Privacy policy

CLEO PRIVACY POLICY

Aesthetic Derm Opco, Inc. and its subsidiaries and affiliates ("“CLEO SKIN +LASER", “CLEO"
“We" or “Us") operates the website located at https://cleoskinandlaser.com and related
websites (the “Website"). We respect the right to privacy of all users of CLEO’s Website and
are entirely committed to keeping all collected information that you provide to us secure,
confidential and private. By accessing the CLEO Website, you acknowledge your agreement
with this Privacy Policy. Furthermore, your ongoing use of the Website after any updates or
changes to our terms and conditions are posted signifies your acceptance of such
modifications. If you disagree with this Privacy Policy, please refrain from using our Site. We
encourage you to carefully read this privacy policy to comprehend our policies and practices
concerning your information and how we handle it.
This privacy policy does not cover information you provide to or that is collected by any third
party, whether it's in connection with your use of our services or otherwise. This includes any
third-party applications or content (including advertisements) that may be linked to or
accessible from our services. By using our services, you agree and acknowledge that CLEO is
not obligated to protect or maintain any information you provide to or that is collected by any
third party, whether it's related to your use of our services or not.

Changes To Our Privacy Policy:

Any changes we make to our privacy policy will be posted on this page. If we enact significant
changes to how we treat our users’ personal information, we will notify you through a notice
on the Website or by any other reasonable means. You are responsible for ensuring we have
an up-to-date and active email address for you, and for periodically visiting our Website and
this privacy policy to check for any changes.
Information CLEO Collects About You:
When you book an appointment for a treatment at CLEO or purchase a CLEO Membership, we
gather personal information like your name and email address. With your permission, we
might send you emails regarding new treatments and updates about our business. The data
we collect through our website or during your use of our services may include:
e Information you provide about yourself or others while using our services, such as
during registration or when requesting additional services. This may include details like
your name, password, email address, and skincare information.

Records and copies of your correspondence with us, including email communications.
Your responses to surveys we conduct for research purposes.

You might also share information intended for publication on public areas of our services, or
for transmission to other users or third parties. This includes questions, answers, posts, and
chat messages (referred to as "User Data’). It's important to note that User Data is shared at
your own risk. While we take measures to limit access to certain information, no security
system is entirely foolproof. We cannot control the actions of other users, so we cannot
guarantee that unauthorized individuals won't access User Data. For your privacy, avoid
sharing personal or sensitive information that you're uncomfortable disclosing publicly.
Please be aware that members of the CLEO team may have access to this information, and it might also appear on search engines like Google or be disclosed to third parties under
specific circumstances outlined in our policies.

Information Collected Through Data Tracking Technologies:

As you use the Services, we may use automatic data collection technologies to collect certain
information about your devices, browsing actions and patterns, including details of your use
of the Services (such as traffic data, location data, logs and other communication data) and
information about your devices and internet connection (including your IP address, operating
system and browser type). The technologies we use for this automatic data collection may include:

CLEO may use “cookies”, or small text files that are stored on your computer's hard
drive. Cookies ensure that our Site's content is presented in the most effective
manner for you and your computer. You can decline cookies by activating a setting on
your browser. If you choose to decline cookies, this may limit the functionality of our
Site. While we use cookies, we do not track our users across websites or over time. We
may automatically collect and store certain information in our server logs when you
use the Services, including details about how you used the Services, IP address, and
information specific to your device (such as system activity, hardware settings,
browser type, and browser language).

Location-Based Data. We may collect and process information about your geographic
location (for example, through GPS signals) when you use the Services. We will not
store or track your device location on an on-going basis or without your permission.
We do not share precise geolocation data with third parties, other than our service
providers as necessary to provide the Services.

Analytics Data. We may also collect analytics data, or use third-party analytics tools, to
help us measure traffic and usage trends for the Services.

Third-Party Collection Of Information:

Some content or applications, including advertisements, on the Services may be served by
third parties, including advertisers, ad networks and servers, content and application
providers. These third parties may use tracking technologies to collect information about you
when you use the Services. The information they collect may be associated with your
personal information or they may collect information, including personal information, about
your online activities over time and across different websites and other online services. They
may use this information to provide you with interest-based (behavioral) advertising or other
targeted content.

CLEO does not control these third parties’ tracking technologies or how they may be used. If
you have any questions about an advertisement or other targeted content, you should
contact the responsible provider directly. For information about how you can opt out of
receiving targeted advertising from many providers, see Your Choices About Our Use and
Disclosure of Your Information below.

Information You Provide To CLEO:

We gather various kinds of information from our Services’ users, some of which can
personally identify you, while others are non-identifying or aggregated. This includes: i)
Personally identifiable information like your name, postal address, email address, telephone
number, biographical details, or any other identifier that can reach you either online or offline
("personal information’). ii) Data about you that doesn't individually identify you. iii) Information
regarding your internet connection, the devices you use to access our Services, and specifics
of your usage.

