1. Introduction

Paige Inc. (“We”, “Our”, “Us”) is a company that provides positive aging expertise in cosmetic skin health through a simple, accessible, and world class consultation experience using web-based and mobile software applications. Our consultation applications use inputted data to generate a visual representation of the user, which can be manipulated to achieve a desired cosmetic goal. Because We respect the right to privacy, We have developed this Privacy Policy (“Privacy Policy”) to inform web visitors, customers, and users of our consultation software (“You”, “Your”) about Our privacy practices regarding the data collected in relation to the use of Our website, located at www.consultpaige.com (the “Website”) and our cosmetic consultation mobile and web-based software applications (the “Apps”) and associated services, including Paige^TM (collectively the “Services”). These Services may be used to directly or indirectly distinguish, identify, or contact a specific individual (“Personal Information”). We may collect and store Personal Information in order to provide access to and use of the Services.

2. Scope of This Privacy Policy

In keeping with Our commitment to Your privacy, this Privacy Policy will apply to:

• The type of information We collect, use, and disclose;
• How the information We gather is used and to whom it is disclosed;
• Your ability to opt-out of future notifications and withdraw consent;
• Security procedures We have put in place to protect Your information from loss, misuse, or alteration.

3. Our Commitment to Privacy

We recognize the importance of privacy and are committed to protecting the privacy of all of those who use Our services. This Privacy Policy sets out our practices regarding the collection, use and disclosure of Personal Information in connection with the Website and the Services. If You are using the Website or the Services, You may be asked to provide Personal Information. Please note, that We are asking for this information for the limited purposes as defined in this Privacy Policy. By using Our Website or Services, You consent to Our collection use and disclosure of Your Personal Information in accordance with the terms of this Privacy Policy. We do not sell the information You provide to any third party without Your consent.

4. Application

This Privacy Policy applies to all information We collect for the purpose of providing access to and use of the Website and the Services. We may require the involvement of trusted third parties required to facilitate the provision of the Website and the Services.  We strive to provide the highest level of privacy possible, and therefore require that any third parties offer no less protection than that offered in this Privacy Policy and as otherwise required by law to meet the data protection requirements of relevant Canadian laws.

5. Information We Collect From You

• How We Collect Information from You

We collect information from You when You interact with the Services through:

• • Access to Our Services: To access Our Services, You may be required to provide Personal Information, including your name, age, sex, date of birth, and other identifiable information. Access to Our Services may also require You to provide payment information if You chose to engage with any of Our paid Services.
  • Using Our Services: Obtaining a digital consultation through Our Services using either Our Apps may require the disclosure of Personal Information, including identifiable photographic information, data regarding facial features, geolocation information, and the completion of a questionnaire.
  • Communicating with Us. You may disclose information to Us via direct email or verbal communication in connection with the Services.
  • Visiting the Website. When You visit the Website, We may collect non-identifiable information about Your visit.
  • Marketing and Promotions: We may collect Your information for marketing purposes by sending You news and promotional materials about Our Services or the services or products of third parties.

• Personal Information

We may collect Personal Information from You that You voluntarily submit to Us, including information that You provide when engaging with any of our Services. We do not collect any Personal Information from a visitor to Our Website unless that visitor explicitly and intentionally consents to providing it. Under no circumstances do We collect any sensitive personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sexual orientation. If You are simply browsing our site, We do not gather any personal information about You.

Personal Information will only be collected for specific identified purposes and consented to at the time of collection or as otherwise outlined in this Privacy Policy.

• Facial Data

Types of facial data we collect: When You use the Apps, You have the option of obtaining a cosmetic consultation. In order to provide You with a cosmetic consultation, You will be asked to provide photos and dermatological information associated with Your facial skin health (“Facial Data”). The Facial Data We collect may include:

• Facial images
• Age of the skin
• Skin tones
• Skin conditions
• Severity of Skin Conditions
• Application-generated results of skin treatments

Facial Images: We collect facial images from the photos that You upload from Your mobile device or computer while using Our Apps. We do not obtain images from You unless You explicitly allow the Apps to access your stored photos or the camera on Your device. We only process the specific photos that You choose to provide for the cosmetic consultation provided through the Apps; We do not collect any other photo or video albums stored on Your device, even if You have granted the Apps access to these albums.

Other Facial Data: We may collect Facial Data based on the questionnaire responses You provide, or extract data related to Your facial features (e.g., skin tone, skin condition and severity, age-related skin information). Facial feature data collected from the photos You provide are used only to provide You with the Services.

Please note: We do not use Your Facial Data for facial recognition purposes or the process biometric data to identify or authenticate an individual.  

Purposes for the collection of Facial Data: We use the Facial Data You provide through the Apps only for the identified purposes in this Privacy Policy. We may use Facial Data for the following purposes:

• To understand and assess Our users and market
• To improve Our technology
• To guide the physicians within Our network
• To enhance the user experience
• To create anonymous, aggregated, or de-identified data

We only disclose or sell Facial Data to third parties once it has been rendered anonymous, de-identified or aggregated, and always in strict compliance with applicable laws.

De-Identified Information

We may de-identify Your Personal Information by removing any identifier of a specific individual, such that it no longer falls within the definition of Personal Information (“De-identified Information”). We may use De-identified Information for the purposes of reporting and analyzing how users interact with the Apps and/or for other research purposes, including research regarding various dermatological conditions disclosed through the Apps. We may share De-identified Information and resulting reports and analyses publicly and with other third parties.

Aggregate Data

We may use De-Identified data that has been compiled and aggregated (“Aggregate Data”) within the Services for the purposes of enhancing the Service, performing aggregated statistical analysis, technical support, and other business purposes. We may use, reproduce, sell, publicize, or otherwise exploit such Aggregate Data.

6. Purposes for Which We Collect and Use Your Information

• Facilitating the Use of Our Services: When you interact with the Services through Our Apps, We may collect Personal Information, including Facial Data, for the purpose of verifying Your identity, providing a You with a cosmetic consultation through Our Services, or transferring Your information to our clinical partners. We use this information to operate, maintain, and provide You with the features and functionality of Our Services.

• Facilitating Contact with a Medical Practitioner: When you interact with the Services, in addition to providing a facial photo, You may be asked to complete a questionnaire, disclosing Facial Data and other Personal Health information. “Personal Health Information” includes but is not limited to information regarding any skin conditions, medications or other treatments You may be taking, and other relevant medical information that You disclose to Us. The responses to this questionnaire are collected for the purpose of providing the Services and related consultation reports. This information is also collected for the purpose of facilitating contact with a local medical practitioner. We will request Your consent prior to disclosing any Personal Health Information with a medical practitioner.

• Privacy Policies of Third-party Medical Practitioners: We require any third-party medical practitioners to whom we disclose Personal Information, including Personal Health Information and Facial Data, to comply with privacy standards that are equal to or exceed the protections afforded under this Privacy Policy. All third-party medical practitioners affiliated with the Apps are required to adhere to the legal requirements for the collection, use, retention, and disclosure of Personal Information and Personal Health Information under PIPEDA and the Personal Health Information Protection Act (PHIPA, Ontario) or equivalent legislation. The privacy practices of the third-party medical practitioner to whom we disclose any Personal Information or Personal Health information will be provided at the time You consent to such disclosure for the purposes outlined in this Privacy Policy. We recommend that You thoroughly review these practices before consenting to the disclosure of Your Personal Information to any third-party medical practitioners.

• Communicating with You: We may use the information that You disclose to Us to communicate directly to You to respond to any inquiries (e.g., support requests or account verification) or service-related emails (e.g., technical and security notices). This communication is necessary for our legitimate interests, namely administering the Services and communicating with You in relation to the Services. We may also use Your information to send You communications regarding news, alerts, and marketing communications. We will only process Your Personal Information in this manner to the extent that You have given Us consent to do so and will only communicate with You in accordance with applicable anti-SPAM legislation.

