Privacy Policy

Effective Date: September 30, 2025

The policy applies to Aspen Glades Corp., a Delaware corporation, or any of its affiliates and subsidiaries, including Nuey AZ, LLC, Nuey CA, LLC, and CA Medical Group PC (collectively, “Nuey,” “Company,” “we,” “us,” or “our”). We respect your privacy and are committed to protecting it through compliance with this Privacy Policy (“Policy”). This Policy explains the types of information that we may collect from you or that you may supply to us when you access or use any material or services offered on or through our Site (nueyaesthetics.com) and any other Site, product or feature that may link to this Policy (collectively, the “Site”). This Policy explains how we collect, use, maintain, protect, and disclose that information. It governs your use of:

  • Our websites, including nueyaesthetics.com and any other site, product, or feature that links to this Policy (collectively, the “Site”);
  • Our communications, including email, text, chatbot, and other messages we send to you; and
  • Our services and locations, including products and services we provide in person or otherwise.

This Policy applies only to information collected by us or on our behalf. It does not apply to information collected by any third party, including applications or content (including advertising) that may link to or be accessible from the Site.

By accessing or using this Site, you agree to this Policy. If you do not agree with our policies and practices, your choice is not to use our Site or services. Your continued use of this Site following any updates or changes to the Policy means you accept and agree to those changes, so please review the policy periodically.

If you are a resident of California, please visit our Privacy Policy for California Residents (our “California Privacy Policy”) and our Notice at Collection.

Information We Collect

We may collect several categories of information from and about users of our Site, services, and locations. For purposes of this Policy, “Personal Information” means any information that identifies, relates to, describes, or could reasonably be used to identify you as an individual, whether collected online or offline, including but not limited to:

  • Name, email address, mailing address, telephone number, date of birth, account credentials (including passwords);
  • Payment details (which are collected and processed by our third-party payment processors, such as Shopify, in compliance with the Payment Card Industry Data Security Standard (PCI-DSS));
  • Health-related information that you choose to provide in connection with our services or that may be shared with us by affiliated professional healthcare providers or aestheticians regarding treatment options and results;
  • Demographic details such as gender, race, and household information;
  • Any other personally identifiable information that you knowingly and willingly provide to us and by which we may contact you online or offline, such as through surveys, membership forms, emails, or other communications.

Additional information we may collect may include, but is not limited to:

  • Information about you that does not individually identify you, such as gender or your preferred Nuey location;
  • Information about your service and purchase history; and/or
  • Information about your internet connection, equipment used to access our Site, and usage details.

How We Collect Information

We may collect this information in the following ways:

  • Directly from you when you choose to provide it to us, including when you:
    • Access or use the Site;
    • Complete forms on our Site or at a Nuey studio;
    • Create an account on our Site;
    • Purchase products or services;
    • Submit reviews or respond to a survey;
    • Participate in or sign up for a promotion, activity, or event;
    • Subscribe to communications (emails, SMS, newsletters);
    • Enter a contest or sweepstakes;
    • Communicate with us through our chatbot or via third-party social media sites (including by posting or tagging content);
    • Search queries on the Site;
    • Request customer support, report a problem, or otherwise communicate with us.
  • Information you provide in the course of your interactions with us, including:
    • Records and copies of your communications (including email addresses) if you contact us;
    • Details of transactions you conduct through our Site or other channels, as well as information related to the fulfillment of your orders (including contact, shipping, and payment details). Our Site is hosted by Shopify, a third-party payment processor that collects and processes your payment information. Your data is stored in Shopify’s systems and protected using encryption in compliance with the Payment Card Industry Data Security Standard (PCI-DSS).
  • Automatically as you interact with our Site, including through the collection of usage data, IP addresses, and information obtained via cookies, web beacons, and other tracking technologies.
  • From publicly available sources and third-party platforms, such as Google, Meta, X (formerly Twitter), TikTok, Reddit, and other social media services. This may include photos, posts, likes, and your interactions with our content. For example, with your consent where required by law, we may share or repost a post you created about our services to our own social media account.
  • From third parties, including our business and marketing partners, advertising networks, and data analytics providers. This may include information from data licensors that supply contact details, profiles, demographic details, and other data, such as details about your household, interests, educational background, booking history, and purchasing history. Some of providers may combine data collected from visitors to our Site through cookies, pixel tags, and similar technologies with email or mailing addresses, enabling us to send you relevant marketing offers via email and direct mail.

