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Effective Date: August 1, 2020
Last Reviewed on: September 10, 2020
This policy is for California residents and any others covered by the California Consumer Privacy Act (CCPA) that use the Club Grin Website or Services (as defined in the Privacy Policy of Club Grin, found here. Club Grin (referred in this policy as Company, our, us, or we) understands the importance of data privacy to you and therefore we want to be transparent in how we collect, share, protect and otherwise use your or your legal guardian’s Personal Information. We also want you to know your rights under the CCPA. We also have a section concerning Health Record Insurance Portability and Accountability Act (“HIPAA”) Notice of Privacy Practices found here.
1. The Scope of this California Privacy Policy
2. The Company’s Collection, Disclosure, and Use of Personal Information
3. Your California Privacy Rights
4. How to Exercise Your Rights
5. Additional Rights Under California Law
6. Changes to This California Privacy Policy
7. For More Information
Alternative formats of this Privacy Statement are available to individuals with a disability. Please contact us at GrinSquad@ClubGrin.com for assistance.
What Is Personal Information?
“Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California Consumer or household. Personal information does not include:
· Publicly available information from government records.
· Deidentified or aggregated consumer information.
· Information excluded from the CCPA’s scope, like:
This California Privacy Policy applies to the Personal Information, as defined in the paragraph above, of California residents as consumers (“California Consumers”). This means it can include both our customers and their legal guardians, where our customers are minors and have parents or legal guardians helping them with our Website interaction.
This Privacy Policy applies to all Personal Information of California Consumers that we collect both online and offline, including through California Consumers’ (a) visits to and/or use of our https://clubgrin.com website (“Website”) or Club Grin mobile application (“Mobile App”), and (b) use of our services and products that reference this California Privacy Policy (collectively, the “Services”). This Privacy Policy does not apply to information that we collect through third-party websites or applications, which may include information obtained through applications or content (including advertising or marketing) that may link to or be accessible from or on the Website or in the Mobile App.
Please read section 5.3 of Club Grin’s main Privacy Policy here, as it contains essential information about your use of our Website. If you have any questions, please contact us using the information below.
This section of the Privacy Policy describes, for the twelve (12) months preceding the date the Privacy Policy was last updated, as listed on the first page of the Privacy Policy, (a) the categories of Personal Information we have collected about you, (b) the sources of that Personal Information, (c) the business and commercial purposes for use, and (d) the categories of third party recipients of your Personal Information.
Unless we inform you otherwise, this section also serves as our “Notice at Collection” by informing you of your Personal Information to be collected in the future and the purposes for its use.
a) Categories of Personal Information We Collect
In the last twelve (12) months, Company has collected Personal Information in the following categories:
b) Our Sources of Personal Information and the Purposes for Our Use of Personal Information
In the last twelve (12) months, Company collected the categories of Personal Information listed above from the following sources and used those categories of Personal Information for the following purposes:
Categories of Personal Information Collected in the Last Twelve (12) Months
Personal identifiers, such as your name, email address, phone number, postal address, other unique personal identifier, online identifiers including Internet Protocol address, and debit and credit card information and other personal credit information.
Sources of that Personal Information
The sources are the consumer in California; service providers that are in the business of supplying such information as a service, and in some cases our business partners
Business Purposes and Commercial Purposes for Collecting that Personal Information
The purpose is to provide the Services, including performing customer service, processing or fulfilling orders and transactions or responding to inquiries about orders and shipments, verifying consumer information, processing payments and other transactions. It is also used for advertising or marketing services and analytic services to enhance our Services.
It is also used to process Sensitive Personal Data when our obligations to you require such activities.
Services to verify or secure data security and the safety of consumers of our Products and Services, including protecting against fraud and protecting the property or other rights of the Company, other consumers and the public generally.
For compliance with legal and regulatory requirements or to assist or comply with law enforcement or other government agencies for purposes of national security, public safety, or other matters of public importance within their jurisdiction in circumstances where we have reason to believe that disclosure of this information is necessary or appropriate or required by law.
Detecting security incidents in the Website or the provision of Services, including in protecting against malicious, deceptive, fraudulent, or illegal activity, and possibly for use in prosecuting responsible parties.
Providing promotional information, such as providing information to consumers about promotional events, such as specials, surveys, sweepstakes or contests and similar events.
Assisting improving and maintaining clear communications with consumers. This could include establishing communications channels, actual communications with current and prospective clients, working their contact information, and handling questions and feedback from current and prospective clients.
