Effective Date: September 30, 2025
Aspen Glades Corp., a Delaware corporation (together with its affiliates and subsidiaries, “Nuey,” “Company,” “we,” “us,” or “our”) values your privacy and is committed to safeguarding it in accordance with this Privacy Policy for California Residents (this “Policy”). This Policy supplements our general Privacy Policy and applies exclusively to all website visitors, users, and others who reside in California (“consumers” or “you”). We adopt this Policy, along with our Notice at Collection, to comply with the California Consumer Privacy Act of 2018, as amended (the “CCPA”). Terms defined in the CCPA carry the same meaning when used in this Policy.
What We Collect
Personal Information: “Personal Information” refers to any data that identifies, relates to, describes, references, or could reasonably be associated with a specific consumer, household, or device, either directly or indirectly. Personal Information does not include publicly available information from government records, or data that has been deidentified or aggregated.
Below are the categories and examples of Personal Information we have collected over the last twelve (12) months:
- Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
- California Customer Records information (Cal. Civ. Code § 1798.80), which may include name, signature, Social Security number, physical characteristics or description, address, phone number, passport number, driver's license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information in this category may overlap with other categories.
- Protected classification characteristics as defined under California or federal law, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information).
- Commercial information, including records of property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other similar network activity, such as browsing history, search history, and details about a consumer's interaction with websites, applications, or advertisements.
- Geolocation data, such as physical location or movement information.
- Professional or employment-related information, including current or past job history or performance evaluations.
- Non-public education records, as defined by applicable law, such as grades, transcripts, class rosters, student schedules, identification codes, financial records, or disciplinary files maintained by an educational institution or its agent.
- Inferences drawn from other Personal Information, such as profiles reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Sensory data, such as audio, electronic, visual, thermal, olfactory, or similar information (including video surveillance data collected for safety and security purposes).
Below are the categories and examples of Personal Information we have not collected over the last twelve (12) months:
- Biometric information, such as genetic, physiological, behavioral, or biological characteristics and activity patterns used to create a template or other identifier (e.g., fingerprints, facial recognition data, voiceprints, iris or retina scans, keystroke dynamics, gait), as well as sleep, health, or exercise data.
Sensitive Personal Information: “Sensitive Personal Information” refers to Personal Information that discloses any of the information listed in the categories below.
Below are the categories and examples of Sensitive Personal Information we have collected over the last twelve (12) months:
- Government-issued identifiers, including Social Security number, driver's license, state identification card, or passport number.
- Precise geolocation data, meaning your physical location within an approximate 1,850 feet radius.
- Characteristics of protected classes, such as racial or ethnic origin, religious or philosophical beliefs, or union membership.
- Health-related information, including medical or health details as defined under applicable law.
Below are the categories and examples of Sensitive Personal Information we have not collected over the last twelve (12) months:
- Complete account access credentials, such as usernames, account numbers, or payment card numbers when combined with the necessary access or security code, password, or credentials.
- Communication content, including mail, email, or text message content (unless we are the intended recipient).
- Genetic data.
- Sexual orientation data, including Personal Information related to a consumer's sex life or sexual orientation.
Sources of Personal Information
We collect Personal Information and Sensitive Personal Information from the following sources:
- Directly from you: when you contact us, complete forms, purchase products, or inquire about our services.
- Indirectly from you: by observing your activity on our website or through video surveillance data for security purposes.
- Automatically: as you browse our website, we may collect IP addresses, device identifiers, and data from cookies or other tracking technologies (e.g., page clicks, time on page).
- Business partners, service providers, and third parties: for example, we may receive your email address if someone purchases a gift card on your behalf.
- Publicly available sources.
Use of Personal Information
We may use, sell, or disclose Personal Information for the following purposes:
- To carry out or satisfy the purpose for which the information was provided;
- To operate, support, and enhance our websites, products, and services;
- To deliver customer support and respond to inquiries, including investigating and resolving issues and improving the quality of our responses;
- To tailor your online experience and provide content or offerings aligned with your interests, including targeted advertising on third-party platforms;
- To safeguard the safety, security, and integrity of our websites, services, databases, technology systems, and business operations;
- For testing, research, analysis, and product development, including enhancements to our websites and services;
- To comply with applicable laws and regulations or respond to law enforcement, court orders, or government requests;
- As otherwise disclosed at the time your Personal Information is collected, or as permitted under the CCPA;
- To evaluate or conduct corporate transactions such as mergers, divestitures, restructurings, reorganizations, dissolutions, or other sales or transfers of assets (including bankruptcy or liquidation), where consumer information is among the assets transferred;
- To evaluate candidates for employment and administer onboarding;
- To manage payroll and employee benefit programs, maintain personnel files, and comply with record retention requirements;
- To provide human resources management and related support services and communications;
- To satisfy obligations under labor, employment, tax, workers' compensation, disability, equal employment opportunity, workplace safety, and other applicable state and federal laws;
- To develop, implement, and promote the Company's diversity and inclusion initiatives;
- To conduct workforce, data, and benchmarking analytics;
- To prevent unauthorized access, use, or loss of Company property; and
- To exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.
