Data Protection

Body Rejuvenation Spa Privacy and Cookies Policy 

Last revised on 02/02/2024. 

WHO WE ARE

We are Body Rejuvenation Spa incorporated and registered in California with company number - 202122310283 whose registered office is at 51N 5th Ave Suite 204 Arcadia CA 91006 USA (hereinafter referred to as “BRS”, “we”, “ us”or “our”,which terms shall also include our Affiliates.  “Affiliates” means any entity that directly or indirectly controls, is controlled by, or is under common control with us. “Control” for purposes of this definition, means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity).  We are a medical technology company specializing in the design, development and sale to individual and corporate customers of Rejuvenation HealthTech to address unmet clinical needs in neurology, and through our wholly owned subsidiary Body Rejuvenation Spa. We offer online and in person vision assessment and treatment services to individual customers (the “Business”).

Your privacy is of paramount importance to us.  This privacy and cookies (the Policy) apply to the Business and 

www.bodyrejuvenationsystem.com websites 

and any sub-domains related to such websites (the “Websites”) and services related thereto (the “Services”)  This policy is designed to protect you, our users, by informing you what Personal Data is collected, how we use your personal data, with whom we share it, how long we keep it and how to contact us if you have any queries or concerns about our use of our personal data.  Your use of the websites is subject to your agreement with this Policy.

In this Policy, the term “Personal Data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes personal data as described in data protection laws (as defined below).  Any personal data that we collect from you for these purposes is hereinafter refer to together as “Your Personal Data”.

Please read the following carefully.  Use of our websites or otherwise accepting the terms of this policy indicates that you have reviewed this policy and have agreed to be bound by it.  If you do not agree to these terms, you must leave our Websites immediately.   If you no longer consent to our processing of your personal data, you may request that we cease such processing by contacting us.   

See “How to contact us” below:

We will handle your personal data in accordance with Data Protection Laws.  “Data Protection Laws” means the California Data Protection Acts and any other applicable law or regulation relating to the processing of personal data and to privacy, as such legislation shall be supplemented, amended, revised or replaced from time to time and all guidance and codes of practice issued by a relevant supervisory authority from time to time and which are applicable to us.

We are a controller (as defined in Data Protection Laws) in relation to any personal data, which we collect from you through your or any other users’ use of our Services.   This policy sets out the basis on which any such personal data will be processed by us.  In some instances, we and certain Affiliates (“Participating Affiliates”) who are party to an inter-company independent controller data sharing agreement (“DSA”) may process certain personal data pursuant to the terms of the DSA.  We and our participating Affiliates shall be responsible, as controllers, for our own processing of the Personal Data and will fully comply with our respective obligations as controllers on the data protection laws in respect of the personal data.

You may be a data subject (as defined in Data Protection Law )  or you may be a controller in respect of the relevant personal data processed by us.  When you are a controller in respect of the personal data of other data subjects, then you must comply with all of your controller obligations under data protection laws.  When you are a controller, we and you act as independent controllers, unless agreed otherwise.

INFORMATION WE GATHER FROM YOU

We fully respect your right to privacy in relation to your interactions with the Services and endeavor to be transparent in our dealings with you as to what personal data we will collect and how we will use your personal data.  We only collect and use personal data where we are legally entitled to do so. Information in relation to personal data collected by California entities is available on California Consumer Privacy Act at 

https://cpaca.gov. Ie. We may collect personal data from you in the course of your use of the Websites/Services.  The information that we process includes the following:

Basic information: such as your first and last name (including prefix or title).

Contact information: such as your billing, home and/ or business postal address, e-mail address and phone number(s).

Profile information: including your username and password, orders made by you, your organization, and feedback and survey responses;

Medical/Health information such as medical history (incl. previous medical conditions), vision history, previous vision treatments, vision assessments ( in the form of questionnaires) vision impairment  severity, anxiety scores, medications, vision charts and vision data. 

Finance information: including your bank account or card details and bank account details for payment processing purposes.

Technical information: such as information from your visits to our websites or applications including Internet Protocol( IP ) address and login data, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer and other technology on the devices you use to access the Websites or applications or in relation to materials and communications we send to you electronically.

Marketing information: including contact information collected from you for marketing purposes such as the issue of newsletters or other communications; and 

Location data: relating to you where you request that we identify the nearest practitioners offering our services.  Any other information relating to you which you may provide to us.  