The purpose is to provide the Services, including performing customer service, processing or fulfilling orders and transactions or responding to inquiries about orders and shipments, verifying consumer information, processing payments and other transactions. It is also used for advertising or marketing services and analytic services to enhance our Services.
It is also used to process Sensitive Personal Data when our obligations to you require such activities.
Services to verify or secure data security and the safety of consumers of our Products and Services, including protecting against fraud and protecting the property or other rights of the Company, other consumers and the public generally.
For compliance with legal and regulatory requirements or to assist or comply with law enforcement or other government agencies for purposes of national security, public safety, or other matters of public importance within their jurisdiction in circumstances where we have reason to believe that disclosure of this information is necessary or appropriate or required by law.
Detecting security incidents in the Website or the provision of Services, including in protecting against malicious, deceptive, fraudulent, or illegal activity, and possibly for use in prosecuting responsible parties.
Providing promotional information, such as providing information to consumers about promotional events, such as specials, surveys, sweepstakes or contests and similar events.
Assisting improving and maintaining clear communications with consumers. This could include establishing communications channels, actual communications with current and prospective clients, working their contact information, and handling questions and feedback from current and prospective clients.
Categories of Personal Information Collected in the Last Twelve (12) Months
Categories listed in Cal. Civ. Code § 1798.80(e), such as government-issued identification documents and their information, such as driver’s license number, passport number, social security number or ITIN, military ID, and personal signature.
Sources of that Personal Information
The sources are the consumer in California; service providers that are in the business of supplying such information as a service, and in some cases our business partners
Business Purposes and Commercial Purposes for Collecting that Personal Information
Providing promotional information, such as providing information to consumers about promotional events, such as specials, surveys, sweepstakes or contests and similar events.
Assisting improving and maintaining clear communications with consumers. This could include establishing communications channels, actual communications with current and prospective clients, working their contact information, and handling questions and feedback from current and prospective clients.
And for the purposes that are listed in the Identifies section above.
Categories of Personal Information Collected in the Last Twelve (12) Months
Characteristics of protected classifications under California or federal law, which include financial information, medical history and files, date of birth.
Sources of that Personal Information
The sources are the consumer in California, service providers that are in the business of supplying such information as a service, and in some cases our business partners, including, if applicable, network dentists, treating physicians or consumers’ dentists.
Business Purposes and Commercial Purposes for Collecting that Personal Information
The purposes listed for “Identifiers” in the section above, but excluding:
Providing information to consumers about promotional events, such as specials, surveys, sweepstakes or contests and similar events.
Assisting improving and maintaining clear communications with consumers. This could include establishing communications channels, actual communications with current and prospective clients, working their contact information, and handling questions and feedback from current and prospective clients.
And for the purposes that are listed in the Identifies section above.
Categories of Personal Information Collected in the Last Twelve (12) Months
Commercial information, examples of which are products or services purchased by the consumer
Sources of that Personal Information
The sources are the consumer in California, service providers that are in the business of supplying such information as a service, and in some cases our business partners, including, if applicable, network dentists, treating physicians or consumers’ dentists.
Business Purposes and Commercial Purposes for Collecting that Personal Information
The purposes listed for “Identifiers” in the section above, but excluding activities such as discovering and detecting security incidents, attempt to prevent fraudulent, deceptive malicious, or illegal activity, and working with authorities to prosecute persons responsible for such activities.
Categories of Personal Information Collected in the Last Twelve (12) Months
Internet and network activity information, which includes information such as IP (Internet Protocol) addresses and Wi-Fi usage
Sources of that Personal Information
Elements of the technology contained in the Website or Mobile App
Business Purposes and Commercial Purposes for Collecting that Personal Information
The purposes listed for “Identifiers” in the section above, but excluding activities such as discovering and detecting security incidents, attempt to prevent fraudulent, deceptive malicious, or illegal activity, and working with authorities to prosecute persons responsible for such activities.
Categories of Personal Information Collected in the Last Twelve (12) Months
Sensory information, meaning data you can experience, such as photographs and other digital media, videos impressions, x-rays and diagnostic imagery.
Sources of that Personal Information
The sources are the consumer in California, service providers that are in the business of supplying such information as a service, and in some cases our business partners, including, if applicable, network dentists, treating physicians or consumers’ dentists.
Business Purposes and Commercial Purposes for Collecting that Personal Information
The purposes listed for “Identifiers” in the section above and communications with consumers that are marketing in nature.
