Effective Date: January 1, 2020

This website is operated on behalf of Espire Dental (“Client(s)”) by MD Connect, Inc. (“MD Connect”, “we”, “us” or “our”). On it, we are assisting the Client(s) with the education of potential and existing patients and caregivers (“Patients”, “you” or “your”) and providing the ability for those Patients to easily contact the Client for potential healthcare services. This Privacy Policy describes our personal information collection procedures and the choices available to you regarding our use and disclosure of your personal information.

MD Connect collects, uses, and discloses personal information you share with us directly or you voluntarily provide through your use of this website (the “Site”), regardless of how you access the Site or our services, which may be through the use of a mobile device. We also may collect personal information through our service providers by means of phone conversations directly with you or conversations you have with the Client, which may be recorded for quality assurance. By providing personal information to us directly or by using the Site, you are consenting to the terms and conditions of this Privacy Policy. The use of information collected through our service shall be limited to the purpose of providing services for which Clients engage MD Connect, primarily the education of Patients and the ability for those Patients to easily contact the Client for potential healthcare services.

Information Collected

When you visit our Site or contact us or we contact you, we collect personal information that you provide voluntarily. MD Connect only collects personal information that is limited and necessary to educate Patients and allow them to easily contact the Client for potential healthcare services.

Personal Data

In the provision of our services, MD Connect (Data Processor) processes Personal Data on behalf of its Client(s) (Data Controllers). Personal Data means any information relating to an identified or identifiable natural person (data subject).

Personal Data includes direct and indirect identifiers such as:

• Name
• E-mail address
• Phone number
• Address
• IP address
• Identification Number
• Location Data (e.g. zip or postal codes)
• On-line Identifier
• Any personally identifiable information that may be disclosed via a phone call with us or Client
• Sensitive Data that may include one or more factors specific to physical, psychological, genetic, mental, economic, cultural or social identity of a natural person.

Sensitive Data

In the provision of our services, MD Connect (Data Processor) may process Sensitive Data on behalf of its Client(s) (Data Controllers). Sensitive Data is a special category of Personal Data that requires additional privacy and security protections. The collection of Sensitive Data is done at the direction of our Client(s) and is limited to specific and necessary Sensitive Data needed to educate Patients and allow them to easily contact the Client for potential healthcare services.

Sensitive personal information that may be collected includes:

• Medical conditions
• Severity of condition
• Medical test results
• Age
• Height & Weight
• Lifestyle/habits (e.g. exercise, smoking)
• Prior medical procedures
• Medical symptoms
• Ethnicity
• Existing participation status or willingness to participate in a clinical trial
• Choice of physician or medical clinic
• Requested or actual appointment date and time

Uses and Disclosures of Information Collected

MD Connect uses and discloses Personal Data (including Sensitive Data) for a variety of purposes that are limited and necessary to the operation of our business and the delivery of services to you. These purposes include to:

• Relay Your Personal and Sensitive Data to Client to follow-up with You via phone or email
• Monitor response of patient outreach programs
• Provide our services and generally manage and administer our business including required records retention processes;
• Develop and improve our services;
• Reply to your requests, inquiries and comments;
• Contact you via land line phone, cell phone, email, text message (cell and data charges may apply);
• Respond to circumstances permitted or required by law, including defending and bringing legal actions; and
• Ensure the security and integrity of our websites and operations.

Transmission of your personal information from your computer to ours is encrypted. We share this information with Espire Dental. The mode of sharing is, at their option, either through a secure portal or through an unencrypted email.

MD Connect may disclose personal information collected through this Site to affiliated third party service providers, such as IT support services, customer service providers, and other services providers that support us and facilitate the services we provide to you. These companies are authorized to use your Personal Data only as necessary to provide these services to us. For example, we use Google Analytics, a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of our Sites, to prepare reports for us on website activities and share them with other Google services. However, Google Analytics offers an opt-out provision for website visitors who do not want their data to be collected. You can access more information about this option at http://tools.google.com/dlpage/gaoptout.

Google may also use the data it collects to contextualize and personalize the ads of its own advertising network. The Personal Data collected for this purpose is limited to cookie and usage data. You should refer to Google’s privacy policy for more details about their data privacy practices related to this usage.

MD Connect may disclose information to a third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data. Further, we may use and disclose information collected through the Site as we believe to be necessary or appropriate, including: (a) as permitted by applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit damages that we may sustain. We may also disclose your Personal Data to any other third party with your prior consent.

MD Connect reserves the right to compile and use the Personal Data collected as described above, in a de-identified or anonymized format, i.e. no longer personally identifiable as defined by data privacy regulations, for data aggregation and data analytics purposes.

Passive Information Collection and Use

MD Connect websites use a passive technology called “cookies” and other similar technologies. MD Connect uses this information to help us understand our website activity and to monitor and improve our websites. Cookies also provide information about you and your preferences, and help us personalize your experience on our Site. You can set your web browser to notify you when cookies are being placed on your system or to not accept cookies. However, if you decide not to accept cookies from our websites, you may not be able to take advantage of all of the features available to you on our websites.

