Privacy Policy

Gargle Inc.
Privacy Notice 

Last updated: January 1, 2026

At Gargle Inc. (“we” and “us”), we are strongly committed to transparency, and we want you (“you” or “your”) to understand how we collect, use, disclose and protect personal information, as well as how you can manage the information we collect from you.

This Privacy Notice applies to our Website and Content under our Terms of Use, available at https://www.gargle.com/terms-conditions (as the terms “Website” and “Content” are defined in those Terms of Use) and all associated software and services including dental marketing services (together with the Website and the Content, the “Services”). 

If you do not agree to the terms of this Privacy Notice, if you do not understand this Privacy Notice, or if you have questions about this Privacy Notice, please contact us before using, or continuing to use, any of the Services.

We may update this Privacy Notice from time to time. Any changes will be posted on the Website, and the date noted above will be revised accordingly. We encourage you to review this Privacy Notice periodically to stay informed about how we are protecting your information.

• PERSONAL INFORMATION 

When we use the term, “personal information”, we mean information that can be used to identify an individual (like you), either alone or by combining it with other information. “Personal information” does not include information that is used to contact an individual (like you) in connection with that individual’s business or employment, such as the name, title, business address, e-mail address, or telephone number of a business or professional person or an employee of an organization; personal information also does not include information that cannot be attributed to an identifiable individual (collectively, “non-personal information”).

We will only collect, use, and disclose the personal information that we need in order to provide you and/or your dental clinic, as applicable, with the Services.

• CONSENT

We will obtain your express consent prior to or when collecting, using, or disclosing your personal information for any purpose not described in this Privacy Notice, or for a purpose that was not identified to you nor reasonably expected at the time of collection, unless we are required or permitted by law not to obtain your consent.

An exception to this is if we collect your personal information from a dental clinic, including from its Practice Management Software (PMS), in which case, we install software on the dental clinic’s server(s), and the dental clinic is required to obtain the necessary consents with respect to any personal information we process in relation to the Services, in accordance with applicable privacy law.

Additionally, we may rely on your implied consent in certain circumstances, after taking into account factors such as the sensitivity of the personal information and your reasonable expectations. We will limit the collection, use, and disclosure of your personal information to only that which is necessary for the purposes identified, unless you have otherwise consented, or when such collection, use, and/or disclosure is permitted or required by law.

You can always refuse to provide your personal information, except that it may prevent you from using the Services or receiving responses to your inquiries or other information of interest. 

• TYPES OF PERSONAL INFORMATION WE COLLECT

We may collect various types of personal information from you and/or your dental clinic, depending upon how you and/or your dental clinic interact with us or use or interact with the Services. This personal information may include your:

• Contact/Location Information. Name, email address, postal address, phone number(s), and other contact information.
• Purchase/Billing Information. Credit card information, account number, record of purchases, other information as requested to facilitate or complete delivery or to make available and provide ongoing support or other Services related to those being purchased.
• Account Information. If you create an account, we may store and use your name, email address, postal code and other personal information you may provide with your account. You can modify some of the personal information associated with your account. If you believe that someone has created an unauthorized account, you can request its removal.
• Device Information. IP address, operating system and platform, browser type and version, browser plug-in types and versions, device type, device identifiers, and other information about how you use Services.
• Metadata. We collect and use various metadata derived from your use of the Services. For example, if you upload a document to the Website, we will record the time that upload occurred.
• Inferences. Inferences drawn from or created based on any of the information identified in this list.
• Services / Treatment Information. Data related to the services and treatment plans that you receive from the dental clinic.

We strive to uphold data minimization principles and only seek to collect personal information from you and/or your dental clinic for the purposes described in this Privacy Notice.

When we combine non-personal information with personal information, we treat the combined information as personal information. You can always refuse to provide your personal information, but please note that some personal information is necessary to provide the Services.

• HOW WE COLLECT PERSONAL INFORMATION 

We need to collect personal information from you and/or your dental clinic in order to provide you and/or your dental clinic with the Services, as well as to improve your experience and/or your dental clinic’s experience using the Services. Your dental clinic may provide us with personal information in several ways, including, for example when you and/or your dental clinic:

• use the Services, including providing us with access to the dental clinic’s Practice Management Software (PMS);
• create an account or profile with us;
• correspond with us, including through surveys;
• sign up to receive our newsletter or promotional information;
• ask for customer service, support or other assistance; or
• interact with us in any other way, online or offline, including through the Services.

