Privacy Notice
Last revised and effective as of: September 10, 2021
We at Cynosure, LLC (along with each of Cynosure, LLC’s Corporate Affiliates (as defined below), collectively, “Cynosure”, “we”, “us” or “our”) respect your concerns about privacy. Cynosure, LLC’s Corporate Affiliates include the entities listed at https://www.cynosurecanada.com/privacy-policy/corporate-affiliates-and-entities/.
This Privacy Notice explains how we use any personal information we collect about you online and offline, including through our websites (listed at https://www.cynosurecanada.com/privacy-policy/corporate-affiliates-and-entities/), as well as any subdomains of the foregoing (together with our Provider Portal, each, a “website”) and your rights in relation to the information. You may also provide information to us when you meet us in person, such as at business conferences or trade shows or when you are involved in our webinars or our networking activities (collectively, “Networking Activities”) and this Privacy Notice relates to such information as well. As used in this Privacy Notice, “you” or “your” refers to a visitor to our website and/or any consumer (as defined below) or professional (as defined below).
To the extent our websites, products, and services are available to individuals located in the European Economic Area (the “EEA”) or the United Kingdom (the “UK”), to the extent we participate in Networking Activities with you in the EEA or the UK, or to the extent we process your personal information in the context of the activities of an establishment in the EEA or the UK, this Privacy Policy sets out our practices and obligations under the General Data Protection Regulation 2016/679 (the “GDPR”), to the extent applicable.
“Personal information” means information that identifies you as an individual or is capable of identifying you as an individual. Personal information amounts to ‘personal data’ for the purposes of and as defined in the GDPR. All references to personal information shall be deemed to include ‘personal data’ as defined and used in the GDPR (to the extent applicable). As used in this Privacy Notice, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within Cynosure or among our Corporate Affiliates within the United States or internationally.
This personal information may include your name, email address, physical address, zip code, telephone number, survey responses, and the content of any request or form you submit to us. If you are a recipient or prospective recipient of any procedures utilizing Cynosure’s devices (a “consumer”), we may also collect information about treatments you are considering or have previously received, the content of any reviews you submit, your inquiries or responses to quizzes that you choose to submit to us, and, if you consent, we may receive before and after photographs from the professional who performed your treatments. If you are a consumer, in connection with any inquiries or responses to quizzes you may submit to us, we may also collect your race, medical conditions (history of pregnancy/childbirth), gender, sex, and age. If you use our provider locator feature, we will collect your precise location in order to identify professionals in your area. If you’re accessing our websites or participating in Networking Activities with us, or if you have leased or purchased (or are considering leasing or purchasing) our products or services in your capacity as a professional, including as a healthcare professional (a “professional”), this personal information may also include your location, photograph, other contact details, information included in your profile on RealSelf.com, records of products or services purchased or leased, job title, company name, practice and specialty. Additionally, we may collect the following information relating to professionals in connection with the lease or purchase of any of Cynosure’s devices: company ownership information, trade references, website, billing/payment information (including credit card number and/or bank account information (including balance)), tax identification number (such as social security number), financial statement, years in practice, and (depending on your financing of your lease or purchase) we may engage third-party service providers to run credit worthiness checks, which third-party service providers may provide to us information on your credit worthiness (including a suggestion as to the maximum credit we should offer you).
If you make a purchase, we may also collect your payment details.
1. Information You Provide to Us
We may collect personal information from you directly, such as when you purchase products or services from us, register on our Provider Portal, submit information through this website (such as through surveys and quizzes), sign up to receive marketing from us, or otherwise communicate with us by telephone or in writing.
