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General Privacy Policy


Privacy Notice

Last revised and effective as of: November 1, 2023

We at Cynosure, LLC (along with each of Cynosure, LLC’s Corporate Affiliates (as defined below), collectively, “Cynosure”, “we”, “us” or “our”) respect your concerns about privacy. Cynosure, LLC’s Corporate Affiliates include the entities listed at https://www.cynosure.com/privacy-policy/corporate-affiliates-and-entities/.

This Privacy Notice explains how we use any personal information we collect about you online and offline, including through our websites on which this Privacy Notice is posted (including but not limited to www.cynosure.com, shop.cynosure.com, and www.cynosureuk.com, and the sites listed at https://www.cynosure.com/privacy-policy/domains/), as well as any subdomains of the foregoing (together with our Provider Portal (available at https://customer.cynosure.com/login), each, a “website”) and your rights in relation to the information. You may also provide information to us when you meet us in person, such as at business conferences or trade shows or when you are involved in our webinars or our networking activities (collectively, “Networking Activities”) and this Privacy Notice relates to such information as well. As used in this Privacy Notice, “you” or “your” refers to a visitor to or user of our website and/or any consumer (as defined below) or professional (as defined below).

To the extent our websites, products, and services are available to individuals located in the European Economic Area (the “EEA”) or the United Kingdom (the “UK”), to the extent we participate in Networking Activities with you in the EEA or the UK, or to the extent we process your personal information in the context of the activities of an establishment in the EEA or the UK, this Privacy Notice sets out our practices and obligations under the European Data Protection Laws, to the extent applicable. As used in this Privacy Notice (a) “GDPR” means the General Data Protection Regulation (EU) 2016/679; (b) “UK Data Protection Laws” means data protection laws enacted under the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 and the UK Data Protection Act 2018; and (c) “European Data Protection Laws” means the GDPR and/or UK Data Protection Laws, in each case to the extent applicable.

“Personal information” means information that identifies you as an individual or is capable of identifying you as an individual. Personal information amounts to ‘personal data’ for the purposes of and as defined in the European Data Protection Laws (to the extent applicable). All references to personal information shall be deemed to include ‘personal data’ as defined and used in the European Data Protection Laws (to the extent applicable). As used in this Privacy Notice, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within Cynosure or among our Corporate Affiliates within the United States or internationally.

This personal information may include your name, email address, username, password, physical address, zip code, telephone number, survey responses, and the content of any request or form you submit to us. If you are a recipient, prospective recipient, or past recipient of any procedures utilizing Cynosure’s devices (a “consumer”), we may also collect information about treatments you are considering or have previously received, the content of any reviews you submit, your inquiries or responses to quizzes that you choose to submit to us, and, if you consent, we may receive before and after photographs from the professional who performed your treatments. If you are a consumer, in connection with any inquiries or responses to quizzes you may submit to us, we may also collect your medical conditions (history of pregnancy/childbirth), gender, sex, and age. If you use our provider locator feature, we will collect your zip code in order to identify professionals in your area. If you’re accessing our websites or participating in Networking Activities with us, or if you have leased or purchased (or are considering leasing or purchasing) our products or services in your capacity as a professional, including as a healthcare professional (a “professional”), this personal information may also include your location, photograph, other contact details, information included in your profile on RealSelf.com, records of products or services purchased or leased, the nature of your transaction with Cynosure, job title, company name, practice and specialty, practice type, and practice name and location. Additionally, we may collect information relating to professionals in connection with the lease or purchase of any of Cynosure’s devices including: company ownership information, trade references, website, billing/payment information (including credit card number and/or bank account information (including balance)), tax identification number (such as social security number), financial statement, years in practice, and (depending on your financing of your lease or purchase) we may engage third-party service providers to run credit worthiness checks, which third-party service providers may provide to us information on your credit worthiness (including a suggestion as to the maximum credit we should offer you).

If you make a purchase, we may also collect your payment details.

