Privacy Policy

This personal information and privacy policy (the "Privacy Policy") was last amended on February 1 2023.

Introduction

LLC Operations Limited, Can Skin & Laser Limited and each of their affiliated companies (collectively "Franchisor") and their network of franchisees across Canada (“Franchisees”, and together with the Franchisor, "Laser Clinics Canada") consider matters relating to the protection of personal information and privacy to be extremely important.  In developing this Privacy Policy, Laser Clinics Canada wants to assure you that Laser Clinics Canada has taken into account your personal information and privacy and those of others.  Laser Clinics Canada encourages you to review this Privacy Policy.  Laser Clinics Canada has created and implemented this Privacy Policy so that you understand how your personal information may be utilized and disclosed and how it is protected. 

This Privacy Policy describes the kind of personal information we may collect during your visit to our websites, any mobile applications we may offer and our other online services and during any other interaction you may have with us, including in connection with your visits to our clinics (collectively, the “Services”). 

By dealing with Laser Clinics Canada or by providing personal information in connection with your use of the Services, we will assume that you have consented to the collection, use and disclosure of your personal information in accordance with this Privacy Policy. 

If you have questions regarding this Privacy Policy or our privacy practises, then please contact us at the Privacy Office, contact details listed below. 

Our Commitment

Except as otherwise provided in this Privacy Policy, Laser Clinics Canada will not sell, rent, loan, trade, lease, transfer or otherwise disclose personal information, including e-mail addresses, to any third party. 

Amendments to this Privacy Policy

Laser Clinics Canada may amend this Privacy Policy at any time by posting a new privacy policy in place of this one.  These amendments may include, without limitation, adding to, deleting from or modifying any of the provisions in this Privacy Policy.  Laser Clinics Canada will post notice that the Privacy Policy has been amended on the fronting webpage of its main website at www.laserclinics.ca for a period of 30 days.  The amended privacy policy shall automatically be effective when posted.  Your continued dealings with Laser Clinics Canada or use of the Services following the posting of the amended privacy policy and the posting of such notice shall mean that you accept the terms of this Privacy Policy as amended.  If you do not agree with any of the terms or conditions in the amended Privacy Policy then you must immediately cease all use of the Services and cease in your dealings with Laser Clinics Canada, which shall be your sole recourse and remedy in the event you are dissatisfied with the amended Privacy Policy.  This Privacy Policy may not otherwise be amended. 

The first sentence of this Privacy Policy indicates when the Privacy Policy was last amended.  Please check back regularly to review for changes. 

Definitions

In this Privacy Policy, the following term has the following meaning:

• "personal information" means information about an individual.  Personal information does not include information that cannot be attributed to an individual, for example, information of an aggregate or anonymous nature.  Personal information may include amongst other things:
• name and date of birth;
• contact details and your emergency contact details;
• bank account or credit card details;
• payment history;
• health information;
• details of our consultations;
• treatment details; and
• before and after photographs.

Personal Information Made Anonymous

To the extent that we make any personal information anonymous or we aggregate it with the personal information of others, then that information will no longer be considered to be personal information.  Therefore, Laser Clinics Canada will be entitled to use and disclose personal information in any manner that it desires provided the personal information has been rendered anonymous or aggregated where that information cannot be attributed to any individual.

Choosing to Provide Personal Information

In using the Services and in dealing with us you will have the ability to control the amount of personal information you provide to us and therefore you may restrict the use and disclosure of personal information we collect from you by not providing personal information in connection with the Services or to us in the first place.  However, if you choose to limit the personal information you provide, it may limit the manner in which you can make use of the Services or otherwise interact with Laser Clinics Canada.

Consent

You are required to obtain any consents needed before you provide any personal information of any other individual in connection with the Services or to us and for the processing and disclosure of that personal information as part of the Services and our handling of the personal information as described in this Privacy Policy. 

When we collect, use or disclose your personal information we will generally obtain your consent.  Most of the time, we will obtain your consent before or at the same time we collect your personal information.  When we collect personal information from you, we will inform you of the uses and disclosures that we wish to make of your personal information unless those uses and disclosures are readily apparent at the time we collect the personal information or are set out in this Privacy Policy.  In some instances, however, we may seek your consent after we have collected your personal information if we wish to make an additional use or disclosure of your personal information where we do not already have your consent for that new use or disclosure.  This additional consent may be obtained through an amendment to this Privacy Policy as provided above.