2. Third-party Sources
We may collect personal information from third-party sources, such as business partners, sub-contractors and analytics providers, search information providers, address update providers, distributors, co-promotion partners and credit reference agencies. We process all data we obtain from such other sources in accordance with this Privacy Notice. If you are a consumer and if you consent, we may receive before and after photographs and other information from the professional who performed your treatments. If you are a professional, we may directly collect personal information about you that is publicly available from sources such as LinkedIn and other publicly available websites. If you are a professional, in connection with the lease or purchase of any of Cynosure’s devices, depending on your financing of your lease or purchase, we may engage third-party service providers who run credit worthiness checks, which third-party service providers may provide to us information on your credit worthiness.
3. Website Usage Information and Other Information Collected Automatically
When you visit our websites or view our advertisements, we (and our service providers) may use cookies and other technologies to automatically collect the following information:
For the avoidance of doubt, our websites may use third-party service platforms (including to help analyze how visitors use our websites). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable “third-party” cookies, you may be able to turn them off by going to the third party’s website.
Here are links to the main third-party platforms we may use:
To learn more about how we use cookies and how to control which cookies are used, please see our Cookies Notice. Information collected from some cookies placed on our websites is used to deliver Cynosure advertisements to Cynosure website visitors when such visitors are visiting other websites.
4. Individuals Under the Age of 13
We are committed to protecting the privacy of children. Our websites are not designed for or directed to children under the age of 13. We do not collect personal information from any person we actually know is under the age of 13.
5. How We Use the Information We Obtain
We use your personal information to provide, improve, and promote our websites and/or our products and services, as well as to facilitate participation in Networking Activities, including without limitation in order to:
The legal bases for which we collect, use, transfer or disclose your personal information may include:
Unless you ‘opt out’ (to the extent permitted by applicable law), we and third parties acting on our behalf may contact you about products and services that may be of interest to you. You will have a right to unsubscribe at any time.
In particular, we would like you to be aware that we may construct profiles about professionals and/or consumers and therefore we may use the personal information described above so that an evaluation can be made about preferences and interests (among other things). We may use these inferences to direct marketing materials to you that are more tailored to your preferences and interests. Under the GDPR (to the extent applicable), this usage may be considered profiling. The GDPR defines “profiling” as “any form of automated processing of personal information consisting of the use of personal information to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements”. To the extent our processing constitutes profiling under the GDPR (to the extent applicable), you have the right to specifically object to the processing of your personal information for the purpose of profiling in accordance with the paragraph below titled “Your Personal Information Rights”. To learn more, please reach out to privacy@cynosure.com.
6. Third Parties
The security of your data is extremely important to us. Access to your personal information is only provided to our staff and certain third parties, including:
In the course of providing such services, these service providers may have access to your personal information. We will use commercially reasonable efforts designed to ensure that all the service providers we work with will keep your personal information secure. In addition to the above, when visitors use our websites, third parties (including without limitation third-party analytics service providers) may directly collect information (including personal information) about our website visitors’ online activities over time and across different websites. Please note in particular that our websites use Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners’ sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.
Our websites also contain a provider locator feature. If you are a professional and you are included in the provider locator feature, your name, company name, photograph, job title, contact information, and any other information you choose to include in your provider locator profile will be publicly viewable to visitors to the website (including consumers).
Our website may, from time to time, contain links to and from the websites of our partners or other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we have no control over how they may use your personal information. A link to a third-party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. You should check the privacy notices of third-party websites before you submit any personal information to them.
7. Public Areas
Our websites may feature various community areas, blogs, and other public forums (the “Public Areas”) where individuals can share information or where individuals can post questions for others to answer. The Public Areas include, without limitation, the provider locator feature on our websites. These Public Areas are open to the public and should not be considered private. We cannot prevent information included within a Public Area from being used in a manner inconsistent with this Privacy Notice, the law, or your personal privacy. We are not responsible for the results of such postings or for the accuracy of any information contained in those postings.