 

1. Information You Provide to Us

We may collect personal information from you directly, such as when you purchase products or services from us, register on our Provider Portal, submit information through this website (such as through surveys and quizzes), sign up to receive marketing from us, or otherwise communicate with us by telephone or in writing.

2. Third-party Sources

We may collect personal information from third-party sources, such as business partners, sub-contractors and analytics providers, search information providers, address update providers, distributors, co-promotion partners and credit reference agencies. We process all data we obtain from such other sources in accordance with this Privacy Notice. If you are a consumer and if you consent, we may receive before and after photographs and other information from the professional who performed your treatments. If you are a professional, we may directly collect personal information about you that is publicly available from sources such as LinkedIn and other publicly available websites. If you are a professional, in connection with the lease or purchase of any of Cynosure’s devices, depending on your financing of your lease or purchase, we may engage third-party service providers who run credit worthiness checks, which third-party service providers may provide to us information on your credit worthiness.

3. Website Usage Information and Other Information Collected Automatically

When you visit our websites or view our advertisements, we (and our service providers) may use cookies and other technologies to automatically collect the following information:

  • technical information, including your IP address, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times and download errors;
  • information about your visit, including the websites you visit before and after our website and products you viewed or searched for; and
  • length of visits to certain pages, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.

For the avoidance of doubt, our websites may use third-party service platforms (including to help analyze how visitors use our websites). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable “third-party” cookies, you may be able to turn them off by going to the third party’s website.

Here are links to the main third-party platforms we may use:

To learn more about how we use cookies and how to control which cookies are used, please see our Cookies Notice. Information collected from some cookies placed on our websites is used to deliver Cynosure advertisements to Cynosure website visitors when such visitors are visiting other websites.

4. Individuals Under the Age of 13

We are committed to protecting the privacy of children. Our websites are not designed for or directed to children under the age of 13. We do not collect personal information from any person we actually know is under the age of 13.

5. How We Use the Information We Obtain

We use your personal information to provide, improve, and promote our websites and/or our products and services, as well as to facilitate participation in Networking Activities, including without limitation in order to:

  • operate our business, administer our services and manage your accounts;
  • contact you to respond to your requests and queries;
  • engage in Networking Activities;
  • process any purchase order, including potential screening and background checks, order confirmations, deliveries and subsequent customer care;
  • unless you opt out (to the extent permitted by applicable law), provide you with marketing information about our products and services (including Networking Activities) that is tailored to your interests (and where necessary, we will obtain your consent to this);
  • manage our risks to help identify, prevent or investigate illegal activity;
  • combine information we receive and collect (e.g. from your browsing behavior) to understand your interests and preferences and provide you with a more personalized experience;
  • keep internal records and manage our relationship with you;
  • process your personal information where this is necessary to keep our website safe and secure; and
  • keep an up-to-date suppression list where you have asked not to be contacted, in order for us to not inadvertently re-contact you.

The legal bases for which we collect, use, transfer or disclose your personal information may include:

  • where you have given consent to our processing of such personal information, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;
  • performance of our contract obligations;
  • our legitimate interests in: effectively pricing and designing our products; improving our offerings as a business; engaging in Networking Activities; personalizing our interactions with you, to better meet your needs as a customer; keeping records of any correspondence with you; monitoring how our website is used to detect and prevent fraud, other crimes, and the misuse of our website; and ensuring that you can safely use our website; where your interests or fundamental rights and freedoms do not override those legitimate interests; and
  • compliance with our legal obligations.

Unless you ‘opt out’ (to the extent permitted by applicable law), we and third parties acting on our behalf may contact you about products and services that may be of interest to you. You will have a right to unsubscribe at any time.

In particular, we would like you to be aware that we may construct profiles about professionals and/or consumers and therefore we may use the personal information described above so that an evaluation can be made about preferences and interests (among other things). We may use these inferences to direct marketing materials to you that are more tailored to your preferences and interests. Under the European Data Protection Laws (to the extent applicable), this usage may be considered profiling. The European Data Protection Laws define “profiling” as “any form of automated processing of personal information consisting of the use of personal information to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements”. To the extent our processing constitutes profiling under the European Data Protection Laws (to the extent applicable), you have the right to specifically object to the processing of your personal information for the purpose of profiling in accordance with the paragraph below titled “Your Personal Information Rights”. To learn more, please reach out to [email protected].

