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Privacy Policy

Effective Date: November 18, 2020

 

REJUUV MEDI SPA is committed to protecting the personal information (includes personal health information) that our customers provide us.

This Privacy Notice (“Notice”) explains how we collect, use and disclose the customer’s personal information.  The information contained in this Notice applies to the customer if the customer has visited REJUUV MEDI SPA, called, or emailed us and provided us with the customer’s personal information.

 

 

  • Scope and application: 

This policy relates to the customer personal information collected by REJUUV MEDI SPA INC, as well as their websites, mobile applications and banners. Throughout this policy, we collectively refer to these as “Rejuuv”, “we”, “us” or “our”. 

In this policy, we describe what personal information we collect; how we use, share and manage it; how you can access, update and/or correct your personal information; the privacy choices available to you; and the specific privacy notices relating to certain programs and services that provide you with more information.

Please also refer to any privacy statements available at our websites available to you at the time your personal information is collected. Please note that specific privacy notices and/or additional terms and conditions may apply to how we are collecting and managing your information when you engage with some of our programs, products, services, promotions, contests and/or events. Those specific privacy notices and/or terms and conditions will apply together with this policy. You are required to accept terms and conditions when you register for our Rejuuv Loyalty Programs and or Rejuuv Membership Programs.

 

2. SECURITY AND CONFIDENTIALITY 

We restrict the access to personal information to only the employees who need to know that information for the purpose described below. We maintain physical and electronic safeguards that comply with applicable laws to safeguard the customer’s personal information.  To the extent we contract with third party service providers, we ensure that appropriate privacy protection is in place to safeguard against any inadvertent access to the customer’s personal information.

 

3. PURPOSES

We collect and use the customer’s personal information for the purposes of providing direct client health care; planning, administration and management of REJUUV MEDI SPA services; client billing; conducting quality improvement activities (such as sending client satisfaction surveys); compliance with legal and regulatory requirements; and as permitted or required by law (hereinafter referred to as the “Purpose”).

 

4. INFORMATION WE COLLECT AND USE

REJUUV MEDI SPA limits the collection of personal information to only the necessary information to fulfill the Purpose identified and in accordance with the requirements set out by applicable law.

Personal information is collected directly from the customer, unless the law permits or requires collection from third parties, custodians or other healthcare providers.

We may ask to collect the following personal information from the customer:

  • relating to the customer’s physical or mental health, including information that consists of the health history of the customer’s family;
  • relating to the provision of health care, including the identification of a person as a provider of health care to the customer;
  • relating to payments or eligibility for health care, or eligibility for coverage of health care;
  • relating to the donation of any bodily substance or derived from the testing or examination of any bodily substance;
  • relating to the customer’s health number; and
  • relating to a person who is acting on the customer’s behalf for treatment purposes (or the customer’s next-of-kin, if appropriate).

In each case we use this personal information for the Purpose, and as otherwise permitted or required by applicable law.

We collect personal information, as defined below, in a variety of ways, including: directly from you, from third parties, through in-store technologies, and when you are interacting with us online or through our mobile applications.

“Personal information” is any information that identifies you or could be reasonably associated with you. The personal information we collect may include contact information such as your name, email address, home address, and phone numbers, as well as information about the specific products and services that you purchase in our spas or from us online, information provided to us in connection with our programs, products and/or services and/or information collected automatically when you interact with us online or visit our various spa locations. 

Personal Information that we collect may include:

Personal transactional information, when you make purchases such as products, treatment package, account transactions and the merchants (name, type and location) that you made purchases from. This type of information is also generated by the use of your loyalty and e-commerce accounts and may include information about your purchases

Personal health information, through the use of any of our healthcare services provided by doctor, nurses, nurse practitioners, healthcare providers which includes any information that identifies or can identify you and relates to the state of your health or the treatment you are receiving. More specifically, personal health information means treatment and care information, and/or registration information with our services. 

 

5. HOW WE COLLECT PERSONAL INFORMATION

We collect personal Information In the following ways: 

Directly from you: 

You may provide personal information to us in our spas, by mail, by email, over the telephone, through our websites or mobile applications or in any other direct manner.

When you voluntarily share information about yourself with us, we will collect that information in order to provide you with our programs, products or services, respond to your inquiry, or for any other purpose disclosed to you at that time.

From Used Technologies at Our Locations 

We may collect personal information through various types of technologies used in our spas. These can include our point-of-sale systems, sales, consultant’s iPad, work phone, treatment or assessment devices, video surveillance. which we may use from time to time.

Through Our Website and Mobile Applications 

We may collect certain types of information electronically when you interact with our websites, email, mobile applications, social media accounts, online advertising, or through the use of our or a third party’s technologies, which include cookies, web beacons, single pixel gifs and other technologies such as Data Management Platforms (DMPs). This information helps us understand what actions you take on our websites and mobile applications and allows our websites and mobile applications to work correctly.

