Privacy Policy

PART ONE: INTRODUCTION

WE AT HELPING MINDS VALUE YOUR PRIVACY AND ARE COMMITTED TO KEEPING YOUR PERSONAL DATA CONFIDENTIAL. WE USE YOUR DATA SOLELY IN THE CONTEXT OF PROVIDING WEBSITE PLATFORMS AND NATIVE APPLICATIONS (THE “PLATFORM”) FOR PERSONS SUFFERING FROM EXCORIATION DISORDER, AND SPECIFICALLY FOR (1) CLIENTS TO PARTICIPATE IN PSYCHO EDUCATIONAL SESSIONS AND SELF ASSESSMENTS, AND DEPENDING ON THE LEVEL OF PROGRAM PURCHASED, TO GET ACCESS TO INDEPENDENT LICENSED THERAPISTS WHO ARE PARTICIPATING IN THE PROGRAM ON OUR PLATFORM, AND (2) PROVIDERS WHO ARE LICENSED THERAPISTS TO PARTICIPATE IN THE PROGRAM AND CONNECT WITH CLIENTS AND REVIEW CLIENTS’ PROGRESS, COMMUNICATE WITH CLIENTS THROUGH WRITTEN AND/OR LIVE COMMUNICATIONS.

THIS PRIVACY POLICY APPLIES TO PERSONAL DATA HELPING MINDS COLLECTS FROM USERS OF THE HELPING MINDS WEBSITES (THE “WEBSITES”). “PERSONAL DATA” INCLUDES ANY INFORMATION THAT CAN BE USED ON ITS OWN OR WITH OTHER INFORMATION IN COMBINATION TO IDENTIFY OR CONTACT ONE OF OUR USERS. WE BELIEVE THAT TRANSPARENCY ABOUT THE USE OF YOUR PERSONAL DATA IS OF UTMOST IMPORTANCE. IN THIS PRIVACY POLICY, WE PROVIDE YOU DETAILED INFORMATION ABOUT OUR COLLECTION, USE, MAINTENANCE, AND DISCLOSURE OF YOUR PERSONAL DATA. THE POLICY EXPLAINS WHAT KIND OF INFORMATION WE COLLECT, WHEN AND HOW WE MIGHT USE THAT INFORMATION, HOW WE PROTECT THE INFORMATION, AND YOUR RIGHTS REGARDING YOUR PERSONAL DATA.

Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.

BY SUBMITTING YOUR PERSONAL DATA THROUGH THIS WEBSITES, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT LOG INTO OR ACCESS THE WEBSITES AND DO NOT SUBMIT ANY PERSONAL DATA TO US.

PLEASE NOTE THAT WE OCCASIONALLY UPDATE THIS PRIVACY POLICY AND THAT IT IS YOUR RESPONSIBILITY TO STAY UP TO DATE WITH ANY AMENDED VERSIONS. IF WE MODIFY THE PRIVACY POLICY, WE WILL POST A LINK TO THE MODIFIED TERMS ON OUR WEBSITES AND NOTIFY YOU VIA THE EMAIL ADDRESS YOU HAVE PROVIDED TO US. YOU CAN STORE THIS POLICY AND/OR ANY AMENDED VERSION(S) DIGITALLY, PRINT IT, OR SAVE IT IN ANY OTHER WAY. ANY CHANGES TO THIS PRIVACY POLICY WILL BE EFFECTIVE IMMEDIATELY UPON PROVIDING NOTICE, AND SHALL APPLY TO ALL INFORMATION WE MAINTAIN, USE, AND DISCLOSE. IF YOU CONTINUE TO USE THE WEBSITES FOLLOWING SUCH NOTICE, YOU ARE AGREEING TO THOSE CHANGES.

In case you have any questions or concerns after reading this Privacy Policy, please do not hesitate to contact us at support@skinpick.com. We appreciate your feedback.

PART TWO: POLICY SUMMARY

For your convenience, we have summarized the key takeaways from our Privacy Policy, below. You may access our full Privacy Policy HERE.

Responsible Entity

Helping Minds (“We”, “Us”, “the Company”) is the controller of your Personal Data, and may process this data in accordance with the Privacy Policy. If we are processing Personal Data on behalf of a third party, the terms of this Privacy Policy do not apply—instead, the terms of that third party’s privacy policy will apply. You can contact Us with any questions about our Privacy Policy at support@skinpick.com.

