Align Global Websites and Apps Privacy Notice

• 1. Scope of this Notice
• 2. Data Categories, Sources of Personal Information, and Business Purposes
• 3. Legal Basis
• 4. Who We Share Your Personal Information With
• 5. Cookies and Similar Tracking Technologies
• 6. Transfer of Personal Information Abroad
• 7. Retaining and Deleting Your Personal Information
• 8. Your Rights and How to Exercise Them
• 9. Patient Data
• 10. Children's Privacy
• 11. Links to Other Websites
• 12. Social Media
• 13. Marketing, Mobile Communications, and Opt-Out Rights
• 14. Updates
• 15. Contact Us

1. Scope of this Notice

This notice applies to websites and applications ("apps") owned or operated by Align Technology Inc. and its Group Members ("Align") that link to this notice.

Please note, if you are a customer of Align, our Customer Privacy Notice will apply to you and if you are an applicant, our Global Applicant Privacy Notice will apply to you.

2. Data Categories, Sources of Personal Information, and Business Purposes

Generally, you do not need to share Personal information with Align to visit our websites or apps, except limited data that may be captured, for the duration of your visit, via essential cookies. However, some functionalities will require that you provide us with your Personal information. In our interactions with you, we collect some Personal information from or about you, such as identifiers (e.g., your name, contact details, mobile phone number), or other personal information categories, for purposes such as to send you promotional or transactional communications, process your orders, and other purposes as described below.

Data Categories and Purposes

3. Legal Basis

Certain jurisdictions require us to identify the legal basis that allows us to process your personal information. These legal bases include our legitimate interests, your consent, the performance of a contract, a legal obligation and procedural rights, or any other legal basis under applicable law.

Where required by applicable law, we will determine the legal basis for processing your personal information, as defined in our Binding Corporate Rules, for each purpose of processing, which can include:

• Legitimate interests: It can be sometimes necessary for us to do certain activities, in our own interest or the interest of a third party. In each case, we balance our legitimate interest with your rights and interests. Our legitimate interest can include (non-exhaustive):
  • Gaining insights on your use of our websites, apps, products, or services;
  • Developing and improving our websites, apps, products, and service offerings;
  • Enabling us to enhance, customize, or modify our communications;
  • Informing you about products and services we believe are relevant to you;
  • If you have made a transaction with us and have not opted-out from such communications;
  • Informing our marketing strategy;
  • Improving our data security and keeping our records updated.
• Your consent: If we process your personal information in reliance on your consent (such as when opting in to SMS notifications or email updates), you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal.
• Contract: Where processing your personal data is necessary for performing a contract you have with us (such as our terms and conditions), or where you have asked us to take specific steps before entering into that contract.
• Compliance with a legal or regulatory obligation: To comply with our legal obligations under applicable law (for example, our transparency obligations under the US or French Sunshine Act, our complaints handling and investigation obligations under applicable medical device regulations, court orders, etc.).
• Judicial or administrative procedures: Exercise of rights in judicial or administrative procedures.
• Other legal bases: Other legal bases as permitted under local law.

4. Who We Share Your Personal Information With

We may share your personal information for legitimate reasons, such as providing services, with Group Members, online advertising partners, legal bodies, and other selected third parties.

• Group Members: we may share your personal information with companies of Align for the purposes, and based on the legal bases, above.
• Online advertiser partners: we may work with social media platforms and digital advertising platforms to show you advertisements for our products and services on other websites and social media platforms. For instance, if you show an interest in, or buy, a product, we may advertise products we think may be of interest to you which you may see on other websites and on your social media feeds. To do this, we share information with our social media and digital advertising partners about you, which may include your purchase, age, gender and interests.
• Law enforcement, regulators, government agencies, courts, or other third parties, if legally required or allowed.
• In the event of an actual or potential merger, acquisition, debt financing, sale of company assets, insolvency, bankruptcy, receivership, or similar transaction, we may share your personal information (such as with third parties, their agents, or advisors) strictly to the extent necessary to facilitate the transaction and as permitted under applicable law.
• We may also share personal information with third parties not listed above if given your consent.

5. Cookies and Similar Tracking Technologies

We may use Cookies and similar technologies on our websites to allow our websites to function, as well as to enhance your experience and better allow us to deliver relevant marketing content to you.

Our websites and applications may use cookies or similar technologies such as, but not limited to, web beacons, pixel tags, and Flash Objects ("Cookies"). Some of these Cookies are essential for our websites and apps to function. Other Cookies provide us with analytical data about your visit, or help us understand users' interactions with systems, or allow us to enhance functionality or to tailor our advertising messaging to you. You can find detailed information about the types of Cookies we use on the website you are accessing. Where applicable, you can accept or reject certain Cookies.

6. Transfer of Personal Information Abroad

Align operates globally and protects your information when we transfer it to countries other than the country in which you are a resident. Your personal information may be transferred internationally to achieve our business purposes mentioned above.

Where Align shares personal information with Group Members or other third parties, including to countries other than your country/region of residence, we may rely on adequacy decisions, standard contractual clauses, Align's Binding Corporate Rules, or other mechanisms recognized by applicable laws.

