Effective Date: July 14, 2026

1. Who We Are

This Privacy Policy explains how Smiley Aesthetics Holdco, LLC, a Tennessee limited liability company (“Smiley Aesthetics,” “we,” “us,” or “our”), collects, uses, and shares information through training.smileyaesthetics.app (the “Site”), our injector-training and continuing-education platform. Our principal address is 339 White Bridge Pike, Nashville, Tennessee 37209.

2. Scope of This Policy

This Site is used to register for, purchase, and access injector-training courses, certification programs, and related educational content. This Site does not provide medical treatment, does not collect health or medical information about trainees, and is separate from our clinical patient-care websites and the Notice of Privacy Practices that governs those sites. If you are looking for the privacy practices that apply to Smiley Aesthetics medical spa patients, see the separate policy posted at smileyaesthetics.com.

3. Information We Collect

Information you give us

  • Account and checkout information: name, email address, billing address, and phone number, collected through WooCommerce when you register, enroll in a course, or make a purchase.
  • Order and course history: which courses, products, or training packages you have purchased or enrolled in.
  • Any information you submit through contact forms or course sign-up forms. Course intake forms on this Site do not ask for and are not intended to collect health, medical, or treatment information about you.

Payment information

Payments are processed by Stripe through the WooCommerce Stripe Gateway plugin. We do not receive or store your full card number; Stripe handles that data under its own privacy policy and PCI-DSS obligations. We retain only what Stripe or WooCommerce provides back to us for order records (e.g., last four digits, transaction ID, amount).

Information collected automatically

  • Standard server logs (IP address, browser type, pages visited, referring URL).
  • Session and cart cookies set by WooCommerce so your cart and checkout function correctly.
  • Order-attribution data (via WooCommerce’s built-in Sourcebuster/Order Attribution feature), which records where a visitor came from (e.g., a UTM parameter or referring site) for a purchase. This is a first-party WooCommerce feature; this Site does not have Google Analytics, Meta/Facebook Pixel, or any other third-party advertising or analytics tracker installed.

4. How We Use Your Information

  • To process enrollments, purchases, and payments, and to deliver course access, certificates, and materials.
  • To communicate with you about your orders, courses, schedule changes, or account.
  • To maintain records of course completion and payment for our own business, tax, and accreditation purposes.
  • To maintain the security of the Site and prevent fraud.
  • To comply with legal and tax obligations.

5. Who We Share Information With

We do not sell your personal information. We share information only as needed to run the Site and our training business:

  • Stripe — to process payments.
  • WooCommerce / Automattic and other hosting and plugin providers that operate the technical infrastructure of the Site, as standard service providers/processors.
  • Professional advisors (accountants, attorneys) and government authorities, where required by law or to protect our legal rights.

We have confirmed there is currently no Google Analytics, Meta Pixel, or Mailchimp/Klaviyo plugin installed directly on this Site, and no active workflow automation currently moves customer or order data from this Site to any outside app.

6. Data Retention

We retain checkout, order, and course-enrollment records for as long as needed for our business, accounting, and tax purposes, and as required by applicable law.

7. Your Choices and Rights

Depending on where you live, you may have rights to access, correct, or delete the personal information we hold about you, or to object to certain uses. To make a request, contact us using the information in Section 10.

Tennessee residents

Because Smiley Aesthetics is based in Tennessee and most of our trainees are Tennessee residents, we reviewed the Tennessee Information Protection Act (TIPA), which took effect July 1, 2025. TIPA only applies to businesses that (a) have more than $25 million in annual revenue, and (b) either process the personal information of at least 175,000 Tennessee consumers in a year, or process at least 25,000 Tennessee consumers’ data while deriving 50% or more of gross revenue from selling that data. Based on the scale of this training business, we do not meet either threshold, so TIPA’s specific consumer-rights and opt-out provisions do not currently apply to this Site. We do not sell personal information and do not engage in targeted advertising.

Because trainees don’t regularly come from California, Colorado, or other states with their own consumer privacy statutes, or from outside the U.S., we have not added state-specific rights language for those jurisdictions. If that changes, this section will be revisited.

8. Children’s Privacy

This Site is intended for licensed or license-track medical and aesthetic professionals and is not directed to children. We do not knowingly collect personal information from anyone under 18.

9. Security

We use reasonable administrative and technical safeguards to protect the information we hold, including secure payment processing through Stripe. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Contact Us

Questions about this Privacy Policy can be sent to admin@smileyaesthetics.com or 629-276-8915, or by mail to Smiley Aesthetics, 339 White Bridge Pike, Nashville, TN 37209.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The effective date at the top of this page reflects the most recent revision.