Candesant Privacy Policy

Last updated: August 15, 2023

Candesant Biomedical Inc. and its affiliates (“Candesant”) respects your privacy. This privacy policy explains what personal information we collect, the uses of the information, who we disclose information to, and your privacy rights, when you access or use our websites www.mybrella.com and www.candesant.com and other websites we own which incorporate this privacy policy, or when you otherwise interact with us online and offline. If you have any questions or comments, please see the contact details under “How to Contact Us” below.

California, Virginia, Colorado, Connecticut and Utah Users

We are currently not subject to (a) California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020; (b) Virginia’s Consumer Data Protection Act; (c) the Colorado Privacy Act; (d) Connecticut’s Act Concerning Data Privacy and Online Monitoring; or (e) when effective, the Utah Consumer Privacy Act. As a result, the additional rights of users under those state laws do not apply to our business at this time.

Individuals Must Be at Least 18

If you are under 18, do not access our website or provide us any information about you. We delete information of people under 18 when we learn that we have collected personal information from them. Please contact us at privacy@candesant.com if you believe that we have information about a person under 18.

Individuals Must Be in the United States

Our website and product are intended for individuals located in the United States only. We do not target individuals outside the United States. You are not authorized to access our website or inquire about our product if you are located outside the United States. 

International Data Transfers

We are based in the United States and any personal information we collect will be stored and processed in the United States. If you are located outside the United States and you access our website and inquire about our product even though our product is only offered to individuals in the United States, you understand that your personal information will be transferred to, stored, and processed in the United States and other countries where we and our service providers operate. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective. This serves as notification to you of the cross-border transfer of data. 

Your consent to this privacy policy represents your consent to such transfer, storage, and processing outside of your country of residence, which countries may have different data protection rules than those of your country of residence.

Special Note to Patients

If you are a patient, please note that this privacy policy is distinct from your healthcare provider’s HIPAA Notice of Privacy Practices, which describes how your healthcare provider uses and discloses individually identifiable health information about you that it collects, as well as any other privacy practices it applies.

What Personal Information Does Candesant Collect?

We collect information from:

  • patients who are interested in our product,
  • providers who are interested in offering our product to their patients (including doctors, nurse practitioners, nurses, medical assistants, and other professionals working in medical offices, clinics and spas), and 
  • other individuals who visit our website or otherwise provide us with their information. 

Patient Information

We collect the following categories of information about patients who are interested in using our product:  

  • Identifiers: first and last name, 
  • Device identifiers and information: IP address, cookie IDs, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), and usage information about your devices, 
  • Contact information: email and phone number,
  • Health information: your interest in using our product and getting information about a provider who offers our product,
  • Location information: your precise geolocation with your consent (for example, when you request to see if we have providers in your area),
  • Other information: any other information you elect to share with us, including testimonials if you authorized us to use your testimonials.

Provider Information

We collect information from providers who are interested in offering our product to their patients. We collect the following categories of information from providers:

  • Identifiers: first and last name, 
  • Device identifiers and information: IP address, cookie IDs, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), and usage information about your devices, 
  • Contact information: email, physical address, and phone number,
  • Registration information: username and password if you have access to our ecommerce web pages,
  • Professional information: information about your practice, specialty, registration number or license, education, experience and professional affiliations, 
  • Financial information: credit card information to enable purchases of our product
  • Transactional information: information related to your purchases of our product
  • Recordings: audio or visual recordings of meetings with your consent, 
  • Location information: the location of your office where you provider your services to patients, 
  • Interaction information: any information about our interactions, for example, communications we may have regarding getting you approved as a provider in our system, and
  • Other information: any other information you elect to share with us, including your interest in offering our product to your patients, your feedback on the product, and testimonials if you authorized us to use your testimonials.

