- "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.
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.
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.
- 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;
- 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.
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;
- 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.
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.
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:
- 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.
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.
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
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.
Contacting or Communicating with Us
- 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
Laser Clinics Canada
Cassels, Brock & Blackwell LLP
2200 HSBC BUILDING
885 WEST GEORGIA STREET
Vancouver, British Columbia