Jan. 9, 2024

This Privacy Policy replaces and supersedes all prior versions.

Your privacy is important to us. We have created this Privacy Policy (this “Privacy Policy” or “Policy”) to notify you how we treat personally identifiable information and other information that we collect and store through the website or mobile application of Imagoworks, Inc. (“Imagoworks,” “we,” “us” or “our”)(collectively, “Imago Website” https://imagoworks.ai, https://dentbird.com, https://cloud.dentbird.com, https://crown.dentbird.com,https://accounts.dentbird.com). This Policy applies only to information collected by Imagoworks through Imago Website and does not apply to information you post to public areas or third-party websites, except as set forth herein. This Policy is incorporated by reference into the Terms and Conditions to which you agreed to upon entering the Imago Website, and capitalized terms used but not defined in this Privacy Policy have the meaning given to them in the Terms and Conditions. When using the Imago Website and Imagoworks Service, your Personal Information is subject to the privacy related laws and regulations of the Republic of Korea, where Imagoworks’s principal place of business is located. This Policy imposes no duties on Imagoworks not imposed by the Applicable Law (as defined below)

By accessing the Imago Website and providing Imagoworks with personally identifiable information and data, you consent to the exclusive jurisdiction of the Republic of Korea for any and all disputes or actions that may arise. Personally identifiable information and data about you includes information such as your name, birth date, e-mail address or mailing address, and any other information or data that is identified with you personally (“Personal Information”). In some countries, like those in the EU, items such as IP addresses, cookies, or mobile device identifiers may also be considered Personal Information.

1. WHY WE COLLECT PERSONAL INFORMATION (PURPOSE)

The purpose of collecting Personal Information by Imagoworks is to provide optimized and customized services by confirming the user’s identity and intention to use Imagoworks Service. When registering as a member for the first time, Imagoworks collects only the minimum information necessary to perform the essential functions of Imagoworks Service, and may additionally collect information necessary for payment, delivery of goods, and refunds according to the use of the service provided by Imagoworks.

Mandatory data may be required by law (e.g., tax law, regulations related to medical devices, and others) or contract. Such Personal Information is collected, processed, stored, used, and disclosed according to applicable legal stipulations. Unless we are required by law to collect, process, store or disclose certain Personal Information, disclosure of your Personal Information is voluntary.

2. WHAT INFORMATION AND HOW WE GATHER FROM USERS OR MEMBERS

The information we learn from you (whether users or members) helps us personalize and improve your experience at the Imago Website, and the following are the types of Personal Information we generally gather:

Information You Provide: We receive information if and when you access the Imago Website, create an account, or make orders and purchases through the Imago Website. Any Personal Information you provide is voluntarily offered by you or is necessary for the purposes for which it is to be used. You have no obligation to provide all information requested on any Imagoworks form, but the failure to do so may impact Imagoworks’ ability to respond to your inquiry, problem, request, or other communication, and may result, in the case of other service request, in the denial of such a request.

Automatic Information: We automatically receive and record certain types of information whenever you interact with us. This information, which is recordable any time you use the internet, includes the Internet Protocol (IP) address used to connect your computer or mobile to the internet; your domain name, if any; and computer and connection information, such as browser type and version. In addition, like many websites, we use a technology called “cookies” to record your activity while visiting Imago Website. You have the option to accept installation of all or some of our cookies, or to reject all cookies by setting options in your web browser. For more information on cookies, please see Article 14 of this Privacy Policy.

We use this information to learn how you use Imago Website, to remember your preferences, and to diagnose problems.

DNT requests: Some browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to digital services that a user does not want to have their online activity tracked. Because there is not yet an accepted standard for how to respond to DNT signals, we and our service providers (like many digital service operators) do not respond to DNT signals.

