Privacy Statement

Last Updated: October 20,2020

Universal Orthodontic Lab, Inc. (“us”,“we”, or “our”) values your privacy. In this Privacy Statement (“Statement”), we describe how we collect, use, and disclose information that we obtain about visitors to our website (the “Website”) and users of the services available through our Website (together with the Website, the “Services”).

This Statement is subject to the Terms of Service for the Website and Services. This Statement does not apply to information collected by us offline or other than through the Services. Certain terms of this Statement apply only to individuals who register for an account on our Services.

By accessing or using the Services, you acknowledge that you have read and understand the statements herein. By accessing or using the Services, whether by visiting the Website and/or voluntarily providing your personal information (“Personal Information“) to us, you acknowledge and agree that we may collect,use, and/or store your Personal Information as provided in this Statement. If you do not agree with the terms of this Statement, do not use the Services or provide any information to us.

We will not use or share your information with anyone except as described in this Statement.

1. INFORMATION WE COLLECT

We may collect the following types of information when you use the Services:

“Personal Information”: information that identifies you or another person as an individual, such as your or someone else’s name, address, contact details, date of birth, gender, relationship to policy holder, job title, IP address, or any other identifier by which you or any other individual may be contacted online or offline. Due to the nature of the Services you are entitled to, your or someone else’s Personal Information may contain sensitive data including, but not necessarily limited to, your medical condition and health status.

“Non-Personal Information”: information that does not identify you as an individual, such as your browser type, your internet connection, the URL of the previous website you visited, the equipment you use to access the Services, and details about how you use the Services.

2. HOW WE COLLECT YOUR INFORMATION.

We may collect information (i) when you provide it to us, or (ii) automatically through the Services.

Information You Provide to Us via the Website. When you use the Website, you may choose to provide us with Personal Information and/or Non-Personal Information, including when you:

• Complete and submit forms on the Services, including registering an account with Universal Orthodontic Lab.

• Use the Services.

• Contact us.

• Report a problem with the Services.

Information We Collect Automatically. We do not collect Personal Information automatically, with the exception of IP addresses, which may be collected automatically and are only used as described below. Other than IP addresses, we do not collect real-time Personal Information about you or your devices via the Services. When you access and use the Services, we may use automatic data collection technologies to automatically collect:

• Usage details (e.g., details regarding your access to, performance of, and use of the Website) which can include passively collected log files that record website activity; and

• Device information (e.g., information about your computer or mobile device and/or internet connection, including the device’s unique device identifier, operating system, browser type, and/or mobile network information).

If you do not want us to collect this information, please do not use the Website.

The technologies we use for automatic information collection may include “cookies.” A cookie is a small file placed on your browsing device to enhance your experience of the Services. It may be possible to refuse to accept cookies by activating the appropriate setting on your computer, tablet, or smartphone. However, if you select this setting you may be unable to access certain parts of our Website.

3. THIRD PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES; DO NOT TRACK

Cookies and Other Tracking Technologies. Some content on the Website or Services, including advertisements, may be served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use the Website. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Do Not Track. “Do Not Track” is a privacy preference that you can set in your web browser. When you turn on the Do Not Track signal, your browser sends a message to websites requesting them not to track you. For information about Do Not Track, visit www.allaboutdnt.org. At this time, we do not respond to Do Not Track browser settings or signals. In addition, we may use other technology that is standard on the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the Website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.

4. HOW WE USE YOUR INFORMATION

Your information is collected for a number of different purposes that are connected with the Services we provide. We use your Personal Information to:

• Make the Website available to you;

• Provide you with information, products, or Services that you request from us;

• Comply with applicable law;

• Fulfill any other purpose for which you provide or we receive the information;

• Continuously develop, improve, and test our Services;

• Send notices, updates, support messages, and security alerts;

• Provide customer support; and

• Investigate and take remedial measures regarding any unauthorized access to your account and any other illegal activity.

5. DISCLOSURE OF YOUR INFORMATION

We do not share your Personal Information with third parties in any manner not described in this Statement.

We may disclose aggregated Non-Personal Information about our users, and information that does not identify any individual, to third parties to help us improve the Services or for any other commercially valid purposes.

