Last Updated October 27, 2022
If you are a California Resident (as defined below), please review the below section, Additional Information for California Residents, for additional disclosures, our Notice at Collection, and a description of your rights under the California Consumer Privacy Act (together with any implementing regulations and as may be amended from time to time, “CCPA”).
THE INFORMATION WE COLLECT AND HOW WE COLLECT IT
Personal Information You Provide to Us. Depending on how you interact with us, the types of personal information we may collect include:
- Identifiers and similar information such as your name, address, phone number, email, IP address, online identifiers, and business information (for business inquiries only);
- Commercial information, including records of Services purchased (such as number of treatments received), obtained, or considered, or other purchasing histories or tendencies;
- Internet or other electronic network activity information, including interactions with our Services or use of certain online tools;
- Geolocation information, including, if enabled, certain GPS location (but not your precise geolocation) that is collected about the location of your device, and, if you provide, your city;
- Audio, electronic, visual, or similar information, such as when you call our help line;
- Correspondence and communications such as information in comments or questions you send to us;
- Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information; and
- Additional information subject to certain federal or state laws such as a signature or financial information.
Information We Collect from Other Sources. We may also collect personal information from other sources including our affiliates, business partners (such as clinics where you have received Prollenium treatments or other Prollenium services), or public websites or publicly available sources like government records.
WHY WE COLLECT THIS INFORMATION
Business and Commercial Purposes. We may collect and otherwise process your personal information for our business or commercial purposes, including to:
- Provide you with our Services;
- Administer promotional programs;
- Fulfill our contractual and legal obligations;
- Coordinate with our business partners (such as clinics);
- Respond to questions, comments, or problems that you report to us concerning the Services;
- Manage and operate the Services;
- Develop new products and services, improve the Services, and conduct analyses to enhance or improve our content, products, and services;
- Provide you with information about our products and other services as well as marketing communications and offers for products and other services;
- Provide you with customized content or targeted offers;
- Conduct analytics on information in an aggregated format; and
- Conduct other everyday business purposes such as fraud prevention, corporate governance, reporting, and legal compliance.
- We may also use your information for other purposes disclosed at the time you provide your information or otherwise with your consent.
WITH WHOM WE SHARE THIS INFORMATION
Depending on how you interact with us, we may share your personal information in the following circumstances with the following entities:
- Affiliates and Business Partners. We may share your personal information with our parent, subsidiaries and affiliates and other parties (such as clinics) 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 Rights and Choices
- Your Health Care Professionals. We may share or otherwise provide your personal information to health care professionals at clinics providing our Services.
- We may share your personal information with vendors that perform services on our behalf. For example, we may hire other companies to handle payment processing, provide data storage, help us operate the Services or our business, provide technical support, provide call center services, and assist in marketing.
- We may share your personal information with your consent or at your direction.
- Sale or Transfer of Business or Assets. We may disclose and transfer information we have collected about you in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets, or other corporate changes, including in connection with any due diligence process.
- Legal Matters. We may disclose your information where required to comply with law (including applicable regulations), or 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.
- Safety and Security. We may disclose your information where we believe the disclosure is necessary or appropriate to prevent physical harm or financial loss. We may also disclose your information to protect the security of the Services, servers, networks systems, and business or as necessary to protect other business or legal interests.
- Other. We reserve the right to share your personal information if required or permitted to do so by law.
Please note that we may also disclose data about you that is not personally identifiable. For example, we may publish reports that contain aggregate and statistical data about our customers. These reports do not contain any data that would enable the recipient to contact, locate, or identify you.
We employ a range of commercially reasonable safeguards designed to protect personal information against loss and theft as well as unauthorized access, disclosure, copying, use, and modification. These safeguards include physical, organizational, administrative, and technical measures commensurate with the sensitivity of your personal information. We do not guarantee the absolute security of your personal information. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.
Our Sites and App are not intended to attract children, and we do not knowingly collect any personal information anyone under the age of 13. If you believe your child is using our website, please contact us using the information provided in Contact Us below so that we can investigate and delete any data as may be appropriate.
- Device Information. We collect information about the device you use to use the Services like your computer, phone, or tablet. This information may include your IP address, browser 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 Sites or use the App, the areas or pages of the Sites or App that you visit, the amount of time you spend viewing or using the Sites or App, content entry, mouse movements, screen captures, the number of times you return to the Sites or App, other click-stream or usage data for the Sites or App, emails that you open, forward or click-through to reach our Sites, and other sites that you may visit.
- Analytics Information. We may use vendors and tools to collect analytics-related information to better understand how the Services are being used and by whom, as well as how to improve the Services. These analytics vendors and tools may collect information about your activity, across your different devices, on our Sites and App as well as on third-party websites and apps (such as web pages you visit and your interaction with our advertising and other communications), and use this information to make predictions about the preferences of our customer base or segments thereof. One of the vendors we use is Google Analytics. Google Analytics has its own cookies that it uses to track and aggregate this information. To find out more about how Google Analytics collects and processes data, please click here.
To learn more about how to exercise your choices related to cookies and other advertising practices, please review Your Rights and Choices below.
Your Rights and Choices
Under applicable law, you have certain rights relating to our collection and use of your personal information, including rights to:
- Opt-Out of Receiving Our Marketing Emails. To stop receiving our promotional emails, follow the opt-out link in any of our promotional emails or call us at 1-877-202-0987 or email us at firstname.lastname@example.org. This opt-out does not apply to transactional or informational emails (e.g., our communication in response to your request for information, products, or services from us) nor to disclosure to a third party that is acting on our behalf and under our instructions in support of our permitted uses of your personal information.