Moreover, the following are the specific types of Personal Information we gather:

Tasks	Collected Information	Retention Period
Contact for notice of violation of privacy policy and modification of these terms and conditions	(Required) Email address, password, occupation, country of origin, phone number	Until membership withdrawal
Order and payment	(Required) Email address, password, occupation, country of origin, phone number, dental scan data (STL, OBJ, PLY, DICOM file), CT data, address	Until membership withdrawal
Integrated service operation such as identification, SSO linkage, identity verification, age verification, illegal use prevention, customized service, etc. (ID/PW search and Imagoworks Service), customer support, utilization of AI data for R&D purpose, business analytics, service improvement	(Required) Email address, password, occupation, country of origin, phone number, dental scan data (STL, OBJ, PLY, DICOM file), CT data, address	Until membership withdrawal
New service development, customized service provision and marketing, service use statistics and surveys	(Optional) Gender, date of birth, mobile phone number, email address	Until membership withdrawal

3. PERIOD OF RETENTION AND USE OF PERSONAL INFORMATION

Imagoworks retains and uses your Personal Information during the period of retention in accordance with relevant laws and regulations or retains and uses your Personal Information during the period of retention agreed upon by you when we collected your Personal Information. Accordingly, the period for which Imagoworks retains and uses your Personal Information is as follows:

Purpose of Collection	Retention and Use Period
Notice of identity verification, SSO linkage, Privacy Policy violation, and changes to the Privacy Policy	Until membership withdrawal
Ordering, payment, and delivery services	Until membership withdrawal
New service development, providing customized service, service usage statistics and surveys	Until membership withdrawal
Integrated service operation, such as identity verification, age verification, prevention of illegal use, customized service (ID/PW search and Imagoworks Service)	Until membership withdrawal

Notwithstanding the foregoing, Imagoworks may retain and use your Personal Information for a certain period of time as follows if it is required under relevant laws and regulations even if the period of retention and use of your Personal Information with your consent has elapsed:

Applicable Laws	Purpose of Collection and Use	Information Collected and Used	Retention and Use Period
Communications Secret Protection Act	Provided upon request by an investigative agency upon receipt of a court warrant	Computer communication, internet log record data, access destination tracking data (IP), etc.	3 months
		Records of labeling and advertisements	6 Months
Consumer Protection in E-Commerce Transactions	Records of transactions such as labeling, advertisements, contract details, and performance, etc.	Consumer identification information, contract/subscription withdrawal records, etc.	5 Years
		Consumer complaints and dispute resolution records.	3 Years
National Tax Basic Law	Calculations of national tax exclusion periods and expiring prescription for national tax collection rights, etc.	Tax base and tax reporting data, etc.	5 Years
VAT Law	Tax invoices, import tax invoices, receipts, etc.	Tax base of VAT and reporting data of tax amount, etc.	5 Years

4. METHOD OF DESTRUCTION OF PERSONAL INFORMATION

We promptly destroy Personal Information when a) the retention period in the foregoing section expires, or b) the purpose for which the use, processing, or retention of the Personal Information expires. We destroy Personal Information recorded and stored in electronic file format in a way that cannot be restored or reproduced, and Personal Information recorded and stored in paper documents is destroyed by crushing or incineration with a shredder.

• If the relevant retention period of applicable Personal Information has elapsed or the Personal Information must be retained in accordance with other laws despite the purpose of the use of the Personal Information having concluded, the Personal Information will be moved to and stored on a separate database for preservation.

• Imagoworks selects and destroys Personal Information with the approval of Imagoworks’ privacy officer.

5. USE OF YOUR PERSONAL INFORMATION

We may use or disclose the Personal Information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns or warranty claims.

• To provide, support, personalize, and develop the Imago Website, Imagoworks Service and all other existing and new services.

• To create, maintain, customize, and secure an account you may have with us.

• To process your requests, purchases, transactions, and payments and prevent transactional fraud.

• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

• To personalize Imago Website experience and to deliver content and service offerings relevant to your interests, including targeted offers and ads through the Imago Website, third-party sites, and via email or text message (with your prior consent, when required by law).

• To help maintain the safety, security, and integrity of the Imago Website and products and services.

• For testing, research, analysis, and product development, including to develop and improve the Imago Website and Imagoworks Service.

