Supplier Data Privacy Policy

This Supplier Data Privacy Policy (“Policy”) governs the protection of Supplier Customer-Identifiable Transactional Data and Supplier Identifiable Pricing Data that Method generates from or collects through dental practice customers as it relates to transactions with suppliers on Method’s procurement platform.

This Policy is supplementary to and should be read in conjunction with Method’s Terms of Use, Supplier Order Transmission Terms, and Privacy Policy. In the event of a conflict between this Policy and any other Method agreement, the terms most protective of supplier data shall control with respect to the subject matter of this Policy.

This Policy applies to all supplier data collected or processed through Method’s platform from the effective date forward.

Method will not share, sell, license, or otherwise disclose Supplier Customer-Identifiable Transactional Data to any third party, including competitor suppliers, without the supplier’s prior written consent, except as required by law or court order, or as outlined in the exceptions in Section 3.6.

Method will not disclose Supplier Identifiable Pricing Data to any third party without the supplier’s prior written consent, except as required by law or court order, or as outlined in the exceptions in Section 3.6.

Protected data under this Policy, as it relates to Supplier Customer-Identifiable Transactional Data and Supplier Identifiable Pricing Data, includes, but is not limited to:

• Pricing negotiations or special rates given to customers by suppliers

• Specific transaction amounts between suppliers and customers

• Purchase frequency data for customers’ transactions with suppliers

• Payment terms or credit arrangements between suppliers and customers

Data NOT protected under this Policy includes, but is not limited to:

• Platform usage statistics that do not reveal customer or supplier identity

• Publicly available information about dental practices

• General product category performance data across the entire platform

• Any public data, including but not limited to public pricing data, that is publicly available or disclosed

• General market pricing data and trends that do not identify suppliers or specific customers

• Aggregated industry benchmarks and metrics

• Anonymized platform performance data

• Product catalog information and specifications

• Anonymized user behavior patterns

• Industry compliance and regulatory data

• Industry-wide purchase patterns that cannot be attributed to suppliers

Method may use Supplier Customer-Identifiable Transactional Data for:

• Facilitating procurement transactions between suppliers and dental practices

• Providing customer support related to transactions

• Internal analytics to improve Method services

• Compliance with legal and regulatory requirements

• Facilitating data access to paying customers as described in Section 3.6

• Other legitimate business purposes that do not violate the data protection commitments set forth in this Policy

The data protection commitments in this Policy do not restrict:

Public Data: Any data and protections outlined in this Policy do not pertain to any public data, including but not limited to public pricing data, that is publicly available or has been publicly disclosed by any party. For the avoidance of doubt, Supplier Identifiable Pricing Data and Supplier Customer-Identifiable Transactional Data that is publicly available or has been publicly disclosed by any party is not subject to the protections established in this Policy.

Internal Access: Method’s employees, directors, board members, officers, managers, contractors, third-party service providers, auditors, legal counsel, data processors, and automated systems and technology infrastructure used to operate and improve the Services may access data as necessary to perform their duties and responsibilities in connection with Method’s business operations, subject to appropriate security measures. Method may also provide access to such data as required for regulatory or legal compliance purposes.

Customer Access: Method’s paying customers, including, but not limited to, dental practices, consultants, and other entities with active subscriptions or service agreements, may access transactional data relevant to their business relationships and program enrollments on the platform. Paying customers who access data through the Services pursuant to their business relationships and program enrollments are accessing it as Method customers, and such access does not constitute disclosure to a third party for purposes of Sections 3.1 and 3.2.

Subject to the exceptions set forth in Section 3.6, no supplier, including those who are also customers and/or resellers of Method software, will have access to competitor Supplier Customer-Identifiable Transactional Data and/or Supplier Identifiable Pricing Data that is protected under this Policy. Method maintains strict access controls to ensure that no supplier can view, access, or obtain any data that identifies a competitor supplier’s customers, pricing, or transactional activity.

Provided such activities do not contravene the protections established herein, this Policy shall not restrict Method’s right to:

• Conduct market analysis using anonymized data

• Publish industry reports based on aggregate trends

• Share statistical insights that do not identify individual customers and/or suppliers

• Improve platform functionality and user experience

• Develop new features and services

• Conduct research and development activities

• Create predictive models and analytics

• Generate business intelligence and insights

• Benchmark platform performance

• Share aggregated insights with business partners and investors

• Provide anonymized data to industry organizations

• Use aggregated data for marketing and promotional purposes

• Support regulatory compliance and auditing requirements

Method retains all right, title, and interest in Aggregated Data and any analytics, insights, benchmarks, reports, or derivative works created by Method from data collected through the platform. For the avoidance of doubt, Method’s ownership of such derived data is independent of, and survives, the termination of any supplier’s or customer’s relationship with the platform.

Method commits to not implementing any programs, features, or functionalities designed to specifically target, discriminate against, or harm the business of any specific supplier on the platform.

By using Method’s platform, suppliers agree not to make any public statements, whether written or oral, that disparage, criticize, or damage the reputation, business, or goodwill of Method, its affiliates, officers, directors, employees, or business practices.

Suppliers agree to communicate about Method in a professional and respectful manner in all business contexts, including but not limited to communications with customers, vendors, industry associations, and the general public.

Nothing in this section prohibits suppliers from making truthful statements when required by law, regulation, or legal process, or in connection with good faith business communications that are factual and not intended to harm Method’s reputation.