit the Services, the areas or pages of the Services that you visit, the amount of time you spend viewing or using the Services, the number of times you return to the Services, other click-stream or usage data for the Site emails that you open, forward or click-through to our Services, and other sites that you may visit.
Use of Third Party Analytic Technologies. We may use third parties’ analytics and tracking tools to better understand who is using the Site, how people are using the Site, how to improve the effectiveness of the Site and related content, and to help us or those third parties serve more targeted advertising to you across the Internet. These tools may combine information from your interaction with the Site with information collected from other sources.

To learn more about your advertising choices relating to the collection and use of your information, please see the “Your Choices and Opt-Outs” section below.

2. INFORMATION USE

A. Use by or for Galderma

Galderma may use the information we collect from and about you for the following business purposes:

To provide you with the Services;
To fulfill our contractual obligations;
To respond to your inquiries, fulfill orders, contact and communicate with you when necessary;
To review the usage and operations of our Site, and email Program, develop new products or services, improve the Services, and conduct analyses to enhance or improve our content, products, and services; and

Galderma may use the information we collect from and about you for the following commercial purposes:

To provide you with customized content or targeted offers;
To provide you with information, newsletters and promotional materials from Galderma and, or on behalf of, our marketing partners and affiliates; and
To use your data in an aggregated non-specific format for analytical and demographic purposes.

Galderma may use information you provide to us for the following additional purposes:

For other purposes disclosed at the time you provide your information or otherwise with your consent.

Additionally, if you use the Services to connect with third party services, you authorize us to use information from and about you, on your behalf, to interact with these third party services based on your requests.

B. How We Use Your Information for Interest-Based Advertising

We may use third parties to measure and target advertisements for us about our products and services, and those of our marketing partners and affiliates, that are tailored to your online interests. We allow these third-party companies to use cookies, web beacons, pixel tags, and similar technologies to collect certain data and other information about your online activity. This information is used to display advertisements for Galderma on the Services or across other websites, mobile applications, social media, or online services that you use.

For information on your choices with respect to interest-based ads, see the “Interest Based Advertising Choices” section below.

3. INFORMATION WE SHARE WITH OTHERS

We may share your personal information with the following:

Service Providers: We may share your information with third party service providers that provide business, professional, or technical support functions for us, help us operate our business and the Services, or administer activities on our behalf.
Select Third Parties: We may share your information with our select partners, affiliates, your healthcare professional(s) and other third parties for their business, operational, promotional, and marketing purposes. These entities’ use of such information is subject to their respective privacy policies. To learn more about your advertising choices relating to the collection and use of your information, please see the “Your Choices and Opt-Outs” section below.
Legal Matters; Safety: We may access and disclose your information to respond to subpoenas, judicial processes, or government requests and investigations, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law. We may disclose your information to protect the security of our Services, servers, network systems, and databases. We also may disclose your information as necessary, if we believe that there has been a violation of our Terms of Use, any other legal document or contract related to our services, or the rights of any third party.
Sale or Transfer of Business or Assets: We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Services in a manner that is consistent with this Privacy Policy.

4. YOUR CHOICES AND OPT-OUTS

A. Use of Tracking Cookies

Certain parts of our Site require cookies. You may adjust your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features of the Services or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable your device or browser from receiving cookies or controlling your tracking preferences.

Our system may not recognize Do Not Track requests or headers from some or all browsers. We may use cookies or other technologies to deliver more relevant advertising and to link data collected across other computers or devices that you may use.

B. Interest-Based Advertising Choices

To understand your choices for receiving more relevant advertising provided on the Service or across other websites and online services, please review the information below:

To learn more about such interest-based advertising, and to opt out of such collection and use for interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit http://optout.aboutads.info.
To opt-out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices.

Even if you opt out, you still may receive advertising from us that is not customized based on your Service or usage information, or advertising from other third parties if they are not a DAA participating company.

C. Unsubscribing from our Marketing Communications

We provide you with the opportunity to opt-out of email marketing communications. To do so, you may:

Send us an email at unsubscribeUS@galderma.com;
Contact us by mail at the address below in the “How to Contact Us” section; or
Unsubscribe from our email communications at any time by following the instructions contained within the email.

Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable. Additionally, we are not responsible for informing third parties or affiliates with whom we have already shared your personal information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.

5. YOUR CALIFORNIA PRIVACY RIGHTS

A. Your Rights

If you are a California resident, you may take advantage of the following rights:

Right to Know: If you are a California resident, you may request, up to two times each year, that we disclose to you the categories and/or the specific pieces of personal information that we collect, use, disclose, and may sell. We will respond to your request within 45 days unless we need additional time, in which case we will let you know. You may also request, up to one time each year, information about our disclosure of personal information about you to third parties or affiliated companies that do not share the same brand name for their direct marketing purposes.