What information do We collect and why?

We collect “PERSONAL DATA”, which includes any information that can be used on its own or with other information in combination to identify or contact one of our users. For a description of the types of Personal Data we collect, review this section in the full Privacy Policy. In some cases, this Personal Data may be or may include healthcare information or “protected health information”.

We may use Personal Data to (1) provide you with the Websites; (2) communicate with you about and manage your User Account; (3) store data; (4) comply with the law; (5) respond to requests from public and government authorities; (6) to enforce our terms and conditions; (7) manage and improve our operations and Websites; (8) provide additional functionality; (9) protect our rights, privacy, safety or property, and/or that of you or others; and (10) allow us to pursue available remedies or limit the damages that we may sustain. Additional uses are described in this section of the full Privacy Policy.

We only use or disclose your Personal Data when it is legally mandated or where it is necessary to fulfill the purposes described above (and in the full Privacy Policy). Where required by law, we will ask for your prior consent before doing so.

Failure to Provide Data. Providing your Personal Data is not statutorily or contractually mandated. However, if you choose not to provide this information, we cannot create a User Account, and you will be unable to use our Services.

Will We share your Personal Data with anyone else?

If you are a patient, then Yes, with the healthcare provider(s) with whom you choose to share your Personal Data via the Websites
Yes, with third parties that help us power our Websites
Yes, with third parties and the government when legal or enforcement issues arise
Yes, with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Helping Minds’ corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings).

For more details regarding the above, review this section in the full Privacy Policy.

Where is your Personal Data stored, transmitted and/or maintained?

Personal Data Helping Minds collects through the Platform will be stored on secure servers in the United States. Some Personal Data may be transmitted to third parties, which parties may store or maintain the data on their secure servers. These third parties are not permitted to transfer your Personal Data outside of the United States.

How long will We maintain your Personal Data?

We will retain your Personal Data for as long as you maintain a User Account and, in certain cases, for at least seven (7) years after the account is closed. For more information on Personal Data retention, review this section of the full Privacy Policy.

How do We protect your Personal Data?

Helping Minds uses a combination of reasonable physical, technical, and administrative security controls to maintain the security and integrity of your Personal Data, to protect against any anticipated threats or hazards to the security or integrity of such information, and to protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm or inconvenience to you. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure. As a result, we cannot ensure the security of information you transmit to us. By using the Platform, you are assuming this risk. For more information on the safeguards We have in place to protect your Personal Data, review this section of the full Privacy Policy.

Your rights

You have certain rights relating to your Personal Data, subject to local data protection laws. These rights may include:

to access your Personal Data held by us;
to erase/delete your Personal Data, to the extent permitted by applicable data protection laws;
to receive communications related to the processing of your personal data that are concise, transparent, intelligible and easily accessible;
to restrict the processing of your Personal Data to the extent permitted by law (while we verify or investigate your concerns with this information, for example);
to object to the further processing of your Personal Data, including the right to object to marketing;
to request that your Personal Data be transferred to a third party, if possible;
to receive your Personal Data in a structured, commonly used and machine-readable format;
to lodge a complaint with a supervisory authority;
to rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;
to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"); and
to the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

For more details on your rights and choices and how to exercise them, please review the full Privacy Policy.

How do you contact Us with questions or concerns?

If you have any questions about this Privacy Policy, please contact us by email at support@skinpick.com. Please note that email communications are not always secure; so please do not include sensitive information in your emails to us.

PART THREE: FULL PRIVACY POLICY

Version 1

Last Updated: February 1st 2022.

WE AT HELPING MINDS VALUE YOUR PRIVACY AND ARE COMMITTED TO KEEPING YOUR PERSONAL DATA CONFIDENTIAL. WE USE YOUR DATA SOLELY IN THE CONTEXT OF PROVIDING YOU WEBSITE PLATFORMS AND NATIVE APPLICATIONS (THE “PLATFORM”) FOR PERSONS SUFFERING FROM EXCORIATION DISORDER, AND SPECIFICALLY FOR (1) CLIENTS TO PARTICIPATE IN PSYCHO EDUCATIONAL SESSIONS AND SELF ASSESSMENTS, AND DEPENDING ON THE LEVEL OF PROGRAM PURCHASED, GET ACCESS TO INDEPENDENT LICENSED THERAPISTS WHO ARE PARTICIPATING IN THE PROGRAM ON OUR WEBSITE BOTH THROUGH WRITTEN AND/OR LIVE COMMUNICATIONS, AND (2) PROVIDERS WHO ARE LICENSED THERAPISTS TO PARTICIPATE IN THE PROGRAM AND CONNECT WITH CLIENTS AND REVIEW CLIENTS’ PROGRESS, COMMUNICATE WITH CLIENTS THROUGH WRITTEN AND/OR LIVE COMMUNICATIONS.