Categories of Personal Information Collected in the Last Twelve (12) Months
Professional or employment-related information, such as what you do for a living or profession
Sources of that Personal Information
The sources are the consumer in California, service providers that are in the business of supplying such information as a service, and in some cases our business partners, including, if applicable, network dentists, treating physicians or consumers’ dentists.
Business Purposes and Commercial Purposes for Collecting that Personal Information
The purposes listed for “Identifiers” in the section above, but excluding:
Providing information to consumers about promotional events, such as specials, surveys, sweepstakes or contests and similar events.
Performing consumer-facing services like customer support, reviewing, processing and fulfilling orders and their related transactions, processing payments, confirming customer information, providing advertising or marketing services and related analytic services.
Enabling communications, with consumers and other users such as setting up methods of communications, collecting and organizing consumer information, and communicating with current and prospective customers, which includes items such as handling questions and providing feedback.
Categories of Personal Information Collected in the Last Twelve (12) Months
Consumer responses to requests for information, such as when a consumer fills out and responds on forms that are a part of our Website, which typically related to registration, subscriptions, posting material, technical updates, survey or study responses.
Sources of that Personal Information
The sources are the consumer in California, service providers that are in the business of supplying such information as a service, and in some cases our business partners
Business Purposes and Commercial Purposes for Collecting that Personal Information
The purposes listed for “Identifiers” in the section above
c) Disclosure of Personal Information to Third Parties
In the last twelve (12) months, we collected the following categories of Personal Information from the following sources and used this Personal Information for the following purposes:
Category of Personal Information
Personal identifiers, such as your name, email address, phone number, postal address, other unique personal identifier, online identifiers including Internet Protocol address, and debit and credit card information and other personal credit information.
Categories of Third Parties with Whom We Disclose Categories of Personal Information for a Business Purpose in the Last Twelve (12) Months
IT service providers, processors of credit cards, third-party Internet security providers, and law enforcement and similar regulatory agencies as required to meet legal obligations
Category of Personal Information
Categories listed in Cal. Civ. Code § 1798.80(e), such as government-issued identification documents and their information, such as driver’s license number, passport number, social security number or ITIN, military ID, and personal signature.
Categories of Third Parties with Whom We Disclose Categories of Personal Information for a Business Purpose in the Last Twelve (12) Months
IT service providers, processors of credit cards, third-party Internet security providers, and law enforcement and similar regulatory agencies as required to meet legal obligations
Category of Personal Information
Characteristics of protected classifications under California or federal law, which include financial information, medical history and files, date of birth.
Categories of Third Parties with Whom We Disclose Categories of Personal Information for a Business Purpose in the Last Twelve (12) Months
IT service providers, processors of credit cards, third-party Internet security providers, and law enforcement and similar regulatory agencies as required to meet legal obligations
Category of Personal Information
Commercial information, examples of which are products or services purchased by the consumer
Categories of Third Parties with Whom We Disclose Categories of Personal Information for a Business Purpose in the Last Twelve (12) Months
IT service providers, processors of credit cards, third-party Internet security providers, and law enforcement and similar regulatory agencies as required to meet legal obligations
Category of Personal Information
Internet and network activity information, which includes information such as IP (Internet Protocol) addresses and Wi-Fi usage
Categories of Third Parties with Whom We Disclose Categories of Personal Information for a Business Purpose in the Last Twelve (12) Months
processors of credit cards, third-party security providers, IT service providers, and regulatory agencies and law enforcement as necessary to comply with legal obligations
Category of Personal Information
Sensory information, meaning data you can experience, such as photographs and other digital media, videos impressions, x-rays and diagnostic imagery.
Categories of Third Parties with Whom We Disclose Categories of Personal Information for a Business Purpose in the Last Twelve (12) Months
processors of credit cards, third-party security providers, IT service providers, and regulatory agencies and law enforcement as necessary to comply with legal obligations
Category of Personal Information
Professional or employment-related information, such as what you do for a living or profession
Categories of Third Parties with Whom We Disclose Categories of Personal Information for a Business Purpose in the Last Twelve (12) Months
processors of credit cards, third-party security providers, IT service providers, and regulatory agencies and law enforcement as necessary to comply with legal obligations
Category of Personal Information
Consumer responses to requests for information, such as when a consumer fills out and responds on forms that are a part of our Website, which typically related to registration, subscriptions, posting material, technical updates, survey or study responses.
