Venus Concept Privacy Policy

Venus Concept and its affiliated entities (listed in the "Venus Concept entities" section below) (together "Venus Concept", "we", "our", or "us") are committed to respecting your privacy.

This Privacy Policy sets out how we collect, store, process, transfer, share, and use your personal data, and which rights and options you may have in this respect. Please also refer to our Cookie Policy which explains the use of cookies and other web tracking devices via our websites.

We collect data about users of our websites, mobile sites, applications (collectively, “Online Services”); about individuals who attend events organized or hosted by us; about our clients or prospective clients (where these are natural persons) or their employees, agents, and/or representatives; and about others who express an interest in us or with whom we carry on business (and these individuals about whom we collect data are referred to as "you" and "your" in this Privacy Policy).

More details are below under How we collect your personal data.

1. Who is responsible for your personal data?

For the purposes of the General Data Protection Regulation (EU) 2016/679 (the "GDPR"), the controller for the personal data you provide or that we collect is Venus Concept (of Toronto, Canada).

2. Are you required to provide your personal data?

You do not have to give us any personal data in order to use most of our Online Services, and in most instances you will provide us with your personal data voluntarily. However, there are circumstances in which we may not be able to assist you, or an organization with which you are associated, unless you provide us with your personal data. For example, your personal data may be required for us to deliver certain products, to carry out training related to those products, for security and other reasons to allow you to access one of our events or premises. In these cases, without the relevant personal data, we may be unable to assist you or your organization, and we would inform you or your organization that this is the case. We also may collect some personal data about you automatically – further details are below.

3. Which personal data do we collect?

When you use our Online Services or when we interact with you, the personal data we collect may include:

• Contact information, such as your name, job title, postal address (including your home address, where you have provided it to us), business name, business address, telephone number, mobile phone number, fax number, and email address
• Profile and usage data, including passwords to our websites or password-protected platforms or services; your preferences in receiving marketing information from us; your communication preferences; and information about how you use our Online Services, including the products or services you viewed. To learn more about our use of cookies or similar technology, please check our Cookies Policy
• Physical access data, relating to details of your visits to our premises
• If you connect to us from a social network, such as LinkedIn or Facebook, we will collect personal data from the social network in accordance with your privacy settings on that social network. The connected social network may provide us with information such as your name, profile picture, network, gender, username, user ID, age or age range, language, country, friends list, follower list, job title, and any other information you have agreed it can share or that the social network provides to us
• Special categories of personal data. In connection with the registration for and provision of access to an event or seminar, we may ask for information about your health for the purpose of identifying and being considerate of any disabilities or special dietary requirements you may have. Any use of such information is based on your consent

For us to provide our products or services, we may collect:

• Contact information, such as your name, job title, postal address (including your home address, where you have provided it to us), business name, business address, telephone number, mobile phone number, and email address
• Payment data, such as data necessary for processing payments and fraud prevention, and other related billing information
• To connect you with a physician, we may ask you for your preferred contact time, mode of being contacted, and gender
• Other personal data regarding your preferences, opinions, and comments where it is relevant to our services
• Information provided by you to undergo training of our products or services, which may include health-related information if you undergo a procedure on one of our products as a part of the training

For our recruitment:

Venus Concept’s Careers site allows you to submit your personal data and resume in order to apply for specific positions at Venus Concept and our affiliates which are advertised on the Venus Concept Careers site and on social media websites, and apply speculatively for positions with us. In addition to some or all of the personal data set out above, we may receive information concerning you from third parties (for example, references)

4. How we collect your personal data

We may collect personal data about you in a number of circumstances, including:

• When you make an inquiry about our services or otherwise interact on our website (e.g., via the “speak to an expert” form or contact us page on our website)
• When you attend a seminar or event or sign up to receive publications from us
• When you or your organization provide services to us or seek to provide such services
• When you apply to join us or express an interest in having a career with us
• When you interact with us by telephone, or by email or other electronic communication
• From third parties, such as government agencies, credit reporting agencies, information service providers, or from publicly available records
• From social media sites
• By making inquiries from your organization, other organizations with whom you have dealings such as former employers and educational institutions, or from third-party sources
• Automatically when you visit our websites as further described in our Cookies Policy