Our Site uses another passive technology called “internet tags” or “web beacons”. This technology allows us to understand which webpages you visit and helps us optimize and tailor our websites to you and other future visitors. You can set your browser to notify you when these passive technologies are being placed on your system to not accept them.

We partner with third parties to display advertising on our website or to manage our advertising on other sites. Our third party partners may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here. Please note you will continue to receive generic ads.

Mobile Device Information

MD Connect also collects information from and about your mobile device, such as a unique device identifier.

Unaffiliated Third Party Sites and Services

MD Connect may make unaffiliated 3rd party sites and services available to you to access. Access to these sites and services requires that you provide your consent to the services or products offered by the unaffiliated 3rd parties before access is granted to the 3rd party sites. This Privacy Policy does not apply to the unaffiliated 3rd party sites and offerings. The 3rd party sites and offerings are governed by the Privacy Policy of the unaffiliated 3rd party. You should review their Privacy Policy before consenting to access their sites and offerings. MD Connect is not responsible for the personal information you provide to these unaffiliated third parties sites and offerings, including and without limitation to any third party operating any site, web property and/or application that is available to you through this Site or to which this Site contains a link. The availability of or inclusion of a link to any unaffiliated 3rd party site or products on the Site does not imply or serve as an endorsement of it, its services or products by MD Connect.

Use of Site by Minors

Use of this Site or our services is not generally directed to individuals under the age of 18, and we request that these individuals not provide Personal and/or Sensitive Data through the Site or through our service providers unless identified as appropriate on the Site. However, there may be some Clients that are specifically seeking this age group. In such cases parental consent may be required prior to Data submission.

If personal information related to individuals under the age of 18 is identified and deemed inappropriate, reasonable steps will be taken to delete the information.

Security

MD Connect uses reasonable measures to protect your information, such as using physical, technical, and administrative security safeguards to reduce the risks of loss, misuse, unauthorized access, disclosure, or alteration. For example, we limit access to your Personal Data to authorized employees, service providers and contractors who need access to perform services described in this Privacy Policy. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please notify us immediately by contacting privacy@mdconnectinc.com or by faxing your notice to +1 (781) 235-0929.

Choices and Access

By providing us with your personal information you are consenting to our collection, use and disclosure of your personal information as described in this Privacy Policy.

Upon request MD Connect will provide you with information about whether we hold any of your personal information. If you wish to:

1. change your preferences about the personal information you provided to us or
2. withdraw your consent to its retention, use or disclosure, or
3. receive a copy of your data and/or
4. generally exercise your rights of access, rectification, cancellation and opposition with respect to your personal data and the health information you submit

Please note that our response to your request to withdraw consent is subject to legal or contractual restrictions and reasonable notice, including: (i) if you withdraw your consent before we submit your information to our Client’s clinical trial site, we will not submit it; (ii) if we receive notice of your withdrawal after we have submitted your information, you will need to contact the Client’s clinical trial site to withdraw your consent to further use; (iii) where we have provided or are providing services to you, your consent will be valid for as long as necessary to fulfill the purposes described in this Privacy Policy or otherwise stated at the time of collection.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Retention Period

We retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.

Cross-Border Transfer

Your information may be processed in the country in which it was collected or transferred to other countries, including the United States (where our servers are generally located), for processing where laws regarding processing of information may be less stringent than the laws in your country. By using this Site and our services, you consent to the transfer of your personal information to countries outside of your country of residence, including the United States.

Platform Data Collection

MD Connect (Data Processor) collects information under the direction of its Client(s) (Data Controller(s)) and processes information on our Client(s)’ behalf. We have no direct relationship with the individuals whose Personal Data we process. If you are a Patient of our Client(s) and would no longer like to participate and/or be contacted by our Client, please contact the Client directly.

We may also transfer Personal Data to companies that support us in providing our services for our Client(s). Such transfers to subsequent third parties are covered by the service agreements with our Client(s) and/or with MD Connect. Such contracts hold the Parties to standards of confidentiality and security consistent with this Privacy Policy.

MD Connect acknowledges that you have the right to access your personal information. Individuals who seek access, or who seek to correct, amend, or delete inaccurate data should direct their query to MD Connect’s Client or MD Connect directly. If requested to remove data we will respond within a reasonable timeframe.

MD Connect will retain Personal Data we process on behalf of our Client(s) for as long as needed to provide services to our Client(s). MD Connect will retain this personal information for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Updates to This Privacy Policy

This Privacy Policy may be revised from time to time. Any changes to this Privacy Policy will become effective when the changes are posted in a revised Privacy Policy on the Site. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. Your continued voluntary provision of personal information or use of the Site following these changes serves as consent to the revised Privacy Policy.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at privacy@mdconnectinc.com. or by faxing to +1 (781) 235-0929.

OP SOP03 APP4-V2