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Introduction

This Privacy Policy describes how Royim Co., Ltd., collects and uses Personal Data about you through the use of our Website, mobile applications, web applications, and through email, text, and other electronic communications between you and Royim.

Royim Co., Ltd., (“Royim” or “we” or “our”) respects your privacy and is committed to protecting it through our compliance with this policy.

This Privacy Policy (“Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website www.royim.com (our “Website”) or use our Royim mobile/web application (our “Application”) and our practices for collecting, using, maintaining, storing, protecting, and disclosing that information.

This policy applies to information we collect:

from you or your legal guardian on or through our Website or Application;
from or on behalf of your licensed dentist, orthodontist or other medical provider or her/his staff;
in email, text, and other electronic messages between you and our Website or Application;
through printed documents, records, and materials; and
when you interact with our advertising, marketing, and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information we collect:

offline or through any other means, including on any other website operated by Royim or any third-party; or
through any third-party website or application, including through any application or content (including advertising or marketing) that may link to or be accessible from or on the Website or in the Application.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you are not permitted to use our Website or Application. By accessing or using our Website or Application, you agree to the terms and conditions of this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of our Website or Application after we make changes shall constitute your acceptance of those changes, so please check this Privacy Policy periodically for updates.

Children Under the Age of 18

Our Application and Website are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Website. We will remove any information provided by a child under the age of 18 if we become aware of it. Parents and legal guardians are welcome to provide information on behalf of children under 18.

No one under age 18 may provide any information to or on the Website or in the Application. We do not knowingly collect personal information directly from children under 18. If you are under 18, please ask your parent or guardian to access and use the Website or Application for you, and please do not use, or provide any information on our Website, Application, or on or through any of their features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information directly from a child under 18 without verification of parental or guardian consent, we will delete that information. If you believe we might have received any information from a child under 18, please contact us at info@royim.com.

Information Collection

We collect different types of information about you, including information that may directly identify you or be used to identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

We collect several types of personal information from and about users of our Application and Website, specifically information:

by which you may be personally identified, such as name; home, shipping, and postal address; e-mail address; home and mobile telephone number; credit card, debit card, or other payment information (solely for payment purposes); date of birth; your medical history and name(s) of your medical and dental providers; and other information about your past, present or future physical or mental health condition or the provision of health or dental care (“Personal Data”);
that is about you but individually does not identify you, such as statistical and other communication data and the resources that you access and use on the Website and in the Applications; and/or
about your internet connection and the equipment you use to access our Website and Application and usage details.

We collect this information:

directly from you when you provide it to us;
automatically as you navigate through the Website or use the Application. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
From third parties, for example, your health and dental providers and our business partners.

As you navigate through and interact with our Application and Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, such as:

details of your visits to our Website or use of our Application, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website or use of our Application, error information, clickstream data, and other communication data and the resources that you access and use on the Website or in the Application; and
information about your computer and internet connection, such as your IP address, operating system, and browser type.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and Application and to deliver a better and more personalized service by enabling us to:

estimate our audience size and usage patterns;
store information about your preferences, allowing us to customize our Website and Application according to your individual interests;
speed up your searches; and
recognize you when you return to our Website or Application.

Details about the automated data collection technologies and the specific cookies that we use can be found in our Cookie Policy.

Information You Provide to Us

The information and data we collect on or through our Website and Application are:

information that you provide by filling in forms on our Website and Application. This includes information provided at the time of registering to use our Website or Application, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, or during a study you consent to participate in, and when you report a problem with our Website or Application;
records and copies of your correspondence (including email addresses), if you contact us;
your responses to surveys that we might ask you to complete for research purposes; and
details of transactions you carry out through our Application and Website and of the fulfilment of your orders. You may be required to provide financial information before placing an order through our Website or our Application.

The Personal Data we collect from you is collected with your consent and required for us to provide you with our products and services and to facilitate communication between you and your licensed dental provider. You may withdraw your consent at any time by terminating your membership with us; however, we may no longer be able to provide you with our goods and services if you do.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website and Application or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website or Application with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Health Information

We may process some Personal Data considered sensitive when necessary to carry out our obligations to you.

Some Personal Data processed by Royim may be considered sensitive, including Personal Data concerning your health. Royim processes this information only to the extent necessary to carry out its obligations to your licensed dental care provider and you, and to provide your licensed dental provider and you with our goods and services.

How We Use Your Information

We use your Personal Data for various purposes described below, including to:

provide our Application and Website to you;
provide you with information you request from us;
enforce our rights arising from contracts;
notify you about changes; and
provide you with notices about your account.

We use information that we collect or receive about you or that you provide to us, including any Personal Data:

to present our Website and Application and their contents to you;
to provide your licensed dental provider and you with information, products, or services that your provider or you request from us;
to fulfil any other lawful purpose for which you provide it;
to provide you with notices about your membership, including expiration and renewal notices;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to notify you about changes to our Website or Application or any products or services we offer or provide though them;
to allow you to participate in interactive features on our Website and Application;
in any other way we may describe when you provide the information; and
for any other purpose with your consent.