5. Use of your personal data

We may use the personal data listed above if and to the extent necessary to achieve the following purposes:

• To provide products or other services, as instructed or requested by you or your organization
• To provide training to you on how to use our products and services
• To manage and administer you or your organization’s relationship with us, including billing and collection, marketing, and support services, and taking other steps linked to the performance of our business relationship
• To comply with our legal and regulatory obligations such as for financial and credit checks, audit requirements, fraud and crime prevention and detection, and record keeping. This may include automated checks of personal data you or your organization provide about your identity against relevant databases, and contacting you to confirm your identity, or making records of our communications with you for compliance purposes
• To analyze and improve our services and promote our business, such as by sending you publications and invites and information about other goods and services that we offer
• To protect the security of and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities
• For insurance purposes, as necessary
• To comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies
• To comply with court orders and to exercise and/or defend our legal rights
• To assist or enhance your experience at an event; for example, details of your dietary requirements
• To personalize and foster the quality of our communications and interaction with you
• For any other purposes related and/or ancillary to any of the above, or any other purposes for which your personal data was provided to us
• For our recruitment, when you apply for a job role with us. We may use information collected throughout the recruitment process to review Venus Concept's equal opportunities profile in accordance with applicable legislation

Additionally, we may aggregate and anonymize personal data related our customers, including you if applicable, in order to help us determine the appropriate target audience for our marketing campaigns

6. Legal justification for our use of your personal data

We may process your personal data in connection with any of the purposes set out above on one or more of the following legal grounds:

• Because it is necessary for us to do so to perform your instructions or another contract with you or your organization
• To comply with our legal obligations, as well as to keep records of our compliance processes or tax records
• Because the processing is necessary for our legitimate interests, provided that those interests are not overridden by your interests or fundamental rights and freedoms
• Because you have expressly given us your consent to process your personal data in that manner

7. Marketing

We may contact you with information about goods and services similar to those which were the subject of a previous sale or negotiation of a sale to you. You may be contacted by us or by one of our selected partners.

You may opt out of receiving marketing communications at any time by contacting us via email at [email protected] or by using the unsubscribe link in any of our electronic communications.

We will continue to contact you for non-marketing related purposes where we need to issue a field corrective or safety notice, or to where we need to send certain information to you under a legal, regulatory, or ethical requirement.

8. Interest Based Advertising

We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies, and other third party services to collect information about your use of our Online Services over time so that they may play or display ads on our Online Services, on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

We may also use certain forms of display advertising and other advanced features through Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Online Services.

You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.

9. Sharing and transferring your personal data

We may share your personal data with the following categories of recipients:

• Venus Concept group entities
• Third party service providers, which we engage to process personal data for any of the purposes listed above on our behalf in accordance with our instructions only including for the purposes of delivery of products and services, customer support, marketing, and/or business analytics
• Companies providing services for credit risk reduction, money laundering, and terrorist financing checks and other fraud and crime prevention purposes, and companies providing similar services, including financial institutions, credit reference agencies, and regulatory bodies with whom such personal data is shared
• Courts, law enforcement authorities, regulators, government officials, or other parties where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim
• Prospective sellers or buyers of any business, stock, or assets to which we might assign or novate any of our rights and obligations; in such case we may disclose your personal data to the prospective seller or buyer of such business, stock, or assets

The personal data we collect may therefore be collected, transferred to, and stored in countries outside of the jurisdiction you are in. Where we transfer your personal data outside of the European Economic Area (“EEA”), any international transfers are made pursuant to appropriate safeguards, such as entering into standard data protection clauses adopted by the European Commission. If you wish to inquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Policy. We do not sell, rent, or otherwise make personal data commercially available to any third party, except with your prior permission.

10. How long do we keep your personal data?

Your personal data will be retained in accordance with our data retention policy, which categorizes all of the information held by Venus Concept, and specifies the appropriate retention period for each category of data. Those periods are determined by the purpose for which the information is collected and used, taking into account applicable data protection laws, legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, and Venus Concept’s business requirements.