We endeavor to keep your personal data accurate and up-to-date.  As such, you must tell us about any changes to such information that you are aware of as soon as possible.

If you are age under 18, please get your parent/ guardian’s permission before you provide your personal data to us/to use the services.  We will not knowingly collect, use or disclose personal data from a minor under the age of 18, without obtaining prior consent from a person with parental responsibility (e.g. a parent or guardian) through direct offline contact.  You will provide the parent with (i)notice of the specific types of personal data being collected from the minor, and (ii) the opportunity to object to any further collection, use, or storage of such information.  We abide by law designed to protect children.

We may collect information from you as necessary in the course of providing our services.  We may collect your personal data while monitoring our technology tools and services, including our website and e-mail communications sent to and from us.  We gather information about you when you provide it to us or interact with us directly.

We may use your personal data on any one or more of the following legal basis: (i) to perform a contract with you; (ii)for our legitimate business purposes in providing the services to you (in which case our legitimate interests will not override your fundamental privacy rights); and/or (iii) where you have given us your express consent.

We have set out below in a table format, a description of all the ways we plan to use Your Personal Data, and which of the legal basis we rely on to do so.  We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data for more than one legal basis, depending on the specific purpose(s) for which we are using your personal data.  Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out in the table below.   See “How to Contact  Us”below.

COOKIES

A cookie is a small text file that is placed on your device by a web server which we store on your browser or the hard drive of our computer if you agree.  Cookies contain information that is transferred to your computer's hard drive. Our websites use cookies to distinguish you from other users of our websites.  This helps us to provide you with a better experience when you browse our websites and also allows us to improve the website. Cookies also help us to improve our services and to deliver many of the functions that make your browser experience more user- friendly.

We use the following types of cookies

Strictly necessary cookies

These cookies are required for the operation of our websites. They include, for example, cookies that enable you to log into secure areas of our websites, use a shopping cart or make use of e-billing services.

Analytical or performance e-cookies

These cookies allow us to recognize and count the number of visitors and to see how visitors move around our websites when they are using.  This help us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily and to see how effective and relevant advertising on our websites is.

Functionality cookies

These are used to recognize you when you return to our website.  This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or location) and remember if we have already asked you for feedback or to complete a survey.

Targeting cookies

These cookies record your visit to our websites, the pages you have visited and the links you have followed.  We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that a number of third parties may also use cookies over which we have no control.

These named third parties may include, for example, advertising networks and providers of external services like Web traffic and analysis services. These third party cookies help us to improve our websites and to deliver many of the functions that make your browser experience more user- friendly.  You may see social buttons during your use of the websites, including but not limited to Twitter, Facebook, LinkedIn and Instagram which enable you to share or bookmark certain web pages. These websites and social platforms have their own cookies and privacy practices which are controlled by them.

We use Google Analytics to obtain high-level “audience measurement” data such as the referral web domain, type of operating system /browser used, date and time of visit, and other information relating to activities on our websites to understand its usage better, analyze trends, and optimize the website experience.  To opt out of being tracked by Google Analytics across all websites, http://tools.google.com/dlpage/gaopout

We use Google tracking cookies to understand if you complete certain actions on our websites after you have seen or clicked through one of our adverts served via Google.  Based on the content you have engaged with on our websites, Google delivers some targeted advertisements across other Google partner websites.  For more information visit: https://support.google.com/ads/answer/2662922?hl=en

The “Help Menu” on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether.  You can also disable or delete similar data used by browser add-ons such as flash cookies, by changing the add-ons settings or visiting the websites of its manufacturer.

Further information about browser privacy settings, and cookies and how to disable them can be found at www.allaboutcookies.org.  You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to fully experience the interactive features of our website or other related websites/applications such as you visit/use.

The website uses cookies.  We use cookies to personalize content and ads, to provide social media features and to analyze our traffic.  We also share information about your use of our site with our social media, advertising and analytic partners who may combine it with other information that you've provided to them or that they've collected from your use of their services.

Cookies are small text files that can be used by websites to make a user’s experience more efficient.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site.  For all other types of cookies we need your permission.

This site uses different types of cookies.  Some cookies are placed by third party services that appear on our pages.

You can at any time change or withdraw your consent from the cookie declaration on our website.

Learn more about who you are, how you can contact us and how we process personal data on your Privacy Policy.

Please state your consent ID and date when you contact us regarding your consent.

Your consent applies to the following domains:

www.bodyrejuvenationsystem.com

Your current state: allow all.

