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Privacy Policy – HIPAA

Introduction
This Privacy Policy describes how Georgia School of Orthodontics, LLC collects and uses
Personal Data about you through the use of our Website, and through email, text, and other
electronic communications between you and Georgia School of Orthodontics.

Georgia School of Orthodontics, LLC (“GSO” or “we” or “our”) respects your privacy and
is committed to protecting it through our compliance with this policy.

This Privacy Policy (“Privacy Policy”) describes the types of information we may collect
from you or that you may provide when you visit the website www.bracestoday.com
(our “Website”) and our practices for collecting, using, maintaining, storing, protecting, and
disclosing that information.

This policy applies to information we collect:

  • from you or your legal guardian on or through our Website;
  • from or on behalf of your licensed dentist, orthodontist or other medical provider or
  • her/his staff;
  • in email, text, and other electronic messages between you and our Website;
  • over the phone;
  • through printed documents, records, and materials; and
  • when you interact with our advertising, marketing, and applications on third-party
  • websites and services, if those applications or advertising include links to this policy.

It does not apply to information we collect:

  • offline (except over the phone) or through any other means, including on any other
    website operated by GSO or any third-party; or
  • through any third-party website or application, including through any application or
    content (including advertising or marketing) that may link to or be accessible from or
    on the Website.

Please read this policy carefully to understand our policies and practices regarding your
information and how we will treat it. If you do not agree with our policies and practices, you
are not permitted to use our Website. By accessing or using our Website, you agree to the
terms and conditions of this Privacy Policy. This Privacy Policy may change from time to
time. Your continued use of our Website after we make changes shall constitute your
acceptance of those changes, so please check this Privacy Policy periodically for updates.

Children Under the Age of 18

Our Website is not intended for children under the age of 18 and children under the age of
18 are not permitted to use our Website. We will remove any information provided by a child
under the age of 18 if we become aware of it. Parents and legal guardians are welcome to
provide information on behalf of children under 18.

We may provide our goods and services to children, and parents or guardians of are welcome
to use our Website to order and use our goods and services on their children’s behalf,
including by entering their children’s information on our Website. However, our Website is
not intended to be directly used by children under 18 years of age. No one under age 18 may
provide any information to or on the Website. We do not knowingly collect Personal Data (as
defined below) directly from children under 18. If you are under 18, please ask your parent or
guardian to access and use the Website for you, and please do not use, or provide any
information on our Website, or on or through any of their features, including your name,
address, telephone number, email address, or any screen name or user name you may use. If
we learn we have collected or received Personal Data directly from a child under 18 without
verification of parental or guardian consent, we will delete that information. If you believe we
might have received any information from a child under 18, please contact us
at clinic@gaorthodontics.org.

Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly
identify you or be used to identify you.

Generally

We collect several types of information from and about users of our Website, specifically
information:

  •  by which you may be personally identified, such as name; home, shipping, and postal
    address; e-mail address; home and mobile telephone number; credit card, debit card,
    or other payment information (solely for payment purposes); date of birth; social
    security number; your medical history and name(s) of your medical and dental
    providers; and other information about your past, present or future physical or mental
    health condition or the provision of health or dental care (“Personal Data”).
    We collect this information:
  • directly from you when you provide it to us;
  • automatically as you navigate through the Website. Information collected
    automatically may include usage details, IP addresses, and information collected
    through cookies, web beacons, and other tracking technologies; and
  • From third parties, for example, your health and dental providers and our business
    partners.

Information You Provide to Us

The information and data we collect on or through our Website are:

  • information that you provide by filling in forms on our Website. This includes
    information provided at the time of registering to use our Website, subscribing to our
    service, posting material, or requesting further services. We may also ask you for
    information when you enter a contest or promotion sponsored by us, or during a
    study you consent to participate in, and when you report a problem with our Website;
  • records and copies of your correspondence (including email addresses), if you contact
    us; and
  • your responses to surveys that we might ask you to complete for research purposes.