- Access and Correct Your Information. You can request to access the personal information that we hold about you and to correct any information that is incomplete or wrong. You can make such requests by contacting us using the information in Contact Us Please note that we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
- Make Choices Concerning Cookies. You can control cookies by using the tools described below, but please note that if you disable cookies, some features of our Services may not function properly:
- Your Browser. You can control cookies through web browsers by changing your cookie settings. These settings will typically be found in the “options” or “preferences” menu of your browser.
- Third Party Tools. You can also visit http://www.allaboutcookies.org/, where you will find comprehensive information on cookie management and blocking that pertains to a wide variety of browsers. You can prevent the use of Google Analytics relating to your use of our website by downloading and installing the browser plugin available here. You can also use the interested-based advertising opt-out tools mentioned above.
If you are a California resident, please review Additional Information for California Residents below for a description of additional rights.
LINKS TO OTHER WEBSITES
Additional Information for California Residents
The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Terms used herein have the meaning ascribed to them in the CCPA. We are a “business.”
Notice at Collection and Use of Personal Information
Information We Collect
Depending on how you interact with us, we may collect the categories of personal information listed above in the section Information We Collect and How We Collect It.
How We Use Collected Information
We also may use personal information from you for the business or commercial purposes described above in the section Why We Collect This Information.
Our Sale of Personal Information
We may “sell” your personal information as that term is defined under the CCPA. You have the right to opt-out of this sale through this link: Do Not Sell My Personal Information.
Our Collection, Use, Disclosure, Sale, and Sharing of Personal Information
What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information
In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information from the sources listed in the above section Information We Collect and How We Collect It. We may collect all or a few of these categories of personal information for the business or commercial purposes identified in the section, Why We Collect This Information.
Our Disclosure and Sale of Personal Information
Depending on how you interact with us, we may disclose or sell (as such term is defined under the CCPA) your personal information. We do not knowingly sell the personal information of consumers under the age of 16 years.
In the preceding 12 months, we may have disclosed for a business purpose or sold the following categories of personal information to the following categories of third parties:
|Category of Personal Information
|Category of Third Party Personal Information is Disclosed to for a Business Purpose
|Category of Third Party Information is Sold To
|Identifiers (for example your name, address, DOB, SSN, driver’s license, passport number, and online identifiers)
|Additional information subject to Cal. Civ. Code § 1798.80(e) (for example, a signature, state identification card number, financial information, or bank account information)
|Commercial Information (for example records of products or services purchased, obtained or considered or purchasing histories or tendencies)
|Geolocation Data (as information about your location or the location of your device)
|Internet or Electronic Network Activity Information, including interactions with our website or use of certain online tools
|Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information
In addition, in the preceding 12 months, we may have disclosed for a business purpose all of the categories of personal information identified in Information We Collect and How We Collect It, to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law.
We may also share your personal information with our service providers (such as our IT providers or customer relationship management (CRM) providers), other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in, or as otherwise permitted by, the CCPA.
California Residents’ Rights under the CCPA
If your personal information is subject to the CCPA, you may have certain rights with regard to such personal information, including the right to:
- You have the right to be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.
- Request to Delete. Request that we delete any personal information about you that we have collected or maintained, subject to certain exceptions.
- Request to Know. Request that we provide you with: (i) the categories of Personal Information we have collected about you; (ii) the categories of sources from which we collected the personal information; (iii) the business or commercial purpose for collecting or selling the personal information; (iv) the categories of third parties with whom we share the personal information; (v) the specific pieces of personal information we have collected about you; and (vi) the categories of personal information about you we have sold or disclosed for a business purpose.
- Not to Be Discriminated Against. Not be discriminated against because you exercised any of your rights under the CCPA.
- Opt-Out of Sale. Request that we not sell your personal information.
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a request to delete where permitted by the CCPA or where another law or regulation is applicable.
How to Submit a Request under the CCPA
You can submit a request to exercise your rights under the CCPA through the following:
- Request to Know and Delete. You may submit a Request to Know or Request to Delete, as described above, through the following toll-free telephone number at 1-877-202-0987, through our website at the following link: Consumer Request Form, or by emailing us at email@example.com with “CCPA Rights Request” in the subject line.
- Opt-Out of Sale. To the extent that we sell your personal information, as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale at any time. You may submit a request to Opt-Out of Sale by: (1) clicking Do Not Sell My Personal Information and filling out the webform; (2) calling 1-877-202-0987; or (3) emailing us at firstname.lastname@example.org.
We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent. When you submit a Request to Know or Request to Delete, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, your name and email address. The amount of information needed may vary depending on the sensitivity of the information you are requesting and the type of request you are making. Any information gathered as part of the verification process will be used for verification purposes only.
You are permitted to designate an authorized agent to submit a Request to Know or a Request to Delete on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit proof that they are authorized to act on your behalf, or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
Notice of Financial Incentive
From time to time, we may offer financial incentives in connection with the collection or use of personal information related to our loyalty programs. The material terms of the financial incentive will generally be presented to you at the time you sign up. You may withdraw from any financial incentive at any time by emailing us at email@example.com or by calling us at 877-202-0987.
Additional Rights for California Residents
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please submit your request in writing by email at firstname.lastname@example.org or by mail using the information provided in Contact Us. Please include the statement “California Shine the Light” in the subject line of your communication.
Some web browsers may transmit “do not track” (“DNT”) signals. We currently do not respond to DNT settings in your web browser.
If you would like to know more about our privacy practices, including our use of service providers outside your jurisdiction of residence, or if you would like to exercise certain rights under this policy (including the right to have your personal information deleted), please contact us at email@example.com or at the address below:
Prollenium® Medical Technologies Inc.
9121 Anson Way
Raleigh, NC 21715