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The general purpose of the Straine Dental Management website (the "Site") is to provide online resources to potential and current partners.

Please note that from time to time in this agreement we will refer to ourselves as "Straine Dental Management," "SDM," "our," "us," "we," and/or "the Company;" and current and future partners, job seekers, current employees, and other visitors as "you" and or a "user." The following Privacy Notice, together with any documents they expressly incorporate by reference, such as the Terms of Use (collectively, "Terms of Use"), govern your access to and use of the Site, including any content, functionality, and services offered on or through the Site.

Please read the Privacy Notice carefully before you start to use the Site. By using the Site, you signify your assent to the SDM of Use and Privacy Notice, which outlines how our Site will collect information about you, how information will be shared and secured, and certain rights you have with respect to your information. All information we collect on this Site is subject to our Privacy Notice. If you do not agree with this Privacy Notice and/or our Terms of Use, do not use the Site. We may revise and update this Privacy Notice from time to time in our sole discretion. Your continued use of the Site following a reasonable notice of changes to this Privacy Notice will mean you accept the changes. All changes are effective immediately when we post them, and apply to all access to and use of the Site thereafter.

SDM is committed to ensuring the privacy of the information you share with us. This Privacy Notice explains our privacy practices, including what information we collect, how we use it, and what rights you have concerning your information. This Privacy Notice applies to information we collect when you engage with us online through the Site, or offline, unless we are processing that information as part of services we provide to others (in which case, another entity’s privacy policy will apply).

What Personal Information We Collect

We have collected and continue to collect to the Site the following categories of personal information from individuals within the last 12 months:

• Identifiers. This includes information such as your name, phone number, postal address, telephone number, email address.
• Professional and Employment Information. This includes practice name, practice role, identifying information such as your name, Social Security number, address, telephone number, driver’s license, education, employment, employment history, bank account information, medical information, and health insurance information. For example, we collect payment account information from clients. how many dental locations you have/work for, the type of services you are looking for/consideration (e.g., consulting, analytics, management, group pricing), the type of dental software you used in your own practice (e.g., Dentrix, Eaglesoft, OpenDental, etc.).
• Internet or Other Electronic Network Activity Information. This includes information such as your browsing history, browser name, domain type, operating system information, IP addresses, access times, and device identifiers.
• Geolocation Data. This includes information on your location when you visit our website or use our application.
• Inferences. We draw inferences from the above information to create a profile about you.

Our sites and apps are meant for adults. We do not knowingly collect personal information from children under 13 years old without permission from a parent or legal guardian. If you think your child under 13 has given us information, you can contact us using the email or phone number below. If you email us, please enter in the subject line: "COPPA Information Request." Parents, you can learn more about how to protect children’s privacy online here: https://www.ftc.gov/business-guidance/privacy-and-security/childrens-privacy.

How We Use Your Information

We may use your information for the following purposes:

• To communicate with you. We may use information to respond to your questions, to communicate about this policy or our terms, or to communicate with you regarding any other purpose described in this Privacy Notice.
• To perform our services. We may use information to send information about our dental services organization ("DSO") services ("Services"), to communicate with you, and to provide such Services. We may also use these technologies to improve the quality of the opportunities we provide to you or the Services we offer.
• For employment purposes. We may use your information for recruitment and hiring, to staff open positions at our Company, to provide payroll and administer benefits, for travel arrangements and performance management, for record-keeping, for safety purposes, to meet legal and compliance obligations, or for other internal purposes.
• For marketing. We may use contact, demographic and site usage information to communicate about our services and to provide information about SDM and its affiliates and subsidiaries. This may be by email, phone, or text. It may also be on social media platforms. We also use this information to provide information about SDM, our brands, affiliates, or other companies in which we believe you may be interested. The information we send includes briefings and newsletters. It also includes seminar information or whitepapers. We also send surveys. We send these materials as permitted by law. We do not use information collected in the context of your employment for marketing.
• To improve our Services. We may use your information to make our Site and Services better, and to keep our records updated.
• To protect our Company. We may also use your information to identify fraud, secure our systems, or for other purposes as permitted by law, including prosecuting or defending legal claims.

For other purposes allowed by law. Such as:

• Auditing.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use, where the personal information is not disclosed to another third party and is not used to build a profile about an individual.
• Performing Services on behalf of other entities.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to improve, upgrade, enhance, or verify or maintain the quality or safety of our services or equipment.
• Ensuring the physical safety of natural persons.
• We do not use your sensitive information, as defined under the California Consumer Privacy Act ("CCPA"), for any purposes other than those specified in CCPA Regulation 7027(m).

