Privacy Policy
Effective date: November 3, 2026 · Last updated: November 3, 2026
This Privacy Policy explains how SCROLL SKIN ("SCROLL SKIN," "we," "us") collects, uses, discloses and protects personal information when you visit scrollskin.com, join our waitlist, contact us, or buy SCROLL SKIN products. It also explains the choices and rights you have, including rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA") and other U.S. state privacy laws.
1. Notice at collection (summary)
| Category | Examples | Why we collect it | Sold or shared? | How long we keep it |
|---|---|---|---|---|
| Identifiers | Email address; name and shipping address (direct orders only) | Waitlist and launch emails, order fulfillment, customer service | No | Until you unsubscribe or ask us to delete it; order records 7 years for tax and accounting |
| Commercial information | Products ordered, returns, the waitlist you joined | Fulfillment, returns, customer service | No | 7 years |
| Internet or network activity | Salted one-way hash of your IP address, page you signed up from, browser type in server logs | Security, preventing spam and abuse, rate limiting | No | Rate-limit records about 24 hours; sign-up record kept as long as the waitlist entry |
| Consent records | Date, time and wording of the email consent you gave | Proving consent and honoring opt-outs | No | As long as we email you, plus 4 years |
| Health-related information you choose to send us (sensitive personal information) | Description of a skin reaction or other problem you report after using a product | Customer safety and the adverse-event records that federal cosmetic law requires us to keep | No | At least 6 years, as required by law for adverse-event records |
We collect this information directly from you, from your device when you use the site, and from the sales platform you buy through (for example TikTok Shop) to fulfill your order. We do not sell personal information, and we do not "share" it for cross-context behavioral advertising. We do not knowingly collect personal information from anyone under 16.
2. Information we collect
Waitlist
When you join the waitlist we collect your email address, a record that you ticked the consent box (with the date, time and the wording shown), the page or campaign link you signed up from, and a salted one-way hash of your IP address that we use only to block spam and repeated automated sign-ups. We do not store your raw IP address in our waitlist database.
Contacting us
If you email us, we collect your email address, what you write, and anything you attach (such as photos). If you tell us about a reaction or other problem after using a product, we collect the details you choose to give us (see section 5).
Purchases
Nothing is sold on this site yet. When we launch, purchases may be made through a sales platform such as TikTok Shop. That platform collects and processes your payment information and account data under its own privacy policy, and shares with us the information we need to ship and support your order (such as your name, shipping address and order details). If we open our own online store, payment card details will be processed by our payment processor; we will not receive or store full card numbers.
Cookies and analytics
The site does not use advertising cookies or third-party tracking pixels. Pages load fonts from Google Fonts, so your browser sends your IP address to Google when the page loads (see Google's privacy policy). Our host, Cloudflare, processes technical data (such as IP address and request logs) to deliver and secure the site. We use Cloudflare Web Analytics, a cookieless tool that counts page views and does not collect personal data. If we add other analytics or advertising tools later, we will update this policy first and provide any opt-outs the law requires.
3. How we use information
- To send you launch news, early-access information and offers you signed up for (you can unsubscribe at any time).
- To process, ship and support orders, returns and replacements.
- To respond to your questions and requests.
- To record and, where required, report product safety information as required by the Modernization of Cosmetics Regulation Act of 2022 (MoCRA).
- To keep the site secure and prevent fraud, spam and abuse.
- To meet legal, tax and accounting obligations and to enforce our rights.
We use sensitive personal information only for the purposes the CCPA permits (such as providing the services you request, safety and security, and legal compliance). We do not use it to infer characteristics about you, and we do not use it for advertising.
4. How we disclose information
We disclose personal information only to service providers and contractors that process it for us under written contracts that limit how they can use it:
- Website hosting and database: Cloudflare, Inc.