Other Individuals

We collect information from other individuals who come to our websites or otherwise share their information with us offline. We collect the following categories of information from individuals who are not patients or providers:

  • Identifiers: first and last name if provided by the individual,
  • Device identifiers and information: IP address, cookie IDs, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), and usage information about your devices, 
  • Contact information: email, phone number, and address if provided by the individual,
  • Job applicants: job applicant information, and
  • Other information: any other information you elect to share with us.
Sensitive Information

We ask that you not provide us any sensitive information about yourself or anyone else. For example, if you are a patient and request information about our product on our website or via email or over the phone, we ask that you not share any health or medical information about yourself or anyone else. 

What Are the Sources of Personal Information That Candesant Collects?

We obtain the categories of personal information above from the following categories of sources:

  • directly from you, for example, when you fill out a form on our website or our social media pages,
  • from your interactions with us online and offline (e.g., via phone, email, in person),  
  • from your interactions with our advertisements,
  • from your public interactions on social media sites,
  • from the use of cookies and similar tracking technologies on our website (see more on this below),
  • from publicly available sources, and
  • from your location.

When you access our website, interact with our advertisements, or interact with our social media pages, we may collect certain information automatically from your browser, IP address, or cookie. See Cookies and Similar Technologies below. This automatically collected information may include cookie identifiers, IP address, device information, browser information, and browsing information.

How Does Candesant Use Your Personal Information?

We may use your information for these purposes:

  • Responding to requests and providing our website. We use your information to provide to you the information you requested. We will use your email address for non-marketing or administrative purposes such as notifying you (as a patient) when our product is available in your geographic location, communicating with you (as a provider) regarding setting you up as one of our providers, notifying you of updates to our website, responding to your requests, and sending you other types of notices. 
  • Facilitating our relationships with businesses. We use patient and provider information to facilitate our relationships with other businesses who help us offer our product for sale. We also use patient information to help identify geographic locations that are interested in our product, which we use to identify existing or prospective providers. 
  • Improving our services. We may use the information that we collect from our patients and providers to understand trends and preferences, to improve the way we offer our product, to improve our marketing and promotional efforts, and to create new features and functionality on our website.  
  • Customizing your experience. We may use your information to remember you when you return to our website (for example, with cookies). If you are a provider accessing our ecommerce page, we may remember you when you return to that page so that you will not have to re-enter your login information. We may also use your information to provide you with custom, personalized advertisements, content and information through the use of cookies. We may also use the location information that you provide or that we collect from your IP address (as a patient), to show you providers that offer our product. 
  • Analyzing the services and website. We may use your information to: (a) monitor aggregate usage metrics such as total number of visitors and number and type of pages viewed, (b) track conversion of visitors into patients or providers who filled out information forms on our website, (c) perform fraud monitoring and prevention and security, and (d) determining the effectiveness of our website and services.
  • Marketing the service. Where permitted by applicable law, we may use your email address or other personal contact information to send you promotional or marketing messages relating to the product, which you will have the ability to opt-out of.  We use your information to monitor the effectiveness of these promotional and marketing campaigns.
  • Third party uses. We may partner with certain third parties to collect other information to engage in analysis, research, and reporting of website usage patterns. While we endeavor to limit their activities to those of a service provider (e.g., selecting restricted or limited data processing) these third parties may still deliver advertising to you on other websites and applications, based on your activity on our website and other websites over time. These third parties may set and access cookies on your computer or other devices and may also use web logs or web beacons. See “Cookies and Similar Technologies” and see “Opting Out” to opt out of interest-based advertising by third parties from cookies.
  • Job applicants. If you apply for a job at Candesant, we will use the information you provide for purposes of processing your application.
  • Evaluating a combination or financing. We may use your information as part of evaluating a merger, acquisition, debt financing, or sale of our assets, as well as in the event of an insolvency, bankruptcy or receivership.
  • Combining information. We may combine information from the website that is linked or reasonably linked to a particular computer or device with personal information. If we combine such information with personal information, the combined information will be treated by us as personal information as long as it is combined.
  • General and legal uses. We may use your information if we believe it is appropriate or necessary: (a) to protect our rights, privacy, safety or property, and that of you and others; (b) to prevent or stop activity we may consider to be, or is at risk of being, illegal, unethical or legally actionable activity; (c) to protect our operations and the security of our product, website and services; (d) under applicable law (including laws applicable to medical devices); (e) to comply with legal process and our legal obligations; (f) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements and requests from the Food and Drug Administration) and private parties; (g) to enforce our terms and conditions; and (h) to allow us to pursue available remedies or limit the damages that we may sustain.
  • With consent. We may use your personal information in other ways with your consent or at your direction.
  • As disclosed. We may use your personal information as described to you when collecting your personal information.
  • Compatible uses. We may also use your personal information for other purposes (when permitted by applicable law) that are compatible with the purposes we have disclosed to you. 