THIS PRIVACY POLICY APPLIES TO PERSONAL DATA HELPING MINDS COLLECTS FROM USERS OF THE HELPING MINDS WEBSITES (THE “WEBSITES”). “PERSONAL DATA” INCLUDES ANY INFORMATION THAT CAN BE USED ON ITS OWN OR WITH OTHER INFORMATION IN COMBINATION TO IDENTIFY OR CONTACT ONE OF OUR USERS. WE BELIEVE THAT TRANSPARENCY ABOUT THE USE OF YOUR PERSONAL INFORMATION IS OF UTMOST IMPORTANCE. IN THIS PRIVACY POLICY, WE PROVIDE YOU DETAILED INFORMATION ABOUT OUR COLLECTION, USE, MAINTENANCE, AND DISCLOSURE OF YOUR PERSONAL DATA. THE POLICY EXPLAINS WHAT KIND OF INFORMATION WE COLLECT, WHEN AND HOW WE MIGHT USE THAT INFORMATION, HOW WE PROTECT THE INFORMATION, AND YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION.

SOME OF THE PERSONAL DATA WE COLLECT AND TRANSMIT WILL, IN SOME CIRCUMSTANCES, BE CONSIDERED “HEALTH DATA” (data related to a user’s physical or mental health) or “Protected Health Information” (information that relates to the past, present, or future physical or mental health or condition of a user; the provision of health care to a user; or the past, present, or future payment for the provision of health care to user). THEREFORE, TO THE EXTENT APPLICABLE, OUR PRIVACY PRACTICES ARE INTENDED TO COMPLY WITH BOTH THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA“) AND THE GENERAL DATA PROCESSING REGULATION (“GDPR”) PROVISIONS REGARDING SENSITIVE PERSONAL DATA. IN ADDITION, WE INTEND TO COMPLY WITH STATE LAW RELATED TO HEALTH DATA, WHERE APPLICABLE. FOR ADDITIONAL INFORMATION RELATED TO YOUR HEALTHCARE INFORMATION, PLEASE CONTACT OUR PRIVACY OFFICER AT support@skinpick.com.

BY SUBMITTING YOUR PERSONAL DATA THROUGH THE WEBSITES, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT LOG INTO OR ACCESS THE WEBSITES AND DO NOT SUBMIT ANY PERSONAL DATA TO US.

PLEASE NOTE THAT WE OCCASIONALLY UPDATE THIS PRIVACY POLICY AND THAT IT IS YOUR RESPONSIBILITY TO STAY UP TO DATE WITH ANY AMENDED VERSIONS. IF WE MODIFY THE PRIVACY POLICY, WE WILL POST A LINK TO THE MODIFIED TERMS ON OUR WEBSITES AND WILL ALSO NOTIFY YOU VIA EMAIL. YOU CAN STORE THIS POLICY AND/OR ANY AMENDED VERSION(S) DIGITALLY, PRINT IT, OR SAVE IT IN ANY OTHER WAY. ANY CHANGES TO THIS PRIVACY POLICY WILL BE EFFECTIVE IMMEDIATELY UPON PROVIDING NOTICE, AND SHALL APPLY TO ALL INFORMATION WE MAINTAIN, USE, AND DISCLOSE. IF YOU CONTINUE TO USE THE WEBSITES FOLLOWING SUCH NOTICE, YOU ARE AGREEING TO THOSE CHANGES.

In case you have any questions or concerns after reading this Privacy Policy, please do not hesitate to contact us at support@skinpick.com. We appreciate your feedback. If you do not agree or no longer agree to the processing of personal information as described in this Privacy Policy, you can delete your account by deleting the Applications from your mobile device, stop using the Platform or notifying us by email at support@skinpick.com.