6. Third Parties

The security of your data is extremely important to us. Access to your personal information is only provided to our staff and certain third parties, including:

    • our group of companies, including our Corporate Affiliates, in order to administer our services and products, provide you with customer support, process your payments, understand your preferences, send you information about products and services that may be of interest to you, and conduct the other activities described in this Privacy Notice. “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with Cynosure, LLC, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.
    • professionals. If you are a consumer and you reach out to us regarding services utilizing Cynosure devices, we may share your information with professionals to reach out to you regarding provision of such services.
    • practice transformation plan partners, with whom we partner to provide professionals with resources to improve and market their practices. Depending on the Cynosure products or services purchased by a professional, we may share such professional’s information with practice transformation plan partners for the purpose of facilitating such professional’s receipt of products and services from such practice transformation plan partner to help such professional market such professional’s services, including services that utilize Cynosure devices.
    • certain of our distributors, who market and sell Cynosure products in jurisdictions where we do not operate directly. If you are a professional, we may provide your information to our distributors who may market products and services to you (including Cynosure products).
    • our service providers, who perform services on our behalf or to assist us with the provision of services and products to you. Such service providers may include the following categories of service providers (among others):
      • infrastructure and IT service providers;
      • marketing, advertising, and communications agencies and service providers, and certain analytics service providers; and
      • credit reference agencies.

    In the course of providing such services, these service providers may have access to your personal information. We will use commercially reasonable efforts designed to ensure that all the service providers we work with will keep your personal information secure.

    • our analytics providers. In addition to the above, when visitors use our websites, third parties (including without limitation third-party analytics service providers) may directly collect information (including personal information) about our website visitors’ online activities over time and across different websites. Please note in particular that our websites use Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners’ sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.
    • our strategic partners. Our selected partner organizations (including financing sources) may use your personal information.  Such sharing of personal information is for the purposes of improving, financing, marketing, and providing our products and services, or (if you are a professional) helping you market your services that utilize Cynosure devices.
    • third parties permitted by law, where we may be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, government agencies, or to judicial or administrative authorities). We may also disclose your personal information to third parties where disclosure is both legally permitted and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our Terms and Conditions or protect your rights or those of the public.
    • third parties connected with business transactions, such as in connection with a reorganization, restructuring, merger, acquisition or transfer of assets, or in connection with a strategic investment by a third party in Cynosure, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Notice.
    • Worldpay (UK) Limited, Worldpay Limited, Worldpay AP Ltd., and Worldpay, LLC (together, “Worldpay”), who provide payment processing services to us. Worldpay is an independent data controller in respect to your personal information. Worldpay’s Privacy Statement can be found on Worldpay’s corporate website.

Our websites also contain a provider locator feature. If you are a professional and you are included in the provider locator feature, your name, company name, photograph, job title, contact information, and any other information you choose to include in your provider locator profile will be publicly viewable to visitors to the website (including consumers).

Our website may, from time to time, contain links to and from the websites of our partners or other third parties.  If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we have no control over how they may use your personal information. A link to a third-party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. You should check the privacy notices of third-party websites before you submit any personal information to them.

7. Public Areas

Our websites may feature various community areas, blogs, and other public forums (the “Public Areas”) where individuals can share information or where individuals can post questions for others to answer. The Public Areas include, without limitation, the provider locator feature on our websites. These Public Areas are open to the public and should not be considered private. We cannot prevent information included within a Public Area from being used in a manner inconsistent with this Privacy Notice, the law, or your personal privacy. We are not responsible for the results of such postings or for the accuracy of any information contained in those postings.

Any information you share in a Public Area (including personal information) is by design open to the public and is not private. You should think carefully before posting any information in any Public Area. What you post can be seen, disclosed to or collected by others and may be used by others in ways we cannot regulate or predict. As with any public forum on any website, the information you post may also show up in third-party search engines like Google, Yahoo, MSN, and Bing. If you mistakenly post personal information in a Public Area, you can send us an e-mail to request that we remove it by contacting us at [email protected]. You should understand that in some cases, we may not be able to remove your information.

