1. INTRODUCTION

This Privacy Policy explains how Hemingway AI, Inc. dba Newton (“Newton,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards your information in connection with our office management and communications software (the “Service”). Our Service may be provided on behalf of various dental practices or other businesses (“Practice Partners”). By using the Service, visiting our website at https://joinnewton.com (the “Website”), or otherwise interacting with us, you consent to the data practices described in this Privacy Policy.

2. INFORMATION WE COLLECT

We may collect “Personal Information” that identifies you directly or indirectly, depending on how you interact with our Service and Website.

2.1 Personal Information (Messaging Service & Practice Partners)

• Name

• Mobile phone number

• Email address

• Appointment dates and times

• Treatment or procedure information

• Text message opt-in status and preferences

2.2 Automated Information

We may automatically collect:

• Message delivery status (e.g., whether a text was delivered/read)

• Response data (e.g., your replies to text or email reminders)

• Usage patterns (e.g., frequency of logins, features used)

• Device information (e.g., hardware model, OS, IP address)

2.3 Additional Data Sources

• Interactions with Newton: When you contact us for support or fill out forms.

• Third-party integrations: If you link or sync with external services (e.g., Google, Facebook).

• Cookies & Tracking: We may use cookies or similar tools for the Website to personalize content, measure performance, and deliver ads.

3. HOW WE USE YOUR INFORMATION

We use collected information to:

1. Send appointment reminders and confirmations on behalf of Practice Partners

2. Provide treatment follow-up and health maintenance reminders

3. Deliver practice announcements or other communications

4. Manage messaging preferences (opt-in/opt-out for SMS)

5. Improve our services, analyze usage data, and measure performance

6. Comply with legal obligations (e.g., HIPAA, if applicable)

For Subscribers (practices/organizations using our Service), we may also:

• Bill and collect fees

• Send administrative/transactional communications

• Ensure security and prevent fraud

• Enforce agreements

4. INFORMATION SHARING AND DISCLOSURE

We share Personal Information only for legitimate business or legal purposes:

• With Practice Partners: If you receive messages from or about a specific dental practice, your data may be shared with that Practice Partner.

• With Service Providers: Vendors or contractors (e.g., payment processors, hosting, SMS gateway) who assist in delivering or improving the Service.

• With Legal/Regulatory Authorities: If required by law or in response to valid legal process.

SMS OPT-IN PROTECTION

• We do not share text message originator opt-in data or consent status with unrelated third parties.

• We may share SMS opt-in data with platform providers, phone companies, or vendors who help deliver text messages.

• We do not sell, rent, or lease customer information to third parties.

5. SECURITY OF YOUR INFORMATION

We take commercially reasonable measures to help protect your data from unauthorized access or misuse, including:

• Encryption of data (in transit and at rest)

• Access controls and authentication

• HIPAA-compliant handling procedures (where relevant)

• Staff training on security and privacy

No security method is 100% foolproof, but we strive to maintain high industry standards.

6. YOUR RIGHTS AND CHOICES

Depending on where you live, you may have certain rights regarding your Personal Information:

• Opt out of messages by replying “STOP” at any time

• Request access to or correction of your information

• Request deletion of your data (where legally applicable)

• Withdraw consent for future processing

If you are a Customer (e.g., a patient of a dental practice), direct such requests to the Practice Partner who sent you the communication. You can also contact Newton at support@joinnewton.com with general inquiries.

7. HIPAA COMPLIANCE

When acting as a Business Associate for covered dental practices:

• We maintain Business Associate Agreements with all Practice Partners

• Implement administrative, physical, and technical safeguards for Protected Health Information (PHI)

• Provide HIPAA training to staff

• Conduct periodic risk assessments and maintain incident response procedures

• Handle PHI only for authorized purposes under our agreements

8. CHILDREN’S PRIVACY

Our services are not directed to individuals under 18. We do not knowingly collect personal information from children under 18. If we discover that such information has been provided inadvertently, we will delete it.

9. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically. If we make material changes:

• We will notify you by sending a notice to the primary contact information provided, or

• Place a prominent notice on our Website.

Your continued use of the Service after changes are posted means you acknowledge the updated Privacy Policy.

10. CONTACT US

If you have questions or concerns about this Privacy Policy, please contact us at:

Newton AI

1885 Mission Street

San Francisco, CA

Email: support@joinnewton.com

Website: https://joinnewton.com