LaserAway provides this Personnel Privacy Policy (the “Policy”) to inform you of our practices regarding the collection, use, storage and disclosure of personal and other information we collect from current and former employees, directors, contractors, and officers (collectively “Personnel” or “You”) in connection with your working relationship with LaserAway.

Scope of the Policy

The Policy covers “Personal Information,” and other information of Personnel that LaserAway collects in connection with your employment or working relationship with LaserAway. When we refer to “Personal Information,” we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or is otherwise defined or regulated as personal information under applicable laws or regulations. This includes information that directly identifies you (e.g., your name, social security number or other government-issued identifier), but also includes information that we have linked to those identifiers (e.g., your date of birth, telephone number, and information about your performance, all of which are linked to your name).

Except as may be specifically required by law, this Policy does not apply to information available from a public source (such as a telephone directory) or to aggregated or de-identified information LaserAway may collect about its workforce, nor to references to Personnel in company work product, such as the names of persons attending a meeting, contributing to a report, or signing a purchase order. You may also provide information on others, such as a family member you name as a beneficiary. When you provide such information, you confirm that you are authorized to do so. LaserAway will process and store such information in accordance with this Policy.

Other LaserAway Company-Wide Policies

In addition to this Policy, LaserAway maintains other policies intended to help protect your Personal Information, such as LaserAway’s privacy and security policies and procedures. Your careful attention to these and other policies and procedures will help maintain your privacy and respect the privacy of others. Relevant company-wide policies are listed on the company’s intranet site.

Protection of Applicable Laws

In addition to this Policy, federal, state, local and similar laws may govern our use of your Personal Information (including certain sensitive information, such as medical and financial records, bank account and payment card details, official identifiers such as Social Security and driver’s license numbers, and student records) and your rights with regard to your Personal Information. Our practices reflect those requirements as set forth by applicable law in the jurisdiction in which you work for LaserAway. Information revealing certain personal or family circumstances, such as age, gender, disability, medical or family leave, physical or mental disabilities, racial or ethnic origin, religious preference, and sexual orientation are also often regulated by anti-discrimination and other laws and by policies designed to promote diversity in employment and contracting. The details of these laws vary among the states, provinces, and countries where we operate. Human Resources can direct you to sources for additional information on these topics. LaserAway conducts its business and handles the information related to Personnel in compliance with applicable law in the relevant jurisdiction for Personnel.

Personal Information Collected Regarding Personnel

Throughout your working relationship with us (e.g., through on-boarding, using our systems, and signing up for benefits), we collect types of Personal Information necessary to manage our relationship with you.

The Personal Information that we collect and use about you may include:

• Application information that becomes part of your file once you become Personnel (e.g., your resume, information you provide on our application form, references supplied by your former employer);
• Right to work information (e.g., work permit / visa application information);
• Basic personal details (e.g., name, date of birth);
• Contact details (e.g., telephone number, email address, postal address);
• Information required for payroll purposes (e.g., bank account details, tax information);
• Information related to benefit entitlements and schemes (e.g., details of participation, contributions made);
• Information related to gender, race or ethnic origin for purposes of complying with applicable anti-discrimination or diversity legislation (where applicable);
• Medical information, if necessary to comply with applicable laws, or in order to provide workplace accessibility, accommodations, or medical care to you (such as through workplace assessments and for the other purposes described below);
• Performance related data (e.g., information about and assessments of your performance collected as part of the employee review process);
• Location information, including through GPS tracking technology on devices owned by LaserAway (e.g., use of technology on laptops owned by LaserAway to locate and/or wipe lost or stolen laptops), or other devices owned by you which you use in connection with your services to LaserAway;
• Information in connection with disciplinary action or investigations;
• Information about your use of our systems or information that you provide to us through our information systems (e.g., information from your company email account, information posted on our website, information you submit through applications or software made available to you);
• Payment information you provide for goods, services, and other transactions authorized by you in your capacity as Personnel, such as travel expenses;
• Information about your office preferences (e.g., adjusting your desk height, cooling the room, starting the fan, etc.);
• Any other information that you provide directly to us in connection with your working relationship with LaserAway or that we receive in the course of your relationship with us.

LaserAway may collect Personal Information from Personnel when they make purchases from or otherwise interact with LaserAway in an individual capacity and outside the context of their working relationship with LaserAway. Personal Information collected from you during these transactions is not subject to this Policy. We will collect, use, store, disclose, and/or otherwise handle Personal Information collected outside the context of your working relationship with us as we describe in our applicable consumer privacy policy, posted at Privacy Policy.

Purposes for which Personnel Personal Information is Used

We will not disclose, sell or otherwise distribute to any third party any of your Personal Information without your prior permission, except under the following circumstances:

• At your direction: We may disclose your Personal Information when you direct us to do so, such as when you enroll in health care benefits.
• Physician-Owned Clinics: We may disclose your Personal Information to our physician-owned clinics.
• Third-party service providers: We may outsource some or all of the operations of our business to third-party service providers and we may use third parties to act as our agents to provide services to us or to you. Services provided by third parties may include payroll processing, benefits, accounting, legal, and other professional services. In such cases, it will be necessary for us to disclose your data to those service providers. In some cases, the third parties may collect data directly from you on our behalf. We restrict how such third parties may access, use and disclose your data.
• Legal requests and investigations and to comply with law: We may be required to disclose certain information about you to comply with government reporting requirements, laws, or regulations. We may disclose any data about you when, in our opinion, such disclosure is necessary to prevent fraud or to comply with any statute, law, rule or regulation of or any legal process issued by any governmental authority or any order of any court of competent jurisdiction. We may also disclose data about you when necessary for LaserAway to exercise and defend legal claims and enforce its rights.
• Business Transfers: As we continue to develop our business, we might sell or buy companies, subsidiaries, or business units. In such transactions, employee data generally is one of the transferred business assets. Any data transferred will, to the extent required by law, remain subject to the promises made in any pre-existing privacy statement unless you consent to the new privacy policy, which may be required as a condition of employment, subject to applicable law in your jurisdiction.

Security of Your Personal Information

We have adopted commercially reasonable security procedures and practices designed to protect your Personal Information in our possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction. Access to our systems that store your Personal Information is restricted, including by means of a user ID and password that are issued only to authorized personnel. You are also responsible for preventing unauthorized access to your Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have accessed your account.

Retention of Your Personal Information

The length of time we retain your Personal Information depends on the status of our relationship with you and applicable legal requirements. We will retain your Personal Information for as long as your working relationship with us lasts, and for a certain period after your working relationship with us has ended. To determine that period, we take into account our legal and regulatory obligations (such as financial reporting obligations and equal opportunity or anti-discrimination reporting obligations) and whether we may need to retain Personal Information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes and/or enforce our agreements.

Changes to this Policy

We may amend this Policy from time to time. If we make any material changes to the way we use or disclose your Personal Information, we will notify you by sending you an email where required by law. If required by applicable law, we will afford you the opportunity to consent or to opt out of any new use or disclosure.

Questions about this Policy

Any questions regarding this Policy may be directed to Human Resources.

Notice to California Residents

California provides additional privacy rights to residents of the state. If you are a California resident, please see our Notice to LaserAway’s California Personnel for more information about how to exercise your privacy rights.