NOTICE TO LASERAWAY’S CALIFORNIA PERSONNEL

This California Personnel Privacy Notice (“Notice”) applies only to LaserAway (“LaserAway”, “our”, “us” or “we”) personnel that are residents of California (“California Personnel”). This Notice sets forth the disclosures and rights for California Personnel regarding their Personal Information, as required by the California Consumer Privacy Act of 2018, as amended from time to time including by the California Privacy Rights Act of 2020, and any implementing regulations adopted thereunder (collectively referred to as “CCPA”). Terms (including defined capitalized terms) used in this California Personnel Privacy Notice have the same meanings given in the CCPA, unless otherwise defined.

Scope of the Policy

The Notice covers “Personal Information,” and other information of LaserAway’s California Personnel that LaserAway collects in connection with your employment application and/or working relationship with LaserAway. When we refer to “Personal Information,” we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or is otherwise defined or regulated as personal information under California law. This includes information that directly identifies you (e.g., your name, social security number or other government-issued identifier), but also includes information that we have that is linked to you (e.g., your date of birth, telephone number, and information about your performance, all of which are linked to your name). Note that we may de-identify personal information so that it is non-personal, such as by aggregating it or converting it to a code (“hash”). We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification process satisfies legal requirements. We will treat de-identified information as non-personal to the fullest extent allowed by applicable law.

EXERCISING YOUR CALIFORNIA RIGHTS

California Personnel have the right to request: (1) that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you (“Right to Know“); (2) that we delete the Personal Information we collect from you (“Right to Delete“); and (3) that we correct inaccurate Personal Information we hold about you (“Right to Correct”), all subject to the meanings and exceptions set forth in the CCPA. More information on each of these rights is below.

Verifying Your Requests

When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. We may require you to log into your internal personnel account or provide your unique personnel ID. We may also need to ask you to provide us with additional information to verify your identity and fulfill your request. We will only use any such information to verify your identity. If we cannot verify your identity, we will not be able to process the request.

Authorized Agents

You may elect to use an agent to submit a request on your behalf. If you choose to do so, your agent must follow the instructions below to make the request. When your authorized agent submits a request on your behalf, we will request written permission signed by you and authorizing your agent to make the request on your behalf. The written permission must state your full legal name as the subject of the request, the full legal name of the individual who is acting as your agent, and must be clear about the scope of permission granted. Alternatively, your agent may, but is not required to, submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, your agent should also indicate in their email the nature of the request. Your identity, in addition to your agent’s identity and authorization, will need to be independently verified in order for us to be able to fulfill the request. We may also ask you to directly confirm with us that you provided your agent permission to submit a request. Please keep in mind that if we do not receive adequate proof that your agent is authorized to act on your behalf, we will deny the request.

Right to Know

To exercise your Right to Know, please submit your request by completing this form or by calling us at 1-855-204-2924.

After your employment application or working relationship with LaserAway ends, you can continue to exercise your Right to Know by calling us at 1-855-204-2924 or by completing this form.

In order to have us provide specific pieces of information, we may require a signed declaration under penalty of perjury that you are the California Personnel whose Personal Information is the subject of the request. We will not provide you specific pieces of information that include the Personal Information of other persons, nor will we disclose certain pieces of information that the law requires us not to or that we determine is a high security risk, including your social security number, driver’s license number, financial account number, health insurance or medical information number, immigration or citizenship status, account passwords, security questions and answers, or unique biometric data, as applicable.

Right to Delete

To exercise your Right to Delete, please submit your request by completing this form or by calling us at 1-855-204-2924.

After your employment application or working relationship with LaserAway ends, you can continue to exercise your Right to Delete by calling us at 1-855-204-2924 or by completing this form.

Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted.

Right to Correct Inaccurate Information

If you would like to exercise your Right to Correct, please submit your request by completing this form or by calling us at 1-855-204-2924.

After your employment application or working relationship with LaserAway ends, you can continue to exercise your Right to Correct by calling us at 1-855-204-2924 or by completing this form.

Right to Limit the Use and Disclosure of Sensitive Personal Information

As disclosed in the chart below, we may collect certain information in connection with your working relationship with us that is considered Sensitive Personal Information under California law. Under the CCPA, a business must only provide the Right to Limit The Use and Disclosure of Sensitive Personal Information when sensitive personal information is collected or processed for the purpose of inferring characteristics about a consumer, or use of such sensitive personal information does not fall under certain statutory exceptions pursuant to California Civil Code § 1798.121. LaserAway’s use and disclosure of its personnel’s Sensitive Personal Information is not used for such purposes and/or falls within this list of exceptions and we therefore do not offer such opt-out right at this time.

Do Not Sell or Share

LaserAway does not sell, or share for cross-context behavioral advertising, the Personal Information or Sensitive Personal Information of its personnel.

Data Retention

LaserAway will retain your Personal Information for as long as your working relationship with us lasts, and for a certain period after your working relationship with us has ended; but we will not retain or store Personal Information for longer than is reasonably necessary to fulfill the purposes (as described in this California Privacy Notice) for which it was collected or that you authorized after collection, or as otherwise required by law. In determining how long we retain your Personal Information, we take into account our legal and regulatory obligations (such as legal requirements to retain your information, financial reporting obligations, and equal opportunity or anti-discrimination reporting obligations), the nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, and whether we may need to retain the Personal Information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes and/or enforce our agreements.

Security of Your Personal Information

We have adopted commercially reasonable security procedures and practices designed to protect your Personal Information in our possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction. Access to our systems that store your Personal Information is restricted, including by means of a user ID and password that are issued only to authorized personnel. You are also responsible for preventing unauthorized access to your Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have accessed your account.

Personnel Younger than 18

We do not knowingly sell, or share for cross-contextual behavioral advertising, Personal Information of employees or other personnel younger than 18 years of age.

Right to Non-Discrimination for the Exercise of Your Privacy Rights

California Personnel have the right to not receive discriminatory treatment for exercising their CCPA rights. We will not discriminate or retaliate against you for exercising your CCPA rights

Changes to this Policy

To the extent allowed by applicable law, we reserve the right to change this Notice at any time without prior notice. If we make material changes to our privacy policy, we will update the effective date and post a notice to our online website and applicant portals where this policy is displayed. We may also provide notice to you in other ways, such as through contact information you have provided, and provide you with the ability to opt-in or opt-out of the changes as required by law.

Changes to this Policy

To the extent allowed by applicable law, we reserve the right to change this Notice at any time without prior notice. If we make material changes to our privacy policy, we will update the effective date and post a notice to our online website and applicant portals where this policy is displayed. We may also provide notice to you in other ways, such as through contact information you have provided, and provide you with the ability to opt-in or opt-out of the changes as required by law.

PERSONAL INFORMATION WE COLLECT

The Personal Information we collect about you will depend upon your working relationship with us, the nature of your specific role with LaserAway, or how you otherwise interact with us. Accordingly, we may not collect all of the below information about you.

In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA.