Last Updated/Effective Date: July 5, 2024

beBright MSO, LLC, and its affiliates and subsidiaries (“beBright,” “we,” “us,” or “our”) respect your privacy.

This Privacy Notice describes the processing of Personal Information (defined below) that we may collect from you or that you may provide when you visit our website (https://bebright.com/) and online platforms, or any of the websites and online platforms for affiliates practices within our dental practice group that link to this privacy notice (collectively, our “Websites”), and our practices for collecting, using, and disclosing that information. It does not apply to information collected by us offline (or through any other means) or information collected by third parties (including via applications or content, including advertising, that may be hyperlinked or otherwise accessible from or through our Websites).

Please read this notice carefully to understand our policies and practices regarding your Personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites. By accessing or using our Websites, you agree to this privacy notice. This notice may change from time to time (see Changes to this Privacy Notice). Your continued use of our Websites after we make changes is deemed to be acceptance of those changes, so please check the notice periodically for updates.

1. Personal Information We Collect

We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you.

The types of Personal Information we collect may include:

• Contact Information – If you submit an inquiry, register for an account, or provide information on or through our Services, we may collect your contact information. This may include your name, address, email address, demographic information, phone number, and similar information for alternative emergency contacts.
• Commercial Information – If you submit an inquiry, or provide information on our Websites, we may collect commercial information including information about Services you have shown interest in.
• Usage Information – When you use our Websites, we may automatically record information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs (e.g., the website you visited before coming to our Websites), domain names associated with your internet service provider, and any other information regarding your interaction with our Websites.
• Employment Information – If you apply for employment with us, we will collect Personal Information related to your potential employment, including your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.
• Communication Information – We may collect Personal Information contained within your communications with us, including audio, electronic, or visual information, screen sharing views, and any files provided to us via email, social media, telephone, or otherwise. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees via message, chat, post, or similar functionality.
• Health Information – If you are a patient with our practice group and elect to complete any patient forms or access any patient portals or other patient-related services we offer online, we may collect health-related (including information about your health, health history, and health insurance) as part of those online features.
• Financial Information – If you become a patient with our practice group, we may collect financial information to facilitate online bill payments for our Services.

2. How We Collect Personal Information

• Directly From You – We collect Personal Information that you provide to us, for example, if you choose to contact us, request or purchase Services or information from us, or sign up to receive updates.
• From Third Parties – We may collect Personal Information from third parties including, business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.
• Through Online Tracking Technologies – We use cookies and similar technologies to collect Personal Information related to activity on our Websites. For additional information regarding our use of these technologies, see the Cookies and Tracking Technologies section below.

How We Use Personal Information

To the extent permitted by applicable law, we use Personal Information:

• To provide and personalize our Services, such as providing our Services and Websites, processing payments, providing customer service, maintaining or servicing accounts, providing financing, verifying customer information, creating and maintaining business records, verifying eligibility, and undertaking or providing similar services.
• For internal research and development, such as testing and verifying the quality of our Services or Websites, improving the quality of our Services or Websites, and creating new Services.
• For marketing, such as sending information about our Services, including using your information to send you messages, notices, newsletters, surveys, promotions, or news about events.
• For communicating with you, such as responding to your questions and comments.
• For legal, security, or safety reasons, such as protecting our and our users’ safety, property, or rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
• As part of a corporate transaction, such as in connection with the sale of part or all of our assets or business, the acquisition of part or all of another business or another business’ assets, or another corporate transaction, including bankruptcy.

If you are applying for employment with us, we also use Personal Information to process your job application, to verify the information you have provided in your application, conduct interviews, perform background and reference checks, to communicate with you and answer your questions, to confirm your eligibility for employment, and improve our recruiting processes. We may also save your Personal Information for future employment opportunities with us.

4. How We Disclose Personal Information

We may disclose your Personal Information in the following circumstances:

• Service Providers – We disclose your Personal Information with third party service providers as necessary to enable them to support our Services or other aspects of our business.
• Affiliates and Subsidiaries – We may disclose your information to our practices for their and our business purposes and for marketing purposes, including to provide you information about the products or services we think may interest you.
• Business Partners – We may disclose Personal Information with trusted business partners or corporate affiliates. For example, we may disclose your Personal Information with a company whose products or services we think may be of interest to you or who we co-sponsor a promotion or service with.
• Legal Obligation or Safety Reasons – We may disclose Personal Information to a third party when we have a good faith belief that such disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of beBright, its employees and clients, or the public against harm.
• Merger or Change of Control – We may disclose Personal Information to third parties as necessary if we are involved in a merger, acquisition, or any other transaction involving a change of control in our business, including but not limited to, a bankruptcy or similar proceeding. Where legally required, we will give you prior notice prior to such disclosure.