Categories of Third Parties with Whom We Disclose Categories of Personal Information for a Business Purpose in the Last Twelve (12) Months
processors of credit cards, third-party security providers, IT service providers, and regulatory agencies and law enforcement as necessary to comply with legal obligations
d) No Sale of Personal Information
Club Grin does not sell, share or otherwise disclose your Personal Data for any purposes other than set out above in this California Privacy Policy. We may need to disclose and share information in response to a court order, law, regulation, or other legal action, including responding to a government or regulatory request, to ensure compliance with our Terms of Use, for billing purposes, and in those cases where we have reason to believe that disclosure and sharing is necessary or appropriate to protect the safety, rights, or property of you, your licensed provider or their staff, Club Grin, other customers, or related third parties. We will share and disclose your Personal Data to some third parties, such as your licensed dental provider, Club Grin’s network dental providers and similar medical professionals, Club Grin’s affiliates and subsidiaries, if applicable, third-party service providers, third-party subcontractors, and other business partners we use to enhance or support our business. In the event we sell our entire company, we will be transferring and therefore disclosing such information to the new owner(s). We will also make disclosures to governmental agencies to the extent such disclosure is required by law or for us to comply with our legal obligations, as well as with organizations involved in fraud protection and reduction of credit risks. We also disclose information to parties for whom you have provided your express consent to such disclosure.
a) Right to Know
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
· The categories of personal information we collected about you.
· The categories of sources for the personal information we collected about you.
· Our business or commercial purpose for collecting or selling that personal information.
· The categories of third parties with whom we share that personal information.
· The specific pieces of personal information we collected about you (also called a data portability request).
· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
We do not provide these access and data portability rights for business-to-business (“B2B”) personal information.
b) Right to Delete
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
1. Complete the transaction for which we collected such personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
7. Enable solely internal uses reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We do not provide these deletion rights for B2B personal information.
c) Right to Opt-Out of Sale of Personal Information
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
· Emailing us at GrinSquad@clubgrin.com.
· Visiting https://clubgrin.com.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
· Describe your request with sufficient detail that allows us to understand, evaluate, and respond to it appropriately.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to the personal information associated with that specific account.
We will only use the personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
To prevent anyone other than you, or your authorized agent, from exercising the right to know or the right to delete with respect to your personal information, we follow procedures to verify your or your agent’s identity. This process seeks to confirm that the person making a request is the person about whom we have collected personal information or that person’s authorized agent. The verification process involves matching data points that you provide with your request against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity. We will use the information you provide in your completed request form to verify your identity, and we may request additional information if necessary, to complete the verification process.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or, at your option, electronically.
Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
a) The Company’s Non-Discrimination Policy
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
· Deny goods or services to you.
· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
· Provide you a different level or quality of goods or services.
· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you specific financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Under California law, California Consumers can request information from us whether we have disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. We will not sell your Personal Information to, or share it with, third-party companies for their direct marketing purposes without your consent. California Consumers desiring to request further information about our compliance with these laws or who have questions or concerns about our privacy practices and policies are welcome to contact us using the contact information below.
b) Your ‘Do Not Track’ Browser Setting
The Website does not collect personally identifiable information about your online activities over time and across third-party websites or online services. We support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser’s settings to let the websites you visit, including the Website, know that you do not want those websites collecting your personally identifiable information.
We provide links to third-party websites operated by organizations not affiliated with Company. We do not disclose your Personal Information to organizations operating such linked third-party websites. We do not review or endorse and are not responsible for, the privacy practices of these organizations. We encourage you to read the privacy policy of every website that you visit. This Privacy Policy applies solely to information collected by Company through the Services.
We respect the privacy of children. Our Services are not designed to attract an audience younger than sixteen (16), and we do not knowingly collect Personal Information from children under sixteen (16). If you are under the age of sixteen (16), you are not permitted to use our Services and should not send any information about yourself to us through the Services. Please contact us using the contact details below if you believe we may have collected data or information from or about your child under the age of sixteen (16), and we will work to delete it.
If we change this California Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above. If we materially change this California Privacy Policy in a way that affects how we use or disclose your personal data, we will provide a prominent notice of such changes and the effective date of the changes before making them.
This Online Privacy Policy does not create rights enforceable by third parties.
If you have any questions or comments about this notice, how Club Grin collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Club Grin, LLC
Website: https://clubgrin.com
Email: GrinSquad@clubgrin.com
Club Grin, LLC
Dallas, Texas, United States
Copyright © 2021 Club Grin LLC. - All Rights Reserved.
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