Privacy Policy

Last Updated: October 1, 2022

This Privacy Policy describes the privacy practices of TruBlu Social Smiles, LLC. (“TruBlu”, “we”, “us” or “our”), including the types of information that we collect and the ways in which we use such information. By accessing our website or associated applications that reference or link to this Privacy Policy,
including https://trublusocialsmiles.com/ (the “Site” “Website” or “Platform”), or by using any products or services that we make available on the Site or that otherwise reference or link to this Privacy Policy (collectively, the “Services”), you agree to be bound by the terms and conditions of this Privacy Policy, and our Terms of Service.

We may add to, modify, or otherwise update this Privacy Policy from time to time in our sole discretion by notifying you that a new version of this Privacy Policy has been posted to the Site or Services. It is your responsibility to review this Privacy Policy for any additions, modifications or updates each time that you access the Site or use any of the Services, and you are bound by such additions, modifications and updates. Your use of the Site or Services following any additions, modifications or updates to this Privacy Policy constitutes your acceptance of the new Privacy Policy.

Information We Collect

In connection with the Site and Services, we may collect the following categories of information:

information you provide to us, including your name, the name of your practice, and your contact information (e.g., email address, phone number, postal address);
information regarding your use of the Site and Services;
data; and
any other information that you provide or otherwise make available to us inconnection with the Site or Services.

You may choose not to provide certain information to us, but as a result you may not be able to take advantage of some or any of the features of the Site or Services.

We may also collect general, non-personal, statistical information about the use of the Site and Services automatically, such as how many visitors visit a specific page on the Site, how long a visitor stays on that page, and the hyperlinks visitors click. We collect this information by using cookies, log files and other similar technologies (as further described below in the section of this Privacy Policy entitled ‘Cookies, Log Files and

Similar Technologies’). This information represents a generic overview of visitors to our Site and users of our Services.

How We Use & Share Information

We may use the information that we collect in order to:

administer the Site and Services;
personalize the Site or Services for you;
provide to you any services or analyses (including analysis of your existing cardprocessing statements) requested by you;
enable your access to and use of the Site and Services;
improve, modify or enhance the Site or Services, including our user experience;
conduct internal business analysis or other business purposes; and
send you communications, including marketing communications.We do not disclose your information to third parties, except:

when we have your permission to make the disclosure;
where the disclosure is necessary for the purpose for which the information wasobtained;
to our business partners, including merchant acquirers whose services you maybe interested in receiving;
to our third party service providers in order to provide services to us (includingmarketing communications, email delivery, targeted advertisements, and otherbusiness operations); or
as otherwise disclosed in this Privacy Policy.We may disclose your information where permitted by applicable law or when the disclosure is necessary, in our discretion, for the establishment or maintenance of legal claims or legal compliance, to satisfy any law, regulation, subpoena or government request, or in connection with litigation.Additionally, in the event we are acquired by, or merge or consolidate into, another entity, or if there is a sale of our assets (including in bankruptcy), your information may be transferred to the entity acquiring us or our assets or that survives the merger or consolidation. You acknowledge and agree that in the foregoing circumstances, your information may be disclosed to such third party.Cookies, Log Files and Similar Technologies

As mentioned above, we may use cookies, log files and similar technologies to collect certain information regarding your use of the Site and Services. A cookie is a small amount of data that is sent to your browser from a website’s servers and stored on your computer’s hard drive which often includes an anonymous unique identifier. Cookies do not identify specific users, only a user’s device. We use cookies to track and record user session information. You may set your browser to notify you when you receive a new cookie or to disable cookies. However, this may hinder performance of the Site or Services, and prevent you from using certain features.

The Site and Services also may use log fIles. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and number of clicks to analyze trends, administer the site, track a user’s movement around the Site and Services, and gather demographic information.

In addition to our own cookies, log files and similar technologies, we may engage third parties (such as Google and Facebook) to use their cookies, log files and similar technologies to report to us usage statistics of the Site and Services, deliver advertisements on and through the Site and Services, and for other similar purposes. Google Analytics, for example, uses cookies to track your interactions with our Site and Services. Google collects information and reports it to us, without identifying individual users. This information helps us improve our Site and Services so that we can better serve users. For more information on Google Analytics, please

visit www.google.com/policies/privacy/partners/.

