We at Smylen,Inc. (“Company,” “we,” “us,” “our”) know that our users (“you,” “your”) care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By visiting or using the Website or Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways. Any capitalized terms used herein without definition shall have the meaning given to them in the Company Terms of Use.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using https://smylen.com (the “Website”). This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage. We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register for the Services (as that term is defined in our Terms of Use. If you are under 18, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 may provide any personal information to us or on the Services. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 18, please contact us at Ashley@smylen.com.

WHAT INFORMATION DOES COMPANY COLLECT?

We gather various types of Personal Information from our users, as explained more fully below. We may use this Personal Information to personalize and improve our services, to allow our users to set up a user account and profile, to contact users, to fulfill your requests for certain products and services, to analyze how users utilize the Website, and as otherwise set forth in this Privacy Policy. We may share certain types of Personal Information with third parties (described in this Section and in Section III below). We collect the following types of information:

A. Information You Provide to Us: We receive and store any information you knowingly provide to us. For example, we collect Personal Information such as your name, email address, age/birthdate, and gender, and browser information. You can choose not to provide us with certain information, but then you may not be able to register with us or to take advantage of some of our features. Further, if you make an offer for a service or procedure to be provided by a Service Provider, any personal information you have submitted over the Website may be disclosed to such Service Provider after your bid  has been matched through the Website. We may also anonymize your Personal Information so that you cannot be individually identified, and provide that information to our partners.

You may also request information directly from a specific health care professional by submitting an inquiry through their profile or inquiry form or from the consultation request feature. You understand these requests, including personally identifiable information, are made voluntarily. There is no guarantee that a health care professional will respond to any request submitted.

By submitting a consultation or quote request, you voluntarily provide the doctor’s office with your name, email address, telephone number and your comments/desired treatment, which is transmitted by Company to the doctor’s office. The information provided to the doctor’s office through the Consultation Request feature is not used by in any other manner other than transmitting that information to the Provider’s office. The Provider obviously may then contact you via the means of contact supplied.

By agreeing to receive promotions or by signing up for the Newsletter, you agree to receive promotions and other types of marketing emails from Company. You may unsubscribe at any time through the Unsubscribe feature on the emails.

B. Information Collected Automatically:

Whenever you interact with our Website, we automatically receive and record information on our server logs from your browser including your IP address, “cookie” information, and the page you requested. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your browser or mobile device and tell us how and when pages in our Website are visited and by how many people. You may be able to change the preferences on your browser or mobile device to prevent or limit your computer or device’s acceptance of cookies, but this may prevent you from taking advantage of some of our Website’s features. Our advertising partners may also transmit cookies to your computer or device, when you click on ads that appear on the Website. Also, if you click on a link to a third party website, such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.

When we collect usage information (such as the numbers and frequency of visitors to the Website), we only use this data in aggregate form, and not in a manner that would identify you personally. For example, this aggregate data tells us how often users use parts of the Website, so that we can make the Website appealing to as many users as possible. We may also provide this aggregate information to our partners; our partners may use such information to understand how often and in what ways people use our Website, so that they, too, can provide you with an optimal experience. We never disclose aggregate information to a partner in a manner that would identify you personally.

C. E-mail and Other Communications: We may contact you, by email or other means; for example, we may send you promotional offers on behalf of other businesses, or communicate with you about your use of the Website. If you do not want to receive email or other mail from us, please indicate your preference by changing your account settings, selecting the opt-out option in emails we send to you or by emailing Ashley@smylen.com. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Website, and you are responsible for reviewing such legal notices for changes.

Tracking Tools, Behavioral Advertising, and Opt Out Options

A. Tracking Tools

We may use tools outlined below in order to provide our Services to, advertise to, and to better understand users.

  • Cookies: “Cookies” are small computer files transferred to your computing device that contain information such as user ID, user preferences, lists of pages visited and activities conducted while using the Services. We use cookies to improve or tailor the Services, customize advertisements by tracking navigation habits, measuring performance, and storing authentication status so re-entering credentials is not required, customize user experiences with the Services, and for analytics and fraud prevention. For more information on cookies, including how to control your cookie settings and preferences, visit  http://www.allaboutcookies.org.
    Some cookies are placed by a third party on your device and provide information to us and third parties about your browsing habits (such as your visits to our Services, the pages you have visited, and the links and advertisements you have clicked). These cookies can be used to determine whether certain third party services are being used, to identify your interests, and to serve advertisements relevant to you. We do not control third party cookies.
  • Web Beacons: “Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect information about the use of our Services, the websites of selected advertisers and the emails, special promotions or newsletters that we send. The information collected by Web Beacons allows us to analyze how many people are using the Services, using selected publishers’ websites or opening emails, and for what purpose, and also allows us to enhance our interest-based advertising (discussed further below).
  • Web Service Analytics: We may use third-party analytics services in connection with the Services, including, for example, to register mouse clicks, mouse movements, scrolling activity and text typed into the Site. We use the information collected from these services to help make the Services easier to use and as otherwise set forth in Section 5 (How We Use Your Information). These analytics services generally do not collect Personal Information unless you voluntarily provide it and generally do not track your browsing habits across web services that do not use their services.
  • Mobile Device Identifiers: As with other Tracking Tools, mobile device identifiers help Smylen learn more about our users’ demographics and internet behaviors in order to personalize and improve the Services. Mobile device identifiers are data stored on mobile devices that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of Personal Information (such as media access control, address and location) and Traffic Data.

