Last updated – October 27, 2025

Thank you for choosing to be part of our community at Redwood MSO LLC, doing business as Smile Partners USA (“Smile Partners USA”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy online.

When you visit our website https://lumadentistry.com/ (the “Website”), and more generally, use any of our online or digital services, such as sales, marketing and events (collectively, the “Services”, which include the Website), we appreciate that you are trusting us with your personal information. This privacy policy applies to all information collected through our Services. In this privacy policy, we set forth what information we collect, how we use it and what rights you have in relation to it.  Please read this privacy policy carefully as it will help you understand what we do with the information that we collect.

If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Services immediately. If you have any questions about this privacy policy, or our practices with regards to your personal information online or wish to review, update or delete any of your personal information, please contact us at marketing@smilepartnersusa.com.

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short:  We collect information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and services, when you participate in activities on the Website or utilize our Services when you contact us. The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:

• Names, email addresses, telephone numbers and other similar information.

In providing us personal information, you agree, represent and warrant that it is true, complete and accurate, and you further agree to notify us of any changes to such personal information.

Information automatically collected by us

In Short:  Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website or utilize our Services.

We automatically collect certain information when you visit, use or navigate the Website or utilize certain other Services. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.

This information does not reveal your specific identity (like your name or contact information) but may include the following:

• Device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about whereand when you use our Website and other technical information.

Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic usage and performance information our servers automatically collect when you access or use our Website or Services and which we record in log files. Depending on how you interact with us, this log data may include:
  •  your IP address, device information, browser type and settings and information about your activity using the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website or utilize our Services. Depending on the device used, this device data may include:
  •  your IP address (or proxy server), device application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system configuration information.

• Location Data. We collect information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type of settings of the device you use to access the Website or utilize our Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Locations settings on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

Mobile Numbers & SMS
We use employee mobile numbers to send company-related notifications such as scheduling, compliance, and system alerts. We do not share mobile numbers, opt-in data, or consent information with third parties or affiliates for marketing or promotional purposes. Information may be shared only with service providers that help us operate our internal communication systems. Message frequency may vary. Message & data rates may apply. Reply STOP to opt out, HELP for help.

HOW DO WE USE YOUR INFORMATION?

In Short:  We process your information for purposes consistent with your consent and based on legitimate business interests, compliance with our legal obligations.

We use and process personal information collected via our Services for a variety of business purposes, consistent with your consent, in reliance on our legitimate business interests, and/or for compliance with our legal obligations.

We use the information we collect or receive, as specified below:

• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• To protect our Services. We may use your information as part of our efforts to keep our Website and Services safe and secure (for example, for fraud monitoring and prevention).
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the personal information we hold to determine how to respond.

• Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website.
• Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.
• To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

• To send you marketing and promotional communications, including targeted advertising. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, including personalized content and advertising tailored to your interests and/or location, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website or Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
• For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short:  We only share personal information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your personal information that we hold under the following circumstances:

• Consent: We may process your personal information if you have given us specific consent to use such information for a specific purpose.
• Legitimate Interests: We may process your personal information when it is reasonably necessary to achieve our legitimate business interests.
• Legal Obligations: We may disclose your personal information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your personal information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following circumstances:

• Business Transfers. We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work:, such as payment processing, data analysis, data de-identification and filtering, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website or Services, which will enable them to collect data on our behalf about how you interact with our Website or Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this privacy policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

WHO WILL YOUR INFORMATION BE SHARED WITH?

In Short:  We only share information with specific third parties.

We only share and disclose your personal information with the following third parties, which are categorized so that you may easily understand the purpose of our data collection and processing practices. If we have processed your personal information based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled “HOW CAN YOU CONTACT US ABOUT THIS POLICY OR OPT OUT OF INTEREST-BASED ADVERTISING?”

• Retargeting Platforms
  AdRoll, Bing, Freshpaint, Google Analytics Remarketing and Meta Custom Audience

• Social Media Sharing and Advertising
  Meta advertising

• User Commenting and Forums
  Meta Comments

• Web and Mobile Analytics
  Google Tag Manager, Google Analytics and Google Ads

• Website Hosting
  WordPress.com

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short:  We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features of our Services. To opt-out of interest-based advertising by advertisers on our Website, visit http://www.aboutads.info/choices/

DO WE USE GOOGLE MAPS AND APPLE MAPS?

