Smile Secure INC, on behalf of itssubsidiaries and divisions (collectively, “Smile Secure”, “us,” “we,” or “our”) has preparedthis Privacy Policy(“Policy”)     todescribe to you, or if you represent an entity or other organization, thatentity or organization (in eithercase, “you,” or “your”) our practices regarding the personal information that SmileSecure collects, uses, and shares through www.smilesecure.com (the “Site”). Capitalizedterms not defined in this Policy shall have the meanings as defined in the Smile Secure “Terms of Use”. Smile Secure reserves the right,at any time, to modify this Policy. Ifwe make revisions that change the waywe collect, use, or share personal information, we will post those changes in this Policy.You should reviewthis Policy periodically to remain updated on our currentpolicies and practices. We will notethe effective date of the latest version of ourPolicy at the end of this Policy. Yourcontinued use of the Site, following posting of changes, constitutes your acceptance of such changes.

1. COLLECTION OF PERSONALINFORMATION

1.1  Personal Information.“Personal information” means information that identifies, relatesto, describes, is capable of being associated with, or could reasonably belinked to, directlyor indirectly, a particular consumeror household. The following are categories (withnon-exhaustive examples) of personal information we may collect about you:

“Personal information” does not include:
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●Publicly Available – Publicly availableinformation from federal,state, or local governmentrecords.
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●Deidentified or Aggregate information – “Deidentified Information” meansinformation that cannot reasonably identify, relate to,describe, be capable of being associated with, or be linked, directlyor indirectly, to a particular individual, and forwhich Smile Secure has implemented technical safeguards and business processes that prohibit reidentificationof the individual. “Aggregate Information”means information that relates to a group or category of individuals, fromwhich individual identities have been removed, that is not linked or reasonably linkable to any individualor household, including via a device.
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●ExcludedInformation – Certain laws require separate privacy notices, orare exempt from general personalinformation privacy policy disclosure requirements.Such laws include health or medical information covered by the Health Insurance Portability andAccountability Act of 1996 (HIPAA) or clinicaltrial data; Fair Credit Reporting Act (FRCA); and the Driver’sPrivacy ProtectionAct of 1994. We will notify you separately according tothose laws if any of our collection, use, or sharingof personal information falls under any of those laws.

1.1 Sources of Personal Information. We obtainthe categories of personal informationlisted above on or through our Site from the following categories of sources:

● Personal Information You Provide: Smile Secure collects personal information when you voluntarilysubmit it to us. For example, we maycollect or receive personal information from a userthat uses our “Schedule Free Consultation” service; provides information to our call center in order to schedule aconsultation; signs up to receivepromotional communications; participates in one of our promotional     sweepstakes,contests, or surveys; posts a review on our services; submits a request to our customer service team;interacts with our social media pages; or otherwiseinteract with us or other users through the Site.
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●AutomaticallyCollected Personal Information: In addition to personalinformation that we may receivedirectly from you, Smile Secure indirectly collects otherinformation from you automatically through the Site. For example, we receive personal information from users when auser visits and navigates our Site on any device. We may also collect personal informationabout users over time and across different websites, apps, and devices when a user accesses the Site.Third parties also collect personal information this wayon our Site. Smile Secure collects some personal informationautomatically using cookies or other online trackingtechnologies as described in our Cookie Policy.
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● PersonalInformation Obtained from Third Parties. In addition to thepersonalinformation that we collect from you directlyand automatically, Smile Secure may receive personalinformation about you from other third-party sources. For example, wereceive personal information from our business partners, our networkof affiliated dental practices,or companies that provide personalinformation to supplement what we alreadyknow about users.We may merge or combine such personal information withthe personal information we collect from you directly or automatically.

2.  USE OF PERSONALINFORMATION

Smile Secure’s primarypurpose in collecting personal information is to provideservices that you request onthe Site. Smile Secure may also usepersonal information for various purposes,including without limitation to:

●  ToProvide Our Products and Services: This could includefulfilling your requests forproducts or services. It could also include processing purchases or other transactions. For example, if you share your personal information to request a quote or ask a question about our productsor services, we will use that personal informationto respond to your inquiry. If youprovide your personal information toarrange a dental procedure, we will use such information to assist in yourlogistics, process your payment and facilitate deliveryof products and services. We may also save your personalinformation to facilitate new product or service orders.
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●ToImprove Our Products and Services: We use personal information tounderstand and analyze the usage trends and preferences of our users tomake our Site, Services, or Contentbetter, diagnose technical issues, prevent fraud, schedule appointments more efficiently, refineour product and services offerings, and develop newfeatures and functionality.
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●ToUnderstand Your Interests:We use your personal information to personalize your experience on the Site, and with our network of affiliateddental practices, and to deliver information about products and services relevantto your interests.
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● ToRespond to Your Requests or Questions: We use personal information to provideyou with support,and to respond to your requests for customer support,including investigating and addressing your concerns andmonitor and improve our responses. This may also include responding to yourfeedback.
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●ToDetermine Your Eligibility and Set Up Your Account: We may use your personal information, including information about you gatheredfrom third party sources, to verifyyour identity or determine your eligibility for some of our dental implant products, services, and promotions. For example, this may include verifyingyour age, date of birth,and place of residence. If you set up an Accounton the Site, we will use the Registration Informationyou provide in relation to that Accountcreation to create, maintain, customize, and secure your Account.
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●ToMarket Products or Services:We use your personal information to provide you with information about our products, services, orpromotions. For example, we may use cookies or other onlinetracking technologies to provide customizedadvertisements, content, and information; to monitor and analyze the effectiveness of marketing activities; andto track your entries, submissions, and statusin any promotions. These might bethird party offers we think you might findinteresting. These communications maycome in the form of interest-based advertisingusing information gathered across multiple websites, devices, or other Sites.
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●ToSecure the Site: We use personal information to maintain the safety,security, and integrity of ourSite, products and services, databases and other technology assets, business, and other users.
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●To Communicate with You: We communicate with you about your Account or our relationship with you. We may also contact you about this Policyor the Terms of Service.
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●As Requiredby Law: We use personalinformation to respondto requests from lawenforcement, and as required by applicable law, court order, or government investigation.

1.  SHARING OF PERSONALINFORMATION

In addition to the specific situations discussed elsewhere in this Policy,Smile Secure may    shareyour personal information in the following circumstances:

1.1  Related Companies and M&A Transactions. We may shareyour personal information with companies that areaffiliated with us (i.e., that control, arecontrolled by, or are under commoncontrol with us). In addition, if we sell all or part of its business, or make a sale or transfer of assets, or are otherwise involved in a mergeror business transfer, we may transferyour personal information to a third party as part of that transaction, including at thenegotiation stage.
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 1.2  Consent. We may ask if you would like us to share your personalinformation with other unaffiliated third parties who arenot described elsewhere in this policy, and wemay do so with your consent.
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 1.3  LegalCompliance. We may disclose personal informationin response to subpoenas, warrants,or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your personal informationin order to establish or exercise ourrights; to defend against a legal claim; to investigate, prevent, or take action regarding possibleillegal activities or fraud; to protect the safety and security of otherusers; or to preventa violation of our Terms of Service.
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 1.4  Service Providers. We may share your personalinformation with third parties who performservices on our behalf that are necessary for the orderly operation of theSite. Among other things, serviceproviders may help us perform website hosting, app design, maintenance services, database management, webanalytics, app analytics, billing,payment processing, fraud protection, credit risk reduction, marketing, or any other use set out in this Policy. Access to your personal information bythese service providers is limited tothe information reasonably necessary for them to perform its limited function.
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 1.5  Behavioral-basedAdvertising. We participate in behavioral-basedadvertising. This means that a thirdparty may use technology (e.g., a cookie) to collect information about your use of our Site so that we canprovide advertising about products and services tailoredto your interest. That advertising may appear eitheron our Site, or on otherwebsites. Please see our CookiePolicy for more information.
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 1.6  AffiliatedDental Practice Offerings. We may jointlyoffer events, promotions, or any otherproduct or service offerings with our network of affiliated dental practices.The personal information that yousubmit through an event, promotion, or otherproduct or serviceoffering rendered with any of our network of affiliated dentalpractices may be combined andtransmitted with the Registration Information related to yourAccount. Thirdparty partners or clients may collect information directly from you,which may be combined withpersonal information disclosed by us. Ifyou decide to request, enter into,or participate in an event, promotion, or other product or service offering that is offered by us andidentified as a joint effort with an affiliated dental practice, the information that you provide may be shared with usand with thatidentified affiliated dentalpractice.  
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‍1.7  Social Networking. The Sitemay offer you the ability to share your personalinformation through a socialnetworking website (e.g., Facebook, Twitter), using such site’s integrated tools (e.g., Facebook “Like” button, orTwitter “Tweet” button). The use of such integrated tools enables youto share your personal information with other individuals or the public,depending on the settings that you have establishedwith such social networking site. Formore information about the purpose andscope of data collection and use in connection with such social networking siteor a site’s integrated tools,please visit the privacy policies of the entities that provide these social networking sites.
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 1.8  Referrals. Users may recommend other users to join the Site or obtain ourdental implant products or servicesby providing their contact information. Usersmay also provide information aboutother users of the Site, such as reviews of the services or products that he or she received, bookingor scheduling information, or referenceinformation.

