Last Updated: December 10, 2025

 

SCOPE OF THIS POLICY

This Platform Privacy Policy ("Policy") describes how SmartBran ("we", "us", or "our") collects, receives, uses, and shares information about you from desktop, mobile, or cloud-based software via our SmartBran Electronic Health Records (EHR), Practice Management (Billing and Scheduling), Patient Portal, or related customer support services. It also outlines the choices available to you regarding our use of your personal information and how you can access and update it.

 

This Policy does not cover information SmartBran may collect or receive through our websites, smartbran.io or any other website owned by SmartBran, or any related services or applications (our Websites). 

 

This Policy does not cover the privacy practices of third parties. SmartBran Products may include links to websites and/or applications operated and maintained by third parties. We encourage you to review the privacy policies of those third parties because we have no control over the privacy policies of websites or applications owned by those third parties, and we cannot guarantee that such third parties will adhere to the same privacy practices that we do.

 

INFORMATION WE COLLECT

The types of information we collect about you depend on how you interact with us and our services. When we use the term “Personal Information,” it means information that identifies you, describes you, relates to you, or can be associated with you.

 

Personal Information does not include publicly available information from government records, de-identified or aggregated consumer information, or information excluded from applicable laws, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA). If you are a patient using SmartBran Products, the information you provide to us through our Products may be considered protected health information (PHI) and will be protected by SmartBran as required by federal and state laws. Our processing of PHI on behalf of our healthcare provider customers is governed by our agreements with our customers, including our Business Associate Agreement as required by HIPAA. If you are a patient, your healthcare provider may also have their privacy practices and policies that govern how your provider collects, uses, and shares your information.

 

The following categories and specific types of Personal Information may be collected by us when you use our Products:

 

Basic Identifiers and Government-Issued Identifiers
When you use SmartBran Products and create an account, we collect basic identifying information about you, including your full name, email address, phone number, mailing address, account name, company name, signature, and other similar identifiers. You may also provide us with Personal Information about other individuals, such as their name, title, email address, phone number, and other identifiers, with their consent. It is your responsibility to get permission from anyone whose Personal Information you provide to us. We will only use that Personal Information to complete your request.

 

Depending on how you interact with us and what products or services you use in our Products, we may collect information related to government-issued identifiers, including your driver’s license number, or other similar government identifiers for identification verification purposes. If you are a provider using our Products, we will also collect your NPI, medical license number, or other credentials.

 

Payment Information
When you use SmartBran products, we may require that you enter your credit card or ACH information.

 

Commercial and Professional Information
When you purchase our Products or request product information, we collect information related to the products or services you purchased or requested information about. When you create an account in our Products, we collect information related to your organization, including your organization’s name, phone number, address, and specialty. We also collect your title, the number of providers in your organization, and the product and service interests of you and your organization.

 

User Content
When you communicate with us through email, chat messages, or other channels, we collect information you provide related to product reviews, testimonials, survey responses, feedback, usernames, passwords, and other content. As a patient, communications received from SmartBran may relate to administrative aspects of your care, e.g., appointment requests, reminders, prescriptions, savings, cancellations, and other notifications.

 

Internet or Other Network Activity
SmartBran may automatically receive and record information on our server logs from your browser, including your internet protocol (IP) address, your search or browsing history, and information related to your interactions with our Products, emails, texts, and advertisements. 

 

Device Information and Other Tracking Identifiers
SmartBran collects data about your device and how you and your device interact with our Products. This may include your IP address, cookies, beacons, pixel tags, browser type, device type, device identifiers, and regional and language settings.

 

Usage and Performance Information
SmartBran collects data related to the use of our Products. This data may include your interactions with our Products, error reports, and general performance data. This data helps us to diagnose problems with our Products and to improve various features and solutions for your future use.

 

Geolocation Data
SmartBran may collect information, including your IP address, that allows us to determine your general location (e.g., your city or state).

 

Audio and Visual Information
SmartBran may record your voice or likeness, such as when you attend an online product demonstration, or when we record training sessions or customer service calls for quality assurance.

 

TrueDepth API
Our app makes use of automatically collected information using the device camera and the TrueDepth API provided by Apple. This information is used to track the user's head and face so that we can detect any kind of image or video spoofing thus making LiveID scan feature more robust. None of the information collected by the TrueDepth API ever leaves the user's device nor is it persistently stored on the device.

 

Inferences
SmartBran may also use the information identified in this section to draw inferences.

HOW WE COLLECT INFORMATION

 

User-Provided Information
SmartBran obtains Personal Information when you provide it to us when you create an account, contact us, otherwise provide information to us, or sign up to receive emails, text messages, and/or postal mailings.

 

Cookies
To improve the use and functionality of our Products, certain portions of SmartBran Products use cookies to recognize your preferences and temporarily store session information on your browser. A cookie is a small text file that often includes an anonymous unique identifier, which is placed on your device’s hard drive by a webpage server. Cookies contain information that can later be read by a web server in the domain that issued the cookie. We link the information we store in cookies to Personal Information you submit while on our Products.

 

SmartBran uses both “session” cookies and “persistent” cookies. A session ID cookie will get removed automatically when you close your browser. We may use session cookies to make it easier for you to navigate our Products. A persistent cookie remains on your hard drive for an extended period. We may also set a persistent cookie to store your passwords, so you don’t have to enter them more than once if you so choose. We have cookies on our Products, but the data is only collected in the aggregate. We use third-party cookies to track non-personally identifiable information about visitors to our Products in the aggregate. If you do not want the Websites to deploy cookies in your browser, you can set your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software. You can also manually clear the cookies within your respective browser (see your browser for help). If you configure your browser to reject certain cookies, the opt-out may not function properly. If you change browsers or devices, or delete cookies, you may need to opt out again.

