PRIVACY POLICY

1. Introduction

[LEGAL ENTITY NAME], doing business as Pacific Crest Dental Alliance ("PCDA," "we," "us," "our"), respects your privacy. This Privacy Policy explains what information we collect through www.pcdentalalliance.com (the "Site") and in connection with our services (the "Services"), how we use and share it, and the rights and choices you have.

This policy is incorporated into our [Terms of Service]. By using the Site, you agree to this policy.

Who this policy covers: The Site is intended for licensed dental professionals and dental practice owners. It is not directed to consumers seeking dental care, and it is not directed to children.

2. IMPORTANT — We Do Not Collect Patient Information

PCDA does not request, and you must not send us, any protected health information ("PHI"), patient records, or individually identifiable patient information.

PCDA is not a HIPAA covered entity and does not act as a business associate. Any financial or operational data you provide about your practice must be aggregated and de-identified.

If you transmit PHI to us despite this prohibition, we will delete it upon discovery and are not responsible for it. You remain solely responsible for your own compliance with HIPAA and all other patient-privacy laws.

3. Information We Collect

a. Information you give us:

Identifiers — Name, email address, telephone number, mailing address, business address.

Professional information — Dental license status, practice name, practice location, years in practice, role/title.

Commercial and financial information — Practice revenue, EBITDA, aggregated performance data, valuation inputs, transaction timeline and intentions.

Payment information — Billing name and address, and payment card data collected and processed directly by our third-party payment processor. PCDA does not store full card numbers.

Communications — Inquiry form submissions, emails, call notes, meeting notes, application materials.

b. Information collected automatically:

Internet and device activity — IP address, browser type, operating system, device identifiers, referring URL, pages viewed, time on page, clicks, session duration.

Approximate location — City or region inferred from IP address.

Cookies and similar technologies — See Section 6.

c. Information from third parties: We may receive information from our website host, payment processor, analytics and advertising providers, publicly available sources, business databases, and referral partners.

We do not collect Social Security numbers, government ID numbers, precise geolocation, biometric data, or the contents of your communications with third parties.

4. Why We Collect It (Purposes)

To respond to your inquiry and evaluate your practice for potential membership

To process the initiation fee and send receipts and confirmations

To provide Member Benefits (benchmarking materials, group purchasing information, networking)

To communicate with you about your application, membership, and any potential transaction

To conduct diligence and verify licensure, identity, and eligibility

To create aggregated, de-identified benchmarking and analytics

To operate, secure, maintain, and improve the Site

To send marketing communications about PCDA (you may opt out at any time)

To conduct advertising and measure its effectiveness

To detect fraud, screen against sanctions lists, and enforce our Terms

To comply with legal, tax, accounting, and regulatory obligations

5. How We Share Information

We share personal information with:

a. Service providers, who process it only on our instructions and for our purposes:

Website hosting and e-commerce: Squarespace

Payment processing: [Stripe / PayPal / Squarespace Payments — CONFIRM]

Email and communications: [e.g., Google Workspace, email marketing provider]

Analytics and advertising: Google Analytics, Google Ads, Meta (Facebook/Instagram), LinkedIn

Professional advisors: attorneys, accountants, and M&A advisors, including King's Ransom Group, bound by confidentiality obligations

b. Prospective transaction counterparties. If you become a member and proceed toward a group transaction, we may share practice information with prospective buyers, investors, lenders, and their advisors — subject to confidentiality agreements, and consistent with any separate definitive agreement you sign.

c. Advertising partners. Our ad pixels share online identifiers and browsing activity with Meta, LinkedIn, and Google. Under California law, this may qualify as "sharing" for cross-context behavioral advertising. See Sections 6 and 9.

d. Legal and safety. We may disclose information where required by law, subpoena, court order, or regulatory request, or to protect our rights, property, or safety, or those of others.

e. Business transfers. In connection with a merger, financing, reorganization, or sale of PCDA's assets, information may be transferred to the successor.

We do not sell your personal information for money.

6. Cookies, Analytics, and Advertising Pixels

We use cookies, pixels, tags, and similar technologies:

Strictly necessary — required for the Site and checkout to function. Cannot be disabled.

Analytics — Squarespace Analytics and Google Analytics, to understand how the Site is used.

Advertising — Meta Pixel, LinkedIn Insight Tag, and Google Ads tags, used to measure campaign performance and to show you PCDA ads on other platforms (including retargeting).

Your choices:

Cookie banner — where shown, you can accept or reject non-essential cookies.

Global Privacy Control (GPC) — we honor GPC browser signals as a valid opt-out of "sale"/"sharing" under applicable state law.

Browser settings — you can block or delete cookies, though parts of the Site may not function properly.

Platform opt-outs — Google Analytics opt-out browser add-on; ad settings within your Meta, LinkedIn, and Google accounts; industry opt-out tools at optout.aboutads.info and optout.networkadvertising.org.

