Privacy policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. We collect, use, and disclose Your information as described in this Privacy Policy and, where required by applicable law, only where We have a valid legal basis to do so, including Your consent (where consent is required). Questions go to privacy@stetica.ai, and We answer plainly.

Interpretation and definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for a Practice and its staff to access Our Service or parts of Our Service.
• Application means the Stetica practice-management software that Practices and their staff sign in to, at practice.stetica.ai and any other address We give a Practice.
• Business, for the purposes of the CCPA/CPRA, refers to the Company as the legal entity that collects Consumers’ personal information, or on behalf of which such information is collected, and that alone, or jointly with others, determines the purposes and means of the processing of Consumers’ personal information, and that does business in the State of California.
• CCPA and/or CPRArefers to the California Consumer Privacy Act (the “CCPA”) as amended by the California Privacy Rights Act of 2020 (the “CPRA”).
• Client means a person a Practice treats, whose record the Practice keeps in the Application.
• Company(referred to as either “the Company”, “We”, “Us” or “Our” in this Privacy Policy) refers to Stetica, Inc., 2 Central Street Suite 204, Middleton, MA 01949, United States.
  For the purposes of the GDPR, the Company is the Data Controller for Visitors and for Practice staff, and a Data Processor for Client data, which the Practice controls. For the purposes of HIPAA, the Company is a Business Associate of a Practice that is a Covered Entity.
• Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website, among its many uses.
• Country/State refers to: Massachusetts, United States.
• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Device means any device that can access the Service, such as a computer, a cell phone or a digital tablet.
• Do Not Track (DNT) is a concept that has been promoted by U.S. regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites.
• GDPR refers to the EU General Data Protection Regulation, and where the context requires, the UK GDPR.
• Health Informationmeans information about a Client’s health, treatment or body that a Practice enters in the Application, including consent forms, intake and medical-history answers, treatment notes, device settings, skin type, contraindications and photographs. Where HIPAA applies, it is Protected Health Information.
• HIPAA refers to the Health Insurance Portability and Accountability Act of 1996 and its regulations.
• Messages means the email and text messages a Practice sends to its Clients through the Service, and the replies.
• Personal Data(or “Personal Information”) is any information that relates to an identified or identifiable individual.
  For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
  For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
  We use “Personal Data” and “Personal Information” interchangeably unless a law uses a specific term.
• Practice means a business, or a self-employed practitioner, that holds an Account: Our customer.
• Service refers to the Website, the Application, the Messages, the pages a Client opens from a Message (such as a consent form or an intake form), and Our support and sales conversations by email or phone.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  For the purposes of the GDPR, Service Providers are considered Data Processors (or sub-processors, for Client data).
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• User means any individual who accesses or uses the Service.
• Visitor means a person who reads the Website or joins its waiting list.
• Website refers to Stetica, accessible from https://www.stetica.ai.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
  Under GDPR, You can be referred to as the Data Subject since You are the individual using the Service.

Two kinds of people

Practices are Our customers. A Practice opens an Account, signs its staff in, enters and controls the records it keeps about its Clients, and decides which of its staff may see what. For a Practice and its staff, We are the Data Controller of the Account, billing and Usage Data.

Clientsare the people a Practice treats. If You are a Client, Your Practice decides what is stored about You, and Your Practice is the one to ask about it. We process Your information on the Practice’s behalf and under its instructions. In the language of privacy law, the Practice is the controller, business or covered entity, and Stetica is the processor, service provider or business associate. This Privacy Policy tells You what We do with Your information in that role. It does not replace the privacy notice Your Practice owes You under the law that applies to it.

Visitors read the Website or join the waiting list. For Visitors, We are the Data Controller, and the sections on the Website and the waiting list are the ones that apply.

