Privacy Policy

Last updated on:

February 5, 2023

We respect the right to privacy of all visitors to the website. This website Privacy Policy is incorporated into and subject to the Terms of Use and serves to notify you of the following:

What information about me is collected?

This Privacy Policy informs you of the policies of SmileSIM®, LLC (“SmileSIM®” "we" or “us” or “our”) regarding information that we collect from users of our SmileSIM® website or other services we may make available from time to time (together with associated and successor websites and services, the "Site") and from users who access our services through various social networking sites (collectively, with the Site, the “Services”). This Privacy Policy applies only to information that we collect (or that you permit social networking sites to provide to us) through the Services. There are two types of information that we collect: personal information and non-personal information.

Non-Personal information.

Personal information is information that identifies you or your patients or can be used to identify or contact you or your patients. Such information may include your or your patients’ names, addresses, email addresses, telephone numbers, birth dates, and medical and health related information you provide to us.

Non-Personal information.

Non-personal information is information which cannot be used to identify or contact you, such as demographic information (like age, profession, current location, zip code, birth date, year of birth, or gender). Non-personal information may also include user IP addresses, browser types, domain names, purchasing history and trends, responses to questionnaires, tools used on the Beauty CanvasTM, and statistical data involving the use of the Services.

Where and when is information collected through the services (including through the use of cookies and action tags)?

We collect personal information from you when you voluntarily submit the information to us. For example, as described below, we collect certain personal information from you when you register to use the Services and set up an account with us. We may also receive personal information about you from third parties screening services as part of your use of the Services and from social networking sites through which you access the Services.

Registering to Use the Services and in the Course of Using the Services.

You may be required to establish an account in order to take advantage of certain features of the Services. If so, if you wish to establish an account you will be required to provide us with information (including personally identifiable and non-personal information) such as name, postal address, telephone number, credit card information, email address, and birth date. We may also receive personal information about you from third parties providing screening services as part of the registration process and from social networking sites through which you access the Services. In addition, we may obtain your personal information from you if you identify yourself to us by sending us an email with questions or comments.

Cookies and Action Tags.

We collect non-personal information passively using "cookies" and "action tags".

"Cookies" are small text files that are placed on your computer in order to identify your Web browser and the activities of your computer on the Site and other websites and through use of the Services. Cookies are used to personalize your experience on the Services (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Services (such as saving time by not having to reenter your name each time you use the Services), and to allow us to statistically monitor how you are using the Services to help us improve our online offerings. We also may use cookies to target certain advertisements to your browser which may be of interest to you or to determine the popularity of certain content.

In addition to cookies that we place on your computer, cookies may also be placed on your computer by third parties that we use to display or serve advertisements or to collect non-personal information in order to provide advertising-related services. In the course of serving advertisements to users of the Services and/or on the Site, our third-party advertisers may place or recognize unique cookies on your browser.

Session cookies and persistent cookies are used in connection with the Services. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Site and subsequent access to the Services. Persistent cookies can be removed by following your web browser help file directions. A session cookie is temporary and disappears after you close your browser.

You do not have to accept cookies to use the Services. Although most browsers are initially set to accept cookies, typically, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the "Help" section of the toolbar. While you are not required to accept our cookies to access the Services, if you reject cookies, certain products, offerings, features, or resources of the Services may not work properly and you may experience some loss of convenience.

"Action tags," also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Services, including advertisements, or email sent on our behalf, may contain action tags.

By using cookies and action tags together, we are able to gain valuable information to improve the Services and measure the effectiveness of our advertising and marketing campaigns. We may disclose your non-personal information, and if you "opt-in", your personal information, to our advertising partners.

Finally, you should be aware that advertisers and other third parties may also use their own cookies or action tags when you click on their advertisement or link to their websites or services on or from the Services. This Privacy Policy does not govern the use by such third-party websites or services or providers of third-party advertising.

Log Files.

We also collect non-personal information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Services. This information may be used to analyze trends, to administer the Services, to monitor the use of the Services, and to gather general demographic information. We may link this information to personal information for these and other purposes such as personalizing your experience on the Services and evaluating the Services in general.

Google Analytics.

The information above is collected primarily through our use of Google Analytics to help analyze how users use the Site. The Google Analytics tool uses "cookies," which are text files placed on your computer, to collect standard Internet log information and visitor behavior information in an anonymous form. The information generated by the cookie about your use of the Site (including IP address) is transmitted to Google. This information is then used to evaluate visitors' us of the Site and to compile statistical reports on website activity for Company. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as

Is information that I submit to the public areas of the services private?