How We Collect Your Information

We collect information from the following sources:

• You. We collect contact and demographic information directly from you, including through our websites. We collect employment and payment information from you, including online and on paper forms.
• Your devices. We collect site usage and demographic information passively using tools like browser cookies and pixels. We collect site and location information about users over time when you use this website. We may have third parties collect personal information this way on our behalf. We may also use tracking tools to pull contact and demographic information from online sources.
• Other Companies. We collect contact and employment information from others, such as clients, social media partners, and technology partners. We also collect contact information and employment information from public records providers. We obtain demographic and site usage information from analytics firms.

When We Disclose Your Information

In the last 12 months, we disclosed personal information in the following ways:

• We disclose information within the SDM family of companies. We disclose information to our affiliates and related entities. Depending on the function of the affiliate or related entity, we reserve the right to disclose data types from any or all of the information categories listed above.
• We disclose information with companies who perform services on our behalf. We disclose information to companies who assist us, including benefits and payroll providers, payment-processing providers, and providers who help us deliver marketing and other communications. We disclose the following categories of information to companies who perform services on our behalf: identifiers; internet or network activity information; and professional or employment-related information.
• We disclose information with our clients and business partners. We disclose the following categories of information to our clients and business partners: identifiers and professional or employment-related information. We provide the to our business partners, lawyers, accountants and other professional service providers so they can provide services.
• We will disclose information if we think we must to comply with the law or to protect ourselves. We disclose information we collect about you to respond to a court order or subpoena or other administrative or government order or investigation request. We provide that information in response to a government agency or investigatory body requests. We also disclose information when we are investigating potential fraud.
• We will disclose information to any successor to all or part of our business. We disclose your information as necessary for any corporate restructuring, such as if we sell all or part of the business, merge with another company, or engage in bankruptcy proceedings.
• We disclose information as permitted by law and for other reasons we may describe to you. We do not disclose your personal information to any third-party vendor or website owner for their own marketing purposes.

When We Sell or Share Your Information

We do not provide your information to third parties in exchange for money. We do not engage in "selling" or "sharing" your information. In the last 12 months, we have not allowed companies to collect the following categories of personal data for targeted advertising or cross-contextual behavioral marketing. Given that we limit our collection of data concerning minors, we do not have actual knowledge that we allowed those companies to collect information on anyone who is younger than 16 years old.

If we do ever sell or share your data that requires consent or opt-out notice, you will be afforded the ability to consent before the collection of your information and/or the ability to opt out.

Our Use of Tracking Technologies

We and our trusted partners use tracking technologies such as cookies, pixels, web beacons, flash cookies, and similar technologies that track users over time and across different websites in order to engage in interest-based or online behavioral advertising. We also use these tools to:

• recognize new or past potential and future partners,
• store your password if you are registered on our Site,
• improve our Site and to better understand your visits on our Site,
• and integrate with third party social media websites,
• observe your behaviors and browsing activities over time across multiple websites or other platforms, or
• better understand the interests of our customers and our website visitors.

[Include only if you are able to honor GPC signals: If your web browser supports Global Privacy Control (GPC), you can configure your web browser to use GPC to opt-out of personal information "sale" or "sharing" as defined in the CCPA. You can find more information on enabling GPC within web browsers at the following web site: https://globalprivacycontrol.org/.]

• https://optout.networkadvertising.org/
• http://optout.aboutads.info/
• http://youradchoices.com/

Some browsers have "do not track" features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.

SMS Texts Terms and Conditions.

Enrollment in our mobile SMS messaging service requires you to provide your mobile phone number and to agree to these terms and conditions. By opting in to SMS messaging you represent and confirm that you are the account holder for the telephone number(s) that you enroll in the SMS messaging and that you are authorized to grant us the right to send text messages to that number. You may not enroll if you are under 18 years old.  SDM has the right to stop offering SMS messaging at any time with or without notice. SDM also reserves the right to change the short code or phone number from which we send you messages, and we will notify you when change such code or phone number.

You expressly consent to receive marketing and/or non-marketing text messages, as applicable, from or on behalf of SDM. You are not required to consent to receiving such messages as a condition of purchasing any property, any goods, or any services. Please consult with your mobile carrier about whether your mobile plan and/or device are capable of receiving text messages. Your agreement with your mobile carrier governs your message and data rates. You acknowledge that you are responsible for any charges incurred from using SMS messaging. We may also provide details of your transaction with us to you via text. Text messages may include, but are not limited to, text messages that may be made with an autodialer, which is an automatic telephone dialing system. You may opt-out of these communications at any time. The process to opt out of SMS messaging is set forth below. Please note that opting out of SMS messaging will only apply to text messages from us. You must unenroll from our email program and any other communication programs with us separately. You cannot opt out of receiving these messages unless you stop using our services.

Your Privacy Rights

Our commitment to privacy includes going beyond what is required. In some states, such as California, Colorado, Connecticut, Montana, New Hampshire, New Jersey, Tennessee, Texas, Utah, and Virginia the law grants you all the below rights (subject to some limitations). But we will endeavor to provide these opportunities to everyone in the United States.