You have the right to opt out of the collection and use of information for ad targeting. Please visit www.aboutads.info/choices.com for additional information regarding such rights and how to exercise them.

Securing Your Information

We use commercially reasonable security measures that we, in our discretion, deem appropriate for the type of information that is provided by you. However, since no method of electronic storage is 100% secure, we cannot guarantee the absolute security of the information stored. We also cannot guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.

Links to Third Party Websites

The Site and Services may include links to other Websites or applications offered or made available by third parties (each, a “Third Party Site”). We do not control or endorse any Third Party Site. You agree that your use of a Third Party Site is at your

own risk and that we are not responsible for the availability or contents of any Third Party Site. We recommend that you review the privacy policy applicable to each such Third Party Site.

California Residents

California residents have the following additional rights:

California Do Not Track Disclosure

At this time, we do not respond to browser ‘Do Not Track’ signals.

California Consumer Privacy Act of 2018

This Privacy Notice for California Residents supplements the information contained in the Notice to California Residents/Your California Privacy Rights and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

You understand and agree that this CCPA supplemental notice incorporates the arbitration agreement provisions set forth in our Terms of Use, including a waiver of any rights to class-wide arbitration.

Information We Collect

The TruBluSocialSmiles.com Platform collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information“), but does not include in particular,

Publicly available information from government records,
Deidentified or aggregated consumer information,
Information excluded from the CCPA’s scope, like: Health or medical information coveredby the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and theCalifornia Confidentiality of Medical Information Act (CMIA) or clinical trial data;
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and the CaliforniaFinancial Information Privacy Act (FIPA); and Driver’s Privacy Protection Act of 1994.We have collected the following categories of personal information from its consumers within the last twelve (12) months:Category Examples Collected

B. Personal A name, signature, physical characteristics or No information description, address, telephone number, and

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, and email address.

categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	payment card information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar Platform activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO

G. Geolocation Physical location or movements. NO data.
H. Sensory Audio, electronic, visual, thermal, olfactory, or NO data. similar information.

I. Professional or employment- related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO

1232g, 34 C.F.R. Part 99)).
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

The Platform obtains the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete, products or services you purchase, or information you choose to post or share.
Indirectly from you. For example, from observing your actions on the Platform. Use of Personal InformationWe may use, or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry;
- To provide, support, personalize, and develop our Platform and services;
- To create, maintain, customize, and secure your account with us;
- To provide you with support and to respond to your inquiries, including to investigate andaddress your concerns and monitor and improve our responses;
- To personalize your Platform experience and to deliver content and service offeringsrelevant to your interests, via email or text message (with your consent, where requiredby law);
- To help maintain the safety, security, and integrity of the Platform, products and services,databases and other technology assets, and business;
- For testing, research, analysis, and product development, including to develop andimprove the Platform and services;
- To respond to law enforcement requests and as required by applicable law, court order,or governmental regulations;
- As described to you when collecting your personal information or as otherwise set forth inthe CCPA; and
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, orother sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about Platform users is among the assets transferred.We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose, but we do not currently sell your personal information to third parties. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

Service providers, including customer service, payment processing, marketing and analytical services; and Data aggregators.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has NOT disclosed the following categories of personal information for a business purpose:

A. Identifiers.
B. California Customer Records personal information categories.
C. Protected classification characteristics under California or federal law. D. Commercial information.
E. Biometric information.
F. Internet or other similar Platform activity.
G. Geolocation data.
H. Sensory data.
I. Professional or employment-related information.
J. Non-public education information.
K. Inferences drawn from other personal information.

Sales of Personal Information

In the preceding twelve (12) months, Company has NOT sold the following categories of personal information:

A. Identifiers.
B. California Customer Records personal information categories.
C. Protected classification characteristics under California or federal law. D. Commercial information.

E. Biometric information.
F. Internet or other similar Platform activity.
G. Geolocation data.
H. Sensory data.
I. Professional or employment-related information.
J. Non-public education information.
K. Inferences drawn from other personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that the we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will disclose to you:

The categories of personal information we collected about you;

The categories of sources for the personal information we collected about you;

Our business or commercial purpose for collecting or selling that personal information;

The categories of third parties with whom we share that personal information;

The specific pieces of personal information we collected about you (also called a data portability request); and

If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.Deletion Request RightsYou have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your verifiable consumer

request (see Exercising Access, Data Portability, and Deletion Rights, we will delete and direct our service providers to delete your personal information from our records, unless an exception applies.