5. Cookies and Other Tracking Technologies

We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Websites. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Websites, to enhance your experience through personalization, and to help us better understand the features of our Websites that you and other users are most interested in.

• Website Delivery and Appearance – We may incorporate content from third party providers such as Adobe. We use Adobe Typekit to serve fonts on our Websites and to enhance the performance of our Websites (for more information, please see the Adobe Typekit’s Privacy Policy). We also use services to enable certain customer interaction opportunities—such as Google Maps (available per the Google Maps/Google Earth Terms of Service and Google’s Privacy Policy) or Disquis comments (to customize your privacy choices for Disquis, submit a request here, per their Privacy Policy)—or enable specific content delivery like audio and video via Vimeo or YouTube (for more information about YouTube, see Google’s Privacy Policy) or service options like online bill payment and online form completion (for more information on one such provider, Sesame Communications, please see their Terms and Conditions and Privacy Policy).
• Website Analytics and Session Replay – We use analytics and session replay services, that use cookies and other technologies that collect your Personal Information, to assist us with analyzing our Websites traffic and site usage. These include, but are not limited to, the following third-party services:
  • Microsoft Clarity: We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our Websites through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
  • Google Analytics: To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data from sites or apps that use our services.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
  • Datadog Session Replay: We also use third-party session replay services to better understand site usage and inform future service or technology improvements. For more information on Datadog, including its data collection and processing practices, please see their replay services here and their privacy policy here.
• Advertising – We allow or enable third parties to collect Personal Information to provide their interest-based advertising services, and we use Google Ads (including Google Dynamic Remarketing and DoubleClick), Adobe Audience Manager, and other third parties to serve ads for our Services across various websites. To opt-out of this type of advertising by Google, customize your ad preferences, or limit Google’s collection or use of your data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. To opt out of advertising under Adobe Audience Manager, please follow Adobe’s Experience Cloud opt-out instructions.

In addition, most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of our Services may not be available, or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time.

6. How Long We Keep Your Personal Information

We will retain each category of your Personal Information for as long as necessary to fulfill the purposes described in this Privacy Notice, unless otherwise required by applicable laws. Criteria we will use to determine how long we will retain your Personal Information include whether we need your Personal Information to provide you with our Services you have requested; we continue to have a relationship with you; you have requested information or Services from us; we have a legal right or obligation to continue to retain your Personal Information; we have an obligation to a third party that involves your Personal Information; our retention or recordkeeping policies and obligations dictate that we retain your Personal

Information; we have an interest in providing you with Personal Information about our Services; or we have another business purpose for retaining your Personal Information.

7. How We Protect Personal Information

We use commercially reasonable efforts to protect the confidentiality and security of Personal Information. However, despite these efforts to store Personal Information in a secure environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems.

8. Children’s Privacy

We do not knowingly collect or solicit any Personal Information from children under the age of 13 without verified written parental consent. In the event that we learn that we have collected Personal Information from a child under the age of 13, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at privacy@bebright.com.

9. Links to Third-Party Websites

We are not responsible for the practices employed by any websites or services linked to or from our Services, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will handled in accordance with the applicable third party’s privacy notice.

In some cases, we offer links to social media platforms (like Facebook, Instagram, Pinterest, X (formerly known as Twitter) and YouTube) that enable you to easily connect with us or share information on social media. Any content you post via these social media pages is subject to the Terms of Use and Privacy Policies for those platforms. For more information about how YouTube collects and processes Personal Information, for example, please see Google’s Privacy Policy.

We also integrate with other sites to provide enhanced services, technological capabilities, or resources for you. Like the social media integrations discussed above and in the Cookies and Other Tracking Technologies section, these plug-in services and capabilities are all governed by the terms, conditions, and policies of the underlying companies. Some of the integrations we currently offer include the ability to view our business and/or provider profiles on Healthgrades, Google, and Facebook, including the customer reviews publicly posted there. This hyperlinked content (including any embedded customer reviews) is governed according to the privacy policies for each platform, and the links to these external websites and services provided for your convenience.

10. Updating Your Preferences

To opt out of marketing emails, please email us at privacy@bebright.com or by following the instructions included in the email or text correspondence. Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law. Additionally, if you withdraw your consent or object to processing of your Personal Information, or if you choose not to provide certain Personal Information, we may be unable to provide some or all of our Services to you.

11. Changes to this Privacy Notice

Please note that we may modify or update this Privacy Notice from time to time, so please review it periodically. We will provide you notice if material changes are made. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to our Websites.

12. Contact Us

If you have any questions about our practices or this Privacy Notice, please contact us at privacy@bebright.com.