Responsible Entity

Helping Minds (“We”, “Us”, “the Company”) is the controller of your Personal Data and may process this data in accordance with the Privacy Policy. If we are processing Personal Data on behalf of a third party that is not an agent or affiliate of Company, the terms of this Privacy Policy do not apply—instead, the terms of that third party’s privacy policy will apply. You can contact Us with any questions about our Privacy Policy at support@skinpick.com.

Links to Other Sites

Our Websites may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information, we recommend that you carefully review the privacy policies of all Third-party Services that you access.

What Personal Data do we collect?

We collect Personal Data, which includes the following types of data we and may include healthcare information or “protected health information”. The types of Personal Data we collect are described below.

Demographic Data

We collect demographic information, such as your name, birth year, gender, phone number, and email address. Primarily, the collection of your Personal Data assists us in creating your User Account, which you can use to securely to receive the Services.

Payment Data

If you make payments via our Websites, We may require that you provide to us your financial and billing information, such as billing name and address, credit card number or bank account information.

Support Data

If you contact Helping Minds for support or to lodge a complaint, We may collect technical or other information from you through log files and other technologies, some of which may qualify as Personal Data. (e.g., IP address). Such information will be used for the purposes of troubleshooting, customer support, software updates, and improvement of the Websites and related services in accordance with this Privacy Policy. Calls with Helping Minds may be recorded or monitored for training, quality assurance, customer service, and reference purposes.

Device, Telephone, and ISP Data

We use common information-gathering tools, such as log files, cookies, web beacons, and similar technologies to automatically collect information, which may contain Personal Data, from Your computer or mobile device as you navigate our Websites, or interact with emails We have sent You. The information we collect may include your Internet Protocol (IP) address (or proxy server), device and Websites identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files you viewed, Your searches, Your operating system and system configuration information, and date/time stamps associated with Your usage. This information is used to analyze overall trends, to help us provide and improve our Websites and to guarantee their security and continued proper functioning.

Health and Device Data

In addition to demographic information, We will collect information regarding your (or, if you are a provider, your patients’) health conditions, age, gender, weight, height, medical history, symptoms, and communications between You and the healthcare provider providing healthcare services to you via the Websites. We collect this information to provide You with the Websites and to provide Your healthcare provider providing healthcare services through the Websites with the information required to provide medical treatment.

Emergency Contact Data

In order to comply with state laws and to protect you in the event of an emergency, we will collect the name, phone number and relationship to you of an emergency contact. We will share this information with your healthcare provider, and such healthcare provider will only utilize this emergency contact information in the event of an emergency.

How will We use Your Personal Data?

We process your Personal Data for purposes based on legitimate business interests, the fulfillment of our Services to You, compliance with Our legal obligations, and/or Your consent. We only use or disclose Your Personal Data when it is legally mandated or where it is necessary to fulfill the purposes described herein. Where required by law, we will ask for your prior consent before doing so.

Specifically, we process Your Personal Data for the following legitimate business purposes:

To fulfill our obligations to You under the Terms of Use
To communicate with You about and manage Your User Account
To properly store and track Your data within our system
To respond to lawful requests from public and government authorities, and to comply with applicable state/federal law, including cooperation with judicial proceedings or court orders.
To protect our rights, privacy, safety or property, and/or that of you or others by providing proper notices, pursuing available legal remedies, and acting to limit Our damages
To handle technical support and other requests from You
To enforce and ensure your compliance with our Terms of Use or the terms of any other applicable services agreement We have with You
To manage and improve our operations and the Websites, including the development of additional functionality
To manage payment processing
To evaluate the quality of service You receive, identify usage trends, and thereby improve Your user experience
To keep our Websites safe and secure for You and for Us
To send You information about changes to our terms, conditions, and policies
To allow us to pursue available remedies or limit the damages that we may sustain
To provide access to the authorized healthcare provider (with your consent), to enable that individual to monitor your progress and overall condition and to follow up with you, as they deem appropriate.

Where is your Personal Data processed?

Personal Data Helping Minds collects through the Websites will be stored on secure servers in the United States. Personal Data may be transmitted to third parties, which parties may store or maintain the data on their secure servers. These third parties are not permitted to transfer your Personal Data outside of the United States.

Will We share your Personal Data with anyone else?

If you are a Patient, then, Yes, with the healthcare provider(s) (“Provider”) with whom You connect via the Websites.

