Effective this Privacy Policy (“Policy”), we describe how cityortho , Inc. and its wholly-owned subsidiary Brands on West Side Orthodentist (individually and collectively doing business as “cityortho ”) collects, uses, and discloses information that we obtain about visitors to our website https://www.cityortho.com/software (the “Site”), users of our mobile Application and the services available through our Site (collectively, the “Services”).
By visiting the Site, using or downloading the Application, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our TERMS OF SERVICE, including its applicable limitations on damages and the resolution of disputes. The West Side Orthodontics PCTerms of Service are incorporated by reference into this Policy.
• THE INFORMATION WE COLLECT ABOUT YOU
• INFORMATION WE COLLECT DIRECTLY FROM YOU
• INFORMATION WE COLLECT AUTOMATICALLY
• HOW WE USE YOUR INFORMATION
• HOW WE SHARE YOUR INFORMATION
• OUR USE OF COOKIES AND OTHER TRACKING MECHANISMS
• LOCAL STORAGE OBJECTS
• CLEAR GIFS, PIXEL TAGS AND OTHER TECHNOLOGIES
• THIRD PARTY ANALYTICS
• THIRD-PARTY AD NETWORKS
• THIRD-PARTY LINKS
• SECURITY OF MY PERSONAL INFORMATION
• ACCESS TO MY PERSONAL INFORMATION
• WHAT CHOICES DO I HAVE REGARDING USE OF MY PERSONAL INFORMATION?
• CHILDREN UNDER 13
• SPECIAL INFORMATION FOR CALIFORNIA CONSUMERS
• CONTACT US
• CHANGES TO THIS POLICY
THE INFORMATION WE COLLECT ABOUT YOU
We collect information about you directly from you and from third parties, and automatically through your use of our Site or Services.
Information We Collect Directly From You.
The information we collect from you depends on how you use our Services. To create an account, you must provide your such as your name, phone number, mailing and email addresses. We may collect additional information from you, including location, credit card data.  If you make a purchase, we will collect your payment information, such as your credit or debit card information and your billing and shipping address.
Information We Collect From Other Entities. 
Information We Collect Automatically.
We automatically collect information about your use of our Site and Apps through cookies, web beacons, and other technologies, including technologies designed for mobile apps. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
Site:
• domain name;
• your browser type and operating system;
• web pages you view on the Site; links you click on the Site; your IP address;
• the length of time you visit our Site and or use our Services;
• the referring URL, or the webpage that led you to our Site.
App:
• mobile device ID; device name and model; operating system type, name, and version;
• language information;
• activities within the App; and the length of time that you are logged into our App;
HOW WE USE YOUR INFORMATION
We use your information, including your personal information, for the following purposes:
• To provide our Services to you and to fulfill your orders.
• To communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes.
• To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Services.
• To send you email marketing about our products and services.
• To send you news and newsletters.
• To send you email marketing about products and services of our affiliated entities.
• To send you email marketing about products and services of other entities that we think may be of interest to you.
• To assist us in advertising on third party websites, mobile apps, and other online services, and to evaluate the success of our advertising campaigns through third party channels (including our online targeted advertising and offline promotional campaigns).
• To better understand how users access and use our Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Site and App are more (or least) used by users, and we will use this information.
• For research and to improve the services we provide to you.
• To administer our customer loyalty program.
• To administer surveys and questionnaires, such as for market research or member satisfaction purposes.
• To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
• Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy. 
HOW WE SHARE YOUR INFORMATION
We may share your information, including personal information, as follows:
• Service Providers. We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. These service providers include [Account Management and payment processors (Chargebee, Stripe and Healthpay24), email services (Sparkpost), telephony services (Twilio), SMS services (Twilio), cloud data storage services (Google and Amazon, web form services (Formstack), Website and Email Hosting services (Firefly Technologies and Squarespace), online citation management services (Moz and Yext), Digital advertising services (Facebook and Google Adwords), Online Review procurement services (Birdeye and Reputation Loop), Digital advertising performance tracking services (SWYDO) Customer Relationship Management services (Hubspot, Monday.com, Asana, Zendesk), Printing and Mailing services (Zenprint) ].
• Affiliates. We disclose the information we collect from you to our affiliates or subsidiaries.
• Legwork’s Users. Your user name and any information that you post to our Site, including, without limitation, reviews, comments, and text will be available to, and searchable by, all users of the Site and Services.
• Third Parties. California based customers should see the section “Special Information for California Consumers” for more information on sharing of personal information of CA residents.
We also disclose information in the following circumstances:
• Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another Legwork, or (ii) if any of our assets are or may be transferred to another Legwork, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other Legwork. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third party advisors, including attorneys and consultants.
• In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other lawful process, such as in response to a court order or a subpoena.
• To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
• Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
OUR USE OF COOKIES AND OTHER TRACKING MECHANISMS 
We and our third party service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf). 
Cookies.  Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
• Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.
• Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.
FLASH LOCAL STORAGE OBJECTS.