Reselling Personal Information
The CCPA prohibits third parties from reselling Personal Information unless you have received explicit notice and the opportunity to opt out. We may sell Personal Information to businesses that could in turn resell the information, subject to your right to opt out. For instructions on how to opt out of those sales, please see the section titled “Exercising Your Rights.”
We do not use or disclose Sensitive Personal Information for any purposes other than the “Permitted Sensitive Personal Information Purposes,” defined under the CCPA (see “Right to Limit Sensitive Personal Information” below).
Personal Information Retention
We retain Personal Information for as long as necessary or permitted for the purpose(s) for which it was collected. In determining the appropriate retention period, we consider:
- the duration of our ongoing relationship with you and the provision of services;
- any applicable legal obligation; and
- whether retention is advisable in light of statutes of limitations, litigation, regulatory investigations, or other legal considerations.
Your Rights Under the CCPA
Right to Know: You may request that we disclose information about our collection and use of your Personal Information over the past twelve (12) months. Upon receipt of a verifiable request, we will disclose to you:
- the categories of Personal Information collected;
- the categories of sources from which it was collected;
- the categories of Personal Information sold or shared, and the categories of third parties who received such information;
- the categories of Personal Information disclosed for a business purpose, and the categories of recipients;
- the business or commercial purpose for collecting, selling, or sharing the information; and
- the specific pieces of Personal Information we collected about you (a data portability request).
Right to Delete: You may request that we delete the Personal Information we collected from you, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for us or our service providers to perform permitted functions (e.g., security, debugging, legal compliance).
Right to Correct: You may request that we correct inaccurate Personal Information we maintain about you. We will use commercially reasonable efforts to correct the information on our systems or, where appropriate, delete the information with your consent.
Right to Opt Out: You may direct us at any time to not sell or share your Personal Information with third parties.
Right to Limit Sensitive Personal Information: You may request that we restrict our use and disclosure of your Sensitive Personal Information to the “Permitted Sensitive Personal Information Purposes,” which include:
- Providing goods or services that an average consumer would reasonably expect when requesting such goods or services;
- Detecting, preventing, and investigating security incidents;
- Resisting malicious, deceptive, fraudulent, or illegal actions and prosecuting those responsible;
- Ensuring the physical safety of individuals;
- Short-term, transient use, including non-personalized advertising shown during your current interaction with us, provided the information is not disclosed to another third party, used to build a profile about you, or otherwise alters your experience outside your current interaction with us;
- Performing internal business functions (e.g., servicing accounts, fulfilling orders, verifying customer information, processing payments, conducting analytics, storing data);
- Maintaining, verifying, or improving the quality, safety, or functionality of our products, services, or devices; and
- Other purposes that do not infer characteristics about you.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny goods or services, charge different prices or rates, or provide a different level or quality of goods or services.
Exercising Your Rights
Right to Know, Delete, or Correct: To exercise your right to know, delete, or correct, please email us at privacy@nueyaesthetics.com.
Right to Opt Out: To exercise your right to opt out, please visit our Privacy Request Form.
Right to Limit Use of Sensitive Personal Information: To exercise your right to limit use of your Sensitive Personal Information, please visit our Privacy Request Form.
Submission and Response Process
Once we receive your request, we will:
- Acknowledge receipt of the request.
- Provide an estimated response timeline, if we are able to verify your identity.
- Request additional detail, if needed, to verify your identity or to properly understand, evaluate, and respond to the request.
Only you, or an authorized agent acting on your behalf, may make a Verifiable Consumer Request related to your Personal Information. You may also submit such a request on behalf of your minor child.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority and confirm that the information relates to you. We may deny your request if an exception applies, such as where disclosure would infringe upon the rights of another consumer or where the information is not subject to the CCPA.
For security reasons, we will not disclose sensitive identifiers such as Social Security numbers, driver’s license numbers, government-issued identification numbers, financial account details, account passwords, or security question answers, if disclosure would create a risk of fraud, identity theft, or compromise of our systems.
You are not required to create an account to submit a Verifiable Consumer Request. Information provided in connection with such a request will be used solely to verify your identity or authority to act on another’s behalf.
We will respond to a Verifiable Consumer Request within forty-five (45) days of its receipt. If additional time is necessary (up to a total of ninety (90) days), we will notify you in writing of the reason and extension period.
Policy Amendments
We may update this Policy at our sole discretion. Any changes will be posted on this Site, and the date of the most recent revision will be indicated at the top of the page. You are responsible for reviewing this Policy periodically to ensure you are aware of any updates. Your continued use of the Site following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or concerns regarding the policies and practices described in this Policy, you may contact us at privacy@nueyaesthetics.com.