No. Any information shared in the public areas of the Services, for example the Discuss section, is available to all members and users. Such information is not protected or treated as confidential, can be used in any manner, and is not subject to this Privacy Policy. If you wish to keep any information private or proprietary, do not submit it to the public areas of the Services, which include, but are not limited to, the Services’ blog, discussion boards, messages and comment areas and within your public profile page. WE HAVE NO RESPONSIBILITY OR LIABILITY IF YOUR INFORMATION OR IDENTIFY IS MISUSED OR STOLEN, OR IF YOU SUFFER HARM AS A RESULT OF YOUR VOLUNTARY DISCLOSURES.

Are photos and images developed through SmileSIM accessible to other users of the services?

Photos and images developed through SmileSIM remain inaccessible to other members and users of the Services unless you actively decide to share this information. This information will be shared with doctors to the extent you authorize us to do so.

Are the Services directed to users in the United States?

Yes. The Services are hosted in the United States and are directed to users in the United States. If you are a user accessing the Services from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of the United States, please be advised that all aspects of the Services are governed by the internal laws of the United States and the Commonwealth of Virginia regardless of your location. If you use the Services, you are transferring your personal information to the United States and you consent to that transfer.

What does SmileSIM® do with the information it collects?

In general, we use the information collected through the Services to provide the Services to you. For example, we share your personal information, including medical and health information you provide to us, only to the extent you authorize us to do so. We also use your personal information to help us understand who uses the Services, for internal operations such as to improve the Services, to contact you for customer service and billing purposes, to facilitate the delivery of advertising, and, if you "opt-in", so that we and third parties can contact you about products and services that may be of interest to you.

We may use your information to send you a welcoming email that may confirm your user name and password. If you "opt-in," we and third parties may send you electronic newsletters, contact you about the Services, products, other services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, we will provide you with the option to change your preferences. In addition, if you identify yourself to us by sending us an email with questions or comments, we may use your information (including personal information) to respond to your questions or comments, and we may file your questions or comments for future reference. We may also use the information collected to send you important service announcements and updates regarding the Services or, if applicable, about your billing account status. You will not be able to unsubscribe from these service announcements and updates as they contain important information relevant to your use of the Services.

We may also use the information gathered through use of the Services to perform statistical analysis of user behavior or to evaluate and improve the Services. We may link some of this information to personal information for internal purposes or to improve your experience with the Services or, if you "opt-in", so that we and third parties may send you information about products and services that may be of interest to you and other communications.

All information collected may be used or shared by SmileSIM® as described in this Privacy Policy on a worldwide basis.

What information does SmileSIM® share with my friends?

If you connect your Services account with a social networking site or access the Services via a social networking site such as Facebook, SmileSIM® provides you the ability to share photos and images developed through the Beauty CanvasTM with your friends.

When does SmileSIM® disclose information to third parties?

Except as set forth in this Privacy Policy or as specifically authorized by you, we will not disclose any information we gather from you through the Services.

To Provide the Services.

Please note that e-mails containing health and other personal information and other communications you send to us through our Site are not encrypted.

Laws and Legal Rights.

We may disclose your information (including personal information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose personal information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating the Terms of Use for our Services, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Services or the general public.

Third Parties Generally.

We may provide to third parties non-personal information about you, including where such information is combined with similar information of other users of the Services. For example, we might inform third parties regarding the number of unique users who visit the Site, the demographic breakdown of our registered users of the Services, or the products and/or services purchased using the Services and the vendors of such products and services. If you "opt-in", we may also provide to third parties personal information about you. For example, if you "opt-in", we might share your responses to questionnaires and e-mail address with third parties in order for third parties to contact you about products and services that may be of interest to you. The third parties to which we may provide personally identifiable and non-personal information may include potential or actual advertisers, providers of advertising products or services (including vendors and website tracking services), merchants, affiliates and other actual or potential commercial partners, sponsors, licensees, researchers and other similar parties.

Outside Contractors.

We may employ independent contractors, vendors and suppliers (collectively, "Outside Contractors") to provide specific services and products related to the Services, such as hosting and maintaining the Site and the Services, providing screening, and developing applications for the Services and e-mail services. In the course of providing products or services to us, these Outside Contractors may sometimes have limited access to information collected through the Services, including your personal information. We require that these contractors (1) protect the privacy of your personal information consistent with this Privacy Policy, and (2) not use or disclose your personal information for any purpose other than providing us with the products or services for which we contracted.

Third Party Sellers.