Even if verifiable, we may nonetheless deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise their free speechrights, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 et. seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the publicinterest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; or
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the contextin which you provided it.Exercising Access, Data Portability, and Deletion RightsYou may exercise the access, data portability, and deletion rights described above by submitting a verifiable consumer request to us using one of the following options:Calling us at 800-772-2160
Sending an email to dataprivacy@trublusocialsmiles.com.Personal Information Sales Opt-Out and Opt-In RightsWe do not sell your information to third parties. If you are 16 years of age or older, you have the right to direct us to not sell your personal information in the event our practices change in the future (the “right to opt-out”). For consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age, we will not sell your information in the event our practices change in the future.In order to exercise the right to opt-out of personal information sales by us, you (or someone legally authorized) may submit a request to us at dataprivacy@trublusocialsmiles.com

DO NOT SELL MY PERSONAL INFORMATION

As noted above, we do not sell your information to third parties. We will retain your opt-out request in the event our practices change in the future. Should your email address change, please submit a new request with your new email address. We reserve the right to take reasonable steps to verify your identity and the authenticity of the request.=

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Verification Requirement for Requests

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access, data portability, or deletion twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
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 we cannot verify your identity or authority to make the request and confirm the personal information relates to you.Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.Response Timing and FormatWe will acknowledge receipt of your request within 10 days and will endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will notify and inform you of the reason and extension period in writing.If we receive a request to opt-out from you, we will act upon that request within 15 days from the date we receive that request.If you have an account with us, we will deliver our written response to that account electronically.If you do not have an account with us, we will deliver our written response electronically.Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from

one entity to another entity without hindrance (e.g., an excel spreadsheet that has been converted into a changed-locked pdf).

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you services.
Provide you a different level or quality services.However, we may offer you certain financial incentives permitted by the CCPA that can result in different service quality or feature levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.Other California Privacy RightsCalifornia’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes. To make such a request, please send an email to dataprivacy@trublusocialsmiles.com.Changes to Our Privacy NoticeWe reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Platform and update the notice’s effective date. Your continued use of our Platform following the posting of changes signifies and constitutes your acceptance of such changes.Notice to Nevada Residents/Your Nevada Privacy RightsUnder Nevada SB 220, Nevada residents have the right to opt out of the sale of their Covered Information (as such term is defined under Nevada law). As noted above, we will not sell your information. However, if you are a Nevada resident, you may submit a request to opt out of future sales by us by writing to us at dataprivacy@trublusocialsmiles.com. We will maintain your request in the event our practices change in the future. Should your email address change, please submit a new request to dataprivacy@trublusocialsmiles.com. with your new email address. We reserve the right to take reasonable steps to verify your identity and the authenticity of the request.

Contact Us

If you have any questions, complaints, or comments regarding this Privacy Policy or our information collection, storage, disclosure and use practices, please email or contact us at:

TruBlu Social Smiles, LLC
7804-C Fairview Road, Suite 190 Charlotte, NC 28226

or email us at dataprivacy@trublusocialsmiles.com.
Any personal information you provide to the above email or postal mail addresses will not be used

to send you promotional materials, unless you request it.

Note to International Users

Our Site and Services are intended for individuals located in the United States. If you are located outside of the United States and access the Site or Services, or submit your information to us, you do so at your own risk and choice. United States law may not offer the same privacy protections as the law of your jurisdiction. If you visit our Site or use our Services or contact us from outside of the United States, please be advised that (a) any information you provide to us or that we automatically collect will be transferred to and processed in the United States; and (b) by using our Site or Services or submitting information to us, you explicitly authorize its transfer to and subsequent processing in the United States in accordance with this Privacy Policy and United States law.

Use By Minors

We do not knowingly collect any information about children under the age of 18. If we become aware that we have unknowingly collected information from a child under the age of 18, we will make commercially reasonable efforts to delete such information.

Contact Us

If you have any questions about this Privacy Policy or treatment of your information, please contact us at:

Email: info@trublusocialsmiles.com Phone: (800) 772-2160