Effective Date: April 15, 2026
Smile Brands Inc. 675 Anton Blvd, Suite 500 Costa Mesa, CA 92626
This Consumer Health Data Privacy Policy (“Health Data Policy”) describes how Smile Brands Inc. (“Smile Brands,” “we,” “us,” “our”) and our affiliated dental practices in Washington State (a list of which can be viewed at smilebrands.com/smile-brands-locations) collect, use, share, and protect consumer health data in compliance with the Washington My Health My Data Act, RCW Chapter 19.373 (“MHMDA”). This Health Data Policy applies to Washington consumers, defined as Washington residents and individuals whose consumer health data is collected in Washington.
This Health Data Policy is separate from, and in addition to, our U.S. Privacy Policy available at smilebrands.com/privacy. Where a conflict exists between this Health Data Policy and the U.S. Privacy Policy with respect to consumer health data governed by the MHMDA, this Health Data Policy controls.
Under Washington law, “consumer health data” is personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status. Because our websites relate to dental health care services, certain information we collect when you visit our Sites may constitute consumer health data, including:
We collect consumer health data from the following categories of sources:
Directly from you. We collect consumer health data when you provide it to us through our websites, including when you fill out appointment request forms, use online chat features, contact us by phone or email, or submit patient intake forms.
Through tracking technologies on our websites. Our Sites may use cookies, pixels, and call tracking scripts that collect session-level data such as your IP address, device information, pages visited, and referring marketing source. Our Sites use dynamic phone number insertion technology, which replaces the displayed phone number with a unique tracking number assigned to your browsing session so that we can attribute calls to the marketing campaign that directed you to the Site.
For Washington consumers, we will not deploy tracking technologies that collect consumer health data, including call tracking scripts, unless you have first provided affirmative opt-in consent through our consent management tool.
From our service providers. Service providers that operate on our behalf, such as our call tracking provider and website analytics tools, may collect consumer health data at our direction and pursuant to our instructions.
From our affiliated dental practices. Our affiliated dental offices may provide us with information about you in connection with the dental services you have received or requested.
We collect consumer health data for the following purposes:
We will not collect consumer health data for purposes beyond those disclosed in this Health Data Policy without first disclosing the additional purpose and obtaining your affirmative consent.
We may share consumer health data with the following categories of entities, and only with your separate, affirmative consent for such sharing or to the extent necessary to provide a product or service you have requested:
Service Providers (Processors). We share consumer health data with service providers that process data on our behalf pursuant to written contracts that limit their use of the data to the services they provide to us. These service providers include:
When we share consumer health data with a service provider in a manner consistent with the purpose for which it was collected and disclosed to you, that disclosure is not considered “sharing” under the MHMDA.
Affiliated Dental Practices. We may share consumer health data with our affiliated dental offices to coordinate and provide the dental services you have requested.
Third-Party Analytics and Advertising Partners. With your separate and distinct consent, we may share de-identified call tracking and session data with third-party analytics partners (such as Google) to measure marketing campaign performance. We de-identify this data before sharing by removing or masking direct identifiers. If you do not consent, or if you withdraw your consent, no consumer health data will be shared with these third parties.
Government Authorities. We may disclose consumer health data to government authorities as required by law, court order, subpoena, or other legal process.
We do not sell consumer health data. If we ever intend to sell consumer health data, we will first obtain a valid written authorization from you that meets the requirements of RCW 19.373.070.
We obtain your consent before collecting or sharing your consumer health data. Our consent process meets the following requirements under Washington law:
Call tracking technology. For Washington consumers, our call tracking script (dynamic phone number insertion) will not fire on our Sites until you have provided affirmative consent through our consent management tool. If you do not consent, no tracking number will be assigned to your session and no session-level data will be collected by our call tracking service provider.
Under the MHMDA, you have the following rights with respect to your consumer health data:
Right to Confirm and Access. You may confirm whether we are collecting, sharing, or selling consumer health data about you. You may access your consumer health data, including a list of all third parties and affiliates with whom we have shared or sold your consumer health data and an active email address or other online mechanism you may use to contact those third parties.
Right to Withdraw Consent. You may withdraw your consent from our collection and sharing of your consumer health data at any time. You may withdraw consent by:
Upon receiving your withdrawal request, we will cease collecting and sharing your consumer health data within 15 days.
Right to Deletion. You may request that we delete your consumer health data. Upon receiving and verifying your deletion request, we will:
How to Submit a Request. You may exercise any of the rights described above by:
We will respond to your request within 45 days. If we need additional time due to the complexity or number of requests, we will notify you within the initial 45-day period and may extend the response period by an additional 45 days.
We will not require you to create a new account to exercise your rights but may require you to use an existing account. We may ask you to provide information reasonably necessary to verify your identity before fulfilling your request.
Right to Appeal. If we decline to take action on your request, you may appeal our decision. To submit an appeal, contact us at privacy@smilebrands.com with the subject line “MHMDA Appeal.” We will respond to your appeal in writing within 45 days, including a written explanation of the reasons for our decision. If your appeal is denied, you may contact the Washington State Attorney General to submit a complaint at www.atg.wa.gov/file-complaint.
No Discrimination. We will not discriminate against you for exercising any of the rights provided in this Health Data Policy or under the MHMDA.
We restrict access to consumer health data to employees, processors, and contractors who need access to fulfill the purposes for which you provided consent or to provide a product or service you have requested. We maintain administrative, technical, and physical security practices designed to protect the confidentiality, integrity, and accessibility of your consumer health data appropriate to the volume and nature of the data we hold.
We do not implement geofences around any entity that provides in-person health care services for the purpose of identifying or tracking consumers seeking health care services, collecting consumer health data, or sending notifications, messages, or advertisements related to consumer health data or health care services.
Our service providers that process consumer health data on our behalf do so only pursuant to binding written contracts that set forth processing instructions and limit the actions the service provider may take with respect to your consumer health data. If a service provider processes your consumer health data outside the scope of its contract with us, that service provider becomes a regulated entity under Washington law and is independently subject to the requirements of the MHMDA.
We may update this Health Data Policy from time to time. When we make changes, we will update the “Effective Date” at the top of this page. We will not collect, use, or share additional categories of consumer health data or use consumer health data for additional purposes not disclosed in this Health Data Policy without first disclosing those changes and obtaining your affirmative consent.
If you have questions about this Health Data Policy or wish to exercise your rights, please contact us:
Email: privacy@smilebrands.com
Phone: (855) 992-7223
Mail: Smile Brands Inc., Attn: Privacy, 675 Anton Blvd, Suite 500, Costa Mesa, CA 92626
Online: smilebrands.com/your-privacy-choices
Orthodontics may be provided by general dentists.
We do not discriminate based on race, color, national origin, ancestry, religion, sex, marital status, gender, gender identity, sexual orientation, age or disability.