The Personal Data we collect from you is collected with your consent and required for us to
provide you with our products and services and to facilitate communication between you and
your licensed dental provider. You may withdraw your consent at any time by terminating
your membership with us; however, we may no longer be able to provide you with our goods
and services if you do.

You also may provide information to be published or displayed (hereinafter, “posted”) on
public areas of the Website or transmitted to other users of the Website or third parties
(collectively, “User Contributions”). Your User Contributions are posted on and
transmitted to others at your own risk. Although we limit access to certain pages, please be
aware that no security measures are perfect or impenetrable. Additionally, we cannot control
the actions of other users of the Website with whom you may choose to share your User
Contributions. Therefore, we cannot and do not guarantee that your User Contributions will
not be viewed by unauthorized persons.

Health Information
We may process some Personal Data considered sensitive when necessary to carry out our
obligations to you.

Some Personal Data processed by GSO may be considered sensitive, including Personal Data
concerning your health. GSO processes this information only to the extent necessary to carry
out its obligations to your licensed dental care provider and you, and to provide your licensed
dental provider and you with our goods and services.

How We Use Your Information
We use your Personal Data for various purposes described below, including to:

  • provide our Website to you;
  • provide you with information you request from us;
  • enforce our rights arising from contracts;
  • notify you about changes; and
  • provide you with notices about your account.

We use information that we collect or receive about you or that you provide to us, including
any Personal Data:

  • to present our Website and its contents to you;
  • to provide your licensed dental provider and you with information, products, or
    services that your provider or you request from us;
  • to fulfill any other lawful purpose for which you provide it;
  • to carry out our obligations and enforce our rights arising from any contracts entered
    into between you and us, including for billing and collection;
  • to notify you about changes to our Website or any products or services we offer or
    provide though them;
  • to allow you to participate in interactive features on our Website;
  • in any other way we may describe when you provide the information; and
  • for any other purpose with your consent.

We may also use your information to contact you through about and/or to promote and
market our own goods and services that may be of interest to you. With your consent, we
may also use your information to contact you through text and voice messages about and/or
to promote and market these goods and services. If you wish to opt-out of such emails, you
may do so by clicking the unsubscribe link in emails that we send you. You may also
unsubscribe or change your choice regarding email, voice, and text communications by
sending a written request to Georgia School of Orthodontics, 8200 Roberts Drive, Suite 550,
Atlanta, GA 30350, or emailing us at clinic@gaorthodontics.org, or calling us at (770) 351-
7737. The treatment you receive from your licensed dental provider is not conditioned on
your consent to receive promotional and/or marketing communications.

Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those
outlined in this Privacy Policy. We disclose your Personal Data to a few third parties,
including:

  • Your licensed dental provider;
  • our third-party service providers, subcontractors, and business associates we use to
    support our business;
  • to any company we might merge with or acquire, or that buys us, or in the event of
    change in structure of our company of any form;
  • to comply with our legal obligations;
  • to enforce our rights; and • with your consent.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those
outlined in this Privacy Policy. However, we may disclose without restriction aggregated
information about our users and information that does not identify any individual. We may
disclose Personal Data that we collect or that you provide as described in this privacy policy:

  • to your dental care provider; • to our subsidiaries and affiliates;
  • to contractors, service providers, subcontractors, and business associates, and other
    third parties we use to support our business;
  • to a buyer or other successor in the event of a merger, divestiture, restructuring,
    reorganization, dissolution, or other sale or transfer of some or all of GSO’s assets,
    whether as a going concern or as part of bankruptcy, liquidation, or similar
    proceeding, in which Personal Data held by GSO about our Website’s users is among
    the assets transferred;
  • to fulfill the purpose for which you provide it;
  • for any other purpose disclosed by us when you provide the information; or
  • with your consent.

We may also disclose your Personal Data:

  • to comply with any court order, law, or legal process, including to respond to any
    government or regulatory request;
  • to enforce or apply our Terms of Use, and other agreements, including for billing and
    collection purposes; and
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or
    safety of you, your licensed provider and/or her/his staff, GSO, our customers, or
    others. This includes exchanging information with other companies and organizations
    for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure
of your Personal Data for third-parties to market or advertise to you, our marketing or
advertising to you, and other targeted marketing and advertising.