• Payment processing, Hosting and Related Services: Third-party vendors and other service providers may be required for one or more of Our Services, including web hosting, payment processing, email, phone, and other risk service providers. If payments are processed through credit card or electronic funds transfer, You may be required to provide Your Personal Information, including credit card details to appropriate financial institutions, processors, and trusted third parties under contract with Us for providing payment. In each case, the distribution of Your Personal Information will be used by such entity for its internal use related to fulfilling the transaction services for Us, will be treated as confidential by this entity, and will be provided to this entity only via encrypted means. Please note, that this information is only used to facilitate transactions. We do not have access to or store any payment information provided to third parties through Our applications or website. We recommend carefully reviewing the Privacy Policies and Terms of Use for any third-party payment services prior to providing any Personal Information to these entities.

7. Consent to the Collection of Personal Information and Personal Health Information

We use Your Personal Information and Personal Health Information only with Your meaningful legal consent, except as otherwise permitted or required by law. The consent provided for the use of Personal Information is for the specified, explicit, and legitimate purposes as outlined in this Privacy Policy, and/or as otherwise specified prior to Your providing express consent. You may withdraw Your consent to the use of Your Personal Information by contacting Our Privacy Officer by emailing info@consultpaige.com. When We collect information from You, You will be given the opportunity to opt-out of receiving further information from Us or any associated third party. We will explain the consequences if You decide to withdraw Your consent for Us to use Your Personal Information. Any request to withdraw consent will be processed within the legally required time periods.

You may explicitly and intentionally provide Us with, and consent to, Our collection of certain Personal Information by:

• E-Mail Request for Information: We use links throughout our site to provide You with the opportunity to contact Us via e-mail to ask questions, request information and materials, or provide comments and suggestions. You may also be offered the opportunity to have one of Our representatives contact you personally to provide information about Our Services. To do so, We may request additional Personal Information from You, such as Your name, email address, and/or telephone number, to help Us satisfy your request.
• Download and Use of Services: If you choose to download and/or use the Services, We will request certain information from You. For certain Services, We may require Your name, e-mail address, date of birth, gender information, photograph, and other skin-related information, including Facial Data, to facilitate a cosmetic consultation.

By corresponding with us, downloading, accessing, or otherwise using the services, you consent to our collection, use, and disclosure of your Personal Information in accordance with the terms of this privacy policy.

8. New Consent Required

In the event that Personal Information or Personal Health Information is required for a new purpose, We will disclose the new purpose and request consent to collect Personal Information.

9. No Consent Provided

Although not legally required to provide Personal Information or Personal Health Information, We reserve the right to withhold or deny Services where the appropriate Personal Information is not provided to carry out the associated purpose.

10. Withdrawal of Consent

You can withdraw Your consent to the collection, use, and disclosure of Your Personal Information or Personal Health Information at any time by contacting Us and informing Our Privacy Officer at privacy@consultpaige.com. Please note that Your withdrawal of consent may impact Our ability to provide You with the Services.

11. Disclosure without Consent

We will only disclose Your Personal Information and Personal Health Information without consent to third parties, government authorities, or law enforcement to the extent that We are permitted or required to do so by law.

12. Accuracy of Collected Information

We implement policies and procedures to ensure that the Personal Information and Personal Health Information in Our possession is accurate, complete, and up-to-date. You can submit updates to Your Personal Information and Personal Health Information to Our Privacy Officer at any time. Any changes to information in Our possession that is used by trusted third parties to facilitate Our Services will also be updated of any new changes.

13. Access to Personal Information

An individual may request access to the Personal Information that We hold about themselves at any time. We will respond to requests for access promptly and within the legally mandated time frame subject to any refusals permitted or required by law. Any refusals to grant access will be accompanied by associated reasons and information regarding available recourse. Requests for access to Personal Information can be directed to Our Privacy Officer at privacy@consultpaige.com.

14. Retention of Personal Information

We retain Personal Information only for as long as needed to perform the purposes identified in this Privacy Policy. Once Personal Information is no longer required for the purpose for which it was collected, or if consent is withdrawn, We will apply all commercially reasonable safeguards to safely and securely destroy said Personal Information.