• To respond to law enforcement requests and as required by the applicable law, court order, or governmental regulations.

• As described to you when collecting your Personal Information or as otherwise set forth in the applicable privacy related laws.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

6. PROCESSING OF PERSONAL INFORMATION BY THIRD PARTIES

As described in this Privacy Policy or with your permission, when Imagoworks provides any services or products you request, or if third parties provide processing services to Imagoworks (for example, data processing, credit card processing, or marketing services), Imagoworks may entrust processing of your Personal Information to a third party consignee. In this case, the third-party consignee has no right to use the information shared by Imagoworks for any other purpose.

The scope of personal information handled by consignees that have signed a Distributor contract with us is limited to the personal information of users accessed through the Distributor's Account Page, and not all users who have joined our company are handled.

Processor	(Re-)Entrusted Assignments	Method of Retention and Use Period
Medit Co., Ltd.	Cloud Service	Withdrawal of membership or termination of contract
Align Technology, Inc. and their subprocessors (Click here for more details.)	Cloud Service	Withdrawal of membership or termination of contract
Axsys Technologies, Inc.	Sales and distribution of our products as a Distributor	Withdrawal of membership or termination of contract
Ci-Medical Co.,Ltd	Sales and distribution of our products as a Distributor	Withdrawal of membership or termination of contract
Microsoft Corporation	Web Service and Server Operations	Withdrawal of membership or termination of contract
Hubspot and their subprocessors (Click here for more details.)	Email Messaging	Withdrawal of membership or termination of contract
Sendgrid and their subprocessors (Click here for more details.)	Email Messaging	Withdrawal of membership or termination of contract
Payment Wall Inc.	Payment Services	Withdrawal of membership or termination of contract

• Imagoworks, in accordance with Article 26 of the Personal Information Protection Act when concluding a consignment contract, prohibits processing of personal information for purposes other than the purpose of entrusted business, takes technical and managerial protection measures, restricts re-entrustment, manages and supervises consignees, and carries out responsibilities such as compensation for damages. It is specified in documents such as contracts, and supervises whether the trustee handles personal information safely.

• If the contents of the consignment work or the consignee changes, we will disclose the changes through this Privacy Policy without delay.

7. SHARING OF PERSONAL INFORMATION WITH THIRD PARTIES

Imagoworks does not use or share your Personal Information to a third party beyond the scope of this Privacy Policy, except with your consent or in accordance with relevant laws and regulations.

We may share Personal Information about you with third parties only in order to provide services or products that you have requested or that provide services to us (such as data processing services, credit card processing, or marketing services), when we have your permission, or as otherwise described in this Privacy Policy. We do not and will not provide your Personal Information to third parties for purposes beyond the scope of this Privacy Policy, unless you consent, or we are required to do so by applicable laws and regulations. Third-party providers, who use such data in accordance with this Privacy Policy, may need Personal Information to perform their functions, and may use this Personal Information to contact you in the future to tell you about services we think will be of interest to you (of which you may opt-out as previously explained above). These companies are not authorized to use the information we share with them for any other purpose.

We will provide Personal Information if required by law, such as in response to a subpoena or similar legal process, or as necessary to enforce the Terms and Conditions for the Imago Website, or as necessary to protect your vital interests; provided, however, that we will ask for your separate consent if required by applicable laws and regulations. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, user information, including Personal Information, may be one of the transferred assets and if so, it we will ask for your separate consent if required by applicable laws and regulations. In any of events in the preceding sentence, we will not be liable for your information no longer in our possession.

8. TRANSFER OF PERSONAL INFORMATION TO OTHER COUNTRIES

We entrust some of the tasks necessary for service provision to an external company. We manage and supervise the entrusted company (the “Consignee”) through a personal information processing and consignment agreement in order to ensure that the Consignee safely and properly processes your Personal Information in accordance with this Privacy Policy, including the destruction or return of your Personal Information in the event the agreement is terminated.