We will share information you enter into the Websites, as well as any reports generated by the Websites based on the information you enter, with the Provider with whom connect via the Websites. If, at any point, you want to deny access to one or more Providers, you can do so by emailing support@skinpick.com. We will also share the emergency contact information with your healthcare provider for the purposes set forth in this Privacy Policy.

Yes, with third parties that help us power our Websites

Helping Minds has a limited number of service providers and other third parties (“Business Partners”) that help us run various aspects of our business. These Business Partners are contractually bound to protect your Personal Data and to use it only for the limited purpose(s) for which it is shared. Business Partners’ use of Personal Data may include, but is not limited to, the provision of services such as data hosting, IT services, customer service, and payment processing.

Yes, with third parties and the government when legal or enforcement issues arise

We may share your Personal Data, if reasonable and necessary, to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in

investigating acts in violation of this Agreement; or (iii) bring legal action against someone who may be violating the Terms of Use or who may be causing intentional or unintentional injury or interference to the rights or property of Helping Minds or any third party, including other users.

Yes, with your Emergency Contact in the event your healthcare provider determines there is an emergency

If your healthcare provider determines there is an emergency, We or the applicable healthcare provider may share your Personal Data with the emergency contact that you provided to Us.

Yes, with third parties that provide advisory services

We may share your Personal Data with Our lawyers, auditors, accountants, or banks, when we have a legitimate business interest in doing so.

Yes, with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Helping Minds’ corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings)

If We share Your Personal Data with a third party other than as provided above, You will be notiﬁed at the time of data collection or transfer, and You will have the option of not permitting the transfer.

How long do We retain Personal Data?

We will retain your Personal Data for as long as you maintain a User Account and, in certain cases, for at least seven (7) years after the account is closed. The exact period of retention will depend on the type of Personal Data, our contractual obligation to You, and applicable law. We may decline to delete certain Personal Data, even upon your request. We keep your Personal Data for as long as necessary to fulfill the purpose for which it was collected, unless otherwise required or necessary pursuant to a legitimate business purpose outlined herein. At the end of the applicable retention period, We will remove your Personal Data from our databases and will request that our Business Partners remove your Personal Data from their databases. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing of such data. We retain anonymized data indeﬁnitely.

NOTE: Once we disclose your Personal Data to third parties, we may not be able to access that Personal Data any longer and cannot force the deletion or modiﬁcation of any such information by the parties to whom we have made those disclosures. Written requests for deletion of Personal Data other than as described should be directed to support@skinpick.com.

What is Our Cookie Policy?

Cookies are small files that a web server sends to your computer or device when you visit a web site that uses cookies to keep track of your activity on that site. They hold a small amount of data specific to that web site, which can later be used to help remember information you enter into the site (like your email or other contact info), preferences selected, and movement within the site. If you return to the previously visited web site (and your browser has cookies enabled), the web browser sends the small file to the web server, which tells it what activity you engaged in the last time you used the site, and the server can use the cookie to do things like expedite logging in and retrieving user data and keeping your browser session secure.

We use cookies and other technologies to, among other things, better serve you with more tailored information, and to facilitate eﬃcient and secure access to the Websites. We only use essential cookies. Essential cookies are those necessary for use to provide services to you. We have provided, below, a full list of our cookies, categorized as described above. We have described the purpose of each, whether they are Helping Minds or Third Party cookies, and how to withdraw consent to their use. We have also indicated which cookies are “session cookies” (which last for as long as you keep your browser open) and “persistent cookies” (which remain on your hard drive until you delete them or they expire).

We may also collect information using pixel tags, web beacons, clear GIFs or other similar technologies. These may be used in connection with some Site pages and HTMLformatted email messages to, among other things, track the actions of Site users and email recipients, and compile statistics about Site usage and response rates.

Essential Cookies:

Cookie Name, Who Controls It, and Duration	Purpose	Information Collected	How to Withdraw Consent
SSESS[session_id] During active session	Identifies the user and allows authentication to the server	A generated token that lets you log in.	Do not use our service and do not unsubscribe from automated emails if you do not want this cookie.

Cookie Name, Who Controls It, and Duration

Purpose

Information Collected

How to Withdraw Consent

SSESS[session_id]

During active session

Identifies the user and allows authentication to the server

A generated token that lets you log in.

