What information we collect, why we collect it, and how it is used

We Process the Following Personal Information in our Website and Platform:

• Contact Us Information. If you send us a Contact Us request, whether by submitting a form that we make available in the Website, calling the W Clinic, or by sending an email to an email address that we display, you may, at your discretion, provide us with certain information such as your name and email address, in order for us to process your request or query.
• Automatic Data Collection. We may automatically collect certain information through your use of the Website, such as your unique user identifier. We currently do not, but we may in the future, process additional Personal Information, upon updating our Privacy Policy, such as processing internet protocol (IP) address, cookie identifiers and other device identifiers that are automatically assigned to your device, browser type and language.

We process information for the following purposes:

• To provide you with the Services. We will use your information to provide the Services and support.
• For Administrative Purposes. The W Clinic may use your information (i) to respond to your questions, comments, and other requests for customer support, or information, including information about potential or future services; (ii) to make an appointment at the W Clinic; (iii) for internal quality control purposes; and (iv) to any other use that is applicable to your inquiry or request.
• To Market the W Clinic Services. The W Clinic may use information to market the Services. Such use includes notifying you about new treatments or services that may be of interest to you or for other purposes disclosed at the time you provide information; and as you otherwise consent.
• Security purposes. Some of the abovementioned information will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; and for security purposes. Information may also be used to comply with applicable laws and/or to exercise or defend legal claims.
• De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your Information and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes.

How we protect and retain your information

Security. We have implemented and maintain reasonable technical, organizational and security measures designed to protect your information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

Retention of your information. Your information will be stored until we delete our records, and we proactively delete it, or if you send a valid deletion request. Please note that in some circumstances we may store your information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your information or dealings.

How we share your information

In addition to the recipients described above, we may share your information as follows:

The information that the W Clinic gathers is shared with our partners and other third parties. We disclose your information as is necessary for us to provide you with the Services, such as making appointments, sending queries or any other Service applicable and provided under the Website.

We may use third party service providers to process your information for the purposes outlined above, including, without limitation:

• With our service providers such as our web-developers, for maintenance purposes.
• With cloud service providers for hosting purposes;
• With websites and web content creation platforms in order to help us manage our Website;
• With email providers, marketing, CRM, other similar tool providers and/or sales dialer software;
• With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy;
• With artificial intelligence tools and features;
• With billing companies; and/or
• With data validation and enrichment companies.
• With service providers to generate Aggregated Anonymous Data (as defined below) and use it for our or our service providers business purposes, including without limitation, for purposes of improving, testing, operating, promoting and marketing products and services. Aggregated Anonymous Data means data submitted to, collected by, or generated with Customers use of the Services, but only in aggregate or anonymized form, which will not include any Customer or user identifiable information.

To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order.

Where you have otherwise provided your consent to us for sharing or transferring your information.

Your privacy rights

Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by certain privacy regulations):

• You have a right to access Personal Information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
• You have the right to request that we rectify any Personal Information we hold that is inaccurate or misleading;
• You have the right to request the erasure/deletion of your Personal Information (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;
• You have the right to object, to or to request restriction, of the processing;
• You have the right to data portability. This means that you may have the right to receive your Personal Information in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
• You have the right to object to profiling;
• You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

You can exercise your rights by contacting us at the contact information provided in the Website. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

Marketing emails – opt-out: If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.

Use by children

Personal information relating to patients under the age of 18 may only be provided by a parent or legal guardian. By submitting personal information on behalf of a minor, the person submitting confirms that they are the minors parent or legal guardian and consent to the collection and processing of the minors information for the purpose of providing dental services and managing appointments.

Interaction with third party products

We may enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us, such as recommending articles or other related service providers that may be recommended to you (each, a Third Party Service). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

Analytic tools

We may use analytical tools for tracking users and website visitors, and will inform you of any specific tools used where such is required under the terms or the applicable laws to such tools.