Collecting and using Your personal data

Types of data collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City

In particular:

• On the Website. If You join the waiting list We collect the email address You enter and the date You joined. If You answer the short survey We link to, We collect Your answers.
• When a Practice opens an Account.The Practice’s name, address, phone number and website; its services, prices, rooms, machines and working hours; and the name, email address and role of each member of staff who signs in. If the Practice rents a room at another Practice, or lets its rooms to a renter, the terms of that arrangement as the Practice enters them.
• Billing. When We charge for the Service, the billing contact, billing address, and the brand, last four digits and expiry of the card used. Full card numbers are held by Stripe, Our payment processor, and never reach Our servers.
• When You contact Us. Whatever You put in the email or tell Us on the phone, and the address or number You used. We do not record calls.

Personal Data a Practice enters about its Clients

A Practice enters, on behalf of its Clients, the record it needs to treat them. We hold it as the Practice’s processor. It may include:

• name, date of birth, mobile number, email address and postal address;
• appointments, who treated her, where, with what, and what it cost;
• consent forms, whether signed on paper and uploaded, or signed online from a link the Practice sent;
• intake and medical-history answers, including medications and conditions;
• treatment notes kept per area of the body, carried forward from one visit to the next, and the settings used on a device;
• photographs taken to plan and record treatment;
• skin type and contraindications; and
• whether the Client agreed to receive text messages, who recorded it and when.

Much of this is Health Information, and some of it is sensitive personal information under state privacy laws. See Health information and HIPAAfor the extra rules that apply to it. A Practice confirms, by entering a Client’s details, that it has the right to do so and to ask Us to message her.

Information from Messages

When a Practice sends an email or text through the Service We collect the address or number it went to, the message, when it was sent, whether the carrier reported it delivered, and any reply. A reply may include a photograph a Client sends back. A photograph sent by text is copied into the Client’s record at the Practice and then deleted from the messaging carrier.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device’s unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

In the Application, Our servers log each request: the time, the page or action, the IP address, the browser, and which member of staff made it. When a Client opens a consent or intake link We record that it was opened, when, from which IP address and browser, and what was submitted; that record is part of the signed form.

Information from other sources

• WorkOS, which signs Practice staff in, tells Us the email address and name of the person who signed in and the method they used.
• Google supplies address suggestions when a Practice types its address during setup. The text typed is sent to Google to produce the suggestion.
• Twilio and Amazon Web Services tell Us whether a Message was delivered, bounced, or was marked as unwanted.
• Stripetells Us whether a Practice’s payment succeeded, and the card’s brand, last four digits and expiry.

We do not buy Personal Data from data brokers, and We do not append it.

Tracking technologies and Cookies

We use Cookies to keep You signed in and to measure the Website. We do not use web beacons, pixels, advertising cookies or cross-site tracking anywhere on the Service. The technologies We use are:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Service.
• Email tracking technologies. The emails We send to the waiting list through Kit may contain technologies that tell Us whether an email has been opened or a link within it has been clicked. We use this information to measure the performance of Our email communications and to maintain email deliverability. The Messages a Practice sends to its Clients through the Service do not contain them. You can prevent most email tracking by configuring Your email client to block the automatic loading of remote images, and You may opt out of marketing emails entirely by using the unsubscribe link in any marketing email We send.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use the following Cookies:

• Necessary / Essential Cookies
  Type: Session Cookies
  Administered by: Us
  Purpose: These Cookies are essential to provide You with services available through the Application and to enable You to use its features. They keep a member of staff signed in from one page to the next and prevent fraudulent use of Accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services. The Website sets none.
• Analytics Cookies
  Type: Persistent Cookies
  Administered by: Google
  Purpose: These Cookies collect information about traffic to the Website and how Visitors use it, such as the pages visited, the time spent on those pages, and the source of the visit. We use this information to understand and improve how the Website performs. We have configured Google Analytics so that the data is not shared with Google’s advertising services and is not used for ads personalisation. These Cookies are set on the Website only, never in the Application.

You can refuse or delete Cookies in Your browser settings. Refusing the Analytics Cookie has no effect on the Website. Refusing the Essential Cookie means You cannot sign in to the Application.