 

We may combine this information with other information collected in our spas or online such as your online and in-store transaction history. We do this to support our customer understanding using website and mobile analytics and to provide you with more tailored advertising and marketing campaigns. This includes serving interest-based advertising to you, subject to your right to withdraw consent, as detailed in our Interest-Based Advertising and Media Notice.

We may use Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses cookies to analyze your use of our websites, to create reports about visitor activities for us and to provide further services associated with the use of the websites and the Internet. Although this information is collected through your Google ad settings, it is not provided to us in a personally identifiable format.

You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features on our websites.

 

6. HOW DO WE USE PERSONAL INFORMATION 

We use your personal information to provide you with our programs, products and services, promotions and recommendations to manage our business operations, to communicate offers and information we think might interest you, to generally enhance your customer experience with us, and as permitted or required by law.

We use your information for the following purposes

  • Providing Reward Programs, Products, Services and Recommendations 

  • We use your personal information in order to provide you with our programs, products and services, which include:
  • Providing you with a quote for a treatment package, reward programs, product or service;
  • Verifying your identity;
  • Determining your eligibility for a reward program, product or service;
  • Processing your applications;
  • Creating, administering, and maintaining your accounts (such as for loyalty or any other reward programs);
  • Processing your transactions online or in spa;
  • Fulfilling your product and service requests, inquiries, and purchases;


  • Managing Our business 

  • Deploying and managing our information technology applications and systems, including managing our websites;
  • Managing and facilitating the use of our websites and mobile applications, which may include using cookies and other similar technology;
  • Enabling your participation in contests, promotions, surveys, chats, seminars or workshops;
  • Maintaining the security of the public and our customers, employees and property (e.g., through video surveillance);
  • Monitoring and investigating incidents and managing claims;
  • Maintaining our programs, products and services, including our loyalty programs and our health and spa services.
  • Meeting our legal and regulatory obligations.


  • Communicating with you

  • Providing you with information and updates about our programs, products, services, promotions, contest, and events. 
  • Responding to your inquiries; 
  • Taking or verifying instructions from you; 
  • If we have your consent, informing you inn a variety of ways (e.g. email, telephone, SMS, direct mail, Wechat, social media platforms, mobile chat applications) about programs, products, services,, special offers, promotions, contents, events that may be of interest to you.
  • Delivering interest-based advertisements relating to our products and services or third party products and services that may be of interest to you. 
  • Subject to your right to withdraw consent, providing you with offers or services based on the approximate location provided by your mobile device (also called “location-based advertising”)

 

D. Conducting Market Research 

  • We may use your personal information in order to conduct market research by tracking and analyzing current or previously collected information to improve or to develop new products, services, programs, promotions, contests or events, and to better understand our customer base. When doing so, we generally will use your information in an aggregated format or with direct personal identifiers removed.
  • The information we use for market research may include:
  • Purchase history (e.g. the number and amount of transactions by type, location of purchase, product information, brand, quantity purchased, date, time, payment method used, promotional offers used in connection with the transaction, etc.);
  • Website or mobile application activities (e.g. offers viewed, opt-out preferences, email bounce backs, click-throughs, content on social media, and IP addresses);
  • Account activity, balances and payment history;
  • Use of mobile devices interacting with our websites or mobile applications (e.g. use of features, and duration, frequency, type and location of calls and text messages); and
  • The methods used to apply for or to access or use our programs, products, services, promotions, contests or events.


  • Conducting Data Analytics 

  • We may use your personal information in order to conduct data analytics for business purposes, such as:
  • Managing and developing our business and operations;
  • Improving our programs, products, and services (e.g. improving our websites);
  • Understanding customer needs and preferences and customizing how we tailor and market products and services to our customers based on their interests; and
  • Measuring the effectiveness of our marketing.

 

7. INFORMATION WE DISCLOSE

REJUUV MEDI SPA operates within the Circle of Care model. This means that implied consent is assumed when providing health care or assisting in providing health care within the Circle of Care (to a health information custodian or to a person who is responsible for providing continuing treatment and care to the customer). This is true unless REJUUV MEDI SPA is made aware that the customer has specifically withdrawn or withheld the customer’s consent.

Further, we will disclose the customer’s personal information to institutions, persons or entities that are not part of the Circle of Care (not for the purposes of providing direct health care) only if customers give us express consent to do so.  We will only collect, use and disclose the customer’s personal information as permitted or required by applicable law.

We may share your personal information with our service providers (companies operating on our behalf) and other third parties (companies with which we provide programs, products or services) for the purposes described in this policy and in accordance with applicable law. We do not sell your personal information to any organization or person; the only exception to this would be if we sell or transfer any part of our business.