Consignee	Contact Information	Purpose of Use of Personal Information	Items Consigned	Consignee Country	Transfer Date	Method of Retention and Use Period
Microsoft Corporation	https://support.microsoft.com/	Web service and server operations	All items consented to for collection and use	United States	Upon consent or as necessary from time to time	Until end of membership or termination of contract
Hubspot	https://help.hubspot.com/	Email services	Name, email address	United States	Upon consent or as necessary from time to time	Until end of membership or termination of contract
Payment Wall Inc.	https://www.paymentwall.com/support	Payment Information	All items consented to for collection and use	United States	Upon consent or as necessary from time to time	Until end of membership or termination of contract
Sendgrid	https://support.sendgrid.com/hc/en-us	Email services	Name, email address	United States	Upon consent or as necessary from time to time	Until end of membership or termination of contract

You refuse the transfer of your personal information by refusing to agree to the Terms and Conditions of Imagoworks. However, you will be able to use Imagoworks Service only if agreed to the Terms and Conditions cause the consent is necessarily required in order to use Imagoworks Service.

9. PROTECTION OF PERSONAL INFORMATION

Imagoworks complies with the Personal Information Protection Act; the Act on Promotion of Information and Communications Network Utilization and Information Protection, etc.; the Act on the Use and Protection of Credit Information; the Act on the Protection, Use, etc. of Location Information; the Act on the Development of Cloud Computing and the Protection of its Users; the Framework Act on Electronic Documents and Transactions; the Electronic Signature Act; the Smart Grid Construction and Utilization Promotion Act; the Medical Service Act; and so on (the “Applicable Laws”). Furthermore, the applicable personal information protection guidelines established by the Korean government to maintain the privacy and security of your Personal Information. If a breach occurs that may have compromised the privacy or security of your Personal Information, we will let you know promptly. We will follow the duties and privacy practices described in this Privacy Policy and the Terms and Conditions.

While no method of data transmission is guaranteed against unlawful third-party interception or other misuse (for example, e-mails sent to or from the Imago Website may not be secure), Imagoworks uses commercially reasonable efforts to ensure protection of your Personal Information from unauthorized access, disclosure, alteration, and destruction. Data collection and processing, by Imagoworks and third-party providers may occur in the United States of America.

10. RIGHTS AND OBLIGATIONS YOU (OR YOUR LEGAL REPRESENTATIVE) HAVE WITH RESPECT TO PERSONAL INFORMATION AND HOW TO EXERCISE THEM

In addition to other rights specified in this Privacy Policy, you and your legal representatives have the following rights: (i) the right to object, for legitimate reasons, to the processing of your Personal Information; (ii) the right to inquire, correct, change, and withdraw your Personal Information you or your legal representative provided to Imagoworks; (iii) upon proof of identity, the right to access information with respect to whether Imagoworks is processing your Personal Information, the purposes of such processing, the categories of Personal Information processed, the recipients of your Personal Information, locations where your Personal Information is transferred or processed, the manner in which the Personal Information was communicated to Imagoworks, and, to the extent your Personal Information is automatically processed, information that enables you to understand and challenge the underlying logic of such processing to the extent a decision by Imagoworks is directly impacted by such processing; and (iv) the right to amend, rectify, complete, update, lock, or delete any of your Personal Information that is inaccurate, incomplete, ambiguous, out-of-date, or expired, or the collection, use, communication, or maintenance of which is prohibited under the Applicable Law or incompatible with the purpose for which it was originally collected or subsequently authorized.

You and your legal representative may exercise rights listed in this Article to Imagoworks in writing, e-mail, fax, or other communication in accordance with Article 41, Paragraph 1 of the Enforcement Decree of the Personal Information Protection Act and we will promptly carry out such request.

We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning information residing on backup tapes), jeopardize the privacy or rights of others, would be extremely impractical, or for which access is not otherwise required.