In some cases, we may collect, use or disclose your personal information pursuant to an agreement with a third-party organization. In those cases, the terms of that agreement may govern how we collect, use or disclose your personal information. If you believe a third-party organization has asked us to collect, use or disclose your personal information on their behalf, please consult with them as they will be responsible for how we do so.

Web Beacons & Cookies

Like many websites and apps, we use web beacons and/or “cookies”, which are small text or image files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions, including how you use a website. We use this information to analyze marketing data and performance. For example, we may track click streams, measure, monitor, and report on website traffic and page views, or other similar marketing related data and analytics. Out of these, the files that are categorized as “necessary” are stored on your browser as they are essential for the working of basic functionalities of the website. Disabling these necessary files may result in a website or app not functioning properly.

You can set your browser or device to refuse beacons or cookies or to indicate when they are being sent. If you delete them or if you opt-out, or if you set your browser or device to decline these technologies, some Services may not function properly. The Services do not currently change the way they operate upon detection of a Do Not Track or similar signal. 

Online Analytics

We also use various types of online analytics including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our Website. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the website, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.

Social Media Integration

The Services may contain links to and from, or otherwise integrate with, social media platforms. You may choose to connect to us through a social media platform, such as Facebook, YouTube, LinkedIn or X (formerly Twitter), and when you do, we may collect additional information from you, including the information listed in the Types of Personal Information We Collect section above. Please be advised that social media platforms may also collect information from you. When you click on a social plug-in, such as X’s “Tweet” button, that particular social network’s plugin will be activated, and your browser will directly connect to that provider’s servers. We encourage you to review the social media platforms’ usage and disclosure policies and practices, including the data security practices, before using them.

Surveys

From time to time, and subject to your consent where required by applicable local law, we may provide you with the opportunity to participate in surveys, some of which might be sponsored or conducted by a third party. Participation in these surveys is completely voluntary. If you choose to participate, we will request certain personal information from you. If there is a third-party sponsor involved in the survey, we may provide certain personal information to the third-party sponsor. Please make sure to review the sponsor’s privacy notice and be aware that any surveys offered by us may be governed by specific rules, terms and conditions that are separate from and in addition to this Privacy Notice. By participating in any such surveys, you will become subject to those rules, including but not limited to receiving emails containing survey communications.

• HOW WE USE PERSONAL INFORMATION

Unless otherwise consented by you in advance, or as may be permitted or required by law, we will only use and disclose your personal information to fulfill the purposes for which it was collected (and in accordance with this Privacy Notice).

We may use personal information to do any or all of the following, as applicable:

• provide and develop the Services and new products and services and build products and features;
• facilitate your interactions and transactions with us, such as requests for support or additional Services;
• administer our relationship with you, including to manage your account with us, for billing, verification and authentication purposes and to contact you in relation to same, to maintain our customer/visitor lists, and allow you to access certain areas of the Website;
• respond to your requests, communications, suggestions, comments, and inquiries, including your feedback about the Services;
• provide you with data and analysis about the performance of your marketing campaigns, potential marketing opportunities, opportunities to maximize your patient spending, retention and acquisition, your employee training, and for other purposes relevant to the Services where we see an opportunity to maximize our relationship with you;
• analyze, measure and improve our performance, maintenance, and operations (such as our customer care interactions with you);
• conduct surveys and research to better understand the preferences of our customers;
• provide you with, and improve, relevant marketing offers or information from us or third parties;
• provide you with promotional items;
• develop and manage relationships with our business partners;
• ensure our systems are secure;
• respond to legally binding demands from law enforcement, regulatory authorities or other third
  parties;
• defend, protect, or enforce our rights or applicable terms of use;
• to prevent fraud or the recurrence of fraud;
• assist in the event of an emergency; and
• comply with applicable law.

We may also combine your personal information collected through various sources, including personal information collected through the Services, and develop a profile that will be used for the purposes above.

Typically, we retain personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law. In many situations, we must retain some or all of your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for other legitimate business purposes, such as for auditing, accounting, or tax purposes. We may retain non-personal information for as long as we have a business need to do so.

In many cases, we de-identify your personal information as soon as we collect it. In these cases, that de-identified information is non-personal information. We may use non-personal information for any legitimate business purpose.

