Privacy Policy

Last Updated: 13 April 2017


SmileBack adopted this Privacy Policy to make it easy for you to understand how SmileBack collects, stores, uses and discloses information you provide to SmileBack. Please read our Terms of Service and this Privacy Policy carefully prior to using this Site, registering to use or using the Service, and/or submitting information through this Site or the Service. If you do not agree with all of the terms of our Terms of Service and our Privacy Policy, you are not authorized to use this Site, register to use or use the Service, and your sole remedy is to stop using this Site and the Service.


This Privacy Policy covers information provided through this Site and/or the Service; provided, however, this Privacy Policy does not apply to information submitted to third parties regardless if you link to such third parties through this Site. By providing information through this Site and/or the Service, you acknowledge and agree that such information is governed by this Privacy Policy.

Customer Data

We respect the confidential nature of your Customer Data. SmileBack will not review, share, distribute, or reference any Customer Data, except as provided in our Terms of Service or as may be required by law. In accordance with our Terms of Service, we may access your Customer Data to provide you with the Service, as well as to prevent or address service or technical problems. We may also access your Customer Data to provide you with customer support.

Personal Information

You can visit this Site without telling us who you are and without revealing any of your Personal Information. However, there are times when we may need certain Personal Information from you, such as when you register to use a Service. When you provide Personal Information to us, we use your Personal Information to provide you with access to the requested Service, content and/or information. We may also use your Personal Information to help us understand who is visiting this Site and using our Service. We may also use your Personal Information to:

  • Provide technical administration and customer support.
  • Respond to your inquiries.
  • Send important notices, such as communications about purchases and changes to our terms, conditions, and policies.
  • Process payment for purchases you make.
  • Deliver products and services you purchase or request.
  • Make it easier for you to log back into this Site and the Service.
  • Contact you about our specials and new services or specials and new services from our affiliated companies or other third parties, unless you ask us not to contact you about these offers. For details on how to opt out of receiving information about specials and new services, please see the “Opting Out of Future Contact” section of this Privacy Policy. Manage your use of the Service.
  • Verify your eligibility and deliver prizes in connection with contests and sweepstakes.
  • Enforce our Terms of Service.
  • Protect against or identify fraudulent transactions.

Aggregated Information

We collect, analyze and use Aggregated Data to help us provide you with a better user experience. For example, we keep track of the domains from which users visit this Site and we also measure visitor activity on this Site. When we use Aggregated Information, we do so in a way that keeps your Personal Information anonymous. You hereby acknowledge and agree that SmileBack may make Aggregated Information publicly available, provided that such information does not incorporate any Customer Data and/or identify you or your Confidential Information. By way of example, we use Aggregated Information to:

  • Analyze our audience size and usage patterns.
  • Develop, deliver, and improve our services.
  • Develop and display content and advertising tailored to your interests.
  • Process payment for purchases you make.

Disclosure of Your Personal Information

SmileBack is not in the business of sharing or selling your Customer Data or Personal Information. We consider this information to be a vital part of our relationship with you. However, in addition to specific requests by you, there are certain circumstances in which we may share your Customer Data and/or Personal Information with third parties without further notice to you, as set forth below:

  • Business Transfers. As we develop our business, we may buy, sell or reorganize businesses or assets. In the event of such sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.
  • Affiliated Companies. We may also share your Personal Information with our subsidiaries, affiliates and other related companies for purposes consistent with this Privacy Policy and providing you with the Service.
  • Agents, Consultants and Service Providers. SmileBack, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
  • Credit Card Processing. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use billing information except for the sole purpose of credit card processing on SmileBack’s behalf.
  • Legal Requirements. SmileBack may disclose your Personal Information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation; (ii) enforce, protect or defend the rights or property of SmileBack; (iii) act in urgent circumstances to protect the personal safety of users of this Site or the public; or (iv) protect against legal liability.

Joint Offerings

From time to time, SmileBack may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly-offered product or service from us, SmileBack may share information collected in connection with your purchase or expression of interest with our joint promotion partner(s). SmileBack does not control our business partners’ use of the information we share with them, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, your sole remedy is to opt not to purchase or specifically express interest in a jointly-offered product or service.



“Confidential Information” means any and all of the following information, disclosed or made available by either party (“Disclosing Party”) to the other party (“Receiving Party”), and any derivatives thereof, which is confidential and proprietary in nature, including, but not limited to, Customer Data, Personal Information and past, present and future Disclosing Party: business and financial records; business and marketing plans; contracts; sales; reports; billings; insurance filings; employees; customers; vendors; proof of concepts; products and/or services, in preliminary and final production form; pricing; intellectual property; source codes; object codes; technical knowledge; trade secrets; internal practices and procedures; feedback relating to any Confidential Information; other information relating to Disclosing Party’s business, including, without limitation, the terms and conditions of any Statement of Work; and any third-party confidential information which Disclosing Party may be authorized, from time to time, to review, have access to and/or use, including, without limitation. Confidential Information will not include information which (i) the Receiving Party lawfully had in its possession prior to disclosure by Disclosing Party; (ii) is now or subsequently becomes generally available to the public without a breach of this Privacy Policy by Receiving Party; (iii) Receiving Party can document as independently created without the use of any Confidential Information of the Disclosing Party; or (iv) Receiving Party can document as lawfully obtained from a third-party who has the unrestricted right to transfer the information to the public.

Non-Disclosure and Non-Use of Confidential Information.

Except to specifically perform their obligations or pursuant to their rights under the Terms of Service and this Privacy Policy, Receiving Party shall not, and Receiving Party shall cause Receiving Party’s principals, shareholders, members, directors, officers, employees, affiliates, consultants, representatives and agents (collectively, “Representatives”) not to (i) disclose any Confidential Information to any other person or entity for so long as the Confidential Information shall remain confidential, including, without limitation, not disclosing idle gossip or Confidential Information (i.e., personal or financial) to individuals within Disclosing Party or Receiving Party who do not need to know such information for a Receiving Party to perform their obligations under this Agreement; and (ii) use, directly or indirectly, any Confidential Information for its benefit or the benefit of any third party (except as otherwise required to provide you with the Service).

Special Notification for California Residents – Your Privacy Rights

Individuals who are residents of California and have provided their personal information to us may request information regarding our disclosures, if any, of their personal information to third parties for direct marketing purposes. Such requests must be submitted to our Privacy Officer in writing at or:

SmileBack, LLC
Attention: Privacy Officer
427 N Tatnall St #64120
Wilmington, DE 19801-2230

Such requests must include the reference “Request for California Privacy Information” in the subject line and in the body of the message and must include the e-mail address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted to us if not submitted pursuant to the terms set forth above.

General Information

Capitalized terms not defined in our Privacy Policy will have the meaning ascribed to such term in our Terms of Service. The Terms of Service are hereby incorporated into and made a part of this Privacy Policy.

Customer Support

If you have questions, comments or concerns about our Privacy Policy, please contact SmileBack at:

SmileBack, LLC
427 N Tatnall St #64120
Wilmington, DE 19801-2230