Any information shared in the Public Areas is available to the public, including to all website visitors. Such information is not protected or treated as confidential, can be used in any manner, and is not subject to this Privacy Notice. If you wish to keep any information private or proprietary, do not submit it to the Public Areas. NOTWITHSTANDING THE FOREGOING, WE HAVE NO RESPONSIBILITY OR LIABILITY IF AN INDIVIDUAL’S INFORMATION OR IDENTITY IS MISUSED OR STOLEN, OR IF AN INDIVIDUAL SUFFERS HARM AS A RESULT OF VOLUNTARY DISCLOSURES.

8. Data Retention

Your personal information will only be stored for as long as necessary for the purposes for which they were collected and only to the extent permitted by applicable laws. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to promptly anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

9. International Data Transfers

The personal information that we collect from you may be transferred to, and stored at, a destination outside the EEA and/or the UK.  It may also be processed by staff operating outside the EEA and/or UK who work for us or for one of our service providers.

We will take all steps reasonably necessary to ensure that your personal information is treated in accordance with this Privacy Notice and the European Data Protection Laws, as applicable, including, where relevant, entering into the appropriate standard contractual clauses (or equivalent measures) with the party receiving the personal information outside the EEA or UK, as applicable.

10. How We Protect Personal Information

We have implemented technical and organizational security measures in an effort to safeguard personal information in our custody and control. These measures include limiting access to personal information only to employees and authorized service providers who need to know such information for the purposes described in this Privacy Notice, as well as other technical, administrative, and physical safeguards.

While we endeavor to always protect our systems and information against unauthorized access, due to the inherent nature of the Internet as an open global communications vehicle (and other risk factors), we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.

11. Your Personal Information Rights

Under the European Data Protection Laws (to the extent applicable), you may have various rights in connection with our processing of your personal information:

  • Access. You may have the right to request a copy of the personal information we are processing about you, which we will provide back to you in electronic form.
  • Rectification. You may have the right to have incomplete or inaccurate personal information that we process about you rectified.
  • Deletion. You may have the right to request that we delete personal information that we process about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims.
  • Restriction. You may have the right to restrict our processing of your personal information where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it. In such case, we would mark stored personal information with the aim of limiting particular processing for particular purposes in accordance with your request, or otherwise restrict its processing.
  • Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you may have the right to object to such processing on grounds relating to your particular situation. Where required by the European Data Protection Laws, we will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise, or defense of a legal claim.
  • Withdrawing Consent. Where we process certain personal information on the basis of your consent, you have the right to withdraw your consent.

In some situations, we may refuse to act or may impose limitations on your rights, as permitted by law. Before we can provide you with any information or correct any inaccuracies, we may ask you to verify your identity and/or provide other details to help us respond to your request. For the exercise of your rights, please contact us using the contact information provided below in the “How to Contact Us” section.

In all cases, you have a right to file a complaint with your local data protection authority if you believe that we have not complied with applicable data protection laws.

12. Do Not Track

The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

13. Translation

This Privacy Notice is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.

14. Changes to this Privacy Notice

We reserve the right to change our Privacy Notice from time to time. To the extent required by applicable law, we will not make changes that result in significant additional uses or disclosures of your personal information that we have collected prior to implementing such changes without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Notice that generally will not significantly affect our use of your personal information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Notice are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using our websites.

15. How to Contact Us

If you have any questions or comments about this Privacy Notice, please contact us:

We can be contacted directly via email at [email protected]

You may also write to us at:

Attn: Legal Department

Cynosure, LLC

5 Carlisle Road

Westford, MA 01886

16. Privacy Notice for California Residents

This Section 16 shall apply only to the extent that we are regulated as a business (as defined in the California Consumer Privacy Act of 2018 (collectively with any regulations promulgated thereunder, the “CCPA”)) under the CCPA. This Section 16 shall apply to you only if you are a California resident.