Automatic Data Collection, Cookies, and Tracking Technology

We may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details on your Site visits, including page views, traffic data, logs, and other communication data;
  • Resources that you access and use on the Site;
  • Information about your device and internet connection, such as your IP address, operating system, browser type and language, browser capabilities, Internet Service Provider, and the web pages that you visit;
  • Pages you visit and your referral websites;
  • Your email address, which may be matched to a postal address to deliver marketing offers from Nuey; and
  • Online activities over time and across third-party Sites or other online services (behavioral tracking). Please note, our Site does not currently respond to “Do Not Track” browser settings or similar mechanisms.

The information we collect automatically is primarily statistical and does not, by itself, identify you. However, we may associate it with Personal Information we collect in other ways or receive from third parties. This information helps us to:

  • Estimate the size of our audience and analyze usage patterns;
  • Store information about your preferences, to help us customize the Site based on your individual interests;
  • Improve search efficiency and overall Site performance; and
  • Recognize you when you return the Site.

We and our services providers use a variety of technologies to collect information, improve the functionality of our Site, analyze trends, and provide a more personalized experience. The technologies may include:

  • Cookies. Cookies are small text file placed on the hard drive of your computer. They ensure our Site’s content is presented effectively for you and your device. You may refuse cookies by activating the appropriate settings in your browser. However, if you do so, certain parts of our Site may not function properly or be accessible. Unless you adjust your browser to refuse cookies, our system will issue cookies when you visit our Site. Learn more about cookies at http://www.allaboutcookies.org/. For details on managing cookies, see the section of this policy titled “Your Privacy Choices”.
  • Web Beacons. Pages of our Site or in emails may contain small electronic files known as web beacons (such as clear gifs, pixels, pixel tags, and single-pixel gifs) that permit us to count users who have visited pages, opened emails, and other related statistics.
  • Google Analytics. We use Google Analytics (“GA”) to help us understand how visitors use our Site. GA collects information such as how often users visit the Site, what pages they view, when they view pages, and what websites referred them. We use this information only to improve the Site. Google Analytics collects only the IP address assigned to you on the date of your Site visit and does not collect other personally identifying information. Although Google Analytics places a permanent cookie in your browser to identify you as a unique user, the cookie can only be used by Google. Google’s use and sharing of information collected is governed by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits by disabling cookies in your browser.

Some content or applications on the Site are served by third parties, including advertisers, and networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your Personal Information or they may collect information (including Personal Information) about your online activities over time and across different Sites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. We encourage you to be aware when you leave our Site and to read the privacy statements of any other sites that may collect your information. For information about how you can opt out of receiving targeted advertising from many providers, see the section of this policy titled “Your Privacy Choices.”

Use of Information

We may use the information we collect about you, or that you provide to us, for the following purposes:

  • To provide services. To present our Site and its contents to you; to provide you with information, products, or services that you request; to process and complete transactions (including purchase confirmations and receipts); and to identify you as a user in our system in order to respond to your questions, requests, comments or requests for assistance.
  • To communicate with you. To respond to your comments, questions, and requests; provide customer service; send administrative notices; and communicate with you about products, services, offers, promotions, contests, sweepstakes, rewards, and events, and to provide other news and information about Nuey and our select partners (unless you have opted out).
  • To support clinical and aesthetic services. To communicate with you about treatment services offered by our physicians, physician assistants, nurse practitioners, and licensed aestheticians, and to coordinate care with contracted healthcare providers or others working on your behalf.
  • To personalize experiences. To customize your Site experience; create and deliver content and advertising most relevant to you; provide content, features, and/or advertisements that match your interests and preferences; and tailor communications such as birthday acknowledgments, rewards, or other offers.
  • To improve operations. To monitor and analyze statistics, trends, usage, and activities; learn more about your interactions and shopping preferences; improve our Site, products, and services; and perform research, surveys and quality control.
  • To administer promotions and rewards. To process and deliver contest or sweepstakes entries, rewards, and prizes.
  • To detect and prevent unlawful activity. To detect, investigate and prevent fraudulent transactions, security incidents and other malicious, deceptive, fraudulent, or illegal activity; and to help protect the rights, property, and safety of Nuey, our customers, or others.
  • To combine and enrich information. To link and combine with information we receive from third parties (such as analytics providers, advertisers, and data licensors) to better understand your needs and provide improved services.
  • To help display advertisements to intended audiences. While we do not directly share your Personal Information for these purposes without your consent, clicking on or otherwise interacting with an advertisement may lead the advertiser to assume that you fall within its target audience.
  • To comply with legal and financial obligations. To comply with applicable laws, regulations, and reporting requirements;
  • To inform you about products and services. To let you know about our own products and services, as well as those of third parties’ we believe may interest you. If you would like to restrict the use of your information in this way, please email your request to privacy@nueyaesthetics.com. For more information, see the section of this policy titled “Your Privacy Choices”;
  • For any other disclosed purposes. In any other way described to you when you provide information, or for any other purpose with your consent.