• HOW WE DISCLOSE PERSONAL INFORMATION

Except as set forth in this Privacy Notice, or as required or permitted by law, we do not disclose your personal information to any parties other than to our service providers, partners, and our affiliates, and their respective directors, officers, employees, agents, consultants, advisors or other representatives that have a need to use your personal information to provide or improve the Services, to legal or regulatory authorities, or for other purposes for which you have provided your consent. In no event will we sell or rent your personal information.

We may disclose your personal information:

• to our third party service providers or partners to help us with the uses described in the How We Use Personal Information section above and as further detailed below;
• to comply with your directions or any additional consent you have provided us;
• to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of our Services or anyone else (including the rights or property of anyone else) that could be harmed by such activities, as well to manage, defend or settle any actual or potential loss, and as otherwise allowed or required by law, such as to respond to court orders and subpoenas, prevent fraud, and investigate suspicious activity;
• to other parties where we are under a duty to disclose your personal information in order to comply with any applicable legal obligation including a regulatory process, or an order of a government institution, investigative body, regulatory body or judicial authority of competent jurisdiction; and
• in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same. 

We may share your personal information with our service providers or partners as follows:

The personal information we collect, use or disclose is stored or processed on servers located in the United States. 

We disclose non-personal information to third parties as reasonably necessary to meet our business needs. We do not disclose your personal information to third parties for their own direct marketing purposes without your consent. 

1. HOW WE PROTECT PERSONAL INFORMATION

We are concerned about ensuring the security of your personal information, and we have taken commercially reasonable measures to ensure its security and confidentiality. We take technical, contractual, administrative, and physical security steps designed to protect personal information that you provide to us. We have implemented procedures designed to limit the dissemination of your personal information to only such designated persons as are reasonably necessary to carry out the stated purposes we and/or your dental clinic have communicated to you. We will keep your personal information for as long as it remains necessary for the purposes described in this Privacy Notice or as otherwise necessary to comply with legal or regulatory requirements, which may extend beyond the termination of our relationship with you and/or your dental clinic. We may retain non-personal information for as long as we have a business need to do so.

An organization must protect personal information that is in its custody or under its control by making reasonable security arrangements against such risks as unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. All of our service providers, partners, and contractors are obligated to employ appropriate data security measures with respect to your personal information and to collect/use/disclose it only within the scope required for the provision of the Services.  However, we are not responsible for the actions and privacy policies of these third parties and their systems, programs, websites, solutions and/or applications.

We try our best to safeguard personal information once we receive it, but please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. If you suspect an unauthorized use or security breach of your personal information, please contact us as soon as possible.

• YOUR RIGHTS

You have the following rights regarding your personal information:

Right of access: You have the right to access the personal information we hold about you and to have a general account of our uses of that information. 

Right of correction: You can ask that we correct inaccurate or incomplete personal information. 

Right to withdraw consent: If you previously gave us consent to collect, use or disclose your personal information, you can withdraw that consent, subject to legal requirements. Doing so may affect your ability to access or use the Service affected by the withdrawal. You may also opt-out of marketing or promotional emails by clicking the “unsubscribe” button.

Please contact us to exercise any of these rights or if you have any questions about your rights. We may verify your identity before responding to your request. 

Updating personal information

We will make every reasonable effort to ensure your personal information is accurate, but it is important that you notify us of any changes so that we can give you the best possible service. You can update some of your personal information directly through your account on the Website, as applicable.

Email communications

You may have the opportunity to receive certain communications from us related to the Services. If you provide us with your e-mail address in order to receive communications, you can opt-out of marketing emails at any time by following the instructions at the bottom of our emails and adjusting your email preferences. Please note that certain emails may be necessary for the operation of the Services. You will continue to receive these emails, if appropriate, even if you unsubscribe from our optional communications.

• THIRD PARTY WEBSITES AND APPS

The Website and Services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Notice do not apply to information gathered through these third-party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.

• CONTACT US

If you have questions, concerns, or would like to exercise any of your rights including the right to access/correct/delete your personal information, as applicable, you can contact us in the following ways:

For your protection, we may need to verify your identity before assisting with your request, such as verifying that the information used to contact us matches the information that we have on file.

Copyright ©2026 Gargle Inc.  All rights reserved.