11. Your rights

The GDPR and other applicable data protection laws provide certain rights for individuals. Depending on where you reside, you may have the following rights:

• To request details of the information we hold about you and how we process it
• To have the personal data we hold rectified or deleted, to object to the processing of your personal data, to restrict our processing of your personal data, receive any personal data we hold about you in a structured and commonly used machine-readable format, and to have personal data relating to you transferred to another organization
• To lodge a complaint in relation to Venus Concept’s processing of your personal data with a local supervisory authority

Please contact us using the details set out at the end of this Privacy Policy if you wish to exercise any of these rights or to advise us of any changes to your information to ensure your personal information is accurate and up to date, where relevant. We will process any request in line with any local laws and our policies and procedures. We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you.

12. California privacy rights

If you are a resident of the state of California, under the California Civil Code, you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California. To do so, send a request for information indicating your preference as to how you would like us to respond to your request (i.e., email or postal mail). To request such information, either send an email to our designated Privacy Administrator or contact us via postal mail, proper postage pre-paid, at:

Venus Concept
235 Yorkland Blvd., Suite 900, Toronto, Ontario, M2J 4Y8
Attn: Your California Privacy Rights

All requests sent via postal mail must be labelled "Your California Privacy Rights" on the envelope or post card and must be clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We will not accept requests via telephone or fax. We are not responsible for notices that are not labelled or sent properly, or do not have complete information.

13. Venus Concept Entities

Subsidiary	Jurisdiction of Organization
Venus Concept SL	Spain
Venus Concept Mexico SA DE CV	Mexico City, Mexico
Venus Concept GmbH	Germany
Venus Concept Australia PTY Ltd	Victoria, Australia
Venus Concept USA Inc.	Delaware, USA
Venus Concept France SAS	France
Venus Concept Canada Corp.	Ontario, Canada
Venus Aesthetic LLP	Gujarat, India
Venus Concept UK Limited	England and Wales, United Kingdom
Venus Concept Africa (PTY) Ltd	Durban, South Africa
Venus Concept Italy S.r.l.	Italy
Venus Concept Singapore Pte. Ltd.	Singapore
Venus Principal Concept LLP	Singapore
Venus Concept Japan Co., Ltd.	Japan
Venus Concept (Shanghai) Co., Ltd.	China
Venus Concept (HK) Limited	Hong Kong
Venus Concept Israel Ltd	Israel
Venus Concept RU Ltd.	Russia
Venus Concept Central and Eastern Europe O.O.D.	Bulgaria
Venus Concept Argentina SA	Argentina
Venus Concept Sucursal Colombia	Colombia
InPhronics Limited	Hong Kong
PT. Neoasia Medical	South Jakarta, Indonesia
Venus Concept Vietnam Company Limited	Vietnam
Venus Concept Korea Ltd.	South Korea
Venus Concept Kazakhstan	Kazakhstan
2two5	United States
NeoGraft	United States
NeoGraftDocs	United States

14. Links to third party sites

This website may, from time to time, contain links to other websites which are outside of our control and are not covered by this Privacy Policy. We do not accept any responsibility or liability for other sites’ privacy policies. If you access other websites using the links provided, please check their policies before submitting any personal data.

15. Our policy towards children

Our products, services, and Online Services are not directed at persons under the age of 16 and we do not knowingly collect personal data from children under 16. If you become aware that your child has provided us with their personal data, without your consent, then please contact us using the details below so that we can use reasonable efforts to remove such information and terminate any account your child has created with us.

16. This Privacy Policy and revisions

We reserve the right to update and change this Privacy Policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make in the future will be posted on this page. Please check back frequently to see any updates or changes.

17. Contacting us

If you have any questions, comments or requests regarding this Privacy Policy, please contact us at [email protected] or by writing to us: 235 Yorkland Blvd., Suite 900, Toronto, ON, M2J 4Y8.

Last updated: October 1, 2019