Asesso Privacy Notice

Last Updated: August 28, 2025

This Privacy Notice ("Notice") applies to the processing of personal information by Asesso Health, Inc. and our affiliates ("Asesso," "we," "us," or"our"), including on our mobile application, our website available at www.asessohealth.com and our other online or offline offerings which link to, or are otherwise subject to, this Privacy Notice (collectively, the"Services").

Special Note to Asesso Patients and Potential Patients:When you visit our website or inquire about or enroll in our Services, we may collect information that identifies you and relates to your past, present, or future physical or mental health, treatment and services received, and payment for such treatment and services. This information may be considered protected health information ("PHI") protected by the Health Insurance Portability and Accountability Act of 1996 (as amended) and the Health Information Technology for Economic and Clinical Health Act. If you receive care from us, this Notice describes how we collect, use, and share your non-PHI personal information and is separate from and in addition to our Notice of Privacy Practices describing how we use and disclose your PHI.

Disclosure Regarding the Supplemental Consumer Health Data Privacy Notice.For information on our processing of "consumer health data" that is subject to the Washington My Health My Data Act or Nevada Senate Bill 370, please see Annex A – Supplemental Consumer Health Data Privacy Notice.

• 1. UPDATES TO THIS PRIVACY NOTICE
• 2. PERSONAL INFORMATION WE COLLECT
• 3. HOW WE USE PERSONAL INFORMATION
• 4. HOW WE DISCLOSE PERSONAL INFORMATION
• 5. YOUR PRIVACY CHOICES AND RIGHTS
• 6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
• 7. CHILDREN'S PERSONAL INFORMATION
• 8. THIRD-PARTY WEBSITES/APPLICATIONS
• 9. CONTACT US

Annex A – Supplemental Consumer Health Data Privacy Notice

1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we'll let you know by posting the updated Privacy Notice on our website, and/or we may also send other communications.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to

• Account Information. We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to, your name, date of birth, email address, phone number, social security number, payment information, and other information you store with your account.
• Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services for non-Asesso patients, but we may receive information associated with your payment card information (e.g., your billing details).
• Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or our web chat tool.
• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered "public."
• Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and CV.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the Services.

• Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).
• Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.
• Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies ("Technologies") to automatically collect personal information through your use of the Services.
• Cookies. Cookies are small text files stored in device browsers.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

See "Your Privacy Choices and Rights" below to understand your choices regarding these Technologies.

• Biometric Information. If, as an Asesso patient, you consent to our collection of biometric information or if our collection of biometric information is otherwise permitted, we may collect "Face Data" (including photos and depth measurements of your face and teeth captured by your device's camera and technical artifacts needed to build a 3D dental/facial model) and/or your teeth grinding/movement patterns to assess the appropriate Asesso device for your needs. Your biometric information may be shared with your healthcare providers (including your dental care team) and our service providers (e.g., dental labs and appliance manufacturers). Your biometric information will be stored pursuant to our federal and state medical record retention obligations.

  Please note: We use Face Data only to create, validate, and service your device and related features; we do not sell it or use it for advertising or identity recognition; we disclose it only to service providers under contract; and we retain raw scan files only as needed to generate your model (then delete them) and keep the resulting model for your account lifecycle or as required by law. For Face Data captured on iOS devices, the app may use Apple's TrueDepth/ARKit APIs to capture depth measurements necessary for scanning. We do not access or store Apple Face ID enrollment templates. Face Data is collected only when you initiate and consent of a scan; ordinary app use does not collect Face Data.

C. Personal Information Collected from Third Parties

We may collect personal information about you from third parties. For example, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, users of the Services may upload or otherwise provide personal information about others.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the Services

We use personal information to fulfill our contract with you and provide the Services, such as:

• Managing your information;
• Providing access to certain areas, functionalities, and features of the Services;
• Answering requests for support;
• Communicating with you;
• Sharing personal information with third parties as needed to provide the Services;
• Processing your financial information and other payment methods for products and Services purchased;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for events.

Our Services are enabled by machine-learning tools fundamental to our ability to provide real-time engagement, inform treatment approaches, and track progress. These machine-learning tools process natural language communications to support user experience and outcomes.

