Angelalign Technology Privacy Notice

Last Updated: 21 October 2025
Effective Date: 21 October 2025

1. Overview

Angelalign Technology Inc., and its global subsidiaries (“Angelalign,” “we,” “us”) care about your privacy. This notice explains what personal data we collect, how we use it, and your rights. You can contact our privacy team at privacyservices@angelaligner.com

2. Who This Notice Applies To

This notice applies to:

• Patients receiving dental treatment using Angelalign products or platforms
• Dental professionals and clinics/practices using Angelalign products or services
• Website visitors interacting with our site
• Partners, distributors, or research collaborators
• Job applicants (see our Candidate Notice)

3. How Angelalign Handles Your Personal Information

Angelalign can handle your information in two main ways, depending on how you interact with us:

When We are in Charge (Data Controller)

Sometimes we decide how and why your personal information is used — for example, when you:

• Create an account on our iOrtho platform
• Contact us for customer support
• Make a payment or receive a product directly from us
• Take part in marketing, training, or research with your consent

In these cases, we are responsible for:

• Keeping your information safe
• Telling you clearly how it is used
• Making sure you can access, correct, or delete it if you wish

When We Work for Your Clinic/Practice (Data Processor)

Sometimes your dentist or orthodontic clinic/practice is in charge of your data, and we simply process it on their behalf.

For example:

• When we host your treatment scans or plans for your clinic/practice
• When we provide digital tools your clinic/practices uses to manage your treatment

In these situations:

• Your clinic/practice decides what data we process and why
• We follow their instructions and keep your information secure
• We  do not use your data for anything else

In Short

• If you are a patient, your clinic usually controls your data, and Angelalign helps by processing it securely.
• If you use our website or contact us directly, we control that data.

4. What Information We Collect

5. How We Use Your Information

We use your personal information to:

• Deliver and manage our products, aligners, and digital services
• Support dental treatment planning and case management
• Manage professional relationships and accounts
• Process payments and orders
• Respond to inquiries and provide customer support
• Improve and operate our services, websites, and technology
• Conduct training, education, and marketing (with your consent)
• Comply with applicable laws, regulations, and professional standards
• Maintain cybersecurity, fraud prevention, and risk management

Sensitive data (like health information) is always processed with your consent or under legal/contractual requirements.

6. Legal Bases for Processing

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Contract performance (e.g., where we need to perform the contract, we are about to enter into or have entered into with you or your licensed orthodontic professional)
• Consent (e.g., for health data, marketing, or cross-border transfers)
• Legal obligation (e.g., tax, medical device, or regulatory reporting)
• Legitimate interest (e.g., service improvement, security)
• Vital interests (e.g., to protect someone’s health or safety)

7. Purpose, Data Type, and Lawful Basis Table

To provide transparency, we have summarized the main purposes for which we process personal data, the types of data involved, and the lawful basis for processing found in the table below;

8. Sharing your Data

We may share your data with:

• Angelalign affiliates and subsidiaries (for operations)
• Clinics or distributors (as part of your treatment)
• Service providers (IT, logistics, payments, marketing)
• Regulators if required by law

We do not sell your personal data. Some data may be shared for analytics or marketing only with consent.

9. International Data Transfers

When personal data moves across borders Angelalign uses legally recognised contractual mechanisms (SCCs, BAAs, PIPL standard contracts) combined with technical safeguards to ensure that cross-border personal data transfers comply with GDPR, UK GDPR, PIPL, LGPD, HIPAA, and other relevant laws.

EU/UK/Switzerland: Standard Contractual Clauses (SCCs), International Data Agreements or adequacy decisions (a copy can be found by contacting us.

10. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

11. Your Rights

Under certain circumstances, you have following rights under data protection laws in relation to your personal data:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Opt out of sale or sharing (for U.S. residents)
• Lodge a complaint with your data protection authority

Send requests to privacyservices@angelaligner.com
We will respond within applicable legal timeframes (usually 30 days).

12. Security Measures

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We use organizational, technical, and physical safeguards, some of these include:

• Encryption of data in transit and at rest
• Multi-factor authentication and role-based access
• Regular vulnerability testing and monitoring
• Employee privacy and security training
• Incident response and breach notification processes

13. Website Users

When you visit our website, we may collect limited technical and usage information automatically to help us operate and secure the site, and to understand how it’s used.

We use cookies and similar technologies to make the site function properly, remember your preferences, and improve your browsing experience. You can manage your cookie choices at any time through your browser settings or our Cookie Preference Centre.

14. Children’s Data

We do not directly collect data from children, however our doctors may treat patients who are children. Data collected as part of treatment from a doctor, including information from children, is stored securely on our systems. We protect this data with strong security measures, restrict access to authorised personnel, and delete any data collected without proper consent.

15. Updates to This Notice

We may update this Notice to reflect changes in laws or practices.

The latest version will always be posted on our website with a new “Last Updated” date.

16. Contact Us

If you have any questions about this Privacy Notice, your personal data, or wish to exercise your privacy rights, you can contact you local office found at Contact Us | Angel Aligner or email privacyservices@angelaligner.com

17. Global privacy offices

Depending on your location, you may have additional rights or protections under local privacy laws. Angelalign complies with these regulations and provides guidance which can be found by contacting privacyservices@angelaligner.com