As used in this Section 16, “sell” (including any grammatically inflected forms thereof) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, CCPA information (as defined below) to another business or a third party for monetary or other valuable consideration. “Selling” does not include (i) disclosing CCPA information to a third party at your direction, provided the third party does not sell the CCPA information except in accordance with the CCPA, (ii) where you intentionally interact with a third party through the Service, provided the third party does not also sell the CCPA information, (iii) using or sharing your CCPA information with a service provider as necessary to perform business purposes, provided that such service provider provides its services on Cynosure’s behalf and provided that the service provider does not further collect, sell or use the CCPA information except as necessary to perform the business purpose, or (iv) transfers of your CCPA information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Cynosure, provided that information is used or shared consistently with the CCPA.

Where noted in this Privacy Policy, until the applicable date specified in the CCPA, the CCPA exempts CCPA information reflecting a written or verbal business-to-business communication (“B2B CCPA information”) from some its requirements, provided that such exemptions shall not apply from and after such date specified by the CCPA.

 

16.1 CCPA Information Collected: We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with particular California residents, devices or households (“CCPA information”). CCPA information does not include deidentified or aggregated information, publicly available information from government records, or any other information that is excepted from the definition of “personal information” under the CCPA, or any information that is otherwise not regulated by the CCPA. In particular, we have collected the following categories of CCPA information from California residents, households or devices within the last twelve (12) months:

Category California personal information collected Purposes (including business or commercial purposes) for which we collect or use California personal information Categories of third parties with whom we have shared California personal information and the business or commercial purpose for sharing such California personal information Categories of third parties to whom we have sold California personal information and the business or commercial purpose for selling such California personal information Categories of third parties to whom we have disclosed California personal information for a business purpose and the business or commercial purposes for disclosing California personal information Categories of sources from which California personal information is collected
A. Identifiers. Name, email address, username, password, physical address, zip code, telephone number, survey responses, and the content of any request or form you submit to us. If you make a purchase, we may also collect your payment details.

 

If you are a consumer: information about treatments you are considering or have previously received, the content of any reviews you submit, inquiries or responses to quizzes that you choose to submit to us, and, if you consent, before and after photographs and other information.

 

If you are a professional: location, other contact details, photograph, information included in your profile on RealSelf.com, job title, company name, practice and specialty, practice type, practice name and location, marketing package selected, the nature of your transaction with Cynosure, and (in connection with the purchase of Cynosure’s devices) company ownership information, trade references, website, billing/payment information (including credit card number and/or bank account information (including balance)), tax identification number (such as social security number), years in practice, financial statements, and (depending on your financing of your purchase) credit worthiness information (including a suggestion as to the maximum credit we should offer you).

Provision, improvement, and promotion of our websites, our products and services, and/or our Networking Activities. N/A If you are a professional (with respect to your business contact details, practice name and location, practice type, your job title, marketing package selected, and the nature of your transaction with Cynosure), to practice transformation plan partners, for the purposes of helping you market your services, including services that utilize Cynosure devices. Our group of companies (including Corporate Affiliates), distributors, service providers, analytics providers, professionals, third parties connected with business transactions, third parties in order to comply with a legal or regulatory obligation, practice transformation plan partners, and strategic partners (each as described in Section 6), for the purposes set out in column 3 of this table. Submitted to us by you.

Third parties, such as business partners, sub-contractors and analytics providers, search information providers, address update providers, distributors, co-promotion partners and credit reference agencies.

If you are a consumer and you consent, from professionals who performed your treatments.

If you are a professional, depending on your financing of a lease or purchase of Cynosure’s devices, third-party service providers who run credit worthiness checks.

B. Personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). If you make a purchase, we may collect your payment details.

 

If you are a professional: address, social security number, bank account information, credit card number, company, job title, practice, and specialty.

Provision, improvement, and promotion of our websites, our products and services, and/or our Networking Activities. N/A N/A Our group of companies (including Corporate Affiliates), distributors, service providers, analytics providers, professionals, third parties connected with business transactions, third parties in order to comply with a legal or regulatory obligation, practice transformation plan partners, and strategic partners (each as described in Section 6), for the purposes set out in column 3 of this table. Submitted to us by you.