B. Administrative Purposes

We use personal information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Carrying out analytics;
• Measuring interest and engagement in the Services;
• Improving, upgrading, or enhancing the Services;
• Developing new products and services;
• Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
• Debugging to identify and repair errors with the Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

C. Marketing

We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.

California Shine the Light: If you are a California resident, you may annually submit a request to us to find out whether we have shared your personal information with third parties for the third parties' direct marketing purposes. If you would like to submit such a request, please "Contact Us."

If you have any questions about our marketing practices, you may contact us at any time as set forth in "Contact Us" below.

D. With Your Consent or Direction

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.

E. Automated Decision Making

We may engage in automated decision making, including profiling. Asesso's processing of your personal information will not result in a decision based solely on automated processing that has a legal or other similarly significant effect on you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making.

If you have questions about our automated decision making, you may contact us as set forth in "Contact Us" below.

4. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide the Services

We may disclose any of the personal information we collect to the categories of third parties described below.

• Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.
• Other Users You Share or Interact With. The Services may allow Asesso users to share personal information or interact with other users of the Services.
• Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a"Third-Party Service").

  Any personal information shared with a Third-Party Service will be subject to the Third- Party Service's privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

  Once your personal information is shared with our business partner, it will also be subject to our business partner's privacy policy. We are not responsible for the processing of personal information by our business partners.

• Affiliates. We may share your personal information with our corporate affiliates.
• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as "interest-based advertising", "personalized advertising", or "targeted advertising."

Some of the advertising Technologies we may use include:

• Meta Connect. For more information about Meta's use of your personal information, please visit Meta's Data Policy. To learn more about how to opt out of Meta's use of your information, please click here while logged in to your Meta account.
• Google. For more information about Google's use of your personal information, please visit Google's Data Policy. To opt out of Google's use of your information, please click here.
• Instagram. For more information about Instagram's use of your personal information, please visit Instagram's Data Policy. To opt out of Instagram's use of your information, please click here while logged in to your Instagram account
• TikTok. For more information about TikTok's use of your personal information, please visit TikTok's Data Policy. To opt out of TikTok's use of your information, please click here.
• X (formerly known as Twitter). For more information about X's use of your personal information, please visit X's Privacy Policy. To opt out of X's use of your information, please click here while logged in to your X account.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).
• Text Messages. If you receive an unwanted promotional text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in "Contact Us" below.
• Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device. To request deletion of your account, please use the standard deletion functionality available via the Services or contact us using the information set forth in "Contact Us" below.
• "Do Not Track." Do Not Track ("DNT" ) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.

  Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt- out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others.

  The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.

  Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Confirm Whether We Are Processing Your Personal Information;
• Request Access to or Portability of Your Personal Information;
• Request Correction of Your Personal Information;
• Request Deletion of Your Personal Information;
• Request Restriction of or Object to our Processing of Your Personal Information;
• Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for "targeted advertising" (as "targeted advertising" is defined by applicable privacy laws), if we "sell" your personal information (as "sell" is defined by applicable privacy laws), or if we engage in "profiling" in furtherance of certain "decisions that produce legal or similarly significant effects" concerning you (as such terms are defined by applicable privacy laws); and
• Withdraw Your Consent to our Processing of Your Personal Information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in "Contact Us" below. We will process such requests in accordance with applicable laws.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in "Contact Us" below and ask us for additional instructions.

To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

7. CHILDREN'S PERSONAL INFORMATION

The Services are not directed to children under 16 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in "Contact Us" below.

8. THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

9. CONTACT US

Asesso is the controller of the personal information we process under this Privacy Notice.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at: support@asessohealth.com.

ANNEX A – SUPPLEMENTAL U.S. PRIVACY NOTICE

This Supplemental U.S. Privacy Notice supplements our Privacy Notice and only applies to our processing of Personal Information from U.S. consumers residing in a state with a comprehensive privacy law.

NOTICE AT COLLECTION

At or before the time of collection, U.S. consumers residing in a state with a comprehensive privacy law have a right to receive notice of our privacy practices. Such consumers can find this information below.