11. PROCESSING OF PERSONAL INFORMATION FOR CHILDREN UNDER THE AGE OF 14

• You may not use or access any part of the Imago Website or the Imagoworks Service if you are under 18 years of age. Imagoworks does not knowingly collect data or Personal Information from minors under the age of 18 years. If you are under 18, DO NOT provide any Personal Information. If you have reason to think that a minor has provided Personal Information to Imagoworks, contact us at [e-mail], and we will use commercially reasonable efforts to delete that information from our databases.

• When Imagoworks collects Personal Information from children under the age of 14, it collects only the minimally required Personal Information necessary to perform the service and with the consent of the legal representative.

  • Required Information: name, relationship, and contact information of the legal representative

• When collecting Personal Information from children under the age of 14 for the purpose of publicity related to processing by Imagoworks, we will obtain separate consent from the legal representative.

• When Imagoworks collects Personal Information of children under the age of 14, we may request minimally required information, such as the legal representative’s name and contact information, from the child, and confirm whether the legal representative has consented in one of the following ways:

  • A method whereby the legal representative indicates whether or not consent by posting through an internet site, and notifying the controller of the Personal Information by sending a text message to the mobile phone of the legal representative that consent has been confirmed.

  • A method whereby a written consent form is issued directly to the legal representative or delivered by mail or fax, and the legal representative signs and seals the consent form and returns it to Imagoworks.

  • A method whereby Imagoworks may receive an expression and contents of consent from the legal representative by email.

  • A method whereby the legal representative is notified of the contents of the requested consent by phone and is instructed on how to provide consent and to check the contents of the requested content online, and a separate phone call to obtain the consent of the legal representative.

  • Other methods similar to the above listed methods to notify the legal representative of the contents of the requested consent and a means to confirm the intention to consent.

12. INTERNATIONAL USERS OR MEMBERS

Imagoworks Service and Imago Website are hosted in Korea. If you choose to use Imagoworks Service and Imago Website from other regions of the world, then by your use of Imagoworks Service and Imago Website, you acknowledge and agree that: (i) Imagoworks may share and transfer your Personal Information outside of those regions to Korea for Imagoworks Service as required for us to perform our contractual obligations to you; and (ii) the laws and regulations of Korea shall govern your use of Imagoworks Service and Imago Website and may differ from those of your country of residence.

Certain users or members who live outside of Korea in certain jurisdictions may have the option of requesting that their Personal Information be accessed, updated, and/or removed at any time from our active databases, subject to the applicable laws and regulations of such jurisdictions. Such users may also have the right to object to our processing of their Personal Information and/or request that we provide their Personal Information to another third party. We may require that such request be provided in writing, subject to the applicable laws and regulations with respect to the Personal Information required for the Imagoworks Service. If you would like to access, update, object to processing, request provision to a third party, and/or request removal from our active database of your Personal Information, please contact us at [e-mail]. Any such requests will be honored within thirty (30) calendar days.

With respect to requests to remove or stop the processing of Personal Information, such requests received prior to initiation of the Imagoworks Service will result in a cancellation of the Imagoworks Service, and no result or output will be provided to you.

If you are a resident of the United States, we will use our best efforts to protect your personal information in accordance with the Health Insurance Portability and Accountability Act (HIPAA). This gives you certain rights regarding access to your personal information as a resident of the United States.

If you are a resident of California (CA), you are granted specific rights regarding access to your Personal Information under the California Online Privacy Protection Act and California Civil Code Section 1798.83. If you are a CA resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are a resident of the European Economic Area (EEA), you have certain data protection rights under the General Data Protection Regulation (GDPR). If you are an EEA resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

13. COOKIES POLICY

We collect information through the use of technologies, including ones called “cookies,” as part of providing our website and services. Our cookie policy includes the definition of cookies, how we use cookies, how affiliated third parties use cookies, your choices regarding cookies, and additional information on cookies.

What Are Cookies And Why They Are Used: Cookies are very small pieces of data sent from a server to a user's browser. Cookie files are stored on your computer's hard drive and allow us and affiliated third parties to identify you and make it easier for you to use our website. Cookies identify your computer, but not you personally. Cookies may be session-only (removed after you close your browser) or persistent (remaining on your computer for a specific period of time after you close your browser).