• Right to Know. You can ask us to give you information about our collection and use of your personal information. Specifically, you can request we provide you one or more of the following: the categories of personal information we collected about you; the categories of sources from which we collected your personal information; our purposes for collecting your personal information; the categories of third parties to whom we disclose your personal information; and the specific pieces of personal information we collected about you. You can also ask that we provide you a copy of your information in a commonly used, machine-readable format.
• Right to Delete. You can ask us to delete your personal information.
• Right to Correct. You can ask us to correct any inaccurate personal information that we have about you. Some information you can change yourself. You may review and change any personal information in your account profile and, where applicable, personal account preferences, stored in our system if you believe it may be out of date or incorrect.
• Right to Opt Out of Targeted Advertising (Sharing). You can ask us to not allow third parties to collect your information on our website for targeting advertisements based on your activity across multiple websites. (This concept is known as "targeted advertising" in most places and "sharing" in California.) Though, as indicated above, we do not engage in this, but have to disclose your right to opt-out of targeted advertising regardless.
• Right to Opt Out of Sales. You can ask us to not sell your information. As noted above, we do not "sell" your information in the traditional sense (an exchange for money), but we do disclose it for targeted advertising—which some jurisdictions may consider a sale. Though, as indicated above, we do not engage in this, but have to disclose your right to opt-out of targeted advertising regardless.

You can exercise these rights by contacting us at info@Straine.com or by calling us at 1-800-568-7200.

Unless you are requesting to opt out of sales or targeted advertising, we must verify your identity before we honor your request. We verify your identity by trying to match the following information you provide to us with information we have about you:

• Contact information (such as name, email, phone number, and address)
• An indication of what SDM brands you have previously interacted with.

If we are unable to verify your identity with the information you provide, we may deny your request or request additional information.

Sometimes we may be unable to fulfill your request. If you disagree with our decision, you can file an appeal by contacting us info@Straine.com. In the subject line, please write: Data Subject Right Appeal – [Full Name]. The body of the email should include: (1) your name, (2) the date of the decision you are appealing, and (3) an explanation for why you disagree with that decision. We will contact you if we need more information.

If you reside in California, you can have an authorized agent submit a Right to Know, Correct, or Delete request on your behalf. If you choose to use an agent, and the agent does not have power of attorney under the California Probate Code, we cannot process the request until:

• The agent provides a copy of your signed permission authorizing the agent to make the request; and either
• You verify your identity directly with us; or
• You provide us direct confirmation that you provided the agent permission to submit the request.

If your authorized agent has a valid power of attorney under California Probate Code sections 4121 to 4130, we may request proof of the power of attorney instead of the foregoing.

Nevada residents may opt out of the future sale of their information to a third party so that the third party may license or sell information by emailing us at: info@Straine.com.

How Long We Keep Your Information

In general, we keep your information for as long as we need it to conduct the relevant purposes described above, and as necessary to comply with our records-management policies. We also keep your information as necessary to comply with other obligations we might have, as permitted, or as required by law, or as otherwise communicated to you.

How We Protect Your Information

We have implemented technical, administrative, and physical security measures designed to protect your personal information from unauthorized access, disclosure, use, and modification. Nonetheless, the Internet is not 100% secure. We cannot promise that your use of our sites or apps will be completely safe. We encourage you to use caution when using the Internet.

We Store Information In the United States

We are in the United States. If you live outside of the United States, you understand and agree that we may process your information in the United States. Our businesses are subject to United States laws, which may not afford the same level of protection as those in your country. By submitting your information, you agree to the processing of it in the United States.

Third Party Links and Tools

We may link to other sites or apps, or have third party services on our platforms that we do not control. If you click on a third party link, you will be taken to a platform that we do not control. This Privacy Notice does not apply to the privacy practices of that website or platform. Please read other companies’ privacy policies carefully. We are not responsible for these third parties. Our Site may also serve third party content that contains their own cookies or tracking technologies. We also do not control the use of those technologies.

How You Can Contact Us

Feel free to contact us if you have more questions about this privacy policy or our data practices. You can email us at info@Straine.com or write to us at: Straine Dental Management LLC, 838 University Ave., Sacramento, CA 95825; Attn: Privacy Officer.

We May Update this Policy

From time to time we may update this Privacy Notice. We will post the updated copy and include the date of the update. If the changes are material, we will post a prominent notice, and we may contact you at your email address we have on file. Please check our site periodically for updates. Your continued use of the site after we post the updated copy constitutes your acceptance of the updated Privacy Notice.

Contact Us

Straine Dental Management LLC

838 University Ave.

Sacramento, CA 95825

1-800-568-7200

info@Straine.com