We may use Flash Local Storage Objects (“Flash LSOs”) to store your Site preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
CLEAR GIFS, PIXEL TAGS AND OTHER TECHNOLOGIES.
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track the activities of Site visitors and app users, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
THIRD PARTY ANALYTICS
We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site, and to the extent permitted, our Apps. We also may use other analytic means to evaluate our Site and Apps. We use these tools to help us improve our Site’s and Apps’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout. 
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.
THIRD-PARTY AD NETWORKS
We use third parties such as network advertisers to serve advertisements on our Site, App, and on third-party websites or other media (e.g., social networking platforms). We may provide these third-party advertisers with information, including personal information, about you. This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. 
Users in the United States may opt- out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) CONSUMER CHOICE PAGE for information about opting out of interest-based advertising and their choices regarding having information used by DAA COMPANIES. You may also go to the Network Advertising Initiative (“NAI”) CONSUMER OPT-OUT PAGE for information about opting out of interest-based advertising and their choices regarding having information used by NAI MEMBERS.
Opting- out from one or more companies listed on the DAA CONSUMER CHOICE PAGE or the NAI CONSUMER OPT-OUT PAGE will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site, Services, or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads).  Also, if your browsers are configured to reject cookies when you opt- out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org. 
THIRD-PARTY LINKS
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
SECURITY OF MY PERSONAL INFORMATION 
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
ACCESS TO MY PERSONAL INFORMATION
You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or Application for a period of time.
WHAT CHOICES DO I HAVE REGARDING USE OF MY PERSONAL INFORMATION?
We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests.  If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.
CHILDREN UNDER 13
Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
SPECIAL INFORMATION FOR CALIFORNIA CONSUMERS
IMPORTANT ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
This document provides specific information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”).  California privacy laws require that we provide California residents information about how we use their personal information, whether collected online or offline, and this document is intended to satisfy that requirement.  
Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular resident or household.  
Categories of Personal Information that We Collect, Disclose, and Sell 
Below please find the categories of personal information about California residents that we collect, sell, and/or disclose to third parties or service providers for a business purpose.
Categories of personal information 
Last Updated: 12-09-2019
NAME, CONTACT INFORMATION AND IDENTIFIERS: Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Do we collect? Yes
Do we disclose for business purpose? Yes
Do we sell? No
CUSTOMER RECORDS: Paper and electronic customer records containing personal information, such as name, signature, social security number, Signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, , employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Do we collect? Yes
Do we disclose for business purpose? Yes
Do we sell? No
PROTECTED CLASSIFICATIONS: Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
Do we collect? Yes
Do we disclose for business purpose? Yes
Do we sell? No
PURCHASE HISTORY AND TENDENCIES:  Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Do we collect? Yes
Do we disclose for business purpose? Yes
Do we sell? No
BIOMETRIC INFORMATION: physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
Do we collect? No
Do we disclose for business purpose? No
Do we sell? No
USAGE DATA: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement.
Do we collect? Yes
Do we disclose for business purpose? No
Do we sell? No
GEOLOCATION DATA: Precise geographic location information about a particular individual or device.
Do we collect? Yes
Do we disclose for business purpose? Yes
Do we sell? No
Do we collect? Yes
Do we disclose for business purpose? Yes
Do we sell? No
AUDIO/VISUAL: Audio, electronic, visual, thermal, olfactory, or similar information.
EMPLOYMENT HISTORY: Professional or employment-related information.
Do we collect? No
Do we disclose for business purpose? No
Do we sell? No
EDUCATION INFORMATION: Information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
Do we collect? No
Do we disclose for business purpose? No
Do we sell? No
PROFILES AND INFERENCES: Inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Do we collect? No
Do we disclose for business purpose? No
Do we sell? No
California Residents’ Rights
California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.
Do-Not-Sell.  We do not sell your personal information. 
Initial Notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.
Verifiable Requests for Copy, Deletion and Right to Know. Subject to certain exceptions, California residents have the right to make the following requests, at no charge, up to twice every 12 months:
Right of Deletion: The right to request deletion of their personal information that we have collected about them, subject to certain exemptions, and to have such personal information deleted, except where necessary that we maintain such personal information in order to: 
• Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
• Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
• Comply with a legal obligation.
• Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
Right to a Copy: The right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.  
Right to Know: The right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the: 
• categories of personal information collected;
• categories of sources of personal information;
• business and/or commercial purposes for collecting and selling their personal information;
• categories of third parties/with whom we have disclosed or shared their personal information;
• categories of personal information that we have disclosed or shared with a third party for a business purpose;
• categories of personal information collected; and
• categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.
Submitting Requests. Requests to exercise the right to deletion, right to a copy, and / or the right to know may be submitted on our California Residents’ Rights Page at ([URL]), as well as through the Requests page in their account profiles, by contacting us at 877-311-4690 (toll free) or by emailing us at PRIVACY@Cityortho.COM.  We will respond to verifiable requests received from California consumers as required by law.    
Incentives and Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their personal information.  
Discrimination: Businesses may not discriminate against residents who exercise their rights under CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices or rates or impose penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data