Third parties, such as business partners, sub-contractors and analytics providers, search information providers, address update providers, distributors, co-promotion partners and credit reference agencies.

If you are a professional, depending on your financing of a lease or purchase of Cynosure’s devices, third-party service providers who run credit worthiness checks.

C. Protected classification characteristics under California or federal law. If you are a consumer, in connection with any inquiries you may submit to us: medical conditions (history of pregnancy/childbirth), gender, sex, and age. Provision of our products and services. N/A N/A Our group of companies (including Corporate Affiliates), distributors, service providers, third parties connected with business transactions, and third parties in order to comply with a legal or regulatory obligation (each as described in Section 6), for the purposes set out in column 3 of this table. Submitted to us by you.
D. Commercial information. If you are a professional: records of products or services purchased or leased (including marketing package selected), and the nature of your transaction with Cynosure. Provision, improvement, and promotion of our websites, our products and services, and/or our Networking Activities. N/A If you are a professional (with respect to the marketing package selected and the nature of your transaction with Cynosure), to practice transformation plan partners, for the purposes of helping you market your services, including services that utilize Cynosure devices. Our group of companies (including Corporate Affiliates), distributors, service providers, analytics providers, third parties connected with business transactions, practice transformation plan partners, third parties in order to comply with a legal or regulatory obligation, and strategic partners (each as described in Section 6), for the purposes set out in column 3 of this table. Submitted to us by you.

If you are a professional, depending on your financing of a lease or purchase of Cynosure’s devices, third-party service providers who run credit worthiness checks.

E. Biometric information. N/A N/A N/A N/A N/A N/A
F. Internet or other electronic network activity information. We may collect the following information from visitors to our websites:

• technical information, including your IP address, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times and download errors;

• information about your visit, including the websites you visit before and after our website and products you viewed or searched for; and

• length of visits to certain pages, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page.

Provision, improvement, and promotion of our websites, our products and services, and/or our Networking Activities. N/A N/A Our group of companies (including Corporate Affiliates), distributors, service providers, analytics providers, and strategic partners (each as described in Section 6), for the purposes set out in column 3 of this table. Submitted to us by you.

Collected when you use the website.

G. Geolocation data. N/A N/A N/A N/A N/A N/A
H. Audio, electronic, visual, thermal, olfactory, or similar information. N/A N/A N/A N/A N/A N/A
I. Professional or employment-related information. If you are a professional: job title, company name, practice and specialty, practice name and location, practice type, company ownership information, and trade references. Provision, improvement, and promotion of our websites and/or our products and services; facilitate participation in Networking Activities. N/A If you are a professional (with respect to your practice name and location, practice type, and your job title), to practice transformation plan partners, for the purposes of helping you market your services, including services that utilize Cynosure devices. Our group of companies (including Corporate Affiliates), distributors, service providers, analytics providers, third parties connected with business transactions, practice transformation plan partners, third parties in order to comply with a legal or regulatory obligation, and strategic partners (each as described in Section 6). Submitted to us by you.

Third parties, such as business partners, sub-contractors and analytics providers, search information providers, distributors, and co-promotion partners.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). N/A N/A N/A N/A N/A N/A
K. Inferences drawn from other personal information. In particular, we would like you to be aware that we may construct profiles about professionals and/or consumers and therefore we may use the personal data described above so that an evaluation can be made about preferences and interests (among other things). Provision, improvement, and promotion of our websites and/or our products and services. N/A N/A Our group of companies (including Corporate Affiliates), distributors, service providers, third parties connected with business transactions, and strategic partners (each as described in Section 6), for the purposes set out in column 3 of this table. Generated by us or by a third party on our behalf.

 

16.2     Purposes for Collection of California Personal Information; Categories of Sources: We collect California personal information for the business or commercial purposes described in the tables above and in the manner described in Sections 3 and 5 of this Privacy Notice with respect to personal information. Regarding the categories of sources from which California personal information is collected, we collect California personal information from the categories of sources described in the tables above and in the manner described in Sections 1, 2, and 3 of this Privacy Notice with respect to personal information.