Any information you share in a Public Area (including personal information) is by design open to the public and is not private. You should think carefully before posting any information in any Public Area. What you post can be seen, disclosed to or collected by others and may be used by others in ways we cannot regulate or predict. As with any public forum on any website, the information you post may also show up in third-party search engines like Google, Yahoo, MSN, and Bing. If you mistakenly post personal information in a Public Area you can send us an e-mail to request that we remove it by contacting us at privacy@cynosure.com. You should understand that in some cases, we may not be able to remove your information.
Any information shared in the Public Areas is available to the public, including to all website visitors. Such information is not protected or treated as confidential, can be used in any manner, and is not subject to this Privacy Notice. If you wish to keep any information private or proprietary, do not submit it to the Public Areas. NOTWITHSTANDING THE FOREGOING, WE HAVE NO RESPONSIBILITY OR LIABILITY IF AN INDIVIDUAL’S INFORMATION OR IDENTITY IS MISUSED OR STOLEN, OR IF AN INDIVIDUAL SUFFERS HARM AS A RESULT OF VOLUNTARY DISCLOSURES.
8. Data Retention
Your personal information will only be stored for as long as necessary for the purposes for which they were collected and only to the extent permitted by applicable laws. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to promptly anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).
9. International Data Transfers
The personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA and who work for us or for one of our service providers.
We will take all steps reasonably necessary to ensure that your personal information is treated in accordance with this Privacy Notice and applicable data protection laws, including, where relevant, entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA receiving the personal information.
10. How We Protect Personal Information
We have implemented technical and organizational security measures in an effort to safeguard personal information in our custody and control. These measures include limiting access to personal information only to employees and authorized service providers who need to know such information for the purposes described in this Privacy Notice, as well as other technical, administrative and physical safeguards.
While we endeavor to always protect our systems and information against unauthorized access, due to the inherent nature of the Internet as an open global communications vehicle (and other risk factors), we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.
11. Your Personal Information Rights
Under the GDPR (to the extent applicable), you may have various rights in connection with our processing of your personal information:
In some situations, we may refuse to act or may impose limitations on your rights, as permitted by law. Before we can provide you with any information or correct any inaccuracies, we may ask you to verify your identity and/or provide other details to help us respond to your request. For the exercise of your rights, please contact us using the contact information provided below in the “How to Contact Us” section.
In all cases, you have a right to file a complaint with your local data protection authority if you believe that we have not complied with applicable data protection laws.
12. Do Not Track
The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.
13. Translation
This Privacy Notice is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.
14. Changes to this Privacy Notice
We reserve the right to change our Privacy Notice from time to time. To the extent required by applicable law, we will not make changes that result in significant additional uses or disclosures of your personal information that we have collected prior to implementing such changes without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Notice that generally will not significantly affect our use of your personal information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Notice are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using our websites.
15. How to Contact Us
If you have any questions or comments about this Privacy Notice, please contact us:
We can be contacted directly via email at privacy@cynosure.com
You may also write to us at:
Attn: Legal Department
Cynosure, LLC
5 Carlisle Road
Westford, MA 01886
16. Privacy Notice for California Residents
This Section 16 shall apply only to the extent that we are regulated as a business (as defined in the California Consumer Privacy Act of 2018 (collectively with any regulations promulgated thereunder, the “CCPA”)) under the CCPA. This Section 16 shall apply to you only if you are a California resident.
As used in this Section 16, “sell” (including any grammatically inflected forms thereof) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, CCPA information (as defined below) to another business or a third party for monetary or other valuable consideration. “Selling” does not include (i) disclosing CCPA information to a third party at your direction, provided the third party does not sell the CCPA information except in accordance with the CCPA, (ii) where you intentionally interact with a third party through the Service, provided the third party does not also sell the CCPA information, (iii) using or sharing your CCPA information with a service provider as necessary to perform business purposes, provided that such service provider provides its services on Cynosure’s behalf and provided that the service provider does not further collect, sell or use the CCPA information except as necessary to perform the business purpose, or (iv) transfers of your CCPA information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Cynosure, provided that information is used or shared consistently with the CCPA.