We may disclose your Personal Information to:

• Our company. Access to Personal Information within the company is restricted to those individuals and entities who have a requirement to access the information for the purposes described in this Statement;

• External third-party service providers, such as IT systems, support and hosting service providers; document and records management providers; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities;

• External professional advisors and partners such as medical professionals, accountants, actuaries, auditors, experts, consultants, lawyers; banks and financial institutions that service our accounts; claim investigators, adjusters and others;

• Our regulators and other governmental or public authorities where necessary to comply with a legal or regulatory obligation;

• The police and other third parties or law enforcement agencies, court, regulator, government authority or other similar third parties where necessary for the prevention or detection of crime or to comply with a legal or regulatory obligation; or otherwise to protect our rights or the rights of a third party;

• Selected third parties in connection with any sale, transfer or disposal of our business; and

• Other third parties, such as emergency providers (fire, police and medical emergency services).

We may use and/or disclose your health information as described in this policy,except our use and disclosure of the information is further limited by the main federal health privacy law known as the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).

We will use and disclose the protected health information only for purposes that are connected with the Services we provide to you as described in this Statement, for those uses and disclosures permitted by HIPAA, and the agreement that we have with an insurance company, billing provider, or other entity subscribed to our claim adjudication service. In the event that there is a conflict or inconsistency about the handling of the protected health information between(i) this Statement and (ii) our compliance obligations with HIPAA and contractual commitments with the subject entity, then the latter will govern.

6.OPTING OUT

We may periodically send you email messages describing news, information, updates,or promotional offers related to the Services or our products.

You can “opt-out” of receiving emails from us at any time by following the instructions included in your email and we will make the requested changes. Whether you opt-out of receiving promotional emails or not, Universal Orthodontic Lab reserves the right to email or otherwise contact you with respect to important information, important notices, or important changes relating to our products and Services.

7.ACCESSING AND CORRECTING PERSONAL INFORMATION

• You can review and change your Personal Information by logging into your account with us; or, if such Personal Information is not available by logging into your account with us, please send us an email at customerservice@uniortholab.com to request access to, or to correct or delete any of your Personal Information in our possession. We may not change or delete information if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.

• California Civil Code Section § 1798.83 permits California residents who use our Services to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to customerservice@uniortholab.com or write us at:

Universal Orthodontic Lab, Inc.
C/O Privacy Officer
11917 Front Street
Norwalk, CA 90650

8.RETENTION AND DATA SECURITY

We retain Personal Information collected through the Services for a reasonable period of time consistent with the purposes of the collection, or for other essential purposes including, without limitation, compliance with applicable laws, dispute resolution, and business operations. The retention periods can vary greatly depending on the type of information collected and the content.

The transmission of information via the Internet and the storage of such information is not completely secure. Personal Information is protected using various physical, administrative, and/or technical safeguards in transit and at rest. Although we utilize reasonable security measures to protect your Personal Information, we cannot guarantee the security of your Personal Information as no method of safeguarding information is 100% secure. The email functionality provided by the Services is not a completely secure and confidential means of communication. It is possible that your email communication may be accessed or viewed by another internet user while in transit to us. If you wish to keep your communication private, do not use such email functionality. In such case, please contact Universal Orthodontic Lab by phone.

You acknowledge and agree that you are providing, or allow us to gather, your Personal Information to us at your own risk. We are not responsible for failure or circumvention of any privacy settings or security measures we may have in place to protect your Personal Information.

9.CHILDREN UNDER THE AGE OF 13

In compliance with the Children’s Online Privacy Act, 15 U.S.C. § § 6501-06 and 16 C.F.R. § § 312.1-312.12, we do not permit children under 13 years of age to become registered users of the Services and we do not knowingly collect information from children under 13 years of age. If you are under 13, do not use our products, the Services, or provide any information to Universal Orthodontic Lab through the Services. If we learn that Personal Information of a child under the age of 13 is collected, we will delete that information from our systems. If you believe we might have any information from or about a child under 13, please contact us at customerservice@uniortholab.com. By using the Services, our products, and/or providing any information to Universal Orthodontic Lab, you represent that you are 13 years of age or older.

10.CHANGES TO OUR PRIVACY STATEMENT

We may update this Privacy Statement from time to time to ensure that it remains accurate. Please check back each time that you provide additional Personal Information to us. Where changes to the Statement will have a fundamental impact on the nature of our processing of your Personal Information, or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights in relation to your Personal Information.

The date this Statement was last revised is identified at the top of the page and the terms of this Statement are effective as of that date.

11.CONTACT INFORMATION

To ask questions or make comment about this Statement or our other privacy practices, contact us at: customerservice@uniortholab.com.