Effective Date: September 30, 2025
This Notice of Data Collection (“Notice”) is issued by Aspen Glades Corp., a Delaware corporation, together with its affiliates and subsidiaries (collectively, “Nuey,” “Company,” “we,” “us,” or “our”). This Notice applies to personal information of individuals residing in California, to the extent such information is governed by the California Consumer Privacy Act, as amended (“CCPA”). For more details, you may access and download our full Privacy Policy, as well as our California Resident Privacy Policy.
We collect personal and sensitive personal information as needed to operate and support our business functions, including the purposes identified below. We do not sell or exchange personal information for monetary consideration. However, our use of cookies, pixels, and similar website analytics tools may be deemed a “sale” of personal information under the CCPA. In addition, some of these technologies involve “sharing” certain categories of personal information with third parties for cross-context behavioral advertising, as reflected below. We do not sell or share sensitive personal data without your consent. If you wish to opt out of the sale or sharing of your personal information, please visit Your California Privacy Choices.
Personal Information Collected
We may collect and use the personal information identified below for the purposes described. The Company will not retain personal information associated with a disclosed purpose longer than is reasonably necessary to fulfill that purpose or as otherwise required by applicable law.
Categories of Personal Information
We collect and use several categories of personal information. This includes:
- 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, 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 included 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.
Note: Categories marked with (**) may be disclosed to third parties in a manner that qualifies as a “sale” or “sharing” of personal information under the CCPA. Categories marked with (*) may be disclosed to third parties in a manner that qualifies as “sharing” but not “sale” under the CCPA.
Use of Personal Information
These categories of personal information may be used 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 overall 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 employee onboarding activities;
- To manage payroll and employee benefit programs, maintain personnel files, and comply with record retention requirements;
- To provide human resources management, employee data administration, and related support services and communications;
- To communicate with employees, their emergency contacts, and plan beneficiaries;
- 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; and
- To conduct workforce, data, and benchmarking analytics.
In addition, we may collect sensory data, such as video surveillance footage, for the following purposes: (i) to comply with applicable state and federal laws, including on workplace health and safety; (ii) to prevent unauthorized access to, use of, or loss of Company property; and (iii) to exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.
Sensitive Personal Information Collected
Sensitive personal information is a specific subset of personal information that includes designated categories under applicable law. We may collect and use sensitive information in the categories described below for the purposes identified. To exercise your right to limit the use of sensitive personal information, please visit Your California Privacy Choices.
Categories of Sensitive Personal Information
We collect and use several categories of sensitive personal information. This includes:
- Government-issued identifiers, including Social Security number, driver's license, state identification card, or passport number.
- 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.
- 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.
Use of Sensitive Personal Information
These categories of sensitive personal information may be used for the business purposes listed above under the section titled “Use of Personal Information.”
Retention Period
We will retain personal information for as long as necessary or legally permissible, depending on the purposes for which it was collected. Factors we consider in determining retention periods include: (i) the duration of our ongoing relationship with you and the services we provide; (ii) legal obligations that require retention; and (iii) whether continued retention is appropriate given our legal rights and obligations, including statutes of limitations, pending or potential litigation, and regulatory investigations.
If you have any questions about this Notice, or if you require it in an alternative format due to a disability, please contact us at privacy@nueyaesthetics.com.