Depending on the circumstances, your consent may be express or implied.  Express consent would arise if you specifically consented to a particular dealing in your personal information.  Express consent can be given orally, electronically or in writing.  Implied consent can be inferred from the circumstances and, in particular, where the uses and disclosures are readily apparent at the time we collect the personal information.  For example, if you send us an email requesting certain information, we will use the email address in your email to send you the requested information without asking you if we can do so: your consent will be implied in those circumstances.  As well, we will assume your consent to the collection, use and disclosure of your personal information for a particular purpose if you voluntarily provide the information for that purpose.

Opting In and Opting Out

Laser Clinics Canada may, from time to time, provide you with an opportunity to opt-out of certain collection, uses and disclosures of your personal information.  At the same time, an implied consent to collect, use and disclose your personal information would arise if you fail to indicate that you wish to opt-out of the particular collection, use and disclosure when you are given an opportunity to do so. 

As well, Laser Clinics Canada may, from time to time, provide you with an opportunity to opt into certain collection, uses and disclosures of your personal information.  In that case, if you do not opt-in, Laser Clinics Canada will assume that you do not consent to your personal information being collected, used and disclosed in that particular manner. 

Consent Through This Privacy Policy

This Privacy Policy sets out certain circumstances where we may collect, use and disclose your personal information and, as such, this Privacy Policy operates to obtain your consent to such collection, use and disclosure.  By using the Services or by providing personal information in connection with your interactions with us, we will assume that you have consented to the collection, use and disclosure of your personal information as set out in this Privacy Policy unless you advise us otherwise. 

Changing Your Consent

You may change or withdraw the consents you have provided at any time on reasonable notice by contacting our Privacy Office as set out below.  Further, you may change or withdraw the default consents set out in this Policy at any time on reasonable notice by contacting our Privacy Office.  If you withdraw certain consents, it may limit the manner in which you can make use of the Services and to otherwise interact with us.  For clarity, your ability to change or withdraw consent is not absolute.  Laser Clinics Canada reserves the right to continue handling your personal information in those circumstances required or permitted by law despite a change or withdrawal of consent.

Collection

Except as otherwise provided in this Privacy Policy, we will obtain your explicit or implied consent to collect your personal information.  The following sets out some of the information we may collect in connection with your use of our Services and your registration on and use of our website and our other online services:

• Identity and contact information: including your name, age, address, postal address, email address and phone number;
• Account data: including username and password;
• Transaction information: including bank and payment card information where used to make a purchase;
• Device information: including information related to the browser or device you use to access our Website, such as your IP address. We typically collect this information through the use of cookies and similar technologies (For additional information, please see below in the section entitled Cookies Policy);
• Your marketing preferences: including any consents you have given us;
• Health information: including medical conditions and allergies you may have;
• Treatment details: including the nature and scheduling of your treatments, treatments provided, treatment results and information relating to any adverse events;
• Consultation details: including telehealth consultations;
• Photographs: before and after treatment photographs; and
• The content of your communications or any other personal data you provide to us directly.

Use

Set out below are certain circumstances where we may use your personal information without obtaining any further consent.  By providing personal information to us, we are assuming that you are consenting to these uses unless you inform us otherwise.  These are:

• when you make an appointment or place an order to purchase a product or service, we will collect information relating to the same including, as applicable, time and date of the appointment, what was ordered, the purchase price, payment information, delivery address and the order date. This information is used to fulfill our obligations relating to the foregoing;
• personal information that is supplied when using the Services will be used: (i) in accordance with the description of uses as set out in the related documentation for the Services, (ii) as may be readily apparent through the general operation of the Services, and (iii) as described in this Privacy Policy;
• using identification information and contact information, such as your name and e-mail address to provide information about Laser Clinics Canada and the Services when you request that information;
• using payment method preferences and related financial information that you provide to us so that we can obtain payment for the products and services that you ordered;
• using identification information and contact information, such as your name and e-mail address so that we can identify you and deliver products and services that you request and to communicate with you regarding those products and services;
• using information relating to your preferences so that we are able to deliver our products and services to you in accordance with those preferences;
• using relationship information such as your service requests, instructions, comments and feed back to assist us in delivering products and services in accordance with your wishes;
• using personal information for the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose. For example, if you send us an e-mail with a question or comment, Laser Clinics Canada will use your e-mail address to respond to you.  Further, Laser Clinics Canada may store your e-mail and e-mail address and a copy of our response for future reference;
• using your e-mail address to provide you with information about new features or enhancements to our products and services;
• using your personal information for the purposes of managing marketing programs that you may choose to participate in, such as any promotional contests we may offer;
• analyzing personal information and how the Services are being used to assist us in developing and enhancing our products and services; and
• analyzing personal information and how the Services are being used to assist us in conducting market analysis and strategic planning.