A. Service Providers 

In the course of providing our programs, products, services, promotions, contests and events we may share personal information with our service providers. These service providers help us operate our business, technology systems and applications, internal procedures, infrastructure and advertising and marketing. They provide services to us such as data hosting, contest administration, email deployment, call centre, marketing, sales and processing or analysis of personal information. We require these service providers to limit their access to and/or use of personal information to what is required to provide their services and to comply with our privacy requirements.

 

 B. Third Parties 

In the course of providing certain of our programs, products and services, we may do so through arrangements with third parties. As a result, your personal information may be collected, used and shared by us and the applicable third party. These third parties may have their own privacy policies and terms and conditions, which will govern their use of your personal information. You will be informed upon signing up for the relevant program, product or service of the third party arrangement so that you can review the relevant privacy policies that apply.

 

8. CONSENT

Where the customer does not wish us to collect, use or disclose the customer’s personal information for specified purposes, the customer can opt-out from such collection, use and disclosure.  Please let us know and we will duly incorporate the lockbox (consent directive) in the customer’s health record. The files (could be physical or electronic) containing the customer’s personal information will be securely maintained by REJUUV MEDI SPA and its authorized employees or agents who need to access the information in the administration and provision of the services we provide to the customer.

By subscribing to our programs, products and services and/or submitting information to us in connection with using our programs, products and services, you are providing your consent to the collection, use and disclosure of personal information as set out in this policy. In some cases, your consent may be “implied” i.e. your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information.

 

9. The Customer’s Rights

The customer has the right to access and rectify the information contained in a file held about the customer.

Access to the customer’s Information

To obtain formal access to the customer’s information, the customer must make a request to REJUUV MEDI SPA in writing. We may ask for the customer to provide us with further information to process the request or ask that the customer pay a fee for processing the request as set out in the applicable legislation.

We will make every reasonable effort to assist the customer and to respond openly, accurately and completely.

We will create a record for the customer if:

  • it can be created from information that is in electronic form and it is in our custody or control, using normal computer hardware and software and technical expertise, and
  • creating the record would not unreasonably interfere with the operations of REJUUV MEDI SPA

We may refuse to disclose information to the customer, if:

(a) the record is subject to a legal privilege that restricts disclosure;

(b) another Act or a court order prohibits disclosure;

(c) the information was collected or created primarily in anticipation of use in a proceeding, and the proceeding (including appeals) have not been concluded;

(d) the following conditions are met:

(i) the information was collected during an inspection, investigation or similar procedure, and

(ii) the inspection, investigation, or similar procedure have not been concluded.

(e) granting the access could reasonably be expected to,

(i) result in a risk of serious harm to the customer or another person,

(ii) lead to the identification of a person who was required by law to provide information in the record to us, or

(iii) lead to the identification of a person who provided information in the record to us in confidence.

Please note that under the law, we must make every reasonable effort to respond to a request within a set number of days after receiving the request or within any extended period.

Nothing prevents REJUUV MEDI SPA from granting the customer access to the customer’s personal information if the customer makes an oral request or informal request.

 

10. Correction or Amendment of the customer’s Information

If the customer believes there is an error or omission in the customer’s information, the customer may request in writing that we amend the information.

We must respond to a request to correct a record with a set number of days as set out in the applicable legislation or seek an extended period of time.

We also have the right to refuse to make the correction or amendment as set out by law. If we refuse to make the correction or amendment, we will provide the customer with written notice, including the reasons for the refusal.

We can refuse to make a correction or amendment that has been requested in respect of:

(a) a professional opinion or observation made by a health services provider about the customer, or

(b) a record that was not originally created by REJUUV MEDI SPA.

If we refuse to correct a record, the customer can either:

(a) ask for a review of REJUUV MEDI SPA decision by the Commissioner; or

(b) submit a statement of disagreement setting out the requested correction or amendment and the customer’s reasons for disagreeing with our decision.

In order to exercise this right and in order to obtain information about our privacy practices and about our collection, use and disclosure of personal information, both by us and any service providers we contract with in Ontario or in other provinces, the customer can contact us at our following address.

REJUUV MEDI SPA

Markham: 32 South Unionville Ave., Unit 1009, ON, L3R 9S6

Yonge: 5314 Yonge St., ON M2N 5P9

Yorkville: 135 Yorkville Ave., Unit 1, ON M5R 0C7

 

11. CHANGES TO THE PRIVACY POLICY

We may make changes to this policy from time to time. Any changes we make will become effective when we post a modified version of the policy on our webpage. If we make any significant changes to the policy, we will post a notice on our websites. By continuing to participate in our programs, and/or use our services or purchase our products after the modified version of the policy has been posted, you are accepting the changes to the policy, subject to any additional requirements which may apply. If you do not agree to the changes in our policy, it is your responsibility to stop participating in our programs, and/or using our services or purchasing our products. It is your obligation to ensure that you read, understand and agree to the latest version of the policy. The “Effective Date” at the top of the policy indicates when it was last updated.