Use of Your personal data

The Company may use Personal Data for the following purposes:

• To provide and maintain Our Service, including to monitor the usage of Our Service: scheduling, Client records, consent, intake, treatment notes, photographs, reminders, and the figures a Practice needs to run its business.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To send the Messages a Practice asks Us to send, and to deliver the replies to the Practice. Every Message to a Client is sent by, and in the name of, her Practice; We do not contact a Practice’s Clients for Our own purposes.
• To contact You: to contact a Practice by email or telephone regarding updates or informative communications related to the functionalities, products or contracted services, including security updates, outages and changes to Our terms and this Privacy Policy, when necessary or reasonable for their implementation.
• To provide You with news, special offers, and general information about other goods, services and events which We offer that are similar to those that You have already purchased or inquired about, where You have joined the waiting list or hold an Account. We send such marketing communications only where permitted by applicable law: where prior consent is required (for example, under the laws applicable in the EEA and the UK), We will send them only with Your consent; otherwise, We may send them until You opt out. You may opt out or withdraw Your consent at any time by using the unsubscribe link in any marketing email We send or by contacting Us.
• To manage Your requests: to attend and manage Your requests to Us.
• To secure the Service: to detect and stop unauthorised access, abuse and fraud, and to investigate incidents.
• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about Our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns, and evaluating and improving Our Service, products, services, marketing and Your experience. Client data is used for these purposes only in aggregate or de-identified form.

Things We do not do:

• We do not sell Personal Data, and We do not share it for targeted advertising.
• We do not advertise inside the Application.
• We do not use Client records, photographs or Messages to train artificial-intelligence models, Ours or anyone else’s.
• We do not make automated decisions about a Client that have legal or similarly significant effects on her.

We may share Your Personal Data in the following situations:

• With Service Providers: We may share Your Personal Data with Service Providers to host and run the Service, to send Messages, to sign staff in, for payment processing, to monitor and analyze the use of the Website, and to contact You. Each is named under Detailed information on the processing of Your personal data.
• Within a Practice:a Practice’s own staff see the records the Practice gives them access to.
• Between Practices:where one Practice rents a room or a machine at another, the host sees only what the booking needs — the time and the room — and never the renter’s Client or her record. Stetica separates every Practice’s data from every other Practice’s.
• For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

The assistant inside the application

The Application includes an assistant that helps a Practice set itself up and, over time, do routine work by asking for it in plain words. When a member of staff uses it, the words she types and the parts of the Practice’s own data that are needed to answer are sent to Anthropic, the Service Provider that provides the underlying model, under terms that forbid Anthropic from using them to train models. The assistant can only see what the member of staff using it is allowed to see, and only within her own Practice. It does not act on a record without her confirming the action. We keep the conversation so that she can return to it. When she removes a conversation, it leaves her list at once, and We erase it ninety days later.

Text messages privacy notice

A Practice may text its Clients through the Service. The texts are sent by the Company on the Practice’s behalf, and every text names the Practice it is from. A Practice may text a number only after the Client has agreed to receive texts. When she agrees, the Practice records in the Application the information needed to show it: her phone number, who recorded the agreement, and when. We also store message delivery information. Until that record exists, the Service sends no text to the number.

No mobile information will be shared with or sold to third parties or affiliates for marketing or promotional purposes. The phone numbers and consent records We collect for texting are never shared with anyone for any purpose, except the Service Providers that technically have to handle them to deliver the texts.

Consent to receive text messages is not a condition of any purchase, treatment or use of the Service. If You consent to receive texts from Your Practice, You agree to receive text messages related to:

• Appointment confirmations and reminders
• Links to a consent form or an intake form to complete before an appointment
• Replies about Your appointments and forms

No marketing or promotional texts are sent through the Service. Reply STOP to opt out. Reply HELP for support. Message & data rates may apply. Messaging frequency may vary. Carriers are not liable for delayed or undelivered messages. See the text message terms and how clients agree to texts.

