California Consumer Privacy Act of 2018

Strata Skin Sciences(“we”, “us”, “our”) is required by the California Consumer Privacy Act of 2018 (“CCPA”) to explain to California residents (“Consumers”) about online and offline practices with regard to how we collect, use and share their personal Information, and about the rights and choices we offer them regarding our handling of the personal information.

 

Personal Information Defined

When we use the term personal information in this notice, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:

  • Information that is lawfully made available from federal, state, or local government records.
  • Information that is de-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, including:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or certain clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
    • Other information subject to an exemption from the CCPA’s coverage, such as certain business contact information.

 

Personal Information We Collect, Use and Share

Strata Skin Sciences does not sell personal information.

  • Cookies and other Tracking Tools
    • We use cookies and other tracking tools to analyze website traffic and facilitate advertising.  If you would like to opt out of our use of cookies follow the instructions when you first access the page.
  • Directed Disclosures
    • When patients share their information with us in the context of interacting with us, it is with the understanding that we will use that information to help direct them to the appropriate service or to assist them in problem resolution. Facilitating these engagements is a core part of our business.

How we collect, use and share personal information about Consumers.

The CCPA requires that companies disclose their collection and use of specific categories of personal information enumerated in CCPA.  Here is a summary of how we currently collect, use and share personal information, and how we have used and shared the information in the preceding 12 months. Strata is required by the CCPA to explain to Consumers about online and offline practices with regard to how we collect, use and share their personal Information, and about the rights and choices we offer them regarding our handling of the personal information.

 

Personal Information Defined

When we use the term personal information in this notice, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:

  • Information that is lawfully made available from federal, state, or local government records.
  • Information that is de-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, including:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or certain clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
    • Other information subject to an exemption from the CCPA’s coverage, such as certain business contact information.

 

Personal Information We Collect, Use and Share

HOW WE USE COLLECTED PERSONAL INFORMATION

We may use your Personally Identifiable Information to:

  • Contact you with information about our products, Services or your transactions;
  • Send e-mail alerts or newsletters;
  • Provide you with customer service;
  • Send you marketing communications or administrative information;
  • Facilitate social sharing functionality that you initiate;
  • Cooperate with law enforcement. If law enforcement officials or judicial authorities request that we provide Personal Information, we may do so.

In matters involving claims of personal or public safety or in litigation where the information is pertinent (including to allow us to pursue available remedies or limit the damages that we may sustain), we may use or disclose Personal Information, including without court process. We may also use or disclose Personal Information to enforce our Terms and Conditions or other agreements, to protect our operations or those of any of our affiliates, or to protect our rights, privacy, safety or property and/or that of our affiliates, you, or others; or investigate security breaches or otherwise cooperate with authorities.

 

California Residents’ Privacy Rights

The CCPA grants Consumers with certain rights, which are subject to certain limitations and exceptions. This section describes these rights.  If we are not able to complete some or all of a Consumer’s verifiable consumer request, we will communicate the reason to the Consumer in writing.  We treat all doctors and other healthcare providers who visit our websites as representatives of their business (whether sole proprietor or otherwise), who provide information through our websites in their business capacity, and this section does not apply to information related to such business contacts.

  • Information.  Consumers can request information about the personal information we have collected about them and how we have used and shared their Personal Information during the past 12 months.
  • Access.  Consumers can request a copy of the personal information that we have collected about them over the past 12 months.  In certain cases, we are not permitted by the CCPA to provide you with certain sensitive information in response to an access request, such as your social security or driver’s license number.
  • Deletion.Consumers can ask us to delete the personal information that we have collected from them.  In certain circumstances, the CCPA allows us to deny Consumer requests to delete their personal information, such as where we need the information to complete a transaction for which the personal information was collected or where we need the personal information to comply with a legal obligation.

Consumers are entitled to exercise the rights described above free from discrimination.

 

How to Submit a Verifiable Consumer Request

  • To request access to or deletion of personal information, Consumers can contact us as follows:
    • STRATA Skin Sciences, Inc.
      Attn: Compliance Manager
      5 Walnut Grove Drive, Ste. 140
      Horsham, PA 19044
      Email:  jsturm@strataskin.com

You may also contact the STRATA Patient Advocate Team at the following:

    • STRATA Skin Sciences, Inc.
      Attn: Patient Advocate Team
      2365 Camino Vida Roble, Suite B
      Carlsbad, CA 92009
      Phone: 1-800-974-8958
      E-mail: PatientAdvocate@strataskin.com

 

  • Identity verification. The CCPA requires us to verify the identity of the individual submitting a Consumer request to access or delete personal information before providing a substantive response to the request.  Where possible, we will attempt to verify your identify by asking you to confirm information that we have on file about your or your interactions with us.  Where we must ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer. You do not need to create an account with us to exercise your rights
  • Authorized agents.  You can designate an “authorized agent” who has registered with the California Secretary of State to submit verifiable consumer requests on their behalf.  You can also make a Consumer request on behalf of your minor child. We will require the authorized agent to have a written authorization confirming that authority.

 

How We Respond to Verifiable Consumer Requests

We will acknowledge receipt of your verifiable consumer request within 10 days of our receipt of your request, and we will endeavor to substantively respond within 45 days of our receipt of your request. If we need to extend our response time (up to 90 days from receipt of your request), we will inform you in writing of our reasons for doing so. We will deliver your personal information via your online account with us, if you have one, or by other secure electronic means. If we are unable to process your verifiable consumer request in whole or in part, we will explain our reasons for doing so.

Please note that we do not typically charge a fee to respond to verifiable consumer requests unless they are excessive, repetitive, or manifestly unfounded. If we determine that your verifiable consumer request warrants the assessment of a fee, we will inform you of the reasons supporting our determination and provide you with our estimate of the costs to fulfill your request before we take action to enable you to determine whether you would like us to complete your request.

 

Requesting Additional Information

If you have any questions or comments about this notice or how we handle personal information, you may contact us via mail at:

STRATA Skin Sciences, Inc.
Attn: Compliance Manager
5 Walnut Grove Drive, Ste. 140
Horsham, PA 19044
Email:  jsturm@strataskin.com

You may also contact the STRATA Patient Advocate Team at the following:

STRATA Skin Sciences, Inc.
Attn: Patient Advocate Team
2365 Camino Vida Roble, Suite B
Carlsbad, CA 92009
Phone: 1-800-974-8958
E-mail: PatientAdvocate@strataskin.com

 

Changes to This Privacy Notice

We reserve the right to make changes to this Policy at any time. Each time any changes are made, the revised Policy will be posted to our website(s) under the “Privacy Policy” link at the bottom of each webpage(s). All revisions will be effective immediately upon release of the new Policy. Your use of our website(s) after we post a revised version of the Policy means that you accept the revised version and associated Terms of Use.