Where noted in this Privacy Policy, until the applicable date specified in the CCPA, the CCPA exempts CCPA information reflecting a written or verbal business-to-business communication (“B2B CCPA information”) from some its requirements, provided that such exemptions shall not apply from and after such date specified by the CCPA.
16.1 CCPA Information Collected: We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with particular California residents, devices or households (“CCPA information”). CCPA information does not include deidentified or aggregated information, publicly available information from government records, or any other information that is excepted from the definition of “personal information” under the CCPA, or any information that is otherwise not regulated by the CCPA. In particular, we have collected the following categories of CCPA information from California residents, households or devices within the last twelve (12) months:
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Category |
Examples |
Business or commercial purposes for which we collect and use CCPA information |
Categories of third parties to whom we have disclosed CCPA information for a business or commercial purpose in the preceding twelve (12) months. |
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A. Identifiers. |
Name, email address, physical address, zip code, telephone number, survey responses, and the content of any request or form you submit to us, and any identifiers that you have included in any Public Area. If you make a purchase, we may also collect your payment details. If you are a consumer: information about treatments you are considering or have previously received, the content of any reviews you submit, inquiries or responses to quizzes that you choose to submit to us, and, if you consent, before and after photographs and other information. If you are a professional: location, other contact details, photograph, information included in your profile on RealSelf.com, job title, company name, practice and specialty, and (in connection with the purchase of Cynosure’s devices) company ownership information, trade references, website, billing/payment information (including credit card number and/or bank account information (including balance)), tax identification number (such as social security number), years in practice, financial statements, and (depending on your financing of your purchase) credit worthiness information (including a suggestion as to the maximum credit we should offer you). |
Provision, improvement, and promotion of our websites and/or our products and services; participation in Networking Activities. |
Our group of companies (including Corporate Affiliates), distributors, service providers, professionals, third parties connected with business transactions, third parties in order to comply with a legal or regulatory obligation, practice transformation plan partners, and strategic partners (each as described in Section 6). Additionally, any information that was included in any Public Area during the last 12 months has been viewable by the public. |
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B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
Name, telephone number, and any personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) that you have included in any Public Area. If you make a purchase, we may also collect your payment details. If you are a professional: address, social security number, bank account information, credit card number, company, job title, practice and specialty. |
Provision, improvement, and promotion of our websites and/or our products and services; participation in Networking Activities. |
Our group of companies (including Corporate Affiliates), distributors, service providers, professionals, third parties connected with business transactions, third parties in order to comply with a legal or regulatory obligation, practice transformation plan partners, and strategic partners (each as described in Section 6). Additionally, any information that was included in any Public Area during the last 12 months has been viewable by the public. |
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C. Protected classification characteristics under California or federal law. |
If you are a consumer, in connection with any inquiries or responses to quizzes you may submit to us: race, medical conditions (history of pregnancy/childbirth), gender, sex, and age. Any protected classification characteristics under California or federal law that you have included in any Public Area. |
Provision and Improvement of the Public Areas. |
Our group of companies (including Corporate Affiliates), distributors, service providers, third parties connected with business transactions, third parties in order to comply with a legal or regulatory obligation, and strategic partners (each as described in Section 6). Additionally, any information that was included in any Public Area during the last 12 months has been viewable by the public. |
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D. Commercial information. |
If you are a professional: records of products or services purchased or leased. Any other commercial information that you have included in any Public Area. |
Provision, improvement, and promotion of our websites and/or our products and services; participation in Networking Activities. |
Our group of companies (including Corporate Affiliates), distributors, service providers, third parties connected with business transactions, practice transformation plan partners, third parties in order to comply with a legal or regulatory obligation, and strategic partners (each as described in Section 6). Additionally, any information that was included in any Public Area during the last 12 months has been viewable by the public. |
