Privacy Policy

SMILETWICE, INC.

LAST UPDATED: 05/14/2021

This privacy policy (the “Privacy Policy”) applies to the website located at www.smiletwice.com and all other sites, mobile sites, services, applications, platforms and tools (collectively, the “Platform”) owned and operated in connection with the Twice business by SmileTwice, Inc, a Delaware corporation, (“Twice,” “we,” “us,” or “our”). We have created this Privacy Policy to tell you what information the Platform collects, how we use that information, and who we will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. Capitalized terms not defined in this Privacy Policy will have the meaning set forth in our Terms & Conditions (the “Terms”) which incorporates this Privacy Policy in its entirety. By visiting and/or using our Platform, you are agreeing to the terms and conditions of this Privacy Policy and the Terms. We encourage you to read the Privacy Policy and to use the information it contains to help you make informed decisions.

Information We Collect or Receive

In the course of operating the Platform, we will collect and/or receive the following types of information. You authorize us to collect and/or receive such information.

Personal Information. We only receive or collect information that identifies you personally if you choose to provide such personally identifiable information to us via email or other means. When you sign up to become a user or contact us, you will be required to provide us with personal information about yourself (collectively, the “Personal Information”). Such Personal Information may include your name, e-mail address, physical address, and phone number. We do not collect any Personal Information from you when you use the Platform unless you provide us with the Personal Information voluntarily.

Payment Information. If you choose to purchase a Product using the Platform or otherwise sign up for a feature or service offered on or through the Platform that requires payment of a fee, you will be required to provide us with your payment information, including, without limitation, bank account numbers, credit card or debit card numbers, account details, ACH information, and similar data (collectively, “Payment Information”). Such Payment Information will be collected and processed by our third-party payment processor pursuant to the terms and conditions of their privacy policies and terms of use, and we do not obtain access to any Payment Information in connection with such Product purchase or other payments. Our third-party payment processor stores your Payment Information; we do not store Payment Information. Storage by our third-party payment processor of your Payment Information is subject to the privacy policies and practices of the third-party payment processor and is not subject to the terms of this Privacy Policy. By providing your Payment Information, you acknowledge and agree to use of your Payment Information by our third-party payment processor for purposes of processing your payment to us. Currently, our third-party payment processor is Stripe, and use and storage of your Payment Information are governed by Stripe’s terms of service and privacy policy (available at: https://stripe.com/us/legal and https://stripe.com/us/privacy or any of its successor sites). We may from time to time request and receive certain information from our third-party payment processor or from you directly for purposes of completing transactions you have initiated through the Platform, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business. In no cases will such requested information allow for a financial transaction to be initiated.

Third-Party Analytics. We and the third-party technology providers, ad exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers with which we work use third-party analytics services (e.g., Google Analytics) to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Platform and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit http://optout.networkadvertising.org/. Please be advised that if you opt out of any such service, you may not be able to use the full functionality of the Platform.

Other Information. In addition to the Personal Information and Payment Information, we may automatically collect or receive additional information regarding you and your use of the Platform; your interactions with us and our advertising; and information regarding your computer and mobile devices used to access the Platform (collectively, the “Other Information”). Such Other Information may include: From You. Additional information about yourself that you voluntarily provide to us, such as your gender and your product and service preferences. From Your Activity. We may collect or receive information regarding: IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device; browser type and language; referring and exit pages and URLs; date and time; and details regarding your activity on the Platform, such as search queries and other performance and usage data. About Your Mobile Device. If you use a mobile device to visit or access the Platform (whether by using a Twice mobile application or otherwise), we may collect or receive information regarding the type of mobile device you use to access the Platform, along with information about that mobile device’s operating system and version (e.g., iOS, Android or Windows), carrier; and network type (e.g., WiFi, 3G, 4G, LTE). Other Information Collected by Automated Means. Additional information collected by automated means as described in Section 2 below.

