LAST UPDATED: November 15, 2017
HIPAA Privacy Notice
- Pure Touch Skin Center’s uses and disclosures of Protected Health Information (“PHI”);
- your privacy rights with respect to your PHI;
- Pure Touch Skin Center’s duties with respect to your PHI;
- your right to file a complaint with Pure Touch Skin Center and/or the Secretary of the U.S. Department of Health and Human Services; and
- the person or office to contact for further information about Pure Touch Skin Center’s privacy practices.
Your California Privacy Rights
If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third-parties, what categories of personal information we have shared with third-parties in the preceding year, as well as the names and addresses of those third-parties, please e-mail us at: email@example.com; or call us at: (818) 986-1077.
Personal Information that We Collect
In connection with completing the App download and/or Site registration process, and in connection with your use of certain of the Pure Touch Skin Center Offerings, Pure Touch Skin Center will collect your: (a) full name; (b) e-mail address; (c) billing/mailing address; (d) telephone number; (e) credit card information (where you wish to purchase Products); (f) what treatments you are interested in; (g) what days and times you prefer for treatments; (h) when you prefer to be contacted; (i) any additional comments that you wish to make; and/or (j) any other information requested on the applicable form.
How We Use Personal Information
The following provisions govern our use of your personal information that is not considered PHI. For more information about Pure Touch Skin Center’s treatment of PHI, please see the Privacy Notice attached hereto.
Pure Touch Skin Center will never share, sell, rent, exchange or barter your personal information to or with any third party for financial gain or marketing purposes. By making that personal information available to Pure Touch Skin Center, you grant Pure Touch Skin Center the right, subject to applicable state and federal law, to use that personal information to send you various marketing messages that contain certain promotional offers from Pure Touch Skin Center, and its third party partners, that Pure Touch Skin Center believes may be of interest to you. If you wish to stop receiving future communications from us, please follow the instructions at the end of each such marketing message, or see the Opt-Out/Unsubscribe section below.
We will also use your personal information for customer service, to provide you with information that you may request, to customize your experience with the Pure Touch Skin Center Offerings and/or to contact you when necessary in connection with your use of the Pure Touch Skin Center Offerings.
You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Pure Touch Skin Center Offerings, and to keep you informed of our other products and services. We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Pure Touch Skin Center Offerings. We may also combine the information we have gathered about you with information from other sources.
We may also employ other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from User lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our Users’ personal information as needed to perform these functions for us, but we do not permit them to use User personal information for other purposes.
Credit Card Transactions
Social Media Websites
If you engage in any interaction with Pure Touch Skin Center or any third party on any Social Media Pages, you should be aware that: (a) the personal information that you submit by and through such Social Media Pages can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where Pure Touch Skin Center responds to any interaction on such Social Media Pages, your account name/handle may be viewable by any and all members of Pure Touch Skin Center’ social media presence.
We are not responsible for the personal information that you choose to submit on any Social Media Websites. The Social Media Websites operate independently from Pure Touch Skin Center, and we are not responsible for such Social Media Websites’ interfaces or privacy or security practices. We encourage you to review the privacy policies and settings of the Social Media Websites with which you interact to help you understand those Social Media Websites’ privacy practices. If you have questions about the security and privacy settings of any Social Media Websites that you use, please refer to their applicable privacy notices or policies.
Non-Personally Identifiable Information
Mobile Device, Geolocation and App Usage Information
We may collect certain non-personally identifiable information about you and your mobile device (“Mobile Device”) when you access the App and/or visit certain App pages. This non-personally identifiable information includes, without limitation, the following information pertaining to your Mobile Device and your use of the App: Mobile Device platform type; Mobile Device identifier; SDK version; API key (identifier for the App); App version; iOS Identifier for Advertising (if applicable); iOS Identifier for Vendors (if applicable); Media Access Control (MAC) address; International Mobile Equipment Identity (IMEI); the model type, manufacture and iOS version and/or Android version of the Mobile Device; your App session start/stop time and date; and the actions taken while utilizing the App. We use the non-personally identifiable information identified in this paragraph to improve the design and content of the Pure Touch Skin Center Offerings and to enable us to personalize your App experience. We also may use this information in the aggregate to analyze Pure Touch Skin Center Offerings usage, and to alter existing Pure Touch Skin Center Offerings, or develop new or different Pure Touch Skin Center Offerings.
Pure Touch Skin Center does not use geolocation technology to track App Users’ locations.
IP Addresses/Browser Type, Cookies and Action Tags
IP Addresses/Browser Type: We may collect certain non-personally identifiable information about you and your desktop computer and/or mobile device when you visit many of the pages of the Site and/or App, as applicable. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Pure Touch Skin Center Offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze usage of the Pure Touch Skin Center Offerings.
Action Tags, Web Beacons and other Data Collection Methods: An action tag or a web-beacon (also known as a clear gif or a pixel tag) is a method used to track responses or actions by visitors who view certain advertisements and/or other information on the Site and/or App, as applicable. Action tags are 1×1 pixel images embedded in a website page that are used to transparently collect information. We may use action tags to count the number of times that visitors click on a particular banner ad or visit the pages of the Site and/or App, as applicable, and to provide information about what products/services are viewed or purchased. We reserve the right to retain this action tag data indefinitely.
The Pure Touch Skin Center Offerings may contain links to other third-party owned and/or operated websites including, but not limited to, the Social Media Websites. Pure Touch Skin Center is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of their third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Pure Touch Skin Center has no responsibility or liability relating to them.
We endeavor to safeguard and protect our Users’ personal information. When Users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where our registration/application process prompts Users to enter Sensitive Information and/or PHI, and when we store and transmit such Sensitive Information and PHI, that information is encrypted with advanced TLS (Transport Layer Security).
Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. All of our Users’ personal information is restricted in our offices, as well as the offices of our third party service providers. Only employees or third party agents who need the personal information to perform a specific job are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all User personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control.
Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site, App, other Pure Touch Skin Center Offerings or otherwise via the Internet or wireless network, is done at your own risk.
In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
No information should be submitted to, or posted by and through, the Site and/or App by visitors under eighteen (18) years of age (or the applicable age of majority, if greater than eighteen (18) years of age). Persons eighteen (18) years of age (or the applicable age of majority, if greater than eighteen (18) years of age) are not permitted to access the Pure Touch Skin Center Offerings and we do not knowingly collect personal information from such individuals. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
Removal, Amending and/or Updating Your Information
At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by contacting us via e-mail at: firstname.lastname@example.org; provided, however, that we ask individuals to identify themselves and the information requested to be accessed, amended or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
Please be advised that deleting your personal information may terminate or limit your ability to participate in the Promotions. If you wish to participate in the Promotions without any hindrance or limitation, you may not be able to delete all of the personal information that we have on file for you.
Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
To opt-out of receiving e-mail communications from us, you can follow the instructions at the end of the applicable e-mail message or e-mail us at: email@example.com
Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Pure Touch Skin Center Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Pure Touch Skin Center Offerings-related and/or inquiry response-related messages from Pure Touch Skin Center, you must cease requesting and/or utilizing the Pure Touch Skin Center Offerings and/or cease submitting inquiries to Pure Touch Skin Center, as applicable.
Transfer of Personal Information Internationally
Filing a Complaint with the Federal Trade Commission
To file a complaint regarding our privacy practices, please visit