Patient Personal Information

We may use patient personal information for the following additional purposes:

  • Reporting information to regulatory authorities, 
  • Assessing the safety of our product,
  • Carrying out ongoing research and development activities,
  • Disclosing product quality issues, and
  • Responding to product complaints.

Provider Personal Information

We may use provider personal information for the following additional purposes: 

  • Enhancing your knowledge of our product,
  • Managing our relationship with you, including validating your qualifications, managing potential contacts and visits, providing you with materials for our product, and selling our product to you,
  • Managing our interaction with you in relation to an agreement under which our product and related documentation and material will be provided to you, including performing our obligations and exercising our rights under such agreement,
  • Managing any requests you may submit to us regarding the product and samples of the product,
  • Recording and managing adverse events or product quality issues that may be reported by you for our product, and
  • Conducting surveys and market research to understand your insights and views on our product.
How Does Candesant Maintain the Security of Your Personal Information?

We maintain reasonable security, administrative, and technical procedures and practices appropriate to the nature of the personal information, to protect the personal information from unauthorized or illegal access, destruction, use, modification, or disclosure and to protect the confidentiality, integrity, and accessibility of personal information.

How Long Does Candesant Retain Your Personal Information?

We will retain your personal information only for the period reasonably necessary to fulfill the purposes outlined in this privacy policy or until an individual requests deletion in accordance with applicable law and this privacy policy, unless a longer retention period is required by law. 

When determining how long we retain your information, we consider the nature, sensitivity, and amount of the personal information, the potential risk of harm from unauthorized disclosure or use, and our legal, regulatory, tax, accounting and other obligations (including data retention laws relating to medical devices).

Who Does Candesant Disclose Your Personal Information To?
  • Affiliated companies. We may disclose information to our affiliated companies (e.g., subsidiaries).
  • Service providers. We may disclose information to our service providers who process personal information on behalf of Candesant. Our service providers perform the following categories of activities for us: 
    • Cloud hosting services
    • Internal and external communication services
    • Document storage services
    • Credit card and payment processing services (provider information only)
    • Marketing and sales services
    • Website analytics services
    • Social media services
    • Job recruiting services
  • Consultants. We may disclose information to our consultants who provide advisory services.
  • Governmental authorities. We may disclose information to governmental, regulatory, judiciary, enforcement and similar authorities as required by law. 
  • Acquirors and investors. We may disclose information to potential acquirors and investors. 
  • The public by you. If we approve you as a provider of our product, your information will be publicly available on our website as a provider of our product. If you are a patient and share information about yourself on public pages of our website, that information will be publicly available to anyone who accesses our website.
Cookies and Similar Technologies

We use cookies or other similar technologies on our website, in online advertisements and on our social media pages. A cookie is a small data file that is stored on your computer’s memory. Cookies act as unique tags that identify your device or browser.  Some cookies help you navigate our website, including setting a cookie to remember your login details when you log in to our ecommerce web page as a provider. Cookies also collect information about how you use our website, which allows us to monitor website performance and identify ways to make the website easier to use and more effective. 