Your consent ID: 

Consent date: 

Change your consent /Withdraw your consent 

Cookie declaration that last updated on 02/02/2024 by Cookiebot:

Necessary ( 5 )

Necessary cookies help make a website usable by enable basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Statistics (6)

Statisticcookie help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Marketing (8)

Marketing cookies are used to track visitors across websites.  The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and 3rd party advertisers.

CASES WHERE WE MAY USE YOUR INFORMATION TO CONTACT YOU

We may contact you (I) for administration reasons related to the Services ( e.g. to provide you with password reminders or to notify you that a particular service, activity or online content has been suspended for maintenance, or in response to a question that you ask us)  (ii) to provide you with information about our services, activities or online content, including sending e-newsletters or similar correspondence and updates or responding to any contact you have made with us - see “How to Contact Us” below: (iii) to invite you to participate in surveys about our Services (participation is always voluntary); and (iv) for direct marketing purposes.

YOUR RIGHTS

As a data subject, you have the following rights under Data Protection Laws and we, as controller in respect of Your Personal Data, will comply with such rights in respect of your Personal Data.  These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your Personal Data, please contact us (see  “How to Contact Us” below).  We will respond to any rights that you exercise within one month of receiving your request, unless the request is particularly complex, in which case we will respond within three months (we will inform you with the first month within the first month if it will take longer than one month for us to respond).

We have a legitimate interest to send you electronic communications in connection with the services and related matters (which may include but shall not be limited to newsletters, announcement of new feature etc. and which may also appear on social media platforms such as Facebook, LinkedIn, X  or Instagram).   We may also ask you for your consent to send you direct marketing from time to time.  You may be able to select your preferences with respect to direct marketing when registering on our websites.   We may also ask you different questions for different services, including competitions.  We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.  You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please (I)click on ‘unsubscribe’ on any e-mail; (ii)respond ‘stop’ on an SMS to a number notified to you; or (iii) send an e-mail via “How to Contact Us” below.  We will provide you with information on action taken on a request to stop direct marketing -this may be in the form of a response e-mail confirming that you have ‘unsubscribed’.   Unsubscribing from direct marketing- does not unsubscribe you from essential electronic communications in respect of the administration of your account/the provision of the Services.  

Rights in relation to automated decision making.

You may ask us to ensure that.  If we are evaluating you, we don't base any decisions solely on an automated process and have any decision reviewed by a member of staff.  Profiling may occur in relation to your Personal Data for the purposes of targeted advertising and de-targeting you from specified advertising.   This allows us to tailor our advertising to the appropriate customers and helps to minimize the risk of you receiving unwanted advertising.   These rights will not apply in all circumstances, for example where the decision is (i) authorized or required by law, (ii) necessary for the performance of a contract between you and us, or (iii) is based on your explicit consent.   In all cases, we will endeavor that steps have been taken to safeguard your interests.  

If you do not think that we have processed your Personal Data in accordance with this policy, please contact us in the first instance (see “How to Contact Us” below).  If you are not satisfied, you can complain to the DPC or exercise any of your other rights pursuant to Data Protection Laws. Information about how to do this is available on the DPC website at https://www.cppa.ca.gov.

Further Information 

Who WE SHARE YOUR INFORMATION WITH 

We will not share your Personal Data without your consent or unless required by law (except as set out in this policy)

We restrict access to your Personal Data to employee’s, contractors and agents who need such access in order to operate, develop or improve our Services.   These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, civil litigation and/ or criminal prosecution, if they fail to meet these obligations.  We may also share your Personal data with our third party suppliers who assist us in the provision of the services.

We also share your personal data with various third parties such as business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you (subject to having appropriate contracts in place with such third parties).

Personal data collected from you may also be transferred to a third party in the event that the business or a part of it and the customer data connected with which it is sold, assigned or transferred, in which case we would require the buyer, assignee or transferee to treat personal data in accordance with this policy.  If we become involved in a merger, acquisition, or any form of sale of some of all of its assets, Your Personal Data will not be transferred to any third party unless there are adequate safeguards in place with the recipient in respect of the security of your personal data.

Your Personal Data may be disclosed to a third party if we are required to do so because of an applicable law, court order or government regulation or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding in California or other states.