16.3     Disclosures of California Personal Information for a Business or Commercial Purpose: Cynosure may disclose your California personal information described in the tables above to a third party for a business or commercial purpose, as described in the tables above and in Section 6 of this Privacy Notice with respect to personal information. In the preceding twelve (12) months, Cynosure has disclosed each of the categories of California personal information described in the tables above for a business or commercial purpose to the categories of third parties described in the tables above.

16.4     Sharing and Sales of California Personal Information:

16.4.1  Your California personal information (as described in the tables above) may be sold for the business or commercial purposes set forth in the tables above.

16.4.2  In the preceding twelve (12) months, Cynosure: (i) has not shared, nor does it or will it share, California personal information; and (ii) has sold the categories of California personal information as described in the tables above.

16.4.3  Cynosure does not have actual knowledge that it sells the California personal information of minors under the age of 16.

16.5     California Residents’ Rights and Choices: The CCPA provides California residents with specific rights regarding their California personal information. This Section 16.5 describes your CCPA rights (to the extent applicable to you) and explains how to exercise those rights.

16.5.1  Access to Specific Information and Data Portability Rights: You may have the right to request that Cynosure disclose certain information to you about our collection and use of your California personal information over the past twelve (12) months or such other period required by the CCPA. Once we receive and confirm your verifiable consumer request (in the manner described in Section 16.6 below), to the extent required by the CCPA, we will disclose to you:

16.5.1.1           The categories of California personal information we collected about you.

16.5.1.2           The categories of sources for the California personal information we collected about you.

16.5.1.3           Our business or commercial purpose for collecting or selling that California personal information.

 

16.5.1.4           The categories of third parties to whom we disclose that California personal information.

16.5.1.5           The specific pieces of California personal information we collected about you (also called a data portability request).

16.5.1.6           If we sold or disclosed your California personal information for a business or commercial purpose, two separate lists disclosing (i) sales, identifying the California personal information categories that each category of third party purchased; and (ii) disclosures for a business or commercial purpose, identifying the categories of recipients to whom such California personal information was disclosed and the California personal information categories that each category of recipient obtained.

We will not provide the foregoing access and data portability rights for B2B CCPA information prior to such date required by the CCPA.

16.5.2  Deletion Request Rights: You have the right to request that Cynosure delete any of your California personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable request from you or your authorized agent (in each case if you are a California resident) in the manner described in Section 16.6 below (“verifiable consumer request”), we will delete (and notify our service providers and/or contractors to delete and notify all third parties to whom we have sold the California personal information to delete, unless this proves impossible or involves disproportionate effort) your California personal information from our records, unless an exception applies or retention of your California personal information is otherwise permitted by the CCPA. We may deny your deletion request if retaining the information is reasonably necessary for us or our service provider(s) and/or contractor(s) to:

16.5.2.1           Complete the transaction for which we collected the California personal information, provide a product or service that you requested, take actions reasonably anticipated by you within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

16.5.2.2           Help to ensure security and integrity to the extent the use of your California personal information is reasonably necessary and proportionate for those purposes.

16.5.2.3           Debug to identify and repair errors that impair existing intended functionality.

16.5.2.4           Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.

16.5.2.5           Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

16.5.2.6           Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete the research, if you have provided informed consent.

16.5.2.7           Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.

16.5.2.8           Comply with a legal obligation.

16.5.3  Correction Request Rights: You have the right to request that we correct inaccurate California personal information about you that we maintain, taking into account the nature of the California personal information and the purposes of the processing of the California personal information. If we receive a verifiable consumer request from you to correct inaccurate California personal information, we will use commercially reasonable efforts to correct such inaccurate California personal information as directed by you, pursuant to Section 1798.130 of the CCPA and regulations adopted pursuant to the CCPA.