We collect this data through three main channels: i) Directly from you when you provide it to
us. ii) Automatically as you use our Services, which might encompass usage details, Internet
Protocol (IP) addresses, and data obtained through cookies, web beacons, and similar
tracking technologies. lii) from third parties, such as our business partners.

Children Under The Age of 13:

CLEO does not knowingly or specifically collect Personal Information from users under the
age of 13 and no one under age 13 is authorized to submit any information, including Personal
Information, on our Site. If you are a minor over age 13, some portions of the Site will require
consent from your parent or guardian before you may use it. Parents or legal guardians of
children under age 13 cannot agree to these terms on their behalf. If it is determined that such
information has been inadvertently collected on anyone under the age of thirteen (13), we
shall immediately take the necessary steps to ensure that such information is deleted from
our system's database.

How We Utilize User Information:

We utilize the information we collect about you or that you provide to us, including any
personal details, for the following purposes:

Optimizing our service offerings, as well as any other information, products, or
services you request from us.
Sending you notices regarding your account.
Fulfilling our obligations and enforcing our rights arising from contracts between you
and us, including billing and collection, if applicable.
Notifying you about available updates to the Services, and any changes to the
products or services we offer through our Services.
Contacting you about our own and third-party goods and services that may interest
you.

Facilitating the display of advertisements to our advertisers’ target audiences.
Although we do not disclose your personal information for these purposes without
your consent, if you interact with an advertisement, the advertiser may assume you
meet its target criteria.
Using the information collected about you or provided by you in any other way
described at the time of collection or for any other purposes with your consent.
Retaining information and content for backup, archival, audit, or other business
purposes, or as required by applicable laws, following account termination or
Deactivation.

Maintaining anonymized, de-identified, or aggregated data, including usage data, for
analytics purposes.

Fulfilling any other purpose for which you provide the information.
If you have questions regarding data retention or deletion, please contact us at
hello@cleoskinandlaser.com. For information on how to opt out of certain uses of your
information, refer to the "Your Choices About Our Use and Disclosure of Your
Information" section below.

Disclosure of Your Information:

We may disclose anonymized, de-identified or aggregated information about our users, and
information that does not identify any individual, without restriction:

To fulfill the purpose for which you provide it. For any other purpose disclosed by us when you provide the information. With your consent. To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

If we believe disclosure is necessary or appropriate to protect the rights, property, or
safety of CLEO, our customers, or others. This includes exchanging information with
other companies and organizations for the purposes of fraud protection and credit
risk reduction.

To our subsidiaries and affiliates.

To contractors, service providers, and other third parties we use to support our
business and who are bound by contractual obligations to keep personal information
confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring,
reorganization, dissolution, or other sale or transfer of some or all of our assets,
whether as a going concern or as part of bankruptcy, liquidation, or a similar
proceeding, in which personal information held by us is among the assets transferred.
To third parties to market their products or services to you if you have consented to or
not opted out of these disclosures. We contractually require these third parties to
keep personal information confidential and use it only for the purposes for which we
disclose it to them.

CLEO holds no responsibility for the disclosure of voluntarily submitted information, including
health information. You accept all associated risks regarding your use of the Services.

Accessing and Updating Your Information:

You can review and update your account information by logging into your Boulevard account
and visiting your profile or settings page. Alternatively, you can reach out to us via email at
hello@cleoskinandlaser.com to request access to, correct, or delete any personal
information you've provided. Please note that we may not be able to accommodate requests
to change information if doing so would violate any law or legal requirement, or if it would
result in incorrect information.

Mobile:

The website utilizes cookies to track items added to your shopping cart, including instances
of abandoned carts. This data is utilized to schedule the sending of cart reminder messages
via SMS. However, it's important to note that text messaging originator opt-in data and
consent are excluded from this process and will not be shared with any third parties.

Data Security:

While we strive to protect your personal information, please be aware that transmitting data
over the internet is never entirely secure. Any transmission of personal information is done at
your own risk. We cannot be held responsible for the circumvention of privacy settings or
security measures provided. We've implemented measures to safeguard your personal
information from accidental loss and unauthorized access, use, alteration, and disclosure. All
data you provide is stored on secure servers behind firewalls. When you transmit information
to us through our Services, it's encrypted using industry-standard technology. However, we
can't guarantee the absolute security of your information. Despite our physical, managerial,
and technical safeguards, breaches can still occur, leading to unauthorized access,
disclosure, alteration, or destruction of your data. You also play a crucial role in the safety and
security of your information. If we've provided you with a password for accessing our
Services, it's important to keep it confidential and not share it with anyone.

Contact Information:

If you have any questions about this privacy policy, please feel free to contact us at:
hello@cleoskinandlaser.com