Privacy Policy for EarlySmile.com
1. Introduction
At Early Smile, accessible at earlysmile.com, your privacy is of paramount importance to us. We are fully committed to safeguarding your personal data and ensuring that your privacy rights are respected and protected in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). This Privacy Policy sets out how we collect, use, disclose, and protect your personal data when you visit or use our website, and outlines your rights in relation to your data.
2. Scope of Policy and Data Controller Role
This Privacy Policy applies to all users of earlysmile.com and governs the personal data collected, processed, and stored through our website, applications, communications, and any associated services (collectively, “Services”). For the purposes of applicable data protection legislation, Early Smile is the Data Controller of your personal data. If you have any questions about how we use your data, please contact us at [email protected].
3. Categories of Data Processed
We may collect and process the following categories of personal data, either directly from you or via automated technologies:
a. Usage Data: We collect information about your use of our website, such as browser type, IP address, pages visited, time spent on pages, date/time stamps, and session duration. This helps us understand how users engage with our content and improve our Services.
b. Account Data: Personal data you provide when registering an account, such as your full name, email address, mailing address, phone number, and password.
c. Profile Data: Data reflecting your preferences, purchase history, behavior on the website, and other profile-related information derived from your interactions with our Services.
d. Communication Data: Includes information derived from your communications with us, such as inquiries, support requests, complaint history, chat transcripts, and messages sent through the website.
e. Technical Data: Device-specific data such as device type, operating system, browser version, screen resolution, language settings, and system configurations.
f. Transaction Data: Information relating to purchases made through earlysmile.com, including order history, payment credentials (where applicable and in encrypted tokenized form), shipping details, and tax identifiers.
g. Preference Data: Your preferences for receiving marketing communications, product interest indicators, and your responses to surveys or promotional events.
4. Legal Bases for Processing Personal Data
We process your personal data under one or more of the following legal bases, as permitted under GDPR and CCPA:
– Consent: Where you have explicitly given us permission to process your personal data for a specific purpose (e.g., email marketing).
– Contractual Necessity: When processing is necessary for the performance of a contract with you or to take pre-contractual steps at your request.
– Legal Obligation: Where we are required to process your data to comply with applicable law.
– Legitimate Interests: When processing is required for our legitimate interests, provided those interests are not overridden by your rights (e.g., improving our Services, providing customer support, preventing fraud).
5. Your Rights
Subject to applicable laws, you have the following rights in relation to your personal data:
– Right of Access: Request confirmation and access to the personal data we hold about you.
– Right to Rectification: Request correction of inaccurate or incomplete personal data.
– Right to Erasure: Request deletion of your data where there is no lawful reason for its continued processing.
– Right to Restriction: Request limited processing of your data in certain circumstances.
– Right to Data Portability: Receive your data in a structured, commonly used format and transmit it to another controller.
– California Residents: You have the right to opt-out of the sale of personal data, request disclosures about collected and shared information, and not be discriminated against for exercising your privacy rights under the CCPA.
Requests to exercise any of these rights can be submitted via email to [email protected]. We may require verification of identity before processing your request.
6. Security Measures
We implement robust technical and organizational security measures to ensure the confidentiality, integrity, and availability of your personal data. These include:
– Data encryption in transit and at rest.
– Access control mechanisms and authentication protocols.
– Periodic security training for personnel.
– Regular data backups and disaster recovery protocols.
While no system is completely secure, we take reasonable steps to prevent unauthorized access and disclosure.
7. International Transfers
We may transfer your personal data to jurisdictions outside your country of residence, including to countries outside the European Economic Area (EEA). Where we do so, we implement appropriate safeguards including the use of Standard Contractual Clauses approved by the European Commission, or rely on other legally compliant mechanisms to ensure an equivalent level of data protection consistent with the GDPR and regional laws.
8. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, regulatory, tax, accounting, or reporting obligations. Retention periods vary based on the type of data:
– Usage and Technical Data: up to 12 months
– Account and Profile Data: until your account is deleted or inactive for more than 24 months
– Transaction Data: retained for 7 years for tax/audit compliance
– Communication Data: up to 3 years unless required longer for servicing purposes
– Preference Data: retained until revoked
We may anonymize or aggregate data for research or statistical purposes indefinitely.
9. Cookie Policy
earlysmile.com uses cookies and similar tracking technologies to enhance user experience, analyze website usage, enable functionality, and support marketing activities. Categories of cookies include:
– Essential Cookies: Required for basic website functionality and security.
– Functional Cookies: Enable enhanced website features and personalization.
– Analytics Cookies: Collect data on usage behavior for performance improvements.
– Performance Cookies: Monitor website responsiveness, load times, and interactions.
10. Cookie Management and Compliance with GDPR & CCPA
You can manage your cookie preferences at any time through our Cookie Consent Manager available on earlysmile.com. Additionally, most browsers allow you to refuse or delete cookies via settings.
For California residents, cookies that constitute “sales” under the CCPA may be opted out via our “Do Not Sell My Personal Information” link. GDPR-compliant users must provide affirmative consent before non-essential cookies are deployed.
11. Children’s Privacy
Our Services are not intended for children under 13 years of age, and we do not knowingly collect personal data from anyone under 13. If we become aware of such data collection, we will delete the data immediately. Parents or guardians who believe their child has provided us with personal data without consent should contact us at [email protected].
12. Policy Updates & Notifications
We reserve the right to update or modify this Privacy Policy at our sole discretion to reflect changes in technology, legal requirements, or our data practices. Updates will be posted on earlysmile.com and, if material, may be communicated to you through available contact methods.
We encourage you to review this Privacy Policy periodically to remain informed of how we protect your personal data.
13. Contact
For questions, concerns, or requests related to this Privacy Policy or your personal data, you may contact us at:
We are committed to ensuring that your data is handled in accordance with applicable data protection legislation and in a transparent, secure, and privacy-focused manner.