Smile Therapy Services LLC | Privacy Policy in Washington

PRIVACY POLICY

Purpose

We are committed to protecting your personal information and your right to privacy.

This website www.smiletherapyservices.com (our “Website”) is owned by SMILE Therapy Services, LLC. At SMILE Therapy Services, LLC (“SMILE”, “we,” “us,” “the Company” or “our”), we care about your privacy and have adopted this Privacy Policy to guide you through the collection, use, retention, and disclosure of personally identifiable information (the “Data”, as further described below) that you may provide while using our Website and other services (collectively, the “Services”). We encourage you to read this Privacy Policy carefully.

By using our Services, you consent to the collection, use, retention, and disclosure of your Data as described in, and subject to the limitations set out in, this Privacy Policy. If you do not want to agree to this Privacy Policy (or our Website Terms of Service), you should not use this Website or our Services.

Note to Residents of the European Union and California: In order to comply with the requirements of the European General Data Protection Regulation (GDPR) for our European users, and the California Consumer Privacy Act (CCPA), this Privacy Policy outlines the legal basis on which we process your Personal Data and provides other information required by the GDPR & CCPA.

Age of Consent

We fully comply with the Children’s Online Privacy Protection Act (COPPA). We do not knowingly collect personal information from children under 13 without the required parental or guardian consent. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [info@smiletherapyservices.com].

Information We Collect

Whenever you visit our Website, join our email list, contact us through our Website or offline, interact with us on social media, make purchases on our Website (if applicable), or use our Services, we collect different types of information from you. This may include the collection of personal Data by which you may be identified personally, such as your name, email address, telephone number, postal address, demographic information (age, gender, education level etc.), and any other identifying information (“Data”). The Data collected may also include financial data such as credit card or bank details related to your payment method, which is transferred to our third-party payment processors (such as PayPal, Stripe, etc.). You should review the privacy policies of these third-party payment processors. We also may collect derivative data when you visit and use our Website including your IP address, the date and time of your visit. Furthermore, if you access our Website via a mobile device or app, our servers may automatically collect information from your device such as location information, model and manufacturer, and device ID.

Through social networking websites and apps, like Facebook, Twitter, Instagram, and other social networking sites, we may also access publicly available information such as your name, account username, profile photo, email address, age, location, gender, and any other publicly displayed information. You may limit this access by changing your privacy settings on each social networking site. If you provide us with additional information to participate in a survey, raffle or giveaway, that information will also be subject to the terms of this policy.

How and Why We Collect Data

With your consent, we collect Data that you provide to us manually (for example, if you join our email list by opting in for a free resource). Our legal basis for collecting this Data is your consent.

The Data we collect is used to create and administer your account, generate a personalized profile for you, compile statistics on site use, analyze trends, correspond with you, deliver targeted advertising, process payments, refunds, deliver any goods or services you purchase, communicate new products and services we think you might be interested in, update you on products and services, request feedback from you, resolve and troubleshoot disputes and problems, prevent fraudulent use of our Website, and assist law enforcement when necessary. Our legal basis for collecting this Data is our legitimate interests in monitoring and improving our Website, business operations, marketing efforts, and proper protection of our business against risks.

Use of Cookies and Pixels

Similar to other commercial websites, our Website utilizes a standard technology called “cookies” and server logs to collect information through Automatic Data Collection Technology about how our site is used. A cookie is a very small text document, which often includes an anonymous unique identifier. We may use session cookies that expire when you close your browser and persistent cookies that remain on your computer until you delete them. You can accept or decline cookies in your web browser settings. No personal identifiable information will be included in cookies and, other than the methods described above, we will not use any other mechanisms to capture data on our Website.

To obtain statistical data and to provide you with relevant information, we also may collect data on the way you use our Website including your browsing activity, browsing patterns, IP address, device information, internet connection, and other actions via Google Analytics and Facebook Pixels. We use these technologies in compliance with all policies of the third-party providers. Our legal basis for collecting this information is our legitimate interests in monitoring and improving our Website, business operations, marketing efforts, and proper protection of our business against risks.

Email Information

If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, via mail, and via telephone.

How Long Your Information Will Be Stored

We use reasonable measures to ensure that your information remains confidential at all times. Personal Data is stored through a data management system. For as long as you choose to remain on our email list, we will retain a minimum amount of personal Data including your name, email address and your behavior on our Website. Any additional personal Data will be retained as long as necessary to fulfill legal obligations, resolve disputes, or as reasonably determined.

Information Protection and Security

We use commercially reasonable methods to safeguard the personal Data you provide to us and the personal Data we collect automatically. We use reasonable online security measures and reputable third party vendors that are compliant with generally accepted security and safety measures, including a Secure Sockets Layer (SSL) on our Website to help secure information. Please note that we cannot guarantee that all information transferred will be secure and, if we become aware of a data breach, we will notify the necessary parties in a timely manner of all the information we have.

By using our Website or Services, you agree that, should your information be intercepted in this way without our knowledge, consent, or permission, you will hold SMILE Therapy Services, LLC (including, its owner(s), employees and subsidiaries) harmless, including a release of any and all claims related to the use of such information by such an unauthorized party.

Due to the nature of our business and information collection activities, we have determined that we do not process sensitive data on a large scale, nor do our core activities involve processing operations that require regular or systematic monitoring of data subjects. For these reasons, we have concluded it is not necessary to appoint a Data Protection Officer. Nonetheless, please submit all questions or comments about our policy to the contact information located at the end of this document.