• Retention of Facial Data: We recognize the highly sensitive nature of any Facial Data that You provide to Us through the Apps. That is why facial images are only stored on the Paige Inc. server until You have obtained a cosmetic consultation report. Any anonymized, aggregated or de-identified facial images and other Facial Data that is not photos will be stored on the Paige Inc. server for as long as necessary to fulfil the purposes identified in this Privacy Policy or as otherwise required by applicable law. All retained Facial Data is encrypted and subjected to all appropriate safeguards as described in this Privacy Policy.

15. Public Access of Our Website and Services

We provide public access to information regarding the Services via the Website.

• Statistical Information About Your Visit: When You visit Our Website, Our computers may automatically collect statistics about Your visit. This information does not identify You personally, but rather provides Us with information about Your visit to Our Website. We may monitor statistics such as how many people visit our site, the user’s IP address, which pages people visit, from which domains our visitors come, and which browsers people use. We use these statistics about Your visit only to help Us improve the performance of the Website.
• Use of Cookies: We only use “cookies” as described in this section. A “cookie” is a piece of information that our Website sends to Your browser, which then stores this information on Your system. Cookies are required to provide access Our Website. When Your browser window is closed; however, the cookie is automatically deleted from Your system. You should be aware that cookies contain no more information than You volunteer, and they are not able to access Your hard drive and return to the sender any personal or other information from Your computer.

You have the option to restrict or deny the use of cookies on the Website through Your browser settings; however, this may result in the inability to access or otherwise interfere with the use of the Website.

• Linked Third Party Websites: The Website may contain links to third party sites. We are not responsible for the privacy practices, privacy statements, acceptable use policies, or any other content regarding these other sites. We strongly recommend that You read the privacy policies and terms and conditions of use of any third party to understand how they collect, use, and share information.

16. Opting Out of Future Notifications

From time-to-time, We may notify You of new products, announcements, upgrades, and updates. If You would like to opt-out of being notified, please contact Us via info@consultpaige.com.

17. Security Procedures and Safeguards

We consider the protection of all data and Personal Information We receive from You as critical to Our corporate mission. Please be assured that We have security measures in place to protect against the loss, misuse, and alteration of any information We receive from You in accordance with applicable law.

• Procedural Safeguards: We maintain physical, electrical, and procedural safeguards in connection with the collection, disclosure, storage, use, and deletion of Personal Information. Proof of identity may be required upon request to disclose Personal Information to You. You should protect against the theft of Your Personal Information through safeguarding Your passwords and devices.
• Technological Safeguards: As with any transmission over the Internet, there is always some element of risk involved in sending Personal Information. To try and minimize this risk, We encrypt all information that You submit in relation to Our Services. Our Website uses the Secure Sockets Layer (SSL) protocol. Your data is stored on the Paige Inc. server located in a secure facility in Ottawa, Ontario, Canada. All data, including Facial Data, stored on the Paige Inc. server is encrypted both in transit and at rest.
• Personnel Safeguards: Our employees who have access to Personal Information receive privacy training and are required to respect the confidentiality of such information pursuant to their employment agreement with Us. Restrictions to access to Personal Information at the personnel level include restricted access to physical locations in which Personal Information is held, as well as technological protections (e.g., passwords). Disclosure and access to Personal information by personnel is limited to the extent required to reasonably fulfill the specific purposes for which it was provided.

18. Notification of a Security Breach

In the event of a security breach of the above mentioned safeguards involving Personal Information in Our control, notice of the breach will be provided without undue delay to the affected individual(s) in accordance with applicable law.

19. Changes to this Privacy Policy

We may revise or update this Privacy Policy from time to time. If a material change is made to this Privacy Policy and/or the way We use Your Personal Information or other data, We will post prominent notice of the nature of such changes on the first page of this policy.

20. Inquiries Regarding This Privacy Policy

Questions, complaints, or requests for further information regarding this Privacy Policy or Our practices related to the collection of Personal Information should be directed to the Privacy Officer at privacy@consultpaige.com. Please specify “Privacy Policy” in the subject line of Your email. All complaints We receive related to Personal Information are investigated.

This Privacy Policy was last modified on July 18, 2023.