Retention of Your personal data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

Where possible, We apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods below are maximum periods (“up to”) and We may delete or anonymize data sooner when it is no longer needed for the relevant purpose. We apply different retention periods to different categories of Personal Data based on the purpose of processing and legal obligations:

• Conversations with the assistant: for as long as the member of staff keeps them; ninety days after she removes one, We erase it. Counts of how much the assistant was used, which contain none of her words, are kept to measure what it costs.
• Client records held for a Practice: for as long as the Practice instructs, which is normally for as long as the law requires the Practice to keep clinical records. When a Practice closes its Account We return its records to it and then delete them, except where the law or Our agreement with the Practice requires Us to keep them for longer.
• Account information:retained for the duration of the Practice’s Account relationship plus up to 24 months after Account closure to handle any post-termination issues or resolve disputes.
• Messages and delivery records:for as long as the Practice’s Account is open, so that it can show what was sent and when.
• Customer support data: support tickets and correspondence, up to 24 months from the date of ticket closure to resolve follow-up inquiries, track service quality, and defend against potential legal claims.
• Usage Data: website analytics data (cookies, IP addresses, device identifiers), up to 24 months from the date of collection; server logs (IP addresses, access times), up to 24 months for security monitoring and troubleshooting purposes.
• Marketing data: the waiting list, retained until You unsubscribe or up to 24 months from Your last engagement (last email opened or clicked), whichever comes first.
• Financial and transaction data: credit/debit card details are not stored on Our servers; they are processed by Stripe. We retain transaction records (invoice details, purchase history, amounts) and billing and invoice records for up to 10 years from the date of transaction to comply with tax laws and financial regulations.

We may retain Personal Data beyond the periods stated above for different reasons: a legal obligation to retain specific data (e.g., financial records for tax authorities); data necessary to establish, exercise, or defend legal claims; Your explicit request that We retain specific information; or technical limitations, where data exists in backup systems that are scheduled for routine deletion.

When retention periods expire, We securely delete or anonymize Personal Data. Residual copies may remain in encrypted backups for a limited period consistent with Our backup retention schedule and are not restored except where necessary for security, disaster recovery, or legal compliance. In some cases, We convert Personal Data into anonymous statistical data that cannot be linked back to You; this anonymized data may be retained indefinitely for research and analytics.

Transfer of Your personal data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. Our servers and Our Service Providers are in the United States. This means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.

Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards and, where relevant, supplementary measures. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of Your data and other personal information.

Delete Your personal data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

A Practice may update, amend or delete its own details, its staff and its Clients’ records at any time from within the Application, and may contact Us to request access to, correct, or delete any Personal Data it has provided to Us, or to export or delete its whole Account.

If You are a Client, Your record belongs to Your Practice’s care of You, and the Practice is the one to ask. Write to Your Practice. We give Practices the tools to respond, and We help when they ask. If You write to Us instead, We will tell Your Practice and act on its instructions.

Please note, however, that We may need to retain certain information when We have a legal obligation or lawful basis to do so.

Disclosure of Your personal data

Business transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice to Practices before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Where the law allows, We tell the Practice first.

Other legal requirements

The Company may disclose Your Personal Data in the good-faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your personal data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security. The measures We take include:

• Personal Data is encrypted in transit and at rest.
• Every record belongs to one Practice, and the Application enforces that boundary on every read and write, not only on the screen.
• Access within a Practice is by role, set by the Practice. A member of staff sees what her role allows and nothing more.
• Sign-in is handled by a dedicated identity provider, and sessions expire.
• Photographs and signed forms are stored in private storage that is never reachable from the public internet. They are served to signed-in staff of the Practice that owns them, and a form is shown to the Client it belongs to only through a one-time link that expires.
• Our own staff reach production systems through named accounts, and only when needed.

If We learn of a breach affecting Your Personal Data We tell the Practice, and where the law requires it, You, without unreasonable delay.

Health information and HIPAA

Where a Practice is a covered entity under HIPAA, the Company acts as its business associate. We sign a business associate agreement with the Practice, and Our Service Providers that handle protected health information sign one with Us before they handle it. Under those agreements We:

• use and disclose protected health information only to provide the Service to the Practice, as the Practice permits, or as the law requires;
• apply the safeguards in the HIPAA Security Rule;
• report any breach to the Practice without unreasonable delay, so that it can meet its own duties to its Clients; and
• return or destroy protected health information when the agreement ends, except where the law requires it to be kept.