Right to Delete: Subject to certain exceptions, you may request that we delete personal information that we have collected from you. Note that there are some reasons we will not be able to fully address your request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation.
Right to Opt Out of the Sale of Personal Information: As described below, we share personal information with certain third parties to enable personalized ads on our Site You may request to opt out of these “sales” (as defined by California law) of personal information at any time using the Do Not Sell My Personal Information link at the bottom of this page, or contact us using our webform or contact details provided below.

To make such requests, please contact us using our webform, at 1-866-735-4137 extension 7, or by mail at the address in the “How to Contact Us” section below. You must put the statement “Your California Privacy Rights” in the subject field. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. We may take steps to verify your identity before responding to your request by asking you a series of questions about your previous interactions with us.

If you use an authorized agent to make a request, please have the agent complete the following webform. We may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to verify your identity directly with us prior to fulfilling the authorized agent request.

If you exercise any of the foregoing rights, we will not discriminate against you, such as by denying you access to our products or restricting your access to products of certain pricing or quality.

B. Personal Information Collection and Disclosures

In addition to the information provided elsewhere in this Privacy Policy, this section describes the types of personal information that, over the past 12 months Galderma collected, used, disclosed and may sell. This personal information is categorized as follows:

Identifiers/Biographical Information: These include your name, postal and email address, phone number, unique identifiers, and characteristics of protected classifications under California or federal law.
Commercial information: Your purchase and usage history, and preferences.
Internet/Electronic Activity: Your geolocation information, IP address, web/app browsing and search history related to our Services, and information regarding your interaction(s) with the Services or Galderma advertising.
Profile Inferences: The inferences that we draw from your information and web activity to create a personalized profile so we can better identify goods and services that may be of interest.
Financial Information: This includes your bank card and credit card information used to process payments.
Medical/Health Insurance/Aesthetic Information: This includes treatment history, loyalty program history, treatment date, treatment type, treating healthcare professional.

Categories of Personal Information Collected:

In the last 12 months (from the Effective Date listed at the top of the Policy), Galderma has collected the following categories of personal information for the business and commercial purposes listed above under “Information Use”: Identifiers/Biographical Information, Commercial Information, Internet/Electronic Activity, Profile Inferences, Financial Information, Medical/Health Insurance/Aesthetic Information associated with you. The sources of the personal information are disclosure by you, automatic collection of information about your online activity, third party analytics tools, healthcare professionals, service providers, data brokers, advertising networks, and other select third parties (as defined above).

Categories of Personal Information Sold

In the last 12 months (from the Effective Date listed at the top of the Policy), Galderma has sold the following categories of personal information to provide you with customized content or targeted offers: Identifiers/Biographical Information, Internet/Electronic Activity, and Profile Inferences. The third parties to whom each identifier was sold are advertising networks and data analytics providers.
Galderma does not sell the personal information of consumers under the age of 16 years.

Categories of Personal Information Disclosed

In the last 12 months (from the Effective Date listed at the top of the Policy), Galderma has disclosed the following categories of personal information for a business purpose: Identifiers/Biographical Information, Commercial Information, Internet/Electronic Activity, Profile Inferences, Financial Information associated with you, and Medical/Health Insurance/Aesthetic Information associated with you. We disclose these categories of personal information to our service providers as described above in “Information We Share With Others.”

6. EXTERNAL LINKS

The Site may have links to third-party websites, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.

7. PUBLICATION OF USER SUBMISSIONS

Any information you may disclose on our Site (e.g., ratings and reviews), in blogs, on message boards, in chat rooms, on social media, or in other public areas becomes public information. Please exercise caution when disclosing personal information in these public areas, including personal health information.

8. CHILDREN’S PRIVACY

We do not direct the Services to, nor do we knowingly collect any personal information from, children under the age of 16. If Galderma learns that a child under the age of sixteen has provided personally identifiable information, we will use reasonable efforts to remove such information from our files.

9. REVISIONS TO THIS PRIVACY POLICY

We reserve the right, at our sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time. When we do, we will post the change(s) on the Site. Your continued use of the Services following the posting of changes to these terms means you accept these changes. If we change the Privacy Policy in a material way, we will provide appropriate notice to you.

10. HOW TO CONTACT US

If you have any questions or concerns about this Privacy Policy or the practices described herein, you may contact us at USPrivacy@galderma.com or by mail to:

Galderma Laboratories, L.P.

14501 North Freeway

Fort Worth, TX 76177

Attention: Chief Privacy Officer