Our service providers may also collect, use, store, and share your Personal Information, and in such cases, it is governed by their own privacy policies. These service providers include, but are not limited to, the following:

  • Data analytics providers (Google Analytics, HubSpot, Shopify, etc.);
  • Marketing service providers (Comma8, Meta, Google Ads, etc.);
  • Payment processors (Shopify, Stripe, Square, etc.);
  • Communication platforms (Microsoft Teams, Slack, etc.);
  • Other technology and service providers (Zenoti, HubSpot, Rippling, etc.).

Disclosure of Information

We may disclose aggregated information about our users, as well as information that does not identify any individual, without restriction. We may disclose Personal Information that we collect or that you provide, as described in this Policy:

  • To our subsidiaries and affiliates;
  • To contractors, service providers, and other third parties who perform services to us or on our behalf, including, but not limited to: operating and maintaining our Sites, processing orders, sending postal mail and email, removing duplicate customer information, analyzing data, providing marketing services, administering customer surveys, processing credit card payments, and providing customer service;
  • To a buyer or other successor in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as part of ongoing business or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information about our users, Site, products, and/or services is among the assets transferred;
  • To third parties for marketing purposes, if you have not opted out of such disclosures. For more information, see the section of this policy titled “Your Privacy Choices”;
  • When you participate in the interactive areas of our Site, where certain information you provide (such as your name, photos, and any other details you choose to provide) may be displayed publicly;
  • To fulfill the purpose for which you provide the information;
  • To comply with any court order, law, or legal process, including responding to any government or regulatory requests;
  • To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes;
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others;
  • For any other purpose disclosed to you at the time of information collection; and
  • With your consent.

Short Messaging System (SMS) Policy

This section explains how we handle information provided through our SMS program:

  • We use your information to send mobile messages and respond to your inquiries. To deliver these messages, we may share your information with platform providers, phone companies, and vendors who support message delivery. Nuey’s SMS program provides opted-in subscribers with both promotional and transactional SMS messages, which may included appointment reminders, exclusive offers, event invitations, information regarding your account or services, or other updates. Message frequency may vary. For assistance, reply HELP to the SMS or contact us at info@nueyaesthetics.com. Please note, carriers are not reliable for delayed or undelivered messages.
  • We do not sell, rent, loan, trade, lease, or otherwise transfer for profit any phone numbers or customer information collected through our SMS program to third parties.
  • Your consent to receive automated marketing text messages is entirely voluntary not a condition of purchase.
  • You may opt-out of receiving SMS messages at any time by replying to any message with STOP, END, CANCEL, UNSUBSCRIBE, or QUIT.

This SMS policy applies exclusively to our SMS program and does not replace or alter any other provisions of our general Privacy Policy that govern your relationship with us in other contexts.