Except as otherwise provided in this Privacy Policy, Laser Clinics Canada will not use your personal information for any other purpose.

Laser Clinics Canada has Franchisees that provide our beauty and cosmetic services.  In that regard, the Franchisor provides a number of services to support its Franchisees.  As such, a Franchisee may provide your personal information to the Franchisor to enable the Franchisor to assist with the Franchisee's operations and, as such, the Franchisor may use your personal information in order to provide that assistance.  As well, if you visit a new location, that Franchisee will access personal information that you previously provided in order to provide Services to you, including your treatment history and health information such as medical conditions and allergies.

Disclosure

Set out below are certain circumstances where we may disclose your personal information without obtaining any further consent.  By providing personal information to us, we are assuming that you are consenting to these disclosures.  These are:

• In the event Laser Clinics Canada transfers or is considering transferring control of any or all of its operations or services to another organization, Laser Clinics Canada reserves the right to transfer and disclose your personal information to that organization.  However, Laser Clinics Canada will require that the organization agree that it will be similarly bound by the provisions of this Privacy Policy and that it will only use and disclose your personal information as Laser Clinics Canada is similarly entitled under this Privacy Policy;
• In the event Laser Clinics Canada amalgamates with another organisation, Laser Clinics Canada reserves the right to permit that amalgamated organisation to continue to use and disclose your personal information.  However, Laser Clinics Canada will require that the amalgamated organisation agree that it will be similarly bound by the provisions of this Privacy Policy and that it will only use and disclose your personal information as Laser Clinics Canada is similarly entitled under this Privacy Policy; and
• Laser Clinics Canada may engage certain service providers.  Those service providers may provide services to Laser Clinics Canada to assist Laser Clinics Canada in its activities.  Other service providers may provide services directly to you at the request of Laser Clinics Canada.  These services provided by the third-party service providers include marketing, market research (including by using other available data to gain greater insights about our clients), promotional contests, customer relationship management, payment, information technology, website hosting, maintenance and identity verification services.  As such, it may be necessary for Laser Clinics Canada to disclose your personal information to these service providers.  However, Laser Clinics Canada will take steps to ensure that these service providers will only use and disclose your personal information as necessary to provide the services.

As well, as discussed above, some of your personal information may be disclosed between the Franchisor and Franchisees and between Franchisees in delivering services and products to you.  For example, if you make an appointment on our website, the relevant Franchisee will have access to the information you provided for the purposes of the appointment.  If you visit a different franchise location, that Franchisee will have access to information that you may have previously provided to any of our other Franchisees.

Accounts

To use certain of the Services, such as certain parts of a website, you may be required to open an account and to provide certain personal information in connection with that account.  You may access, modify or delete your account at any time.

Information We Collect Automatically When You Use the Services

When you access or use our Services, we automatically collect certain information through certain mechanisms, including, but not limited to:

• Log Information: We collect and log information about your access and use of our website and any mobile applications, such as your domain name and/or your IP address, the type of browser you use, access times, pages or information viewed, browsing behavior, the page you visited before navigating to our website and any search terms and search engines used to find the Services.
• Device Information: We collect information about the computer or mobile device you use to access our Services, such as the hardware model, operating system and version, unique device identifiers, settings of the device and mobile network information. 
• Location Information: We may collect information about the precise location of your device or computer each time you access or use our websites or mobile applications, including geolocation information associated with your computer or device's IP address, your mobile device's GPS signal or information about nearby WiFi access points and cell towers that may be transmitted to us when you use the Services.
• Information Collected with Tracking Technologies: We and our service providers use various tracking technologies, including cookies, web beacons and embedded scripts, to collect information about you and your interaction with our Services, including information about your browsing behavior.  Cookies are small data files stored on your hard drive or in device memory.  Web beacons (also knowns as clear GIFs and pixel tags) are electronic images that may be used with our Services or emails.  Embedded scripts are programming code that run when you use our Services which can facilitate the collection of information. 

The foregoing mechanisms and the information collected are used to: (i) to recognize a visitor when they return and to tailor the information and services provided to the visitor based on their previous visits; (ii) understand use of the Services, such as number of visits, average time spent on the Services, pages viewed, features used and campaign effectiveness; (iii) improve the Services and related systems; (iv) assist with the operation and management of the Services; and (v) monitor use of the Services, to ensure proper operation, security and to prevent misuse. 

For more information about the foregoing, and how to disable them, please see "Managing Cookies, Trackers, Scripts, Location and Social Media Information" below. 