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E. Internet or other similar network activity. |
We may collect the following information from visitors to our websites: • technical information, including your IP address, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times and download errors; • information about your visit, including the websites you visit before and after our website and products you viewed or searched for; and • length of visits to certain pages, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page. |
Provision, improvement, and promotion of our websites and/or our products and services; participation in Networking Activities. |
Our group of companies (including Corporate Affiliates), distributors, service providers, and strategic partners (each as described in Section 6). |
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F. Geolocation data. |
If you use our provider locator feature, we will collect your precise location in order to identify professionals in your area. Any geolocation you have included in any Public Area. |
Provision, improvement, and promotion of our websites and/or our products and services. |
Our group of companies (including Corporate Affiliates), distributors, service providers, and strategic partners (each as described in Section 6). Additionally, any information that was included in any Public Area during the last 12 months has been viewable by the public. |
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G. Professional or employment-related information. |
If you are a professional: job title, company name, practice and specialty, company ownership information, trade references. Any professional or employment related information you have included in any Public Area. |
Provision, improvement, and promotion of our websites and/or our products and services; participation in Networking Activities. |
Our group of companies (including Corporate Affiliates), distributors, service providers, third parties connected with business transactions, practice transformation plan partners, third parties in order to comply with a legal or regulatory obligation, and strategic partners (each as described in Section 6). Additionally, any information that was included in any Public Area during the last 12 months has been viewable by the public. |
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H. Inferences drawn from other personal information. |
In particular, we would like you to be aware that the we may construct profiles about professionals and/or consumers and therefore we may use the personal data described above so that an evaluation can be made about preferences and interests (among other things). |
Provision, improvement, and promotion of our websites and/or our products and services. |
Our group of companies (including Corporate Affiliates), distributors, service providers, third parties connected with business transactions, and strategic partners (each as described in Section 6). |
16.2 Use of CCPA information; Categories of Sources: We use CCPA information for the business or commercial purposes described in the table above and in the manner described in Sections 3 and 5 of this Privacy Policy with respect to personal information. Regarding the categories of sources from which CCPA information is collected, we collect CCPA information that you submit to us as described in Section 1 with respect to personal information. We may also receive CCPA information from third-party sources as described in Section 2 with respect to personal information. We also receive information that is otherwise collected when you use our website, including as described in Section 3. We may receive CCPA information from or about you when we meet you at a Networking Event or when you contact us. If you are a professional, we may directly collect personal information about you that is publicly available from sources such as LinkedIn and other publicly available websites.
16.3 Disclosures of CCPA information for a Business or Commercial Purpose: Cynosure may disclose your CCPA information described in the table above to a third party for a business or commercial purpose, as described in the table above and in Sections 6 and 7 of this Privacy Policy with respect to personal information. In the preceding twelve (12) months, Cynosure has disclosed the categories of CCPA information described in the table above for a business or commercial purpose to the categories of third parties also as described in the table above. Additionally, any information that was included in any Public Area during the last 12 months has been viewable by the public.
16.4 Sales of CCPA information:
16.4.1 If you are a professional, your CCPA information (as described in the table above) may be sold (as defined above) to practice transformation plan partners for the business or commercial purpose of facilitating your receipt of products and services from such practice transformation plan partners to help you market your services, including services that utilize Cynosure devices.
16.4.2 In the preceding twelve (12) months, Cynosure has sold the following categories of CCPA information (as described in the table above) relating to professionals to practice transformation plan partners:
16.4.2.1 Category A – Identifiers;
16.4.2.2. Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
16.4.2.3 Category D – Commercial information; and
16.4.2.4 Category G – Professional or employment-related information.
16.4.3 Cynosure does not have actual knowledge that it sells the CCPA information of minors under the age of 16.
16.5 California Residents’ Rights and Choices: The CCPA provides California residents with specific rights regarding their CCPA information. This Section 16.5 describes your CCPA rights (to the extent applicable to you) and explains how to exercise those rights.