The Practice remains responsible for its own notice of privacy practices and for the consents it obtains from its Clients. If You are a Client and want a copy of Your record, a correction to it, or an accounting of who has seen it, ask Your Practice. We help the Practice respond.

Where HIPAA does not apply to a Practice, We treat its Clients’ Health Information with the same care.

Detailed information on the processing of Your personal data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information in accordance with their Privacy Policies and under contracts with Us that limit them to providing their service. Those that handle Health Information sign a business associate agreement with Us before they handle it. If We add or change a Service Provider that handles a Practice’s data, We tell Practices before it takes effect.

Analytics

We use a third-party Service Provider to monitor and analyze the use of the Website.

• Google Analytics
  Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. It is used on the Website only, never in the Application. We have turned off Google signals, ads personalisation and the sharing of this data with other Google services, so that it is used to report on the Website and for nothing else.
  You can opt out of making Your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript from sharing information with Google Analytics about visit activity.
  For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Email

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You, where You have joined the waiting list or hold an Account. You may opt out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

• Kit— holds the waiting list and sends its emails. Their Privacy Policy can be viewed at https://kit.com/privacy
• Amazon SES— sends the email a Practice sends to its Clients through the Service, and Our email to Practices. Their Privacy Policy can be viewed at https://aws.amazon.com/privacy/

Payments

We may provide paid products and/or services within the Service. In that case, We may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

• Stripe— takes payment from Practices for the Service. Their Privacy Policy can be viewed at https://stripe.com/us/privacy

Usage, performance and miscellaneous

We use third-party Service Providers to run, maintain and improve Our Service.

• Amazon Web Services— hosting, databases, file storage and secrets, in the United States. Their Privacy Policy can be viewed at https://aws.amazon.com/privacy/
• Twilio— sends and receives the text messages a Practice sends to its Clients, and the photos a Client texts back. Their Privacy Policy can be viewed at https://www.twilio.com/en-us/legal/privacy
• WorkOS— signs Practice staff in. Their Privacy Policy can be viewed at https://workos.com/privacy
• Anthropic— provides the model behind the assistant, as described under The assistant inside the application. Their Privacy Policy can be viewed at https://www.anthropic.com/legal/privacy
• Google Places— a service that returns information about places using HTTP requests, operated by Google, used to suggest a Practice’s address during setup. The information gathered by Google Places is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

GDPR privacy

The Company serves Practices in the United States. This section applies where the GDPR or the UK GDPR nonetheless applies to Our processing, for example because You visit the Website from the EEA or the UK. For Client data, the Practice is the controller and the Company is its processor; Clients exercise their rights through their Practice.

Legal basis for processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or those of another natural person.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

The legal basis We rely on depends on the purpose of the processing:

• Performance of a contract:creating and administering a Practice’s Account, providing and maintaining the Service, processing purchases and payments, and providing customer support.
• The Practice’s instructions: for Client data, We process on the documented instructions of the Practice under Our data processing agreement with it.
• Legitimate interests: securing the Service and preventing fraud and abuse; monitoring, analyzing, and improving the Service; sending non-marketing service communications; enforcing Our agreements and establishing, exercising, or defending legal claims; and evaluating or completing business transfers. Where We rely on legitimate interests, Our interest is the effective, secure, and commercially sustainable operation and improvement of the Service, and We balance that interest against Your rights and freedoms.
• Consent:sending marketing communications where consent is required; placing and reading non-essential cookies and similar technologies, as described in the “Tracking technologies and Cookies” section, where consent is required.
• Legal obligation: retaining transaction, tax, and accounting records, and responding to lawful requests from courts and public authorities.

Where the provision of Personal Data is a statutory or contractual requirement, or necessary to enter into a contract with Us, We will make this clear at or before the point of collection, including whether You are obliged to provide the Personal Data and the possible consequences of not providing it. If You have questions about the legal basis for any specific processing activity, please contact Us.

International transfer of Personal Data

We may transfer, store, and process Personal Data in countries other than the country in which You are located, including countries outside the European Economic Area (“EEA”) and the United Kingdom (“UK”), where data protection laws may differ. Our servers are in the United States.