16.6     Exercising Access, Data Portability, Correction, and Deletion Rights:

16.6.1  To exercise the access, data portability, correction, and deletion rights described in Section 16.5 above, please submit a verifiable consumer request to us by either: (1) calling us at 800.886.2966; (2) visiting https://www.cynosure.com/; or (3) contacting us in accordance with Section 15. Only you, or someone legally authorized to act on your behalf (such as an authorized agent), may make a verifiable consumer request related to your California personal information. Someone legally authorized to act on your behalf (such as an authorized agent) may make a verifiable consumer request on your behalf, provided that you have duly authorized that person or entity to make such a verifiable consumer request on your behalf and provided that that person or entity can provide verification of their authority to make such a request on your behalf where required. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability no more than twice within a twelve (12) month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected California personal information or an authorized agent; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with California personal information if we cannot verify your identity or authority to make the request and confirm the California personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use California personal information provided for the purposes of verification of a consumer request to verify the requestor’s identity or authority to make the request. We use the following process to verify consumer requests: in the event you make a request under this Section 16, we may take various approaches to verify your identity depending on the nature of your request. These approaches may include initiating telephone calls with you or reaching out to by email or otherwise to ask you questions pertaining to the information we have about you. For instructions on exercising sale opt-out rights, see Section 16.7 below.

16.6.2  We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your California personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you of the reason for refusing the request.

16.7     Notice of Right to Opt-Out of Sale of California Personal Information:

16.7.1  If you are 16 years of age or older, you have the right to direct us to not sell your California personal information at any time (the “right to opt-out“). We do not sell the California personal information of California residents we actually know are less than 16 years of age. California residents who opt-in to California personal information sales may opt-out of future sales at any time.

16.7.2  To exercise the right to opt-out, you (or your authorized agent) may submit a request to us by visiting the following Internet Web page link:

Do Not Sell My Personal Information

            16.7.3  Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize California personal information sales. However, you may change your mind and opt back in to California personal information sales at any time by visiting the following Internet Web page link:

https://www.cynosure.com/ccpa-information-request/

16.7.4  You do not need to create an account with us to exercise your opt-out rights. We will only use California personal information provided in an opt-out request to review and comply with the request.

16.7.5  Someone legally authorized to act on your behalf (such as an authorized agent) may make a request on your behalf under this Section 16.7, provided that you have duly authorized that person or entity to make such request on your behalf and provided that that person or entity can provide verification of their authority to make such a request on your behalf where required.

16.7.6 For clarification, if you are a professional, certain of your personal information as described above, may made be available with your knowledge to practice transformation plan partners, for the purposes of helping you market your services, including services that utilize Cynosure devices.  We collect this personal information from you directly and not through any browser or device and the personal information we collect from you is not tied to your browser or device.  Accordingly, you would only be able to use an opt-out preference signal with respect to personal information that is tied to your browser or device, which Cynosure does not sell.  If you want to exercise the opt-out right, please follow the instructions above in Section 16.7.2 or contact us in accordance with Section 15.

16.8     Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights, including, unless permitted by the CCPA, by:

16.8.1  Denying you goods or services;

16.8.2  Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

16.8.3  Providing you a different level or quality of goods or services;

16.8.4  Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services; or

16.8.5  Retaliating against an employee, applicant for employment, or independent contractor, as defined in subparagraph (A) of paragraph (2) of subdivision (m) of Section 1798.145 of the CCPA for exercising their rights under the CCPA.

16.9     California Personal Information Retention. We will only retain your California personal information (including sensitive California personal information) for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law. To determine the appropriate retention period for California personal information, we consider the amount, nature, and sensitivity of that California personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your California personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

16.10   Contact. If you have any questions or concerns relating to this Privacy Notice and/or our California personal information practices, please contact us in accordance with Section 15.

16.11   Deidentified Data. To the extent required by applicable law, Cynosure hereby publicly commits to process Deidentified Data only in a de-identified fashion and not attempt to re-identify such Deidentified Data. “Deidentified Data” means data that cannot reasonably be used to infer information about, and that cannot reasonably be linked to, an identified individual or an identifiable individual, or to a device linked to such individual.

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