Do not use our service and do not unsubscribe from automated emails if you do not want this cookie.

How can You “Opt Out” of Cookies?

If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you enable a do not track (DNT) signal or otherwise configure your browser to prevent Helping Minds from collecting cookies, You will need to reenter your user name each time you visit the login page.

How do We protect Your Personal Data?

Helping Minds is committed to protecting the security and conﬁdentiality of your Personal Data. We use a combination of reasonable physical, technical, and administrative security controls to maintain the security and integrity of your Personal Data, to protect against any anticipated threats or hazards to the security or integrity of such information, and to protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm or inconvenience to you. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure. As a result, we cannot ensure the security of information you transmit to us. By using the Websites, you are assuming this risk.

Safeguards

The information collected by Helping Minds and stored on secure servers, is protected by a combination of technical, administrative, and physical security safeguards, such as authentication, encryption, backups, and access controls. If Helping Minds learns of a security concern, We may attempt to notify You and provide information on protective steps, if available, through the email address that You have provided to Us or by a notification within the Websites. Depending on where You live, You may have a legal right to receive such notices in writing.

You are solely responsible for protecting information entered or generated via the Websites that is stored on Your device and/or removable device storage. Helping Minds has no access to or control over Your device’s security settings, and it is up to You to implement any devicelevel security features and protections You feel are appropriate (e.g., password protection, encryption, remote wipe capability, etc.). We recommend that You take any and all appropriate steps to secure any device that You use to access Our Websites.

NOTWITHSTANDING ANY OF THE STEPS TAKEN BY US, IT IS NOT POSSIBLE TO GUARANTEE THE SECURITY OR INTEGRITY OF DATA TRANSMITTED OVER THE INTERNET. THERE IS NO GUARANTEE THAT YOUR PERSONAL DATA WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. THEREFORE, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU TRANSMIT TO US AND YOU TRANSMIT SUCH PERSONAL DATA AT YOUR OWN RISK.

How can You Protect Your Personal Data?

In addition to securing Your device, as discussed above, We will NEVER send you an email requesting conﬁdential information such as account numbers, usernames, passwords, or social security numbers, and You should NEVER respond to any email requesting such information. If You receive such an email purportedly from Helping Minds, DO NOT RESPOND to the email and DO NOT click on any links and/or open any attachments in the email, and notify Helping Minds support at support@skinpick.com.

You are responsible for taking reasonable precautions to protect Your user ID, password, and other User Account information from disclosure to third parties, and You are not permitted to circumvent the use of required encryption technologies. You should immediately notify Helping Minds at support@skinpick.com if You know of or suspect any unauthorized use or disclosure of Your user ID, password, and/or other User Account information, or any other security concern.

Your rights

You have certain rights relating to your Personal Data, subject to local data protection laws. These rights may include:

to access your Personal Data held by us;
to erase/delete your Personal Data, to the extent permitted by applicable data protection laws;
to receive communications related to the processing of your personal data that are concise, transparent, intelligible and easily accessible;
to restrict the processing of your Personal Data to the extent permitted by law (while we verify or investigate your concerns with this information, for example);
to object to the further processing of your Personal Data, including the right to object to marketing;
to request that your Personal Data be transferred to a third party, if possible;
to receive your Personal Data in a structured, commonly used and machine-readable format;
to lodge a complaint with a supervisory authority;
to rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete; and
to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making").

Where the processing of Your Personal Data by Helping Minds is based on consent, You have the right to withdraw that consent without detriment at any time or to exercise any of the rights listed above by emailing Helping Minds at support@skinpick.com.

If you are a California resident, the California Consumer Privacy Act (“CCPA”) may apply to you. To the extent it applies, please see the CCPA attachment.

If you are an EU data citizen, the GDPR may apply to you. To the extent it applies, please see the GDPR attachment.

How can You update, correct, or delete Personal Data?

You can change your email address and other contact information and make other changes to your supplied information by editing your proﬁle in the Platform. Please note that in order to comply with certain requests to limit use of Your Personal Data, we may need to terminate your account and Your ability to access and use the Services, and You agree that We will not be liable to you for such termination or for any refunds of prepaid fees paid by You. You can deactivate your account by clicking “Cancel Your Subscription” on the App or the Website.

We are required to maintain certain Personal Data for periods often exceeding seven (7) years in accordance with state and federal law. Please note that We may decline to delete certain Personal Data, even upon your request.