THIRD PARTY WEBSITES

This policy applies to websites and services that are owned and operated by us.   We do not exercise control over the sites/applications that may be linked from the websites.  You may see ‘social buttons’ during your use of the websites, including but not limited to X, Facebook, LinkedIn and Instagram which enable you to share or bookmark certain web pages.   These websites and social platforms have their own cookies and privacy practices, which are controlled by them.   These other sites/applications may place their own cookies or other files on your computer, collect data or solicit personal information from you.  You acknowledge that the websites may enable or assist you to access content of, correspondent with, and purchase goods and services from, third parties via third party websites and that you do so solely at your own risk.   We make no representation or commitment and shall have no liability or obligation whatsoever in relation to the content or use of all correspondence with, any such third-party website, or any transactions completed, and any contract entered into by you, with any such third party and the use by any such third-party of Your Personal Data.  We do not endorse or approve any third-party website nor the content of any of the third-party website made available via the website. Privacy policy applicable to any websites and/or services operated by third parties.  Please be aware that we are not responsible for the privacy practices of any third parties. 

HOW WE PROTECT YOUR PERSONAL DATA

We do our utmost to protect user privacy through the appropriate use of security technology.   We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risks that are presented by the processing of your Personal Data.  In particular, we consider the risk presented by accidental or unlimited or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your personal data transmitted, stored or otherwise processed.  

We restrict access to your personal data to employees, contractors and agents who need to know your Personal Data in order to operate, develop or improve the services.   We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place.   However, our websites may contain hyperlinks to websites owned and operated by third parties. These third-party websites have their own privacy policies, including cookies.   We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of certain websites is at your own risk.

Unfortunately, the transmission of information via the Internet is not completely secure.  Although we will do our best to protect Your Personal Data, we cannot guarantee the security of any data transmitted to us and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.   To the extent permitted by law, we are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities,  including the Internet,  or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that  our services may be subject to limitations, delays and other problems inherent in the use of such communications facilities.  You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses.  Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of Your Personal Data arising from such risks.

All information you provide to us is stored in our (or contracted third party) secure servers. Where we have given you (or where you have chosen) a password which enables you to access any part of our services, you are responsible for keeping this password confidential.  We ask you not to share a password with any person not authorized to use the services. 

PERSONAL DATA BREACH REPORTING

We will notify serious personal data breaches in respect of your personal data to the state of California Department of justice at oag.ca.gov without undue delay, and where feasible, not later than 72 hours after having become aware of same.  If notification is not made after 72 hours, we will record a reasoned justification for the delay.  However, it is not necessary to notify the OAG where the Personal Data Breach is unlikely to result in a brisk to the rights and freedoms of natural persons.   A Personal Data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed.

We will keep a record of our personal data breaches, including their effects and the remedial action taken, and will notify you of any personal data breach affecting Your Personal Data (which poses a high risk to you) when we are required to do so under data protection laws.   We are not required to notify you of a personal data breach where (i) we have implemented appropriate technical and organizational measures that render your personal data unintelligible to anyone not authorized to access it, such as encryption;  (ii) we have taken subsequent measures which ensure that the high risk to data subjects is not likely to materialize; (iii) it would involve disproportionate effort, in which case we may make a public communication instead.

RETENTION OF PERSONAL DATA

Your personal data will be kept and stored for such period of time as we deem necessary taking into account the purpose for which it was collected in the first instance.  This may include retaining your personal data as necessary to administer your account, comply with our legal obligations, resolve disputes, enforce our engagements, support business operations, and continue to develop and improve our services.  

Where we retain information for improvement and development of the services, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our services, not to specifically analyze personal characteristics about you.

AMENDMENTS TO POLICY

We may change our policy from time to time and it's our sole discretion.   The date of the most recent revisions will appear on the top of this policy.  If you do not agree to these changes, please do not continue to use the website to submit your personal data.  If material changes are made in the policy, we will notify you by placing a prominent notice on our websites or by sending you a notification in relation to this.

HOW TO CONTACT US

You need to contact us with regard to any of your rights as set out in this policy, all such requests should be made in writing by e-mail to cs@bodyrejuvenationsystem.com or write to us at Data Protection, Huntington Body Rejuvenation Centre  51 N 5th AveSuite 204 Arcadia CA 91006 USA.  We have appointed David Nima Sharifi Esq. to act as our legal representative.  If you wish to exercise your rights or have any queries in relation to your rights or general privacy matters, please e-mail our representative at david@latml.com. Please ensure to include our company name in any correspondence you send to our representative.