In Short:  Yes, we use Google Maps and Apple Maps for the purpose of providing you with better service.

Our Services use Google Maps and Apple Maps APIs which are subject to Google’s Terms of Service and Apple’s Terms of Service, respectively. You can learn more about Google’s Privacy Policy and Apple’s Privacy Policy by following their respective link. On the device(s) that you use to access our Services, we obtain and store (‘cache’) your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer time period is required by law.

We will only keep your personal information for as long as it is necessary up to two (2) years for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other financial or legal requirements).

When we have no ongoing legitimate business or legal need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short:  We take measures to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Therefore, the transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at marketing@smilepartnersusa.com.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. We do not  respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

This section is provided in the event that we are subject to the California Consumer Privacy Act (“CCPA”). We have received the following categories of consumer Personal Information within the last twelve (12) months:

California Rights and Choices

CCPA provides California residents with certain rights regarding their Personal Information (subject to certain limitations at law). The following paragraphs describe these CCPA rights.

Right to Access and Portability

California residents have the right to request disclosure of certain information about the collection and use of Personal Information over the last twelve (12) months. Once we receive and confirm your verifiable consumer request, we will discloe to you the following:

• The categories of Personal Information collected
• The categories of sources for the Personal Information collected Our business or commercial purpose for collecting Personal Information
• The categories of third parties with whom we share that Personal Information
• The specific pieces of Personal Information collected about you (also called a data portability request)
• If we disclose your Personal Information for a business purpose, identifying the Personal Information categories disclosed.

Right to Deletion

The CCPA allows California residents the right to request the deletion of any Personal Information that we collect and retain, subject to certain exceptions.

A request may be denied if retaining the information is necessary to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated or within the context of our ongoing business relationship with you
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity
• Debug products to identify and repair errors that impair existing intended functionality
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
• Enable solely internal uses that are reasonably aligned with consumer expectations
• Comply with a legal obligation and requests from law enforcement agencies
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it

Right to Opt-Out of the Sale of Your Information

We do not currently sell data, as it is defined in the CCPA and we restrict our service providers from doing so. We have also not sold Personal Information in the preceding twelve (12) months.

Request Submissions

To exercise the access and deletion rights under the CCPA as described above, please submit your request to us as set forth below.

Verifiable Consumer Requests

A verifiable consumer request may be submitted by a California resident or a person registered with the California Secretary of State that is authorized to act on your behalf. Requests for access can only be made twice during a twelve (12) month period. Requests for access and deletion must:

• Detail sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if your identity or authority to make the request cannot be verified.

Timeframe for Responding to Requests

We will respond to requests from you within forty-five (45) days of receipt. The period of response may be extended to sixty (60) or ninety (90) days if more time is required. In that event, we will inform you of the reason and extension period in writing.

Fee

We do not charge individuals a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

No Discrimination

The CCPA prohibits a business from discriminating against California residents for exercising the rights outlined above.

No Financial Incentive

We do not offer any financial incentives or price or service differences to influence a resident’s decision to exercise a right afforded to the consumer under the CCPA.

Authorized Agent

A California resident may use an authorized agent to submit an access request or a request to delete.

DO WE MAKE UPDATES TO THIS NOTICE?

In Short:  Yes, we will update this notice as necessary, such as to stay compliant with relevant laws or reflect changes in our processes.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you by prominently posting a notice of such changes. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY OR OPT OUT OF INTEREST-BASED ADVERTISING?

If you have questions or comments about this privacy policy, you may contact our Data Protection Officer (DPO), by email at marketing@smilepartnersusa.com, or by post to:

Redwood MSO LLC
800 Kirts Blvd, #650
Troy, MI 48084
United States

To opt-out of interest-based advertising by advertisers on our Website, visit http://www.aboutads.info/choices/.

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your jurisdiction, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit: https://www.smilepartnersusa.com/contact/. We will endeavor to respond to your request within thirty (30) days.