Disclosure of Your Information to Others

For very limited purposes, like legal assistance, accounting, or technical support, we may share your confidential information with necessary third parties. When that happens, any parties who accesses your information will keep your information confidential. To the best of our ability, we will not share your Data with any unnecessary parties. If, in good faith, we determine that disclosure of your information is necessary to protect the rights of our business or comply with the law, prevent or mitigate a crime, or protect the rights or safety of our other website users, we may do so. We may also disclose necessary information in the event of a sale of SMILE Therapy Services, LLC.

Third-Party Sharing

We are not responsible for the policies or any information handling of third-party websites or third-party apps.

Third Party Links Are Not Covered by This Policy

If we provide links to third-party websites, please understand that any information collected on those websites is not covered by this Privacy Policy. If you click on a link and access another website, this Privacy Policy does not attach. By using our Website or Services, you acknowledge and agree that we are not

responsible for the policies or practices of any third-parties. You should review of the privacy policies of each individual website you visit.

Your Rights

Pursuant to this Privacy Policy and applicable laws, you have certain rights when it comes to controlling and protecting your private data:

• You have a right to request that your information be deleted and no longer retained by us. Upon your request, we will remove your information from our database.

• You have a right withdraw your consent to give us your personal information by clicking the “unsubscribe” button at the end of any email you receive from us at any time.

• You also may contact us to request access to information that SMILE Therapy Services, LLC retains about you, including to request that such information be updated, edited, or deleted from our database at any time.

• You have the right to contact us about information on how your data is collected, stored, or used, and to request a copy of the data we have.

• You also may contact us to restrict how we process your data in certain circumstances.

• In the event that you wish to inquire about, or seek to exercise any of these rights (as they may be applicable), you may contact us using our contact information at the end of this policy.

CAN-SPAM Act

In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact us. In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us. Users who no longer wish to receive our emails or promotional materials may opt

out of receiving these communications by clicking on the unsubscribe link in the e-mail.

California Online Privacy Protection Act (CalOPPA)

Pursuant to CalOPPA, we agree that users can visit our site anonymously and we will add a link to this privacy policy on our home page or on the first significant page after entering our Website. Any changes to this Privacy Policy will be published on our privacy policy page.

Do-Not-Track Signals and Similar Mechanisms. Some web browsers transmit “do-not-track” signals to websites. We currently don’t take action in response to these signals.

If you are a California resident, once a year and free of charge, you have the right to request and obtain from us: information about what data we disclose to third-party marketers, and the names and addresses of each third-party we disclose your personal Data to. You may use the contact information listed below to make any such requests.

California Consumer Privacy Act (CCPA)

This section provides additional details about California consumers and the rights afforded to them under the California Consumer Privacy Act or (“CCPA”). Under CCPA “Personal Information” is defined as anything that identifies, relates to, describes or is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular California consumer household. In the last 12 months, we may have collected the following categories of personal information subject to the CCPA:

• identifiers (such as email address and IP address),

• approximate geolocation information,

• Internet or other electronic network activity information (such as browsing history and related usage data).

We collect this information for the business and commercial purposes described above. We do not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing you with a right to opt out).

The CCPA requires opt-in consent to information use for minors under the age of 16 and verified parental consent for children under the age of 13. We do not knowingly collect or process the information of children.

Subject to certain limitations, the CCPA provides California residents the right to request, free of charge, to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at info@smiletherapyservices.com. We will verify your request using the information associated with your account, by asking you to provide information that matches information we have on file about you. You can also designate an authorized agent to exercise these rights on your behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.

GDPR Compliance and Privacy Shield Notice

If you are within the European Union, you are entitled to certain information and have certain rights under the General Data Protection Regulation (“GDPR”). To comply with the GDPR, we confirm that we have lawful grounds for processing the information we collect from you and a legitimate interest to respond to user inquiries. At any time, you may request that your information be deleted or edited. No sensitive personal data is collected. To the best of our ability, we have researched and concluded that all third-party data processors we use are also compliant with the General Data Protection Regulations.

If you reside in the EU, we may collect and transfer your Data to the U.S. only with your consent, to perform a contract with you, or to fulfill a compelling legitimate interest of SMILE Therapy Services, LLC. Whenever appropriate and feasible, we enter into model clauses and data processing agreements with vendors to protect and maintain your privacy.

Legal Basis for Storage of Data Collected under GDPR

We process personal Data based on consent according to Art. 6(1) of the GDPR, which you are free to give or refuse. More specifically, Art. 6(1) lit. (a) of the GDPR serves as the legal basis for processing data for

which we have obtained your consent to process. Art. 6(1) lit. (b) of the GDPR serves as the legal basis for processing your personal Data when it is necessary to fulfill a contract or a contract-like relationship with you. Art. 6(1) lit. (c) of the GDPR serves as the legal basis for processing your personal Data to fulfill a legal obligation. Art. 6(1) lit. (f) of the GDPR serves as the legal basis for processing your personal Data when it is necessary to safeguard our or a third-party’s legitimate business interests, or your fundamental rights, freedoms, or interests that do not require the protection of your personal Data.

Jurisdiction and Applicable Law

The servers and parties that make this Website available are located within the United States. All matters relating to the Website will be governed by the laws of the United States and Washington, D.C., as well as the General Data Protection Regulation (GDPR), as it applies to residents of the European Union.

Updates and Changes to Privacy Policy

The terms of this Privacy Policy may change from time to time at our sole discretion. Please refer back to this policy regularly. By accessing and using this Website, you agree to any such changes we make to this Privacy Policy.

We welcome your questions or requests regarding this policy. Please contact us at:

SMILE Therapy Services, LLC

650 I Street NE

Washington, DC 20002

info@smiletherapyservices.com

Effective Date: This Privacy Policy was last updated on 3/16/2022 and is deemed effective as amended as of this date.