Privacy Policy

Dated May 12, 2018

At Lasyk Networks, Inc. “SimpleSpa” we respect your privacy and are committed to maintaining your trust.


This Privacy Policy describes our practices in connection with information that we collect through:

Collectively the “SimpleSpa Services”.

When you access or use the SimpleSpa Services, you agree to the terms and conditions of this Privacy Policy.

1. Defined Terms.

The following terms will have the meanings indicated below. Please refer to our Subscriber Terms of Service or the SimpleSpa User Agreement for any capitalized terms that are not defined in this policy.

“End User” means any individual who interacts with the SimpleSpa Services, including users of our mobile applications such as the SimpleSpa, and individuals who book appointments, purchase services and otherwise interact with our Subscribers through the SimpleSpa Services.

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as SimpleSpa usage data.

“Personal Information” is information that identifies you as an individual or relates to an identifiable person, such as name, postal address, telephone number, email address, credit card number, and social media account ID. It does not include strings of code such as browser cookie IDs.

“Subscriber” is any business or entity that subscribes to (or otherwise accesses or uses) our Software Service.

Sometimes, we use the term “information” in this Privacy Policy, which may refer to either Personal Information or Other Information.

2. Categories of Personal Information.

Personal Information we collect or obtain includes:

3. How We Collect Information.

We need to collect Personal Information in order to provide the requested SimpleSpa Service to you. If you do not provide or enable us to collect the necessary information, we may not be able to provide the SimpleSpa Service. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the SimpleSpa Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

4. How Personal Information May Be Used.

We may use your Personal Information for legitimate business purposes, including:

To the extent that we process your Personal Information based on your consent, you may withdraw your consent at any time.

5. How Personal Information May Be Disclosed.

We may disclose your Personal Information:

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information. In some instances, we may combine Other Information with Personal Information. If we combine any Other Information with Personal Information, we will treat the combined information as Personal Information.

6. Your California Privacy Rights: Notice to California Customers and Opt-Out Information.

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. If you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes offline, please follow the instructions in Sections 8 below.

7. How to access, correct, delete or exercise other rights regarding your Personal Information.

Where applicable law allows for such a request, if you would like to request to access, correct, object to the use, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact SimpleSpa at privacy@simplespa.com with the subject line “Data Subject Request.” We will respond to your request consistent with applicable law.

For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Moreover, where you are an End User, SimpleSpa may need to forward your request and refer you to your Subscriber who may be better placed to address your request.

Please note that we may need to retain certain information for record-keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). There may also be residual information that will remain within our databases and other records, which will not be removed.

If you are under 18 years of age and a user of the SimpleSpa Services, you may also be entitled to ask us to remove content or information that you have posted to the SimpleSpa Service by submitting a request to support@simplespa.com. Please note that your request does not ensure complete or comprehensive removal of the content or information.

If you are a customer of one of our Subscribers and would no longer like to be contacted by one of our Subscribers, or would like request the exercise of a right as set out above in relation to Personal Information held by a Subscriber, please contact the Subscriber directly.

8. Your choices regarding our use and disclosure of information.

Information you provide may be used by SimpleSpa for marketing purposes such as one-off promotional emailing, mobile text messages, direct mail, and sales contacts. We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:

We will try to comply with your request(s) as soon as reasonably practicable. Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you messages for administrative or other purposes directly relating to your use of the SimpleSpa Services, and you cannot opt-out from receiving those messages.

Our mobile applications may also send push notifications to your mobile device. If you have previously consented to receiving push notifications and no longer wish to receive them, you can also turn push notifications off at the device level. The applications may also request access to your device’s calendar application, camera, and microphone. If you have previously allowed access to your device’s calendar and no longer wish to allow access, you may edit the application settings at the device level.

9. Tracking and Advertising.

We and our third party service providers may collect Other Information in a variety of ways. We and/or our third party partners may employ various tracking technologies, such as cookies, web beacons and analytics software, that help us better manage content on the SimpleSpa Services by informing us what content is effective.