We do not control the collection and use of your information collected by third parties.
When possible, these organizations are under contractual obligations (including through the
use of Business Associate Agreements) to maintain appropriate safeguards and protections, to
use this data only for providing the services to us, and to maintain this information strictly
confidential. These third parties may, however, aggregate the information they collect with
information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to
us. We will only use your contact information to promote or market our own products and
services through voice and text messages with your express consent. If you wish to consent
to such use, you can check the relevant box located on the form on which we collect your
Personal Data or otherwise seek such consent. If you wish to change your choice, you may do
so by sending a written request to Georgia School of Orthodontics, 8200 Roberts Drive,
Suite 550, Atlanta, GA 30350, or emailing us at clinic@gaorthodontics.org, or calling us
at (770) 351-7737. We may also use your contact information to promote or market our
products and services through email. If we have sent you a marketing or promotional email,
you may click the unsubscribe link to be omitted from future email distributions. This opt
out does not apply to information provided to GSO as a result of a product service
experience or other transactions. Your orthodontic treatment is not conditioned on your
consent to receive marketing or promotional communications.

Accessing and Updating Your Personal Data

You may update your Personal Data at any time. You can change your Personal Data by
notifying us of any changes or errors in any Personal Data we have about you to ensure that
it is complete, accurate, and as current as possible. We may not be able to accommodate your
request if we believe it would violate any law or legal requirement or cause the information to
be incorrect.

Do Not Track Signals

We may use automated data collection technologies to track you across websites. We
currently do not honor do-not-track signals that may be sent by some browsers.

We also may use automated data collection technologies to collect information about your
online activities over time and across third-party websites or other online services (behavioral
tracking). Some web browsers permit you to broadcast a signal to websites and online
services indicating a preference that they “do not track” your online activities. At this time,
we do not honor such signals and we do not modify what information we collect or how we
use that information based upon whether such a signal is broadcast or received by us.

Data Security

Information transmitted over the Internet is not completely secure, but we do our best to
protect your Personal Data. You can help protect your Personal Data and other information
by keeping your password to our Application and Website confidential.

We have implemented measures designed to secure your Personal Data from accidental loss
and from unauthorized access, use, alteration, and disclosure. All information you provide to
us is stored on our secure servers behind firewalls. Any payment transactions and health
information will be encrypted when being communicated between us and you.

The safety and security of your information also depends on you. Where we have given you
(or where you have chosen) a password for access to certain parts of our Website or the
Application, you are responsible for keeping this password confidential. We ask you not to
share your password with anyone. We urge you to be careful about giving out information on
the Website or in Application like message boards and other areas where you may post
photographs, videos or other content. The information you share in public areas may be
viewed by any user of the Website or Application.

Unfortunately, the transmission of information via the internet is not compl etely secure.
Although we do our best to protect your Personal Data, we cannot guarantee the security of
your Personal Data transmitted to or from our Application or Website. Any transmission of
Personal Data is at your own risk. We are not responsible for circumvention of any privacy
settings or security measures contained on the Website, the Application, or the operating
system of your computer or mobile device.

Changes to Our Privacy Policy

We will post any changes to our Privacy Policy on our Website. If we make material changes
to our Privacy Policy, we may notify you of such changes through your contact information
and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Policy at any time. It is our policy to post any changes we make
to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on
the Website’s home page/screen. If we make material changes to how we treat our users’
Personal Data, we will provide notification through a notice on the Website’s home
page/screen. The date this Privacy Policy was last revised is identified at the top of the page.
You are responsible for periodically visiting our Website and this Privacy Policy to check for
any changes.

Contact Information

You may contact us through the contact information below. If you have any questions,
concerns, complaints or suggestions regarding our Privacy Policy, have any requests related
to your Personal Data, or otherwise need to contact us, you may do so at: Geor gia School of
Orthodontics, 8200 Roberts Drive, Suite 550, Atlanta, GA 30350, or emailing us
at clinic@gaorthodontics.org, or calling us at (770) 351-7737.
Last Revised: October 2019

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