Privacy Policy

Last updated: March 4, 2025

Table of Contents

1. What Information Do We Collect?

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You

In Short: The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

Payment Data

We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Apple.

Application Data

If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

Important: All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Sensitive Information

We do not collect or process sensitive personal information, such as biometric data (selfies, facial recognition, etc.).

Payment Data

If you make purchases, we may collect data necessary to process your payment, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by Apple. You can find their privacy notice here.

Application Data

If you use our application(s), we may also collect the following information if you choose to give us access or permission:

Information Automatically Collected

In Short: Some information such as your Internet Protocol (IP) address and/or browser and device characteristics is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as:

This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Log and Usage Data

Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include:

2. How Do We Process Your Information?

We process your data to provide, improve, and secure our services. This includes:

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable laws, like with your consent, to comply with laws, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If You Are Located in the EU or UK

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases:

If You Are Located in Canada

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

4. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations and with specific third parties.

We may share your data with service providers, contractors, or agents who perform services for us or on our behalf. These third parties are bound by contractual obligations to protect your data.

Vendors, Consultants, and Other Third-Party Service Providers

We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work.

We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that:

The categories of third parties with whom we may share personal information include:

Business Transfers

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. What Is Our Stance on Third-Party Websites?

In Short: We are not responsible for the security of any information you share with third-party providers who advertise, but are not affiliated with, our websites.

The Services, including our offer wall, may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us. These third parties may link to other websites, services, or applications.

Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications.

Important: The inclusion of a link to a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties.

Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content, privacy, or security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services.

You should review the policies of such third parties and contact them directly if you have any questions about how they handle your data.

5. What Is Our Stance on Third-Party Websites?

In Short: We are not responsible for the security of any information you share with third-party providers who advertise, but are not affiliated with, our websites.

The Services, including our offer wall, may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us. These third parties may link to other websites, services, or applications.

Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications.

Important: The inclusion of a link to a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties.

Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content, privacy, or security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services.

You should review the policies of such third parties and contact them directly if you have any questions about how they handle your data.

6. Is Your Information Transferred Internationally?

In Short: Yes, your information may be transferred, stored, and processed in countries other than your own.

Our servers are located in Switzerland. We may transfer your personal data to countries outside Switzerland. In such cases, we ensure that appropriate safeguards are in place to protect your data, in compliance with Swiss data protection laws.

If you are located in the European Economic Area (EEA), United Kingdom (UK), or another region with laws governing data collection and use, please be aware that your information may be transferred to countries that do not have the same data protection laws as your jurisdiction. In such cases, we ensure that appropriate safeguards are in place, such as relying on Standard Contractual Clauses approved by the European Commission, to protect your personal information.

You can request a copy of these safeguards by contacting us at contact@acne-track.com. These transfers will always comply with the laws and regulations of the countries from which the data originates, including any additional requirements based on your location.

European Commission's Standard Contractual Clauses

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers.

7. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice, unless otherwise required by law.

We retain your personal information for as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law (such as for tax, legal, accounting, or other regulatory purposes). The specific retention period depends on the type of data and the purpose for which it was collected.

Important: Once your personal information is no longer necessary for our legitimate business interests or required by law, we will securely delete, anonymize, or isolate it to prevent further processing.

8. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These measures are aimed at preventing unauthorized access, disclosure, loss, theft, destruction, or alteration of your data.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

Our Security Measures

Important: Although we do our best to protect your personal information, the transmission of personal data to and from our Services is at your own risk. You should only access the Services within a secure environment. We encourage you to take steps to protect your information, such as using strong passwords and avoiding sharing your account details with others.

9. Do We Collect Information from Minors?

Our app is designed for general audiences, and we prioritize the privacy and safety of all users, including minors.

We do not knowingly collect personal information from children under the age of 13 where this is restricted by law, such as under the Children's Online Privacy Protection Act (COPPA) in the United States. If we become aware that personal information has been inadvertently collected from a child under the applicable age of consent in their jurisdiction, we will take immediate steps to delete such data.

Our application does not have an age restriction and can be used by individuals of all ages. However, we encourage parents or guardians to actively supervise and be involved in the online activities and app usage of their children.

Important: If you believe that your child has provided us with personal data without your consent, please contact us at contact@acne-track.com, and we will address your concerns promptly.

10. What Are Your Privacy Rights?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In certain regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to:

In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the details provided in the "How Can You Contact Us?" section below.

Opting Out of Marketing and Promotional Communications

You can unsubscribe from our marketing and promotional communications at any time by:

After opting out, you will be removed from our marketing lists. However, we may still communicate with you for essential service-related messages, such as:

Contact Us: If you have questions or comments about your privacy rights, you may email us at contact@acne-track.com.

11. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and applications include a Do-Not-Track ("DNT") feature or setting that you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

At this time, no uniform standard for recognizing and implementing DNT signals has been adopted. As a result, we do not currently respond to DNT browser signals or other mechanisms that automatically communicate your choice not to be tracked.

However, if such a standard is adopted in the future, we will update this privacy policy and provide you with details on how we comply with those changes.

Stay Informed: We encourage users to review this policy regularly to stay informed about our practices regarding online tracking.

12. Do United States Residents Have Specific Privacy Rights?

In short: If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you are granted specific rights regarding access to your personal information.

We comply with the California Consumer Privacy Act (CCPA) and other applicable laws that grant specific privacy rights to residents of the United States.

You can learn more about your rights, such as the right to request access or deletion of your personal information, and how to exercise those rights by contacting us at:

Contact Us: If you have any privacy-related questions or wish to exercise your rights, you may email us at contact@acne-track.com.

13. Do Other Regions Have Specific Privacy Rights?

In short: You may have additional rights based on the country you reside in.

If you are a resident of other regions, including Australia, New Zealand, or the Republic of South Africa, we will collect and process your personal information in line with the specific legal requirements of your country.

You may have the right to:

If you believe your data has been processed unlawfully, you can file a complaint with the appropriate data protection authority in your country.

Need Assistance? If you have any questions about your rights under your country's data protection laws, please contact us at contact@acne-track.com.

14. Do We Make Updates to This Notice?

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date, and the updated version will be effective as soon as it is accessible.

If we make material changes to this privacy policy, we may notify you in one or more of the following ways:

Stay Informed: We encourage you to review this privacy policy frequently to stay informed about how we are protecting your information.

15. How to Contact Us

If you have any questions, contact us at:

Email: contact@acne-track.com

Address: 210 impasse des Brasse, 74100 Vétraz-Monthoux