7. Retaining and Deleting Your Personal Information

Align will retain your personal information for the ongoing and legitimate need to achieve the purposes set out in this notice.

In certain circumstances, we will need to keep some or all of your personal information after our contractual relationship has ended to comply with required retention durations and surviving regulatory obligations applicable in your country and/or state.

When we have no ongoing legitimate need or legal justification to process your personal information, we will either delete or anonymize it or securely isolate it from any further processing until deletion is possible.

8. Your Rights and How to Exercise Them

Many countries will provide their residents or citizens with specific rights in relation to their personal information. We comply with applicable law in respect to such rights. To make such request, please contact us at the contact detailed below or submit a request here.

You may have some or all of the following rights, as provided under applicable law:

• To request access to, copies of, correction of, updating of, or deletion of your personal information.
• To object to the processing of your personal information, ask us to cease or restrict processing of your personal information.
• To request data portability.
• To complain to your local data protection authority.

Align, by law, will not discriminate in response to any privacy requests you make. To exercise your data privacy rights, please submit a request here.

9. Patient Data

If you are a patient, in most cases, Align acts at the direction of your treating clinician, including in circumstances regarding your personal information. This means that the personal information collected for treatment planning, Virtual Care, or the MyInvisalign App is done by Align as a processor and your doctor is the controller of your personal information.

In limited cases, Align may act as a controller in its own right with regards to your patient data (such as for internal R&D or medical device compliance). In these cases, this notice applies to you.

10. Children's Privacy

At Align, we do not intend to collect any personal information from children under the age of thirteen (13) or above this age depending on your jurisdiction, unless the personal information is collected from a parent or guardian or with a parent or guardian's consent. If you are a parent or guardian and believe your child under the required age has provided us personal information, please contact us at contact@aligntach.com.

11. Links to Other Websites

We may provide links to other websites via our website, however please note that we are not responsible for the privacy practices or content of such websites. Therefore, we invite you to review the content and privacy practices of these websites before sharing any information with them.

12. Social Media

If you are a user of Meta, X, or other social media websites with public account settings and you hashtag using one of our public campaigns, or using one of our product names, such as #Invisalign or #iTero, your comments related to our products may be liked, reposted, or otherwise used in marketing materials by Align where permitted.

13. Marketing, Mobile Communications, and Opt-Out Rights

We may send you promotional information about us from time to time if you have given us your consent (where required) or if you have not opted out. You can always opt-out of such electronic communication by contacting us or by using the unsubscribe option.

SMS/MMS Text Messaging Program Terms

When you consent or opt-in to receive SMS/MMS messages from Align (e.g., via webforms, account updates, or appointment scheduling):

• Usage: Text communications are sent to provide account notifications, appointment updates, service alerts, or promotional offers.
• Opt-Out Instructions: You can opt out of SMS messaging at any time by replying STOP to any message sent from us. After sending STOP, you will receive one confirmation text confirming that you have been unsubscribed.
• Help Instructions: Reply HELP to any text message for assistance or contact our support team at contact@aligntach.com.
• Rates and Frequency: Message frequency varies based on user interactions. Standard message and data rates may apply according to your wireless service provider.
• Carriers: Mobile carriers are not liable for delayed or undelivered messages.
• Data Exclusion Notice: Text messaging originator opt-in data and phone numbers will strictly not be shared with or sold to third parties or affiliates for marketing or promotional purposes.

14. Updates

We may update this notice from time to time. When we do, we will list the last updated date at the beginning of the statement. Notice of material updates and/or modifications will be provided to you directly if required by law.

15. Contact Us

If you believe we have made a mistake or inappropriately used your personal information, we want to know about it so we can make it right. Feel free to contact us using any of the below methods.

Privacy Office Email: contact@aligntach.com
Support Phone: 1-888-822-5446 or visit our contact page: https://www.aligntech.com/contact_us

APPENDIX

MIA Appendix Supplemental Terms

For MyInvisalign App ("MIA APP") users, the following appendix applies supplementarily to the above privacy notice.

DEVICE PERMISSIONS WE REQUEST

You need to enable permissions to access products, features, and services. To provide relevant products and services, we need you to authorize permissions for the first time to collect relevant information.

1. Camera Permission: Used for the photo-taking function in the photo library and User Profile modification.
2. Push Notification Permission: Used to send notifications about updates, status changes, and notifications.
3. Storage Permission: Used for data caching services to reduce data consumption.

Country Appendix

Brazil

Se você tiver alguma dúvida sobre esta Política de Privacidade, entre em contato com:

ALIGN TECHNOLOGY DO BRASIL LTDA.
Rua Santa Justina, nº 660, Conjuntos 71 a 74 – Vila Olímpia – CEP: 04542-042 São Paulo/SP – Brasil
contact@aligntach.com

United States

Certain states in the United States have passed legislation granting consumers legal rights regarding personal information, like California, Colorado, Utah, Virginia, Oregon, Montana, Texas, Tennessee, Indiana, Iowa, Delaware and Connecticut.