Where We transfer Personal Data outside the EEA/UK to a country that has not been recognized as providing an adequate level of protection, We rely on appropriate safeguards where the law requires them, such as the European Commission’s Standard Contractual Clauses and the UK Addendum or International Data Transfer Agreement, together with supplementary measures such as encryption in transit and at rest, access controls and data minimization. You may contact Us to request further information about the safeguards We use for international transfers.

Your rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law where the GDPR or the UK GDPR applies to Our processing of Your Personal Data (including, in particular, if You are in the EEA or the UK), to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request restriction of processing. You have the right to ask Us to restrict processing of Your Personal Data in certain circumstances (for example, while We verify accuracy or consider an objection).
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation that makes You want to object to Our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent to Our use of Your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising Your GDPR data protection rights

You may exercise any of the rights described above by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try Our best to respond to You as soon as possible. We generally respond within one month, and may extend by two further months where necessary, in accordance with applicable law.

You have the right to complain to a supervisory authority about Our collection and use of Your Personal Data. If You are in the EEA, please contact Your local data protection authority. If You are in the UK, You can complain to the Information Commissioner’s Office (ICO).

Automated decision-making

We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning You or similarly significantly affect You. If this changes, We will update this Privacy Policy and provide the information and safeguards required by the GDPR.

CCPA/CPRA privacy notice (California privacy rights)

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to visitors, users, and others who reside in the State of California. It describes the Personal Information We collect as a Business, from Visitors and from Practices and their staff. Client records that a Practice keeps in the Application are processed by Us as the Practice’s service provider, and Health Information covered by HIPAA or the California Confidentiality of Medical Information Act is outside the CCPA/CPRA.

Categories of Personal Information collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which We may collect or may have collected from California residents within the last twelve (12) months.

The categories and examples provided in the list below are those defined in the CCPA/CPRA. Listing a category does not mean that every type of information it describes was in fact collected by Us. It means only that, to the best of Our knowledge, some information within that category may be, or may have been, collected. Certain categories would be collected only if You provided that information to Us directly.

• Category A: Identifiers. Examples: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. Collected: Yes.
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: a name, signature, address, telephone number, credit 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. Collected: Yes (name, address, telephone number, and the brand, last four digits and expiry of a payment card).
• Category C: Protected classification characteristics under California or federal law. Examples: age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information. Collected: No.
• Category D: Commercial information. Examples: records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Collected: Yes.
• Category E: Biometric information. Collected: No.
• Category F: Internet or other similar network activity.Examples: browsing history, search history, information on a consumer’s interaction with a website or application. Collected: Yes.
• Category G: Geolocation data. Examples: approximate physical location, physical location or movements. Collected: No (an approximate location derived by Google Analytics from an IP address falls under Category F).
• Category H: Sensory data. Examples: audio, electronic, visual, thermal, olfactory, or similar information. Collected: No as a Business. (We hold treatment photographs as a service provider to Practices.)
• Category I: Professional or employment-related information. Examples: current or past job history or performance evaluations. Collected: Yes(a staff member’s role at a Practice).
• Category J: Non-public education information. Collected: No.
• Category K: Inferences drawn from other personal information. Collected: No.
• Category L: Sensitive personal information. Examples: government-issued identifying numbers; account log-in credentials; precise geolocation; racial or ethnic origin; religious beliefs; the contents of mail, email, and text messages; biometric data; health data; sexual orientation. Collected: No as a Business. (Health Information entered by a Practice is held as its service provider and used only to provide the Service.)

Under CCPA/CPRA, Personal Information does not include:

• Publicly available information, meaning: information lawfully made available from federal, state, or local government records; information that the Business has a reasonable basis to believe is lawfully made available to the general public by the Consumer or from widely distributed media; or information made available by a person to whom the Consumer has disclosed it, unless the Consumer restricted the information to a specific audience
• Deidentified or aggregated consumer information
• Information excluded from the CCPA/CPRA’s scope, such as health or medical information covered by HIPAA and the California Confidentiality of Medical Information Act (CMIA), and Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from You. For example, from the forms You complete on Our Service, from preferences You express or provide through Our Service, or from Your purchases on Our Service.
• Indirectly from You. For example, from observing Your activity on Our Service.
• Automatically from You. For example, through cookies We or Our Service Providers set on Your Device as You navigate through Our Service.
• From Service Providers. For example, third-party vendors to monitor and analyze the use of Our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information

We may use or disclose Personal Information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA/CPRA), which may include the following examples:

• To operate Our Service and provide You with Our Service.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve Our Service.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about Our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
• Other purposes consistent with the context in which the information was collected, or as otherwise disclosed to You at the time of collection.