B. Behavioral Advertising

We may use a type of advertising commonly known as interest-based or online behavioral advertising. This means that some of our partners use Tracking Tools, such as cookies, pixel tags, and web beacons, to collect information about a user’s online activities to display Smylen ads to the user based on the user’s interests (“Behavioral Advertising”). Such partners may include third-party service providers, advertisers, advertising networks or platforms, traffic measurement service providers, marketing analytics service providers, and other third party service providers (collectively, “Advertising Service Providers”). Other Tracking Tools used by our partners may collect information when you use the Services, such as IP address, mobile device ID, operating system, browser, web page interactions, geographic location and demographic information, such as gender and age range. These Tracking Tools help Smylen learn more about our users’ demographics and internet behaviors.

C. Options for Opting out of Cookies and Mobile Device Identifiers

Some web browsers allow you to reject cookies or to alert you when a Cookie is placed on your computer, tablet or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept Smylen’s cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.

You may opt out of receiving certain cookies and certain trackers by visiting the Network Advertising Initiative (NAI)  opt out page or the Digital Advertising Alliance (DAA) consumer opt-out page, or by installing the DAA’s AppChoice app (for iOS; for Android) on your mobile computing device, or by visiting https://www.fullstory.com/optout/. When you use these opt-out features, an “opt-out” Cookie will be placed on your computer, tablet or mobile computing device indicating that you do not want to receive interest-based advertising from NAI or DAA member companies. If you delete cookies on your computer, tablet or mobile computing device, you may need to opt out again. For information about how to opt out of interest-based advertising on mobile devices, please visit  http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device . You will need to opt out of each browser and device for which you desire to apply these opt-out features.

Even after opting out of Behavioral Advertising, you may still see Smylen advertisements that are not interest-based (i.e., not targeted toward you). Also, opting out does not mean that Smylen is no longer using Tracking Tools — Smylen still may collect information about your use of the Services even after you have opted out of Behavioral Advertising and may still serve advertisements to you via the Services based on information it collects via the Services.

This Privacy Policy does not cover the use of cookies and other Tracking Tools by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that some cookies placed by third parties can continue to track your activities online even after you have left our Services.

D. How Smylen Responds to Browser “Do Not Track” (DNT) Signal

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to web services that a visitor does not want to have his/her online activity and behavior tracked. If a web service operator elects to respond to a particular DNT signal, the web service operator may refrain from collecting certain Personal Information about the browser’s user. Not all browsers offer a DNT option and there is currently no industry consensus as to what constitutes a DNT signal. For these reasons, many web service operators, including Smylen, do not proactively respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.

WILL COMPANY SHARE ANY OF THE PERSONAL INFORMATION IT RECEIVES?

We neither rent nor sell your Personal Information in personally identifiable form to anyone. We share your Personal Information in personally identifiable form with third parties as described below.

A. Advertisers: We allow advertisers and/or merchant partners (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers and you agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in New York to show you ads or offers for  New York businesses, but we will not tell such businesses who you are. We may deliver a file to you through the Website (known as a “web beacon”) from an ad network. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their site.

B. Affiliated Businesses and Third Party Websites We Do Not Control: In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through the Website (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. One such service may include the ability for you to automatically transmit Third Party Account Information to your Website profile or to automatically transmit information in your Website profile to your third party account. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.

C. Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

D. User Profiles and Submissions: Certain user profile information, including without limitation a user’s name, location, and any video or image content that such user has uploaded to the Website, may be displayed to other users to facilitate user interaction within the Website or address your request for Company’s services. Your account privacy settings allow you to limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others. Any content you upload to your public user profile, along with any Personal Information or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by others. Your user name may also be displayed to other users if and when you send messages or comments or upload images or videos through the Website and other users can contact you through messages and comments. Additionally, if you sign into the Website through a third party social networking site or service, your list of “friends” from that site or service may be automatically imported to the Website, and such “friends,” if they are also registered users of the Website, may be able to access certain non-public information you have entered in your Website user profile. Again, we do not control the policies and practices of any other third party site or service.

E. Business Transfers: We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.

F. Protection of Company and Others: We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

G. With Your Consent: Except as set forth above, you will be notified when your Personal Information may be shared with third parties in personally identifiable form, and will be able to prevent the sharing of this information.

IS PERSONAL INFORMATION ABOUT ME SECURE?

Your account is protected by a password for your privacy and security. If you access your account via a third party site or service, you may have additional or different sign-on protections via that third party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. The Website may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site’s privacy policy.

WHAT PERSONAL INFORMATION CAN I ACCESS?

Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:

• name and password

• email address

• Phone number

• Bid history

The information you can view, update, and delete may change as the Website changes. If you have any questions about viewing or updating information we have on file about you, please contact us at Ashley@smylen.com.

WHAT CHOICES DO I HAVE?

• You can always opt not to disclose information to use, but keep in mind some information may be needed to register with us or to take advantage of some of our special features.

• You may be able to add, update, or delete information as explained in Section V above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by deleting your account through your customer portal a https://smylen.com. Please note that some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email. You are bound by any changes to the Privacy Policy when you use the Website after such changes have been first posted.

QUESTIONS OR CONCERNS

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to  Ashley@smylen.com, and we will try to resolve your concerns.

Effective:  November 1, 2017