- Sales platform and fulfillment: TikTok Shop and its logistics partners; shipping carriers
- Our product manufacturer, only when needed to investigate a product quality or safety report (we send the minimum details needed, without your contact information wherever possible)
- Professional advisers (lawyers, accountants, insurers) as needed
We may also disclose information to government authorities when the law requires it. This includes serious adverse-event reports that federal law requires us to submit to the U.S. Food and Drug Administration (FDA). If our business is sold or merged, personal information may transfer to the new owner, who must honor this policy.
5. Product safety reports
If you tell us about a reaction or other problem after using a SCROLL SKIN product, we will keep a record of your report. If it meets the legal definition of a "serious adverse event," we are required to report it to the FDA. These records must be kept for at least six years, so we may not be able to delete them on request. We do not give medical advice; if you have a reaction, stop using the product and contact a healthcare provider. Washington and Nevada residents: health-related information you send us is used only to handle your report and meet our legal duties, and is never sold. You can ask us for a copy or, where the law allows, deletion by writing to hello@scrollskin.com.
6. Your choices
- Unsubscribe: use the link in any email, or write to hello@scrollskin.com. We process unsubscribes within 10 business days and usually much sooner.
- Global Privacy Control: if your browser sends a Global Privacy Control (GPC) signal, we treat it as a request to opt out of the sale or sharing of your personal information (even though we do not sell or share it).
7. Your privacy rights (California and other U.S. states)
Depending on where you live, you may have the right to:
- Know and access the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of recipients.
- Delete personal information we collected from you, subject to legal exceptions (for example, records we must keep for tax purposes or adverse-event records).
- Correct inaccurate personal information.
- Opt out of the sale or sharing of personal information, and of targeted advertising and profiling. We do not sell or share personal information or use it for targeted advertising.
- Limit the use of sensitive personal information. We use it only for the permitted purposes described above.
- Data portability: receive your information in a portable format.
- Non-discrimination: we will not deny you goods, charge you a different price, or give you a different quality of service because you exercised these rights.
- Appeal: if we decline your request, you can appeal by replying to our decision. If your appeal is denied, you may contact your state attorney general.
How to make a request: email hello@scrollskin.com with the subject "Privacy request" and tell us which right you are using. To protect you, we will verify your request by confirming control of the email address associated with your information, and we may ask for order details. You may use an authorized agent; we will ask for proof of the agent's authority and may ask you to verify your identity directly. We will confirm receipt within 10 business days and respond within 45 calendar days (we may extend once by another 45 days and will tell you if we do). Requests are free.
Shine the Light (Cal. Civ. Code § 1798.83): we do not disclose personal information to third parties for their own direct marketing purposes.
8. Notice of financial incentive (waitlist offers)
Waitlist members get first notice of the launch and may get early access or any launch offer we choose to run. No offer has been set. If we run one, joining is a "financial incentive" under California law because you give us your email address in exchange for these offers. The personal information involved is your email address and consent record. You opt in by ticking the consent box when you join, and you can withdraw at any time by unsubscribing or emailing hello@scrollskin.com. We estimate the value of your email address to us as roughly equal to the value of the offer you receive, based on the expected cost of providing the offer; we do not calculate a separate value for each person. You do not need to join the waitlist to buy our products.
9. Retention
We keep personal information only as long as needed for the purposes above: waitlist data until you unsubscribe or ask us to delete it (we keep a minimal suppression record so we don't email you again), order records for 7 years, and adverse-event records for at least 6 years as required by law. Spam-prevention records expire after about 24 hours.
10. Security
We use reasonable safeguards, including encrypted (HTTPS) connections, restricted access to our database, and one-way hashing of IP addresses. No method of transmission or storage is completely secure.
11. Children
Our site and products are intended for adults. We do not knowingly collect personal information from children under 16. If you believe a child has given us information, contact us and we will delete it.
12. Where we process data
We are based in the United States and our site is intended for U.S. residents. Information is processed and stored in the United States and in other countries where our service providers operate.
13. Changes
We will post any changes here and update the "Last updated" date. If a change is material, we will notify waitlist members by email before it takes effect.
14. Contact
Email: hello@scrollskin.com