CALIFORNIA CONSUMER PRIVACY POLICY

Privacy Contact: OC Perfect Smile Attn: Privacy Officer 24953 Paseo De Valencia, #3c, Laguna Hills, CA 92653. (949) 837-7112, OCPerfectSmileDental.com

THIS PRIVACY POLICY APPLIES TO OUR OFFICE’S WEBSITE, ONLINE SERVICES, AND APPLICATIONS.

Effective Date: 09.2023, last updated 06.2025

This California Consumer Privacy Policy (“CCPA Privacy Policy” or “Policy”) is designed for consumers who are residents of the State of California (“consumers” or “you”). It supplements the information contained in our general Privacy Policy (Notice of Privacy Practices) and aligns with the practices of OC Perfect Smile.

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”). The CCPA/CPRA imposes specific obligations on businesses processing the personal information of California residents. Terms used in this CCPA Privacy Policy, such as personal information, consumers, third party(ies), and service providers, have the same meaning as they are defined in the CCPA/CPRA.

Important Note on Protected Health Information (PHI) and CCPA/CPRA: Please be aware that much of the health and medical information we collect and maintain as a dental office falls under the definition of Protected Health Information (PHI), which is primarily governed by the Health Insurance Portability and Accountability Act (HIPAA) and the California Confidentiality of Medical Information Act (CMIA). To the extent that personal information we collect is PHI subject to HIPAA and CMIA, it is generally exempt from many of the CCPA/CPRA’s requirements. Our comprehensive approach to your PHI is detailed in our Notice of Privacy Practices. This CCPA Privacy Policy specifically addresses the collection and use of personal information that is not PHI or is not otherwise exempt, particularly in the context of your interactions with our website, digital ads, and OC Perfect Smile-managed online platforms (e.g., Smile Generation website, contests, and promotions).

1. Notice at Collection

At or before the time of collection, you have a right to receive notices of our practices. This includes the categories of personal and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details below.

2. What Is Personal Information?

The CCPA provides personal information rights to California residents. The CCPA defines personal information as information that “identifies, relates to, describes, is reasonably 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 or consumer information that is deidentified or aggregate consumer information.

3. Categories of Personal Information We Collect About You

We collect or generate personal information about you in a number of ways depending on the product or service and the relationship we have with you. For example:

Your contact information: Such as your email, home address, ZIP code, and phone number. These items are collected when you sign up for our contests or promotions, or use online services managed by OC Perfect Smile
Your public information: Such as comments or reviews that you post on our site or OC Perfect Smile-managed sites. We also collect requests or questions that you publicly post.
Your demographic information: Such as your postcode, preferences, and interests.
Other online activity information: Such as your location, your IP address, the browser/device/hardware you are using, your GPS location, and what pages you visit on our site or OC Perfect Smile-managed sites. Such items are collected when you visit our websites, affiliated websites, or interact with our digital ads.
Communications Content: When you communicate with us through the sites, over the phone (e.g., calls to our contact center), via social media, or other platforms, we collect the content of the communications, information about the channel in which you contacted us. We may also collect personal information about you indirectly through monitoring or other means, such as recording telephone calls and collecting phone metadata and digital information.
Digital Interaction Data: When you interact with the sites or our advertisements, we collect digital information using cookies, web beacons, page tags, pixels, or similar tools that we and our service providers and other third parties have set.
Social Media Interaction Data: When you interact with the sites via a social media platform, we collect a copy of the posts and other information, such as account ID or username.

For more detailed information, see below for a list of the categories of personal information, along with some descriptions and examples that we (OC Perfect Smile and its supported Dental Entities) may collect through each of the processes described above:

Personal Identifiers: This includes first and last name, previous name, address, telephone number, unique personal identifier, and signature.
Device and Online Identifiers and Related Information: This includes online identifiers, Internet Protocol (IP) address, email address, account user name, mobile/wireless number, social media profile, unique device identifier and serial number, and other device information.
Demographic Information: This includes date of birth and household income data.
Internet, Application, and Network Activity: This includes text messages or emails sent to us, clickstream/online website tracking information, and data related to user activity (e.g., browser visits and cookies or other similar technologies).
Location Data: We may receive information about your location and your mobile device, including a unique identifier for your device; in addition, in some instances, location information can be derived from your IP address or through your Wi-Fi connection.
Sensory Data: This includes audio data, such as a recording of your voice when you call our contact center (note: you will be informed if calls are recorded).