4.  SECURITY OF PERSONALINFORMATION 

No method of transmission over theInternet, or method of electronic storage is fully secure. While we use reasonable efforts toprotect your personal information from the risks presented by unauthorized access or acquisition, we cannotguarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition ofyour personal information we may notify youelectronically, in writing,or by telephone, if permitted to do so by law.

4.  SECURITY OF PERSONALINFORMATION 

No method of transmission over theInternet, or method of electronic storage is fully secure. While we use reasonable efforts toprotect your personal information from the risks presented by unauthorized access or acquisition, we cannotguarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition ofyour personal information we may notify youelectronically, in writing,or by telephone, if permitted to do so by law.

6.  OPTING OUT

You can make the following choicesto opt out of certainactivities regarding your personal information: 

‍1.1  Promotional E-mails. You may choose to provide us with your e-mail address for thepurpose of allowing us to send newsletters, surveys, offers, and otherpromotional materials related toour Site and dental implant products and services, as well as targeted offers from third parties. You can stop receiving promotional e-mailsby clicking the “unsubscribe” linksin the e-mails or by contacting us as described below. If you decide not to receive promotional e-mails, we may stillsend you service-related communications,such as those about your Account, to fulfill orders for products and service you have requested, or delivernotifications directly to you through the Site.

 1.2  Behavioral-based Advertising. We use behavioral-based advertising. This means that athird party may use technology (e.g., a cookie) to collect information about your use of our Site so that we canprovide advertising about products and services tailoredto your interest. That advertising may appear eitheron our Site, or another website. If you wish to limit third parties’collection of information about your use of our Site, you can opt-out at the Digital Advertising Alliance or Network. Advertising Initiative. Please note that opting-out of behavioraladvertising does not mean that you will not receiveadvertising   while using the site. It will, however, exclude you from interest-based advertisingconducted through participating networks, as provided by their policies andchoice mechanisms.

  1.3  Do-not-track. Some web browsers and devices permityou to broadcast a preference that you cannot be “tracked”online. In such situations, we do not modify your experience, based upon whether such a signal is broadcast. 

7.  CALIFORNIAN USERS

The following applies to individuals inlocated in California.

‍1.1 Categories ofPersonal Information Disclosed for a Business Purpose or Valuable Consideration. Smile Secure must disclose whether the followingcategories of personalinformation are disclosed for a “business purpose” or “valuable consideration”, as these terms are definedunder the California law. Note that,while a category below may be marked,that does not necessarily mean that we have personal information in that category about you. In thepreceding 12 months, we have disclosedthe following categories of personal information in the manner described.

1.1 Shine the Light. Under California Civil Codesections 1798.83-1798.84, California residentswho have an established business relationship with Smile Secure, are entitled to ask us for a notice, describing whatcategories of personal information we share aboutthem with third parties for their direct marketing purposes. This notice willidentify the categories of information shared, and willinclude a list of the third parties with which it is shared,along with their names and addresses. If you are aCalifornia resident and would like a copy of thisnotice, please submit a written request to us at the addresses listed below.

8.  EXERCISING YOUR PRIVACYRIGHTS

 When exercising the rights or options described in this Policy,the following guidelines apply:  

‍1.1  No Fee Usually Required. You will not have to pay a fee to access your personal information (or to exercise any of theother rights). However, we may chargea reasonable fee or decline to complywith your request if your request is clearlyunfounded, repetitive, or excessive.

 1.2  What We May Need from You. When exercising your rights or otherwise assisting you, we may need to request specific information from you tohelp us confirm youridentity. This is a securitymeasure to ensure we do not disclose personal information to any personwho is not entitled to receive it. We may also contactyou to ask you for furtherinformation in relation to your request to speed up our response. 1.3  Timeto Respond. We try to respond to all legitimaterequests within 45 days of yourrequest. Occasionally it may take us longerthan 45 days to respond. For instance, ifyour request is particularly complex or you have made a number of requests. In thiscase, we will notify you of the delay, and may continue to update you aboutthe progress of our response.

 1.4  Nodiscrimination. You will not be subject todiscrimination due to exercising the rights described herein. In some cases, when you exercise one ofyour rights, we will be unable tocomply with the request due to legal obligations or otherwise, or we will be unable to provide you certain productsor services. These responses are not discrimination, and ourreasons for declining your request or ceasing services will be provided at thattime.

 1.5  Authorized Agent. You may designate an authorized agentto make a request on yourbehalf. In order to designate an authorized agent to make a request on yourbehalf, you must providea valid powerof attorney, the requester’s identification information and theauthorized agent’s identification information.

1.  CONTACTINGUS

If you have any questions or concerns aboutour Policy or any other privacy or security issue, please contact us.
Our address: Smile Secure INC 2731 Lakefield WaySugaland Texas 77479USA