If We decide to collect additional categories of Personal Information or use the Personal Information We collected for materially different, unrelated, or incompatible purposes, We will update this Privacy Policy.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of Personal Information for business purposes, to Service Providers only: Category A (Identifiers), Category B (Customer Records), Category D (Commercial information), Category F (Internet activity) and Category I (Professional information).

When We disclose Personal Information to a Service Provider or contractor for a business purpose, We enter into a contract that describes the purpose, requires the recipient to keep that Personal Information confidential, and prohibits the recipient from using it for any purpose other than the limited and specified purposes stated in the contract, consistent with the CCPA/CPRA. The Service Providers are named under Detailed information on the processing of Your personal data.

Sale or sharing of Personal Information

As defined in the CCPA/CPRA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information by the Business to a third party for valuable consideration. “Share” and “sharing” mean disclosing, making available, or otherwise communicating a Consumer’s personal information by the Business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

We do not sell Personal Information, and We do not share it, as those terms are defined in the CCPA/CPRA, and We have not done so in the preceding twelve (12) months. We have configured Our analytics provider so that it does not use the information for its own advertising purposes. We have no actual knowledge of selling or sharing the Personal Information of Consumers under 16 years of age. Because We do not sell or share Personal Information, there is no sale or sharing to opt out of, and opt-out preference signals such as the Global Privacy Control have nothing to act on. If this changes, We will update this Privacy Policy, provide a “Do Not Sell or Share My Personal Information” link, and honour such signals as the law requires.

Retention of Personal Information

We retain California residents’ Personal Information for as long as reasonably necessary to achieve the purposes described in this Privacy Policy (including the purposes disclosed in this CCPA/CPRA notice), taking into account: (i) how long We need the information to provide and maintain the Service and Your Account; (ii) whether You have requested deletion (subject to applicable exceptions); (iii) Our legal, tax, accounting, and regulatory obligations; (iv) security, fraud prevention, and abuse monitoring needs; and (v) the time periods needed to resolve disputes and enforce Our agreements. Specific retention periods are described in the “Retention of Your personal data” section.

Personal Information of minors under 16 years of age

We do not knowingly collect personal information from minors under the age of 16 through Our Service, although certain third-party websites that We link to may do so. These third-party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission. If You have reason to believe that a child under the age of 16 has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

• The right to notice. You have the right to be notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
• The right to know/access. You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and sharing of personal information. Once We receive and confirm Your request, We will disclose to You the categories of personal information We collected about You, the categories of sources, Our business or commercial purposes for collecting it, the categories of third parties with whom We share it, and the specific pieces of personal information We collected about You.
• The right to say no to the sale or sharing of Personal Information. We do not sell or share Personal Information, so there is nothing to opt out of.
• The right to correct Personal Information. You have the right to correct or rectify any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct Our Service Providers to correct) Your personal information, unless an exception applies.
• The right to limit use and disclosure of sensitive Personal Information. See “Limit the use or disclosure of My sensitive Personal Information” below.
• The right to delete Personal Information. You have the right to request the deletion of Your Personal Information under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your Personal Information from Our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to: complete the transaction for which We collected the Personal Information, provide a good or service that You requested, or otherwise perform Our contract with You; detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activity; debug products to identify and repair errors; exercise free speech or another right provided for by law; comply with the California Electronic Communications Privacy Act; engage in public or peer-reviewed research in the public interest with Your informed consent; enable solely internal uses that are reasonably aligned with consumer expectations; comply with a legal obligation; or make other internal and lawful uses of that information that are compatible with the context in which You provided it.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer rights, including by denying goods or services to You; charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to You; or suggesting that You will receive a different price or rate or a different level or quality of goods or services.