10. Social Media Features and Widgets

The SimpleSpa Services includes social media features such as the Facebook Like button, and widgets, such as the Share This button or interactive mini-programs that run on our websites. These features may collect your IP address, which page you are visiting on our websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our websites. Your interactions with these features are governed by the privacy policy of the company providing it. See Section 24 for a list of third parties and their applicable privacy policies.

11. Public Forum.

Our websites offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose Personal Information through SimpleSpa public message boards, blogs, or forums, this information may be collected and used by others. To request removal of your Personal Information from our blog or community forum, contact us at support@simplespa.com. In some cases, we may not be able to remove your Personal Information or some content (if, for example, it is reposted by another user), in which case we will let you know if we are unable to do so and why.

12. Facebook Connect.

You can log in to some of the SimpleSpa Services using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address to pre-populate our sign up form. Some services like Facebook Connect give you the option to post information about your activities on our websites to your profile page to share with others within your network. In addition, when using some of our mobile applications we may allow you a chance to tell friends about our services by accessing the contacts in your Facebook or other social media account.

13. Testimonials, Ratings and Reviews.

If you submit testimonials, ratings or reviews, to the SimpleSpa Services, any Personal Information you include may be displayed in the Service. If you want your testimonial removed, please contact us at support@simplespa.com.

We also partner with third-party service providers to collect and display ratings and review content on our web site.

14. Third Party Payment Processor

We currently use third party payment processors as a Third Party Offering for internet based payment services. If you wish to make a payment through SimpleSpa Services, your Personal Information may be collected by such processors directly and not by us, and will be subject to the third party’s privacy policy. See Section 24 for a list of third parties and their applicable privacy policies. We have no control over, and are not responsible for, third parties’ collection, use and disclosure of your Personal Information.

15. Links To Other Websites.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including our Subscribers and any third party operating any Third Party Offering, site or other products and services used in connection with the SimpleSpa Services. The inclusion of a link does not imply endorsement of the linked site or service by us or by our affiliates.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the SimpleSpa Services, including our social media pages.

16. Data Retention.

We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

17. Security of Your Information.

The security of Personal Information is a high priority at SimpleSpa. We seek to use reasonable technical, administrative and physical safeguards to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

18. Use of Service By Minors.

The SimpleSpa Services are not directed or targeted at children under the age of sixteen (16), and we request that they do not provide Personal Information through the SimpleSpa Services.

19. Cross-Border Transfer.

The SimpleSpa Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the SimpleSpa Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Some of the non-European Economic Area (“EEA”) countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses with our vendors (based on the clauses published at http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087.

20. Sensitive Information.

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g. information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics, trade union membership or criminal background) on or through the SimpleSpa Services or otherwise to us, except where explicitly requested or consented to.

21. EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield.

SimpleSpa participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.

SimpleSpa is responsible for the processing of personal data it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. SimpleSpa complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, SimpleSpa is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

22. Changes to This Privacy Policy.

SimpleSpa may make changes to this Privacy Policy from time to time. Any changes we make will become effective when we post a modified version of the Privacy Policy to https://www.simplespa.com/privacy. If we make any material changes to the Privacy Policy, we may also notify you by posting notice on our websites or within the applicable SimpleSpa Services, or by sending you an email. If you continue using the SimpleSpa Services after any notice of any such changes, it means you have accepted them. If you do not agree to any changes, you must stop using the SimpleSpa Services, as applicable. It is your obligation to ensure that you read, understand and agree to the latest version of The Privacy Policy. The “Last Updated/Dated” legend at the top of the Privacy Policy indicates when it was last updated.

23. Contact Us.

Please contact us if you have any questions regarding our Privacy Policy.

For the EEA, you may also:

24. Third Party Vendors

The following is a list of current third party vendors that may either directly or indirectly collect information from you. Please review the relevant privacy policies (links current as of the date of publication of this Privacy Policy) for further information on how each third party handles your Personal Information:

Third Party Name

Privacy Policy/Notice Link

Amazon Web Services

https://aws.amazon.com/privacy/

Google Analytics

https://policies.google.com/privacy

Google RWG/Maps

https://policies.google.com/privacy

PayPal

https://www.paypal.com/va/webapps/mpp/ua/privacy-full

Stripe

https://stripe.com/us/privacy

Twilio

https://www.twilio.com/legal/privacy