Third parties (for example, Google Analytics and Google Tag Manager) may use cookies or similar technologies on visitors of our website to provide us with analytical information regarding the website and information regarding website traffic and page views. We attempt to restrict the activities of all of these service providers by selecting restricted or limited data processing so that these companies cannot send targeted advertising to you when you visit other websites. The collection of information through cookies or similar technologies by such third parties is governed by such third parties’ own privacy policies, which Candesant does not control. For Google Analytics, we have disabled sharing with Google products and services, and for Google Tag Manager, it already currently operates with restricted processing. Because of this disabling and restricted processing, Google may only use your information as our service provider.

For more information about cookies, including how to see what cookies have been set on your device and how to delete them, visit www.allaboutcookies.org.  

To read about how to manage your cookie preferences (including information about our Cookie settings solution on our website, which allows you to decline cookies), see Opting Out below.

Some internet browsers allow you to limit or disable the use of tracking technologies that collect unidentified information, such as a “Do Not Track” (“DNT”) setting. Currently, Candesant does not respond to DNT signals received from your web browser.

Opting Out

Opting Out of Marketing from Candesant

You may opt-out from receiving electronic marketing communications from us (or opt in, if required by applicable law). If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing related emails by contacting us at unsubscribe@candesant.com or by clicking on the opt-out link within the email message that you receive from us.

Please also note that if you do opt-out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to the website from time to time.

Opting Out of Candesant’s Cookies Generally

In addition to declining cookies through our cookie settings (see above), you may also disable cookies, including all of our cookies, by modifying the settings in your browser. However, please note that certain features of the website may not work if you delete or disable cookies. Also, if you delete all cookies after previously declining cookies (see above) or opting out of third parties’ interest-based advertising cookies (see below), you will need to renew your preference to “decline” cookies and your opt-out choice with respect to interest-based advertising because opt-outs are usually managed by cookies, meaning that a cookie is needed to honor your decision to decline cookies.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

Opting Out of Interest-Based Advertising by Candesant from Our Website

If Candesant begins to use its own retargeted cookies, you will be able to opt out of receiving interest-based advertising (including retargeting) from our website through the use of cookies by selecting “decline” within the Cookie Settings located in the bottom footer of our website. 

Opting Out of Interest-Based Advertising by Third Parties from Cookies

If Candesant begins to allow third parties to use retargeting cookies, you will be able to opt out either directly on their website or through an industry-developed web page. The following web pages provide information on how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services, devices, and applications for interest-based advertising purposes:

www.aboutads.info/choices
http://optout.aboutads.info/ 

When you opt out of receiving interest-based advertising from third parties, note that the opt out only applies to the applicable browser in which you set it.

Note also that most opt-out tools are cookie-based. This means that, if you have cookies blocked, you will not be able to use the opt-out tool. If you delete cookies entirely, then you will need to opt out from interest-based advertising again.

Once the opt-out has been completed, you will still receive advertisements on properties that you visit, but such advertisements will not be interest-based ads targeted by the third parties whose cookies you opted out of.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

Opting Out of Use of Precise Location

To disable the collection of precise location information from your device, you can access your device settings and choose to limit that collection.

User Rights

You may send us an email at privacy@candesant.com to request access to, correct or delete any personal information that we have on you. See your additional opt out rights above.

Updates to This Privacy Policy

We may update this privacy policy from time to time in response to changing legal, technical or business developments. When we update our privacy policy, we will take appropriate measures to inform you, consistently with the significance of the changes we make. We may also obtain your consent when required by law. 

Candesant recommends that you review this privacy policy regularly for any changes. You can see when this privacy policy was last updated by checking the “last updated” date displayed at the beginning of this Notice.

How to Contact Us

If you want to exercise any of your data protection rights, please email us at privacy@candesant.com.  

If you have any questions or concerns about our use of your personal data, you can always contact us at the email address above or at this address: 1718 Church Street #1458, Nashville, TN 37203, USA.

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