Although you don’t have to supply any of the personal information we request, we may not be able to provide certain products or services to you or you may not be able to interact with our sites if you do not.

4. The Purposes for Which Your Personal Information is Collected or Used

We OC Perfect Smile use your personal information for the following business purposes:

To keep an internal record for our reporting and analysis purposes.
To provide you with relevant content, materials, offers, programs, and to administer your participation in our contests or sweepstakes.
To respond to your requests or questions that you may provide via our social sites.
To improve our sites, products, services, and for other marketing purposes.
To protect our company, other patients, and our assets and sites, and for other security measures.
To remain in communication with you regarding any products or services you requested.
From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, or mail.
We may provide your information to our third-party service providers for marketing or promotional purposes.
To target ads to you based on your past online activity.
Customer information retention is indefinite and is shared with select third-party service providers and supported dentists (as outlined below).
Supporting our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.
Complying with contractual obligations, relevant industry standards, and our policies.
Notifying you about changes to the sites, products, and policies.
Performing analytics concerning your use of the products and sites, including your responses to our emails and the pages and advertisements you view.
Mitigating fraud and enhancing the security of the sites and our online services.
Managing institutional risk.
Operating, evaluating, and improving our business (including developing new products and services; improving existing products and services; and performing accounting, auditing, and other internal functions).
Authenticating your identity, including when scheduling appointments and financial application processes through the sites as well as afterwards.
Quality control and training purposes.

Any information collected is disclosed to you here and is used as permitted or required by law. We also abide by the set of rules prescribed to us by Google AdWords: https://support.google.com/adwordspolicy/answer/143465.

We may also use your personal information for any other purpose that we disclose at the time you provide, or when we collect your information and other purposes permitted by applicable law. We may also use data that we collect on an aggregate or anonymous basis for various business purposes, where permissible under applicable laws and regulations.

We are required to identify the categories of personal information we share with third parties for operational purposes. We disclose the following categories of personal information for operational purposes: personal identifiers; device and online identifiers and related information; demographic information; internet, application, and network activity; location data; sensory (audio data).

5. The Source of The Personal Information We Collect About You

We OC Perfect Smile collect personal information from various sources:

Directly from You: When you sign up for things automatically like a contest or a promotion or when you register to any of our sites.
Through Tracking Tools: Automatically collected through tracking tools, such as cookies, tags, and other technologies, when you visit our websites or interact with our digital properties.
Social Media: We may also use information associated with your social media account, e.g., your name, username, email address, gender, profile picture, etc. We may also collect information about your friends or family if you share any of our social content using web tools.
Third-Party Contractors: Any information that you provide to a third party with whom we have a contractual relationship, e.g., social media platforms, digital display media (banner ads), and any other advertising partners.

6. Sharing of Your Personal Information

We OC Perfect Smile share personal information as set forth below:

Service Providers: We share personal information with our third-party service providers (as defined by CCPA/CPRA, not necessarily HIPAA Business Associates) who perform services on our behalf, including those who show our ads on sites across the internet.
Advertising Partners: Please be aware that third parties (e.g., Google, Facebook) may use cookies, web beacons, and similar technologies to collect or receive information from our website and use that information to provide measurement services and target ads.
Within the OHCA: As detailed in our Notice of Privacy Practices, information, including personal information, may be shared between OC Perfect Smile, its subsidiaries, and the Dental Entities within the Organized Health Care Arrangement for treatment, payment, and healthcare operations.