We may also use your information to contact you through about and/or to promote and market our own goods and services that may be of interest to you. With your consent, we may also use your information to contact you through text and voice messages about and/or to promote and market these goods and services. If you wish to opt-out of such emails, you may do so by clicking the unsubscribe link in emails that we send you. The treatment you receive from your licensed dental provider is not conditioned on your consent to receive promotional and/or marketing communications.

Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:

Your licensed dental provider;
our subsidiaries and affiliates;
our third-party service providers, subcontractors, and business associates we use to support our business;
to any company we might merge with or acquire, or that buys us, or in the event of change in structure of our company of any form;
to comply with our legal obligations;
to enforce our rights; and
with your consent.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose without restriction aggregated information about our users and information that does not identify any individual. We may disclose Personal Data that we collect or that you provide as described in this privacy policy:

to your dental care provider;
to our subsidiaries and affiliates;
to contractors, service providers, subcontractors, and business associates, and other third parties we use to support our business;
to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Royim Co., Ltd.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Royim Co., Ltd., about our Website’s and Application’s users is among the assets transferred;
to fulfill the purpose for which you provide it;
for any other purpose disclosed by us when you provide the information; or
with your consent.

We may also disclose your Personal Data:

to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
to enforce or apply our Terms of Use, our Application’s End User License Agreement, and other agreements, including for billing and collection purposes; and
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of you, your licensed provider and/or her/his staff, Royim Co., Ltd., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to market or advertise to you, our marketing or advertising to you, and other targeted marketing and advertising.

We do not control the collection and use of your information collected by third parties. When possible, these organizations are under contractual obligations (including through the use of Business Associate Agreements) to maintain appropriate safeguards and protections, to use this data only for providing the services to us, and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We will only use your contact information to promote or market our own products and services through voice and text messages with your express consent. If you wish to consent to such use, you can check the relevant box located on the form on which we collect your Personal Data or otherwise seek such consent. If you wish to change your choice, you may do so at any time by logging into the Website or Application and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes. We may also use your contact information to promote or market our products and services through email. If we have sent you a marketing or promotional email, you may click the unsubscribe link to be omitted from future email distributions. This opt out does not apply to information provided to Royim as a result of a product purchase, your membership, product service experience or other transactions. Your aligner therapy treatment is not conditioned on your consent to receive marketing or promotional communications.

Accessing and Updating Your Personal Data

You may access and update your Personal Data at any time.

You can review and change your Personal Data by logging into the Website or Application and visiting your account profile page. You may also notify us through the Contact Information of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

Retention Administration & Management of Personal Data

We will take reasonable efforts to ensure that your personal data is accurate and complete, based on the information that you have provided us with. Please ensure that all information provided to us is up to date and keep us informed of any relevant changes.

We value your privacy and have security arrangements to ensure that your personal data is adequately protected and secured. We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that: (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes. Otherwise, personal data collected by us is generally only retained for as long as it is reasonably necessary for the purpose for which the data provided and we may destroy or delete any information or personal data provided by you thereafter, unless required by law, regulation or other business or audit requirements.

Where your personal data is to be transferred out of Singapore or such other jurisdiction in which it is collected, we shall take reasonable steps to ascertain that the recipient of the personal data is bound by legally enforceable obligations to protect your personal data in accordance with this Privacy Policy and the PDPA.

Changes to Our Privacy Policy

We will post any changes to our Privacy Policy on our Website or in the Application. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’s or Application’s home page/screen. If we make material changes to how we treat our users’ Personal Data, we will provide notification through a notice on the Website’s or Application’s home page/screen. The date this Privacy Policy was last revised is identified at the bottom of the page. You are responsible for periodically visiting our Website or the Application and this Privacy Policy to check for any changes.

Cookie Policy

We may collect information from you (or others on your behalf) de-identified information to help us in our business and provide you with the relevant Services. Such anonymised and de-identified information may be transferred, disclosed, assigned, leased, licensed, sold and otherwise shared with and by our partners, service providers, advertisers and/or other third parties for purposes permitted under law.

Cookies (small text files placed on your device that record information about your preferences and enable logins, provide interest-based advertising, analyse how our Services are performing) are an example of such anonymised data which we collect. While compiling information about your browsing habits, cookies can also enhance your user experience. There may also be third party cookies on our Websites and Channels. For more information on cookies, please refer to allaboutcookies.org/manage-cookies/.

You can control cookies through your web browser settings. This allows you to determine which cookies to allow and which to refuse. If you disallow the use of cookies on our Website or Channels, please note that you may not be able to access the full range of functions that our Website or Channels offer.

Our advertising partners may also transmit cookies to your browser or device, when you click on advertisements that appear on the Services. Further, if you click on a link to a third-party website or service, a third party may also transmit cookies to you. For the avoidance of doubt, this Privacy Policy does not cover the use of cookies by any third parties, and we are not responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honour ‘Do Not Track’ requests that you have set using your browser or device.

If you do not consent to our use of cookies, you should adjust your browser settings accordingly or not use any of the Services.

Contact Information

You may contact us through the contact information below. If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data, or otherwise need to contact us, you may do so at: info@royim.com.

Last Revised: May 2020

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