In addition, through the Services (under the Products section, you can purchase (or to obtain more information regarding) products sold by parties other than us (collectively, "Merchants"). We are not responsible for the privacy practices of Merchants. We encourage you to be aware when the Services link to Merchants’ websites and to read the privacy policies or statements of each and every Merchant website. This Privacy Policy applies solely to information collected directly by SmileSIM® at this Site and through the Services.

Sale of Business.

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of SmileSIM®, provided that the third party agrees to adhere to the terms of this Privacy Policy.


We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with SmileSIM®, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

Does this privacy policy apply when I link to other web sites?

No. Our Site and our provision of the Services may contain links to other websites not owned or operated by SmileSIM® (for example, if you "click" on a banner advertisement, you will likely be taken off the Site). However, please be aware that we are not responsible for the privacy practices of such websites. We encourage you to be aware when the Site links to other websites and to read the privacy policies or statements of each and every website. This Privacy Policy applies solely to information collected through use of the Services.

Is the information collected through access to the Services secure?

We want your information (including personal information) to remain as secure as possible. We strive to provide secure transmission of your information from your computer to our servers through industry-standard techniques.

Notwithstanding the above commitments to protect your information (including personal information) from loss, misuse or alteration by third parties, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot guaranty, ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.

What choices do I have regarding the collection, disclosure and distribution of personal information?

Except as otherwise described in this Privacy Policy, we will only use personal information for the purposes described above or as otherwise disclosed at the time we request such information from you. You must "opt-in" and give us permission to use your personal information for any other purpose. For example, we may have an "opt-in" mechanism so that those who become registered users of the Services must give us permission to send them marketing materials and our electronic newsletter and so that we may share their personally-identifiable information with third parties in order to receive information about products and services that may be of interest. You may also change your preferences and "opt-out" of receiving certain marketing communications by changing that option in the My Profile feature of the Services, following the directions provided in association with the communication, or by contacting us at

Can I update or correct my personal information?

You have the right to request the restriction of certain uses and disclosures of personal information as follows. You can contact us in order to (1) update or correct your personal information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personal information maintained about you on our systems (subject to the following paragraph), by accessing My Profile or contacting us at Such updates, corrections, changes and deletions will not have an effect on other information that we maintain, or information that we have provided to third-parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back-up our systems to protect information from inadvertent loss means that a copy of your personal information may exist in a non-erasable form that will be difficult or impossible for us to locate. We promise that promptly after receiving your request, all personal information stored in databases we actively use and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably practicable.

How will I know if there are any changes to this privacy policy?

You should be aware that we may revise this Privacy Policy at any time, but we will not make changes that result in significant additional uses or disclosures of your personal information without allowing you to "Opt In" to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your personal information. We encourage you to check this page periodically for any changes. Your continued use of the Services following the posting of changes to this Privacy Policy will mean you accept those changes.

Security of your information

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that e-mails containing health and other personal information and other communications you send to us or doctors through our Site are not encrypted.

By using SmileSIM®, you are authorizing your chosen physicians to communicate with you through SmileSIM® using public email systems to your personal email address and that you acknowledge that such emails may contain your personal protected health information. You should NOT use the SmileSIM® communication platform to communicate any other information including:

  • (a) emergencies or other time-sensitive issues;
  • (b) inquiries which deal with sensitive information;

SmileSIM® shall exercise reasonable efforts to ensure the confidentiality of your e-mail communications, however, you should understand that e-mail communications to SmileSIM® and your chosen physician(s) are not secure, and there is therefore some possibility that the confidentiality or security of such communications, particularly public email communications, or SmileSIM®’s email system, may be breached by a third party. Email communication through public email is not a secure medium for sending or receiving PHI. A public email message may be inadvertently sent to the wrong recipient; it may be opened or viewed by another person with access to your email account or computer/personal digital device; the message will be cached in any number of Internet servers along the path to the your identification; and the message is susceptible to being hacked or intercepted. Therefore, communications regarding highly confidential medical matters should be conveyed through other forms of communication (e.g., telephone, personal visit). Your chosen physicians may keep copies of your communications that occur through SmileSIM®, and may include such copies in your medical record.

Who do I contact if I have any privacy questions?


If you have any questions or comments about this Privacy Policy or feel that we are not abiding by the terms of this Privacy Policy, please contact our Privacy Agent in any of the following ways:

By email:

By postal mail or courier:
Attn: Privacy Agent

PO Box 329
Avon, MN 56310

By using the services, you signify your acceptance of this privacy policy. If you do not agree to this privacy policy, you should not use the services. Your continued use of the services following the posting of changes to this privacy policy that do not significantly affect the user or disclosure of your personally information will mean that you accept those changes.