Exercising Your CCPA/CPRA data protection rights

In order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us by email at privacy@stetica.ai or by mail at 2 Central Street Suite 204, Middleton, MA 01949, United States.

We may verify Your identity before responding to requests to know, delete, or correct Personal Information, as permitted or required by applicable law. Only You or an authorized agent acting on Your behalf may make a verifiable request relating to Your Personal Information. Your request to Us must provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Information or an authorized representative, and describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it. We cannot respond to Your request or provide You with the required information if We cannot verify Your identity or authority to make the request and confirm that the personal information relates to You.

No later than 10 business days after receiving a request to know, delete, or correct, We will confirm receipt and provide general information about how We will process and verify the request and when You should expect a response, unless We have already granted or denied the request. We will respond no later than 45 calendar days after receipt. If reasonably necessary, We may extend the response period once by an additional 45 calendar days. If We do, We will notify You during the initial 45-day period and explain the reason for the extension.

Unless You request a longer period, Our response to a request to know will cover the preceding 12 months. You may request information collected on or after January 1, 2022, for a longer period, unless providing it is impossible or requires disproportionate effort. We are not required to retain Personal Information for any specific period. For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

If You are a Client of a Practice, Your request about Your record goes to Your Practice, which controls it; We help the Practice respond.

Limit the use or disclosure of My sensitive Personal Information

We do not collect or use sensitive Personal Information for purposes other than those specified in the CCPA/CPRA and its implementing regulations, and We do not collect or process sensitive Personal Information for the purpose of inferring characteristics about consumers. Accordingly, We are not required to provide, and do not provide, a method for submitting requests to limit the use or disclosure of sensitive Personal Information. If Our practices change, We will update this Privacy Policy and provide the required means to exercise this right.

“Do Not Track” policy as required by CalOPPA

Our Service does not respond to Do Not Track signals, because it does not track You across other websites and there is nothing for the signal to stop. However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California privacy rights (California’s Shine the Light law)

Under California Civil Code § 1798.83 (California’s Shine the Light law), California residents with an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes. We do not disclose Personal Data to third parties for their own direct marketing purposes. If You would like to make such a request, please submit Your request in writing using the contact information provided in the “Contact Us” section of this Privacy Policy.

California privacy rights for minor users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. The Service has no public areas, so nothing posted on it is public. To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below. Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

State consumer health data laws

Several states, including Washington (My Health My Data Act), Nevada and Connecticut, give their residents rights over consumer health data that HIPAA does not cover. Under those laws the Practice that collects a Client’s Health Information is the regulated entity, and We are its processor. We process that information only on the Practice’s instructions and only to provide the Service, We never sell it, and We give Practices the tools to honour a Client’s request to access, withdraw consent for or delete it. A Client exercises those rights through her Practice.

Children’s and minors’ privacy

The Service is not directed to, and We do not knowingly collect Personal Information directly from, anyone under the age of 16. A Practice may treat a minor with a parent or guardian’s consent, and the Practice is responsible for obtaining it; We hold that record as the Practice’s processor. If You are a parent or guardian and You believe Your child has provided Us with Personal Information, please contact Us. If We become aware that We have collected Personal Information directly from anyone under the age of 16, We will take steps to remove that information from Our servers as soon as reasonably possible.

Some countries and states set a higher age at which an individual can consent to the processing of their own Personal Information. Where We rely on consent as a legal basis and the law applicable to a User sets an age higher than 16, We may require the consent of that User’s parent or guardian before We collect and use their Personal Information.

Links to other websites

Our Service may contain links to other websites that are not operated by Us, such as a Practice’s own website or a survey. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the “Last updated” date at the top. We will let Practices know by email, prior to a change becoming effective, where it affects how their or their Clients’ information is handled; a change to how We process Client data is governed by Our agreement with the Practice. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If You have any questions about this Privacy Policy, You can contact Us:

• By email: privacy@stetica.ai
• By mail: Stetica, Inc., 2 Central Street Suite 204, Middleton, MA 01949, United States