Information Collected By Automated Means

When you visit or use the Platform, we may collect certain information automatically. To collect this information, we may use cookies, web beacons, and similar technologies. A “cookie” is a text file that websites send to a visitor‘s computer or other internet-connected devices to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as a pixel tag or clear GIF, is used to transmit information back to a web server. We may also collect information about your online activities over time and across third-party websites. The information we collect automatically may include: URLs that refer visitors to the Platform; Search terms used to reach the Platform; Details about the devices that are used to access the Platform (such as IP address, browser information, device information, and operating system information); Details about your interaction with the Platform (such as the date, time, length of stay, and specific pages accessed during your visits to the Platform, and which emails you may have opened); and Usage information (such as the number and frequency of visitors to the Platform).

We may associate this information with your Account with Twice if you have one, the mobile device or browser you use to access to the Platform, or email or social media accounts that you use to engage with Twice. If you do not want us to deploy cookies in the Platform, you can opt out by setting your mobile device or browser to reject cookies. You can still use the Platform if you choose to disable cookies, although your ability to use some of the features may be affected.

Advertising Services Provided By Others

We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in mobile applications. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Platform and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information and we may the same kinds of information with such third parties for the same purposes. This information may be used by Twice and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Platform and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for interest-based advertising purposes, please visit www.aboutads.info/choices.

How Information is Used and Shared

You authorize us to use the Personal Information, Payment Information, and the Other Information (collectively, the “Information”) to: provide and improve the Platform or any services offered or made available through the Platform; provide and improve our Products provide any services offered or made available through the Platform; administer our promotional programs; solicit your feedback; and inform you about our Products, the Platform, and any services offered or made available through the Platform.

In order to provide our services and administer our promotional programs, we may share the Information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.

We engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, marketing assistance, and administration of promotional programs. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.

In an ongoing effort to better understand our users, the Platform, any services offered or made available through our Platform, and our Products, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage, and improve the Platform and/or such Products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the Platform and these Products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.

We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

To the extent permitted by law, we may also disclose the Information (a) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (b) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.

Accessing and Modifying Information and Communication Preferences

If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth below. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases. You cannot opt out of receiving transactional e-mails related to the Platform (e.g., requests for support).

We may also deliver notifications to your mobile device (e.g., push notifications). You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.

Your Sharing of Information Through The Platform

We do not control your use of the Platform to share Information about you (whether Personal Information or otherwise) with others. If you chose to share any Information about yourself publicly through on or through the Platform, you understand and acknowledge that we cannot control the actions of third parties who could collect this Information.

Do Not Track

We do not monitor, recognize, or respond to any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

How We Protect Your Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

The security of your use of your Account relies on your protection of your username and password. You may not share your username and password with anyone. If you believe that unauthorized access to your Account has occurred please report it immediately at help@smiletwice.com. You must promptly notify us if you become aware that any information provided by or submitted to your account has been lost, stolen, or used without permission. We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information on a Twice website.

Any email or other communication purporting to be from Twice or our Platform or made by a third party on Twice’s behalf that requests your password or asks you to provide sensitive account information via email should be treated as unauthorized and suspicious and should be reported to us immediately by emailing help@smiletwice.com. If you believe someone else has obtained access to your password, please change it immediately by logging in to your Account and selecting the provided option to change your password and report it immediately by emailing help@smiletwice.com.

Important Notice To Non-U.S. Residents

The Platform and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Platform, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

App-stores; External Websites

In the event you are accessing the Platform by means of a mobile application owned or operated by Twice, your app store (e.g., iTunes or Google Play) may collect certain information in connection with your use of the Platform, such as Personal Information, Payment Information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.

The Platform may contain links to third-party websites. We have no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Children

Neither Platform nor the Products are directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act and will not knowingly collect Personal Information from any child under the age of 13. We ask that minors (under the age of 13) not use the Platform. If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.

Changes to this Privacy Policy

Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the Platform. By accessing the Platform after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at help@smiletwice.com with “Privacy Policy” in the subject line or mail us at the following address: SmileTwice, Inc, 14 Harrows Lane, Purchase, NY 10577; Attn: Legal Dept.