Information We Collect from Other Sources

In some instances, we may collect your personal information directly from a third party.  In that case, we will generally either obtain your consent to do so or we will require that the third party confirm to us that they are entitled to disclose your personal information to us.  We may combine this information with information about you that we collect from you.

Do-Not-Track Signals

Some web browsers may provide the option to transmit "do-not-track" signals to websites a user visits.  We currently do not respond to browser “Do-Not-Track” signals. 

Managing Cookies, Trackers, Scripts, Location and Social Media Information

Many web browsers have settings to notify you when you receive a cookie, web beacons and other trackers and to allow you to block these cookies, web beacons and other trackers and may allow you to disable scripts.  If you block any of these items you may not be able to access certain parts of the websites making up the Services or certain functionality or features may not work properly or may not be available.  You may be able to block cookies, web beacons and other trackers and scripts by following the instructions on your browser.  Your browser may also allow you to delete cookies and other trackers already stored. 

As well, your computer or mobile device or browser may allow you to prevent your location from being shared with third parties.

Many social media services allow you to select how your personal information is collected, used and shared.  Please check with your social media services for your options.

Storage and Processing Information Outside Canada

Certain of our affiliated companies are located in Australia.  As well, certain of our service providers are located outside of Canada.  As such, we may transmit your personal information to our affiliated companies and to third parties who are located outside Canada to assist us in the operation of our business.  By providing personal information to us, you are consenting to the delivery, storage, processing and handling of your personal information outside of Canada.  Please note that many governments around the world can require that organizations under their jurisdiction deliver information, including personal information, that is in the control of that organization to the government.  This is often done without notice to or the consent of the affected individual.

Other Collection, Use and Disclosure

Laser Clinics Canada may monitor your use of the Services to ensure the proper use, operation and security of the Services and your compliance with any terms of use related to the Services or other related agreements.

As well, the law permits or requires the collection, use and disclosure of personal information without the knowledge or consent of the individual in a number of circumstances.  We reserve the right to collect, use and disclose your personal information in these circumstances without your knowledge or consent as the law may permit or require.

Links to Third-Party Sites

Our Services may link to third-party websites and services.  We are not responsible for the security or privacy of any information collected by third-party websites and services.  Please exercise caution and review the privacy statements applicable to the third-party websites and services you use.

Accuracy and Completeness

When we collect, use or disclose personal information, we will make a reasonable effort to ensure that it is accurate, up-to-date and complete.  To do so, we may need to request additional information from you or have you verify your information.  If your personal information does change, we would appreciate it if you could inform us of those changes in order that your personal information in our possession remains accurate.

Retention and Destruction

For legal and business purposes we may retain your personal information for as long as it is reasonably needed.  Upon expiry of the appropriate retention period, bearing in mind our reasonable legal and business requirements, your personal information will either be destroyed in a secure manner or made anonymous.  You should be aware that there are legally required minimum retention periods, which Laser Clinics Canada must and does observe.

Security of Personal Information

Laser Clinics Canada recognizes its obligation to protect personal information in its possession and will make reasonable arrangements to secure that personal information against unauthorized access.  These measures will be reasonable in the circumstance and may include providing access to only those individuals with a need to know the information, locked doors and/or filing cabinets and other physical and electronic security measures as well as contractual measures, such as non-disclosure or confidentiality agreements. 

While these security measures are implemented and maintained in accordance with the foregoing standards and in accordance with applicable law, they may nevertheless be breached by motivated individuals despite our efforts.

Requests with Respect to Personal Information. 

Subject to certain limitations, you have the right to access your personal information in our possession or control, be informed of how we have used and disclosed your personal information and to have incorrect information corrected.  To make a request please contact us as set out below.  All requests may be subject to reasonable fees and disbursements.  We require that all requests be in writing and be signed by the requestor.  As well, we required sufficient information and detail from the requestor in order to verify their identity, properly locate the information and respond to the request.

Limited Nature of this Privacy Policy

Nothing contained in this Privacy Policy is intended to create a contract or agreement between Laser Clinics Canada and you and you may not rely on it as such.

Contacting or Communicating with Us

If you:

• have any questions with respect to our privacy policies or practises;
• have any questions with respect to our handling of your personal information;
• if you wish to request access to or correction of your personal information under our care or control; or
• if you are dissatisfied with our handling of your personal information or any of our responses,

please contact our Privacy Office at:

Attention: Privacy Office
Address:	Laser Clinics Canada c/o Cassels, Brock & Blackwell LLP 2200 HSBC BUILDING 885 WEST GEORGIA STREET Vancouver, British Columbia V6C 3E8
email:	privacy@laserclinics.ca