 

Web Beacons / GIFs

SmartBran uses software technology called clear GIFs or web beacons to help us better manage content on our Products by informing us what content is effective. These technologies are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear GIFs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. In some cases, we tie information gathered by clear GIFs to our customers’ Personal Information; an example would be tracking emails that have been opened by recipients, which allows us to measure the effectiveness of our communications and marketing campaigns.

 

Third-Party Tracking

The use of cookies by any tracking utility company is not covered by our Policy. We do not have access to or control over these cookies. A tracking utility company may use session ID cookies and/or persistent cookies.

 

We use local storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features in our Websites or to display advertising based upon your browsing activity also use HTML5 to collect and store information. Various browsers may offer their management tools for removing HTML5.

 

Behavioral Targeting / Re-Targeting

We partner with a third-party ad network to either display advertising on our Websites or to manage our advertising on other sites. Our ad network partner uses cookies and web beacons to collect information about your activities on our Websites and other websites to provide you with targeted advertising based on your interests. If you do not wish to have this information used to serve you targeted ads, you may opt out of interest-based advertising across browsers and devices that participate in the Digital Advertising Alliance or Network Advertising Initiative by visiting their websites www.aboutads.info/choices and www.networkadvertising.org, respectively. You may also opt out of interest-based advertising through the settings on your device or within a mobile app, but your opt-out preferences may apply only to the browser or device you are using when you opt out. Please note this does not opt you out of advertising. You will continue to receive generic ads.

 

Additional Sources

We may also receive information about you from third-party partners or publicly available sources, where permitted by law, such as data analytics providers, fraud prevention service providers, vendors that provide services on our behalf, marketing and advertising service providers, or publicly available sources. We may combine this information with information collected directly from you.

 

HOW WE USE INFORMATION COLLECTED

 

SmartBran uses the information we collect for the following purposes:

• Communication. If you contact us through our Products, we will use your Personal Information to communicate with you and provide customer service and support. For example, we will send service-related announcements on occasions when it is necessary to do so, including if our Products will be temporarily suspended for maintenance. We may share updates regarding our products and services or provide relevant offers from third-party partners.

• Providing Services. If you request a product demo and sign up for our Products, we may use the information you provided in your request to service and maintain your account, provide customer support, and communicate with you about our Products and services.

• Product Performance and Personalization.  We use Personal Information to save user preferences, authenticate users, debug, and improve the performance of our Products. Additionally, we use Personal Information to understand how you interact with our Products, advertisements, and communications with you, to determine which of our products or services are most popular, and to improve our Products, services, and marketing campaigns.

• Marketing and Advertising. We use Personal Information to market, promote, and advertise to you. This includes sending communications via email, text message, or postal mail to inform you about our services, Products, new product launches, and referrals, as well as displaying advertisements for our Products and services on social media and other websites.

• Analysis & Product Development. We use Personal Information to conduct research and analytics, including to improve our Products and services.

• Business Operations. For our operational purposes and the operational purposes of our service providers and integration partners.

• Employment Matters. When you inquire or apply for a job at SmartBran, we use the information to make decisions about recruiting and in anticipation of a contract of employment. For more information about how we collect and use applicant data, please see our Privacy Notice Regarding the Collection of Personal Information to California Job Applicants.

• Legal & Security. We may provide access to your Personal Information to respond to law enforcement requests, court orders, governmental regulations, or as otherwise required under applicable law; to take appropriate action regarding any use of our Products that may violate any law or regulation; to protect the health, safety, security, property, and interests or rights of us or others; and to investigate or respond to or resolve problems or inquiries or defend our interests.

• Additional Purposes. We may disclose other purposes for collecting information from you at the time of collection.

 

HOW WE SHARE INFORMATION

With regard to Personal Information, SmartBran appreciates its sensitivity and the need to limit its disclosure. Accordingly, we limit our sharing of your Personal Information as follows:

 

• As Required By Law. We may provide access to your Personal Information or PHI when we are legally required to do so, such as to comply with a subpoena, search warrant, court order, judicial proceeding, or similar legal process, or if your conduct violates our Terms of Service.

• Protection. When SmartBran believes in good faith that disclosure is necessary to protect the Products and anything related to them, protect your safety or the safety of others, protect our rights and the rights of third parties, investigate fraud, or respond to a governmental agency or court order.

• Service Providers. When SmartBran provides such information to trusted service providers who work on our behalf, they do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules outlined in this Policy and applicable law. Such information is provided to them subject to the terms of this Policy.

• Business Partners. When SmartBran obtains your consent, we share your name and email with partners we may work with. You may opt out of this sharing by contacting SmartBran using the contact information provided in this Policy.

• Control Transfers. If SmartBran is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice in our Products of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding such information.

• Third Parties. Information may be collected and shared between SmartBran and third parties. For example, SmartBran engages third parties to help us deliver advertisements, and these third parties may collect your information over time across our Products (and third-party websites) in order to associate different devices you use and further gain insights into the services and products that may interest you.

 

SmartBran will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. SmartBran may share your Personal Data, including your SMS opt-in or consent status, with third parties that help SmartBran provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

 

CATEGORIES OF PERSONAL INFORMATION COLLECTED

The following categories of Personal Information may have been collected from or about you, and we may have disclosed, shared, or sold that information with the categories of third parties provided below within the last twelve months.