Last Updated: August 1, 2020

This Privacy Policy applies to the websites, mobile applications and other online products and services provided with the Aesthetic One Physician Application (collectively, the “Services”) and when you otherwise interact with us. This Privacy Policy explains how information is collected, used and disclosed by AnzuBridge L.L.C. and its affiliates (“AnzuBridge”) in connection with the Services. To the extent that we collect, use, and disclose Protected Health Information (“PHI”) as defined and governed by the Health Insurance Portability and Accountability Act and the Health Information Technology for Economic and Clinical Health Act, the Business Associate Agreement between you and AnzuBridge applies.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage and app or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

Collection of Information

Information You Provide to Us. We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Services, including when you create and update your Physician Procedure Profile, provide information about procedures, and upload information about implants. We also collect information when you fill out a form, request customer support or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, phone number, information about your medical practice, your patients’ PHI, your patients’ responses to surveys, and any other information you choose to provide.

Information We Collect

We collect information about your procedures and notes directly from your files and records, including information stored electronically on your network or server, such as:

  • Patient health data, including pre-operation, operation, and post operation data; responses to patient intake forms; and information from breast implant registration cards;
  • Patient schedules; and
  • Patient name, email address, postal address, phone number, date of birth

Information We Collect Automatically When You Use the Services. When you access or use our Services, we automatically collect information about you, including:

  • Log Information: We collect log information about your use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
  • Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and personalize your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see “Your Choices” below.
  • Location Information: In accordance with your device permissions, we may collect information about the location of your device. For more details, please see “Your Choices” below.
  • Transaction Information: We maintain records of each transaction or interaction with the Services together with a time stamp.

Information We Collect Through the Aesthetic Neural Network Application (“ANN”)

Through the ANN Application, we collect information about your sales and business operations directly from your files and records, including information stored electronically on your network or server, such as:

  • Procedures Sold: We collect information about the names and numbers of procedures performed at your business.
  • Costs of Procedures Sold: We collect information about the prices charged for the procedures performed at your business.
  • Conversion Rates: We collect information about the number of times an individual interacts with your business before purchasing a procedure or product from you.
  • Retail Sales: We collect information about products purchased at your business.
  • Business Type: We collect information about the type of business that you are, such as whether you operate as medical spa or other medical practice.
  • Staff Statistics: We collect information about the medical training your staff have undergone. For example, we may collect information about how many doctors and nurses are employed by your business, and the procedures they perform and the gross charges they generate for the business.

Use of Information

We may use the information we collect for various purposes, including to:

  • Provide, maintain and improve our Services;
  • Provide and deliver the Services you request;
  • Send you technical notices, updates, security alerts and support and administrative messages;
  • Respond to your comments, questions and requests and provide customer service;
  • Conduct product studies;
  • Combine information we collect from our Services for the purposes described in this Privacy Policy;
  • Communicate with you about products, services, offers, and events offered by AnzuBridge and others, and provide news and information we think will be of interest to you;
  • Monitor and analyze trends, usage and activities in connection with our Services;
  • Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of AnzuBridge and others;
  • Personalize and improve the Services and provide content or features that match user profiles or interests;
  • Link or combine with information we get from others to help understand your needs and provide you with better service;
  • Comply with our legal obligations; and
  • Carry out any other purpose for which the information was collected.

Sharing of Information

We may share information about you and your patients as follows or as otherwise described in this Privacy Policy:

  • With the Aesthetic Society;
  • With the Anaplastic Large-Cell Lymphoma (ALCL) registry;
  • With the Aesthetic Surgery Education and Research Foundation (ASERF);
  • With the US Food and Drug Administration (FDA);
  • With manufacturers for the purpose of providing information about the patient and their implants such as reference number, serial number, and other uses as described in their privacy policies;
  • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
  • If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of AnzuBridge or others;
  • In connection with, or during negotiations of, any merger, sale of AnzuBridge assets, financing or acquisition of all or a portion of our business by another AnzuBridge;
  • Between and among AnzuBridge and its current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
  • With your consent or at your direction

We may also share and sell aggregated or de-identified information, which cannot reasonably be used to identify you or your patients.

Advertising and Analytics Services Provided by Others
We may allow others to provide analytics services regarding user activity on our Services. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by AnzuBridge and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

Security

AnzuBridge takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Transfer of Information to the U.S. and Other Countries

AnzuBridge is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing, transfer and storage of information in and to the U.S. and other countries, where you may not have the same rights and protections as you do under your local law.

Your Choices

Account Information. You may update, correct or delete information about you at any time by emailing us at AOinformation@anzubridge.com. If you wish to deactivate your account, please email us at AOinformation@anzubridge.com, but note that we may retain certain information as required by law or for business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or
reject cookies, this could affect the availability and functionality of our Services. To learn more about cookies and your cookie choices, please visit www.aboutads.info/choices.

Location Information. When you first launch our mobile application, you will be asked to consent to the application’s collection of this information. If you initially consent to our collection of location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. You may also stop our collection of location information by following the standard uninstall process to remove our mobile application from your device.

Your California Privacy Rights. California law permits residents of California to request certain details about how their information is shared with third parties for those third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at PrivacyOfficer@anzubridge.com.

Contact Us
If you have any questions about this Privacy Policy, please contact us at: PrivacyOfficer@anzubridge.com.