Your Privacy Choices

We want you to have clear options for controlling how your Personal Information is used and shared. You may exercise the following controls:

  • Tracking Technologies. You may adjust your browser to refuse all or some cookies, or to alert you when a cookie is being placed on your device. Please note that if you disable or refuse cookies, certain parts of this Site may become inaccessible or may not function as intended. To learn more about interest-based advertising, including how to opt-out of having your browsing information used by companies for behavioral advertising, you may visit the Digital Advertising Alliance at www.aboutads.info/choices.
  • Third-Party Advertising. To prevent us from sharing your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you may opt out by emailing your request to privacy@nueyaesthetics.com.
  • Promotional Offers. If you no longer wish to receive promotional communications about our services, products, or those of third parties, you may opt-out at any time by emailing privacy@nueyaesthetics.com, updating your account settings, or using the unsubscribe link provided in our promotional emails.
  • Targeted Advertising. To opt out of our use of your Personal Information that we collect or that you provide to us to deliver ads tailored to advertiser audience preferences, you can opt-out emailing your request to privacy@nueyaesthetics.com.

We do not control how third parties collect or use your information for interest-based advertising. However, these third parties may offer options limit or opt-out of such data collection and use. For example, you may opt out of receiving targeted advertisements from members of the Network Advertising Initiative ("NAI") by visiting the NAI's Site at www.networkadvertising.org.

In addition, residents of certain states, such as California, Colorado, Virginia, and Utah may have additional rights and choices regarding their personal information. Please see the “State Privacy Rights” section for more information.

Accessing and Updating Your Information or Communication Preferences

You may send us an email at privacy@nueyaesthetics.com to request access to, correct or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Information provided by you directly to one of our service providers is governed by their respective privacy policies and any other applicable documents.

Residents of certain states may have additional rights and choices with respect to their Personal Information. For more information, please see the section of this policy titled “State Privacy Rights.”

State Privacy Rights

Certain U.S. state laws provide their residents with additional rights regarding our use of their Personal Information.

California Residents: To learn more about California residents' rights, please see our California Privacy Policy.

Other States: CO, MD, MN, NJ, OR, TN, TX, UT and VA, (now or in the future) provide their residents with some or all of the following rights, which may vary by state:

  • Confirm whether we process their Personal Information;
  • Access and delete certain Personal Information;
  • Correct inaccuracies in their Personal Information, taking into account the nature of the information and the purposes of processing (not applicable in UT);
  • Data portability.
  • Opt-out of personal data processing for targeted advertising and sales; and
  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects (not applicable in UT).

Nevada: Nevada residents have a limited right to opt-out of the sale of certain personal information. To exercise this right, please email privacy@nueyaesthetics.com with your request.

The exact scope of these rights varies by state. To exercise any applicable rights, please email privacy@nueyaesthetics.com with your request. Some states (e.g. CO and VA), allow residents to appeal a decision regarding a consumer rights request. To submit an appeal, please email privacy@nueyaesthetics.com with your request.

Data Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect your Personal Information against accidental loss and unauthorized access, use, alteration, or disclosure.

However, no method of transmission over the internet or method of electronic storage is completely secure. Accordingly, while we strive to use reasonable measures to protect your Personal Information, we cannot guarantee its absolute security. Any transmission of Personal Information to our site is at your own risk. We are not responsible for circumvention of any privacy, security, or technical measures implemented on the Site.

You are responsible for maintaining the confidentiality of any login credentials, including passwords, associated with your account and for restricting access to your devices. We ask that you do share your credentials with third parties.

Retention Policy

We retain Personal Information for as long as necessary to fulfill the purposes described in this Policy, including to provide services, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, protect our operations, and pursue our legitimate business interests.

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. If we make material changes to the manner in which we collect, use, or disclose Personal Information, we will provide notice by email (where feasible) and/or by posting a notice on the home page of the Site.

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.

Minors

Our Site and services are not intended for use by children under the age of 16. We do not knowingly collect, use or disclose Personal Information from children under age 16. No one under age 16 may provide any Personal Information to or on our Site, including, but not limited to, name, address, telephone number, or email address.

If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will take immediate steps to delete that information from our systems.

If you believe we might have inadvertently collected information from or about a child under age 16, please contact us at privacy@nueyaesthetics.com so that we can promptly investigate and take the necessary steps to ensure that such information is deleted from our system’s database.

Severability

If any provision of this Policy is held to be invalid, illegal, or unenforceable for any reason, the remaining provisions shall remain in full force and effect to the maximum extent permitted by law.

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.