16.5.1 Access to Specific Information and Data Portability Rights: You may have the right to request that Cynosure disclose certain information to you about our collection and use of your CCPA information over the past 12 months. Once we receive and confirm your verifiable request (in the manner described in Section 16.6 below), to the extent required by the CCPA, we will disclose to you:
16.5.1.1 The categories of CCPA information we collected about you.
16.5.1.2 The categories of sources for the CCPA information we collected about you.
16.5.1.3 Our business or commercial purpose for collecting that CCPA information.
16.5.1.4 The categories of third parties with whom we share that CCPA information.
16.5.1.5 The specific pieces of CCPA information we collected about you (also called a data portability request).
16.5.1.6 If we disclosed your CCPA information for a business or commercial purpose, a list disclosing disclosures for a business or commercial purpose, identifying the CCPA information categories that each category of recipient obtained.
We will not provide the foregoing access and data portability rights for B2B CCPA information prior to such date required by the CCPA.
16.5.2 Deletion Request Rights: You have the right to request that Cynosure delete any of your CCPA information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable request from you (if you are a California resident) in the manner described in Section 16.6 below (“verifiable request”), we will delete (and direct our service providers to delete) your CCPA information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
16.5.2.1 Complete the transaction for which we collected the CCPA information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
16.5.2.2 Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
16.5.2.3 Debug products or services to identify and repair errors that impair existing intended functionality.
16.5.2.4 Exercise free speech, ensure the right of another individual to exercise their free speech rights, or exercise another right provided for by law.
16.5.2.5 Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
16.5.2.6 Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
16.5.2.7 Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
16.5.2.8 Comply with a legal obligation.
16.5.2.9 Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will not provide the foregoing deletion rights for B2B CCPA information prior to such date required by the CCPA.
16.6 Exercising Access, Data Portability, and Deletion Rights:
16.6.1 To exercise the access, data portability, and deletion rights described in Section 16.5 above, please submit a verifiable request to us by either: (1) calling us at 800.886.2966; (2) visiting https://www.cynosurecanada.com/; or (3) contacting us in accordance with Section 15. Only you, or someone legally authorized to act on your behalf (such as an authorized agent), may make a verifiable request related to your CCPA information. You may also make a verifiable request on behalf of your minor child. You may make a verifiable request for access or data portability no more than twice within a 12-month period. The verifiable request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected CCPA information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with CCPA information if we cannot verify your identity or authority to make the request and confirm the CCPA information relates to you. Making a verifiable request does not require you to create an account with us. We will only use CCPA information provided in a verifiable request to verify the requestor’s identity or authority to make the request. In the event you make a request under this Section 16, we may take various approaches to verify your identity depending on the nature of your request. These approaches may include initiating telephone calls with you or reaching out to by email or otherwise to ask you questions pertaining to the information we have about you. For instructions on exercising sale opt-out rights, see Section 16.7 below.
16.6.2 We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your CCPA information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you of the reason for refusing the request.
16.7 CCPA Information Sales Opt-Out and Opt-In Rights:
16.7.1 If you are 16 years of age or older, you have the right to direct us to not sell your CCPA information at any time (the “right to opt-out”). We do not sell the CCPA information of California residents we actually know are less than 16 years of age. California residents who opt-in to CCPA information sales may opt-out of future sales at any time.
16.7.2 To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:
Do Not Sell My Personal Information
16.7.3 Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize CCPA information sales. However, you may change your mind and opt back in to CCPA information sales at any time by visiting the following Internet Web page link:
https://www.cynosurecanada.com/ccpa-information-request/
16.7.4 You do not need to create an account with us to exercise your opt-out rights. We will only use CCPA information provided in an opt-out request to review and comply with the request.
16.8 Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights, including, unless permitted by the CCPA, by:
16.8.1 Denying you goods or services.
16.8.2 Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
16.8.3 Providing you a different level or quality of goods or services.
16.8.4 Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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