Although We will use reasonable efforts to do so, You understand that it may not be technologically possible to remove from our systems every record of your Personal Data. The need to back up our systems to protect information from inadvertent loss means a copy of your Personal Data may exist in a nonerasable form that will be diﬃcult or impossible for us to locate or remove.

Can You “OPTOUT” of receiving communications from Us?

We pledge not to market third party services to You without Your consent. We only send emails to You regarding Your Helping Minds account and services. You can choose to ﬁlter these account emails using Your email client settings, but We do not provide an option for You to opt out of these emails.

Information submission by minors

The Children’s Online Privacy Protection Act (COPPA) protects the collection of identifiable information from children under the age of 13. If your child is under the age of 13, you must give parental consent prior to allowing your child to use the Website.

The Website does NOT allow children or any user to make their information publicly available. Parents/legal guardians have the right to review or ask us to delete their child’s personal information, as well as to refuse to permit us to further collect or use your child’s personal information. To do any of these, please contact us at support@skinpick.com with your request.

If you are a resident of California under the age of 18 and have registered for an account with us, you may ask us to remove content or information that you have posted to our websites.

California Residents

California residents may request and obtain from Us, once a year, free of charge, a list of third parties, if any, to which We disclosed their Personal Data for direct marketing purposes during the preceding calendar year and the categories of Personal Data shared with those third parties. If You are a California resident and wish to obtain that information, please submit Your request by sending Us an email at support@skinpick.com with “California Privacy Rights” in the subject line.

Contact Us

If You have any questions about this Privacy Policy, please contact Us by email at support@skinpick.com or please write to: support@skinpick.com. Please note that email communications are not always secure; so please do not include sensitive information in Your emails to Us.

CALIFORNIA CONSUMER PRIVACY ACT PRIVACY RIGHTS ADDENDUM

To the extent that the California Consumer Privacy Act applies to You, You have the following additional data privacy rights:

Privacy; Confidential Information

If You are an individual user and Your employer purchased the online service to which this Privacy Policy applies, all of the information described in this Privacy Policy is subject to Your employer’s policies regarding deletion, encryption, export, monitoring, passwords, and retention of data associated with the Services.

We may aggregate or deidentify any Personal Data that We collect in connection with our Services, such that the information is no longer personally identifiable or attributable to You. We may use such aggregated information for Our own legitimate business purposes without restriction.

Sale of Information

We have not disclosed Personal Data to third parties for a business or commercial purpose in the preceding 12 months, and we do not sell the personal information of any of our Customers.

Your Rights:

You have the right

1. to request that We disclose what information We collect, use, disclose, and sell.

2. to request that We delete any Personal Data We have collected about You.

To submit a request for (1) or (2) above, you may email us at support@skinpick.com.

For your protection, any request you send to Us to delete your Personal Data is subject to the following verification procedure: we will confirm your identity according to FTC guidelines.

We reserve the right to deny Your request if we cannot verify Your identity. If We deny Your request in whole or in part, We will notify You of the denial and provide the reasons for the denial.

We will not discriminate against you for exercising any of your above rights.

You may designate an authorized agent to make a request to exercise Your rights on Your behalf. Your authorized agent must be able to provide to Us proof of your authorization. For Your protection, We reserve the right to deny any request from an agent who does not submit proof that they have been authorized to act on Your behalf.

GENERAL DATA PROCESSING REGULATION RIGHTS ADDENDUM

If you are an EU data citizen, the GDPR may apply to the Personal Data We collect from you. If so, You have the following rights:

to access Your Personal Data held by Us;
to erase/delete Your Personal Data;
to receive communications related to the processing of Your Personal Data that are concise, transparent, intelligible and easily accessible;
to restrict the processing of Your Personal Data to the extent permitted by law (while we verify or investigate Your concerns with this information, for example);
to object to the further processing of Your Personal Data, including the right to object to marketing;
to request that Your Personal Data be transferred to a third party, if possible;
to receive Your Personal Data in a structured, commonly used and machine-readable format;
to lodge a complaint with a supervisory authority;
to correct inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete; and
to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making").

Privacy Policy

PART ONE: INTRODUCTION

PART TWO: POLICY SUMMARY

PART THREE: FULL PRIVACY POLICY

Do I have dermatillomania?

Do I have dermatillomania?