How We Use Cookies And Their Purposes: When you access the Imago Website or use our services, we may place cookie files on your Web browser. We use cookies for the following purposes: to provide analysis information, to store preferences, and to store preference information to provide customized advertisements. We use both persistent cookies and session cookies. Certain cookies are essential for authenticating users and protecting user accounts from fraud.

Third Party Cookies: We may use third-party cookies to report usage-related statistics of the Imago Website and services and to deliver advertisements.

Your Choices Regarding Cookies: You have the right to decide whether to accept or reject our cookies. To delete cookies or instruct your web browser to delete or reject cookies, visit your web browser's help page. You can also choose to receive a prompt each time a cookie is saved, accept all cookies by default, or refuse to save cookies. However, if you delete cookies or do not accept cookies, you may not be able to use all features available to you, you may not be able to save your preferences, and some pages may not display properly.

For More Information: You can learn more about cookies at the following websites:

All About Cookies: http://www.allaboutcookies.org/

Network Advertising Initiative: http://www.networkadvertising.org/

14. OUR PRIVACY OFFICER AND CONTACT INFORMATION

Imagoworks manages Personal Information protection matters at its business headquarters.

Imagoworks Privacy Officer: Hakwan Kim

Email: [e-mail]

Telephone: [phone]

Department and Position: Business Group/Director

15. DEPARTMENT FOR RECEIVING AND HANDLING REQUESTS FOR ACCESS TO PERSONAL INFORMATION

The department responsible for handing requests for access to Personal Information is stated in Article 14 of this Privacy Policy.

16. REMEDIES FOR INFRINGEMENT OF RIGHTS AND INTERESTS IN PERSONAL INFORMATION

• A user residing in Korea with rights and interest in Personal Information may apply for dispute resolution or consultation with the Personal Information Dispute Mediation Committee or the Korea Internet & Security Agency Personal Information Infringement Report Center in order to receive relief from an infringement of their Personal Information. For Personal Information infringement reports and consultations, the following organizations may be contacted:

  • Personal Information Dispute Mediation Committee: (no area code) 1833-6972 (http://www.kopico.go.kr)

  • Personal Information Infringement Report Center: (no area code) 118 (privacy.kisa.or.kr)

  • Supreme Prosecutors’ Office: (no area code) 1301 (http://www.spo.go.kr)

  • National Police Agency: (no area code) 182 (ecrm.cyber.go.kr)

• Imagoworks guarantees the right to self-determination of the subject of Personal Information and strives to provide counseling and relief from damage caused by any infringement of Personal Information.

• For customer consultation and reporting related to the protection of Personal Information, please contact:

  • Department Name: Business Group

  • Privacy Officer: Hakwan Kim

  • Email: [e-mail]

  • Telephone: [phone]

• A user residing in Korea whose Personal Information was infringed due to a disposition or omission made by the head of a public institution in response to a request under Article 35 (Perusal of Personal Information), Article 36 (Correction/Deletion of Personal Information), and Article 37 (Suspension of Personal Information Process, etc.) of the Personal Information Protection Act may request an administrative trial as prescribed by the Administrative Appeals Act.

  • Central Administrative Judgment Committee: (no area code) 110 (http://www.simpan.go.kr)

Please contact us with any questions or comments about this Privacy Policy, your Personal Information, our use and disclosure practices, or your consent choices by email at [e-mail].

17. PRIVACY POLICY CHANGES AND UPDATES

We encourage you to visit this Privacy Policy periodically to check for any changes. This Privacy Policy is updated from time to time. If we change this Privacy Policy, we will provide the updated Privacy Policy through the Imagoworks website and service and indicate the latest revision date. If the modifications materially change your rights or obligations under this Privacy Policy, Imagoworks will use reasonable efforts to notify you of such changes. Your use of the Imago Website after the revised Privacy Policy takes effect indicates you have read, understand, and agree to the current version of this Privacy Policy.