# Website Privacy Policy

**State Supplement: Minnesota**
*This document serves as a template for a Minnesota medical spa's public-facing website privacy policy, integrating federal requirements and the strict data consent standards of the Minnesota Consumer Data Privacy Act (MCDPA).*

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## 1. Introduction
Welcome to our website. We respect your privacy and are committed to protecting your personal information. This Privacy Policy details how we collect, use, and process your personal information when you visit our website, book an appointment, or interact with our digital services.

## 2. Information We Collect
We collect information that identifies or could reasonably be associated with you ("Personal Data"). 

We may collect the following categories of Personal Data:
- **Identifiers:** First and last name, email address, postal address, phone number.
- **Commercial Information:** Products, treatments, or services you have inquired about or purchased.
- **Internet Activity:** Browsing history, IP address, device information, and interactions with our website.
- **Sensitive Data & Biometrics (MCDPA):** Under the Minnesota Consumer Data Privacy Act, data revealing your medical history, mental or physical health condition, or diagnosis is considered "sensitive data." If we use technologies like 3D facial mapping that process **biometric data** for the purpose of uniquely identifying you, this is also highly sensitive data. We collect this ONLY with your explicit, affirmative, opt-in consent.

## 3. Strict Prohibitions on Sensitive Data (MCDPA)
In accordance with the MCDPA:
- **We DO NOT process your Sensitive or Biometric Data** for marketing or tracking purposes without first obtaining your explicit, separate opt-in consent. 
- **We DO NOT sell your Sensitive Data.** 

## 4. Use of Personal Information
We use the basic personal information we collect for the following business purposes:
- To provide our aesthetic services and respond to your inquiries.
- To process your payments securely.
- To improve our website and customer service.
- To send administrative information and, with your consent, marketing communications.

## 5. Your Rights Under the Minnesota Consumer Data Privacy Act (MCDPA)
If you are a resident of Minnesota, and we meet the requisite processing thresholds set by the MCDPA (effective July 31, 2025), you are granted specific rights regarding your personal data:
- **Right to Know/Access:** You have the right to confirm whether we process your personal data and to access such data.
- **Right to Correct:** You have the right to correct inaccuracies in your personal data.
- **Right to Delete:** You have the right to delete personal data provided by or obtained about you.
- **Right to Data Portability:** You have the right to obtain a copy of your personal data in a portable, readily usable format.
- **Right to Opt-Out:** You have the right to opt-out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling. We honor recognized Universal Opt-Out Mechanisms (UOOMs).

To exercise these rights, please contact us using the information provided on our contact page. We will authenticate your request and respond within 45 days.

## 6. Data Security & Breach Notification
We safeguard your personal data through industry-standard administrative, technical, and physical security measures. 
- **Notification:** In the event of a security breach involving your computerized, unencrypted personal information, we will notify you and relevant authorities in compliance with Minnesota law (Minn. Stat. § 325E.61). Notice will be provided in the most expedient time possible and without unreasonable delay.

## 7. Exemption for Medical Information
Please note that "protected health information" (PHI) collected by our clinic acting as a covered entity governed by the Health Insurance Portability and Accountability Act (HIPAA), is subject to specific medical privacy laws that interact with and supersede general website data privacy rules. The rights provided by the MCDPA generally do not apply to PHI.

If you are a patient receiving medical aesthetic treatments, the privacy of your clinical and health information is governed by our separate Notice of Privacy Practices (NPP).

## 8. Changes to Our Privacy Policy
We may update this privacy policy from time to time to comply with changes in state or federal regulations. The updated version will be indicated by an updated "Effective Date."

*Effective Date: July 31, 2025*