7. Selling or Sharing of Your Personal Information

California law requires that we describe certain disclosures of personal information where we receive valuable consideration. California law treats such disclosures as “sales” even if no money is exchanged. Additionally, the CPRA introduced the concept of “sharing,” which refers to disclosing personal information for cross-context behavioral advertising.

To the extent that OC Perfect Smile “sells” or “shares” your personal information (as the terms “sell” and “share” are defined by the CCPA/CPRA and where such activities are not exempt under HIPAA), you have the right to opt-out of that “sale” or “sharing” going forward. See the section titled “Right to Opt-Out of the Selling or Sharing of Your Personal Information” below for more information.

We do not “sell” or “share” Protected Health Information (PHI) as defined and protected under HIPAA and CMIA.

8. Amount of Time Your Personal Information is Retained

We OC Perfect Smile retain personal information for various periods depending on the nature of the personal information, the purposes for its collection and use, and based on our legal and ethical obligations. Generally, we retain personal information only for so long as necessary to fulfill the purposes for which we collected it. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements.

Customer information retention for non-PHI consumer data is indefinite for certain purposes as described above, and this data is shared with select third-party service providers and supported dentists.

9. Your Rights to Your Personal Information (California Residents)

If you are a California resident, you have a number of legal rights when it comes to your Personal Information under the CCPA/CPRA. Without being discriminated against for exercising these rights, you have the right to request that we disclose what personal information we collect from you, the purposes for which we disclose your personal information, the right to request that we delete that information, the right to correct inaccurate personal information, and to opt-out of the sale or sharing of your personal information, subject to certain restrictions.

Right to Know You have the right to request that we disclose what categories of your personal information we collect, use, or “sell” or “share,” and the purposes for which the personal information is disclosed. You may request access to the specific pieces of personal information that we have collected from you.
Right to Delete You have the right to request that we delete your personal information, subject to certain limited exceptions. For example, we may retain an archived copy of your records consistent with applicable law, or where retention is necessary for completing a transaction, providing a service, or complying with legal obligations (e.g., maintaining PHI as required by HIPAA/CMIA).
Right to Correct You have the right to request that we correct inaccurate personal information that we collect about you, considering the nature of the personal information and the purposes of the processing of the personal information.

To exercise any of the privacy rights detailed above (Right to Know, Right to Delete, Right to Correct), please submit a CCPA request form online or call 888-508-2033.

Right to Opt-Out of the Selling or Sharing of Your Personal Information You have the right to opt-out of the “sale” or “sharing” of your personal information with third parties who are not our service providers (as those terms are defined under the CCPA and CPRA, and where such activities are not exempt under HIPAA). To exercise this right, click the “Do Not Sell/Share My Information” link typically found at the bottom of the webpage where your information is being collected, or contact us using the information below.
Right to Limit Use and Disclosure of Sensitive Personal Information You have the right to request that we limit our use and disclosure of your “sensitive personal information” (as that term is defined under the CCPA/CPRA) to certain permissible purposes. However, we OC Perfect Smile process sensitive personal information only as permitted by the CCPA/CPRA, and we don’t use sensitive personal information to infer characteristics about you beyond those purposes. Accordingly, we currently do not offer a separate option to limit further processing of Sensitive Personal Information.

10. How Will We Verify Your Identity If You Make a CCPA Request?

In order to verify your identity when you make a CCPA/CPRA request, we will collect your:

Name
Date of Birth
Email
Telephone Number
Address

We will use this information to verify your identity using reasonable methods in order to process your rights request. These methods may include matching information you provided to us with information already maintained by us or through the use of a third-party identity verification service.

We cannot respond to your request or provide you with personal information if we are not able to verify your identity or authority to make the request or confirm the personal information relates to you.

You are not required to have an account with us to make a verifiable request.

11. Contact, Questions or Complaints

We take your privacy seriously and invite you to contact us with any further questions or concerns you may have regarding your privacy or our collection, storage, and use of your Personal Information:

Email: ocperfectsmile@gmail.com

For general inquiries or to speak with our office directly about your dental care, please call 949-837-7112