• Personal Information Collected. See the section of this Supplemental U.S. Privacy Notice titled "Overview of Personal Information Collected, Disclosed, Sold and/or Shared" for a list of Personal Information which may be collected.
• Uses of Personal Information.See the section of this Supplemental U.S. Privacy Notice titled "Uses of Personal Information" for a list of the purposes for which we use Personal Information.
• Is Personal Information "Sold" or "Shared" for "Cross-Context Behavioral Advertising"? See the section of this Supplemental U.S. Privacy Notice titled "Overview of Personal Information Collected, Disclosed, Sold and/or Shared" for more details. See the section of this Supplemental U.S. Privacy Notice titled "'Sales' of Personal Information and/or 'Sharing' for 'Cross-Context Behavioral Advertising" for instructions on how to opt-out of these activities.
• For How Long is Personal Information Retained? To determine the appropriate retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, certain risk factors, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means.
• Additional Information. For more information on our privacy practices, please review this Supplemental U.S. Privacy Notice and our Privacy Notice.Importantly, the section of our Privacy Notice titled "Your Privacy Rights" includes important details about how you can exercise some of the rights which you have under the CCPA.

CATEGORIES OF SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED

We collect Personal Information you provide to us, collected automatically when you use the Services, and from third-party sources.

OVERVIEW OF PERSONAL INFORMATION COLLECTED, DISCLOSED, SOLD, AND/OR SHARED

U.S. consumers residing in a state with a comprehensive privacy law are provided with the right to know what categories of Personal Information Asesso has collected about them, whether Asesso disclosed that Personal Information for a business purpose (e.g., to a service provider), whether Asesso "sold" that Personal Information, and whether Asesso "shared" that Personal Information for "cross-context behavioral advertising" in the preceding twelve months. U.S. consumers residing in a state with a comprehensive privacy law may find this information below:

USES OF PERSONAL INFORMATION

We may use and disclose the Personal Information that we collect for the following business and commercial purposes:

• Providing the Services as further described in our Privacy Notice;
• Processing for administrative purposes as further described in our Privacy Notice;
• Processing for marketing purposes as further described in our Privacy Notice;
• Processing with your consent or direction as further described in our Privacy Notice;
• Processing to carry out automated decision making as further described in our Privacy Notice;
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Helping to ensure security and integrity to the extent the use of Personal Information is reasonably necessary and proportionate for these purposes;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with Asesso;
• Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar Services;
• Providing advertising and marketing services;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or product owned, manufactured, manufactured for, or controlled by Asesso, and to improve, upgrade, or enhance the service or product that is owned, manufactured, manufactured for, or controlled by Asesso.

"SALES" OF PERSONAL INFORMATION AND/OR "SHARING" FOR "CROSS-CONTEXT BEHAVIORAL ADVERTISING"

We do not "sell" personal information as defined under state consumer privacy laws. Our Services use advertising and analytics tools provided by third parties that may constitute a "sharing" of personal information or "targeted advertising" in certain states. Once you enroll in or become a user of our Services, we do not engage in any sharing or targeted advertising as defined by these certain state laws. Under these certain state laws, we may "share" the following personal information categories to data analytics providers, advertising technology vendors, and social media platforms as described in this Notice: identifiers, internet or other electronic network information, commercial information, and inferences derived from these categories. To opt out of such sharing, please email us at support@asessohealth.com.

DISCLOSURE REGARDING INDIVIDUALS UNDER THE AGE OF 16

We do not have actual knowledge of any "sale" of Personal Information or "sharing" of Personal Information of minors under 16 years of age for "cross-context behavioral advertising."

DISCLOSURE REGARDING SENSITIVE PERSONAL INFORMATION

Asesso only uses and discloses sensitive Personal Information for the following purposes:

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted Personal Information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed at Asesso and to prosecute those responsible for those actions.
• To ensure the physical safety of natural persons.
• For short-term, transient use.
• Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services.
• To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Asesso, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Asesso.
• For purposes that do not infer characteristics about individuals.

RIGHT TO LIMIT USE AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

U.S. consumers residing in a state with a comprehensive privacy law may have the right to limit certain uses and disclosures of "sensitive Personal Information" by Asesso. Such consumers may exercise these rights by following the instructions on that page or by emailing us at: support@asessohealth.com.

NON-DISCRIMINATION

U.S. consumers residing in a state with a comprehensive privacy law have the right not to receive discriminatory treatment by us for the exercise of their rights conferred under applicable comprehensive privacy law.