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KLOwen Orthodontics Global Privacy Policy 

Revised: April 1, 2026

1. Introduction

KLOwen Braces, Inc. and its affiliates ("we", "our" and "us") are committed to protecting your privacy and managing personal information responsibly. This policy is designed to comply with the Privacy Act 1988 (Cth) (Australia), the Privacy Act 2020 (New Zealand), the California Consumer Privacy Act (CCPA/CPRA), the Texas Data Privacy and Security Act (TDPSA), and the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) amongst other US and State requirements.

KLOwen acts as a service provider and data processor on behalf of licensed clinics; we do not provide direct medical care to patients.

2. What Is Personal Information?

"Personal information" is information or an opinion about an identified or reasonably identifiable individual.

  • Sensitive Information: Includes health information, genetic/biometric data, racial or ethnic origin, and religious beliefs.
  • Health Information: We collect dental scans, clinical images, X-rays, and treatment prescriptions as sensitive information.
  • Anonymity (AU/NZ): Where lawful and practicable, you may browse our public website anonymously. However, identifying information is mandatory for orthodontic device manufacturing.
  • Consequences of Withholding Data: If you or your clinic choose to withhold requested information, we will be unable to provide the products and services requested, such as manufacturing custom medical devices.
  • No Sale or Sharing: We do not sell personal information in the traditional sense. However, certain uses of cookies, analytics, or advertising technologies may be considered ‘sharing’ under applicable laws.
  • Right to Opt-Out: Any user has the formal right to opt-out of any future sale or sharing of their information.
  • Sensitive Data: We only use sensitive health data for the specific purpose of manufacturing your prescribed medical device.
  • Sources of Personal Information: We collect personal information from:
    • Licensed clinics and providers
    • Users interacting with our platform
    • Automated technologies (cookies, logs)
    • Service providers and third parties
  • Foreign Legal Access: While stored in the US, your information may be accessible to US law enforcement under local laws.
  • Overseas Safeguards: We take reasonable steps to ensure that overseas recipients provide comparable safeguards to those in your home jurisdiction, including contractual safeguards, data processing agreements, and vendor due diligence.
  • Retention: Active case data is retained for the duration of the clinic agreement plus 7 years. Manufacturing records are kept for the device lifetime plus 2 years (minimum 2 years).
  • Security: We use AES-256 encryption, Multi-factor authentication (MFA), and role-based access. All treatment plans are reviewed and approved by a human orthodontist.
  • Appeals: You have the right to appeal our decision regarding a privacy request. Requests may be submitted via email at support@klowenortho.com.
  • Patient Data Process: Please direct requests to your treating clinic first. We will support clinics in response within 30 days. You may also contact us directly to exercise your rights.
  • Name: Privacy Officer — Jay Widdig, KLOwen Braces, Inc.
  • Email: support@klowenortho.com
  • Address: 1703 N. Plano Road Suite 200 Richardson, Texas 75081
  • Phone: +1-737-265-5220

3. Anonymity and Data Requirements

4. Regional Disclosures & Notice at Collection

4.1 Notice at Collection

We collect the following categories of personal information:

Category

Examples

Business Purpose

Identifiers

Name, Clinic Address, Email, IP Address.

Provide services and manage accounts.

Commercial Info

Billing records and purchase history.

Process payments and fulfill orders.

Biometric & Health

Scans, STL files, and X-rays.

Manufacture medical devices.

Network Activity

System logs and usage data.

Maintain security and performance.

Professional Info

Resumes and work history.

Evaluate candidates for roles.

 

4.2 Supplemental Notice for International Residents

All personal information will be transferred to and stored in the United States via Microsoft Azure.

5. Disclosure and Data Transfers

We may disclose personal information to internal personnel, service providers (hosting, logistics), professional advisers (insurers, auditors), and in the event of a business acquisition or asset sale.

6. Data Retention and Security

7. Your Rights and Appeals

You have the right to access, correct, delete, or restrict use of your personal information. We will not discriminate against individuals for exercising their rights. We may verify your identity before processing requests. You may designate an authorized agent to submit requests on your behalf.

You may request details regarding the categories and specific pieces of personal information we have collected, the sources of that information, and the categories of third parties with whom it has been shared

8. Direct Marketing

We may communicate with licensed clinics via mail, phone, or email to promote our services. You can unsubscribe at any time by contacting us. We do not use patient health information for direct marketing.

9. Cookies, Tracking Technologies, and Website Use

We use cookies and similar technologies to operate our website, improve performance, and understand how users interact with our services.

These technologies may include analytics tools, functional cookies, and performance or security-related tools. They may collect information such as IP address, device and browser type, and interactions with our website.

We obtain prior express consent before deploying any non-essential cookies or tracking technologies, in accordance with applicable laws, including the California Invasion of Privacy Act (CIPA). Non-essential technologies are disabled by default and are only activated after you provide consent.

You may accept or reject non-essential cookies through our consent banner and may modify or withdraw your consent at any time through available preference settings.

We recognize and honor Global Privacy Control (GPC) signals as a valid request to opt out of the sale or sharing of personal information where applicable.

Some technologies may be provided by third-party service providers who process information on our behalf.

10. California Privacy Rights (CCPA/CPRA)

California residents have rights to know, access, delete, correct, and opt out of the sale or sharing of personal information.

We do not sell personal information in the traditional sense; however, certain data sharing may be considered 'sharing' under California law.

You may designate an authorized agent to submit requests on your behalf.

11. Additional Information for Australian Individuals

We comply with the Australian Privacy Principles (APPs), including APP 1 (transparency), APP 3 (collection), APP 6 (use and disclosure), APP 8 (cross-border disclosure), and APP 11 (security).

In the event of an eligible data breach, we will notify affected parties and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches (NDB) scheme.

12. Questions and Complaints

If you believe we have not complied with this policy, please contact us. We request your cooperation during the investigation. You may also contact the OAIC (AU) or the NZ Privacy Commissioner.

13. Contact Us

Address all privacy inquiries, including appeals and toll-free requests, to:

  • Name: Privacy Officer — Jay Widdig, KLOwen Braces, Inc.
  • Email: support@klowenortho.com
  • Address: 1703 N. Plano Road Suite 200 Richardson, Texas 75081
  • Phone: +1-737-265-5220