7. Retention

We keep personal information only as long as needed for the purposes described above, and thereafter as required for legal, tax, accounting, audit, and dispute-resolution purposes. As a general matter: inquiry and application data is retained for up to [3] years after last contact; transaction and payment records are retained for [7] years; marketing contact data is retained until you opt out. We delete or de-identify information when it is no longer needed.

8. Security

We use commercially reasonable administrative, technical, and physical safeguards to protect personal information, including encryption in transit, access controls, and reliance on reputable, security-certified vendors for hosting and payments.

However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You transmit information to us at your own risk. Notify us immediately at [PRIVACY EMAIL] if you believe your information has been compromised.

9. Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the right to:

Know / Access — what personal information we collect, use, disclose, and share, and to receive a copy

Delete — request deletion of personal information we collected from you

Correct — request correction of inaccurate personal information

Opt out of Sale/Sharing — direct us not to sell or share your personal information for cross-context behavioral advertising

Limit use of sensitive personal information — though we do not use sensitive personal information for purposes requiring this right

Non-discrimination — we will not deny service, charge different prices, or provide a different quality of service because you exercised a right

Sale/Sharing disclosure: We do not sell personal information for monetary consideration. We do share identifiers and internet activity with advertising partners for cross-context behavioral advertising, which qualifies as "sharing" under the CPRA.

To exercise your rights: Email [PRIVACY EMAIL], call (818) 601-2253, or use the "Your Privacy Choices" link in our footer. We will verify your identity before responding and will respond within 45 days (extendable by another 45 with notice). You may use an authorized agent with written permission.

10. Other U.S. State Privacy Rights

If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Minnesota, Maryland, or another state with a comprehensive privacy law, you may have rights to access, correct, delete, and obtain a portable copy of your personal data, and to opt out of targeted advertising, sale, and certain profiling.

Appeals: If we decline your request, you may appeal by emailing [PRIVACY EMAIL] with the subject line "Privacy Appeal." We will respond within the time period required by your state's law. If your appeal is denied, you may contact your state Attorney General.

To exercise these rights, use the same contact methods in Section 9.

11. Nevada

Nevada residents may direct us not to sell certain covered information. We do not engage in such sales, but you may submit a request to [PRIVACY EMAIL].

12. European Economic Area and United Kingdom (GDPR / UK GDPR)

Our Services are directed to the United States and we do not target the EEA or UK. If you nonetheless access the Site from the EEA or UK, the following applies.

a. Controller. [LEGAL ENTITY NAME], [MAILING ADDRESS], [PRIVACY EMAIL].

b. Legal bases for processing:

Responding to inquiries and evaluating applications — Performance of a contract, or steps taken prior to entering a contract (Art. 6(1)(b)).

Processing payments — Performance of a contract (Art. 6(1)(b)).

Site security, fraud prevention, improving the Services, and aggregated analytics — Our legitimate interests (Art. 6(1)(f)).

Marketing emails, advertising cookies, and pixels — Your consent (Art. 6(1)(a)).

Tax, accounting, sanctions screening, and legal compliance — Compliance with a legal obligation (Art. 6(1)(c)).

c. Your rights. Access, rectification, erasure, restriction of processing, data portability, objection to processing (including to direct marketing and to processing based on legitimate interests), and withdrawal of consent at any time (without affecting the lawfulness of prior processing). You may lodge a complaint with your national supervisory authority or, in the UK, the Information Commissioner's Office (ico.org.uk).

d. International transfers. Information is processed in the United States, which has not received an EU adequacy decision. Where we transfer personal data from the EEA or UK, we rely on the EU Standard Contractual Clauses and the UK International Data Transfer Addendum, together with supplementary measures as appropriate.

e. No automated decision-making. We do not make decisions producing legal or similarly significant effects based solely on automated processing.

13. Marketing Communications and Text Messages

You may opt out of marketing emails using the unsubscribe link in any message, or by emailing [PRIVACY EMAIL]. You may opt out of text messages by replying STOP. We may still send you transactional or administrative messages (receipts, application status, legal notices) regardless of marketing preferences.

Consent to receive calls or texts is not a condition of any purchase.

14. Third-Party Links

The Site may link to third-party sites and services that we do not control. This policy does not apply to them. Review their privacy policies before providing information.

15. Children

The Site is not directed to anyone under 18, and we do not knowingly collect personal information from children. If we learn we have collected such information, we will delete it. Contact [PRIVACY EMAIL] if you believe a child has provided us information.

16. Changes to This Policy

We may update this policy at any time. We will post the revised version with a new "Last Updated" date and, where required by law, provide additional notice or obtain your consent. Your continued use of the Site after the effective date constitutes acceptance.

17. Contact Us

Pacific Crest Dental Alliance

433 North Camden Dr., Beverly Hills, CA 90210

General: drfrey@pcdentalalliance.com

Phone: (818) 601-2253

To exercise a privacy right, please write "Privacy Request" in the subject line.