LAST UPDATED: May 3, 2018 Keystone Dental Inc. and its affiliates (“Keystone Dental” or “we”) want you to be familiar with the information we collect about users of our websites, how we use and share that information, and the choices you have regarding the information you provide. This Privacy Policy (“Privacy Policy”) describes our practices with respect to information collected through our website located at http://KeystoneDental.com and other Keystone Dental websites where this Privacy Policy is made available (“collectively, the “Site”). This Privacy Policy does not address information that may be collected through services offered by Keystone Dental (the “Keystone Dental Services”), including those aspects of Keystone Dental Services that are accessible via this Site, including the documentation. For more information about information collected through Keystone Dental Services, please see our Keystone Dental Services Privacy Policy. By using the Site, you agree to this Privacy Policy, the policies referenced in this Privacy Policy, and our Terms and Conditions. If you do not agree to this Privacy Policy, the policies referenced in this Privacy Policy and our Terms and Conditions, do not use the Site. If you have any questions about this Privacy Policy, or our privacy practices generally, please contact us at privacy@KeystoneDental.com. Contents of the Privacy Policy: Information We May Collect How We May Use Your Information How Your Information May Be Shared International Data Transfers Other Important Notices Regarding Our Privacy Practices User Rights Additional Notice for Certain European Residents Additional Notice for Canadian Residents Privacy Shield Notice Changes to this Privacy Policy How to Contact Us Information We May Collect We may collect information from or about you, such as: Personal information that you voluntarily provide, including name, address, and email address. Communication preferences. Unique IDs such as IP address and device IDs. Site-viewing activity, such as pages visited, videos watched, duration of sessions and search terms. Referring domain, destination domain and destination path. Geolocation data. To the extent permitted by applicable law, we may also combine information you provide to us, either via our Site or via another means (such as at a trade show) with publicly-available information, such as your organization’s name. Information Collected by Automated Means. We may collect certain information about you by automated means, such as your MAC address, IP address, computer type, screen resolution, OS version, and browser type and version. This information is collected by most websites and is used to optimize your experience on the Site. Job Applicants: You may voluntarily provide data about yourself in connection with a job application. Such provision of data is subject to the privacy policy of the third-party platform you use to submit your application. You will have the opportunity to review that privacy policy before providing the data. Cookies and other tracking technologies. We and our third-party service providers may use cookies or similar technologies to collect information about you, such as personal information, information about the devices you use to access the Site and your interactions with the Site. For more information about the use of cookies on the Site, please review our Cookies Policy. We may also use web beacons on our Site and in email communications. Web beacons, also known as clear GIFs or single-pixel GIFs, are small image files that we, or our third-party service providers, place on our Site and in emails. Alongside cookies, web beacons allow us to accurately count the number of unique users who have visited a specific page on the Site, or opened or acted upon an email. This information allows us to measure the performance of our Site and our email campaigns. Advertising on Third-Party Websites and Ad Networks. We partner with third parties to manage our advertising on the Site and third-party websites, which may include serving or tracking advertisements on or relating to the Site. Our third-party service providers may use technologies such as cookies to gather information about your activities on the Site and third-party sites in order to provide you advertising based upon your browsing activities and interests. The privacy policies of those third parties will govern your interactions with such third-party websites or ad networks. Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on the Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. Your IP address is a number that is automatically assigned to the device you are using by your ISP and, in many cases, IP addresses are shared by multiple people or computers and may be dynamically generated (meaning they change over time). This number is identified and logged automatically in our server log files whenever you use the Site, along with the time(s) of your visit(s) and the page(s) you visited. We may combine this automatically-collected log information with other information we collect from you. We do this to improve the functionality of the Site. Analytics. We use third-party analytics provided by Google Analytics. For information on how Google Analytics collects and processes information about you and information on how to opt out from Google’s collection of information from you, please click here. Do Not Track. The Site does not recognize a “do not track” setting (or similar mechanism) from your browser to indicate that you do not wish to be tracked or to receive interest-based ads. Security. The security of personal information that Keystone Dental collects from Site users is of great importance to Keystone Dental. We use organizational, technical, and administrative measures to protect personal information under our control. No data transmission over the Internet or data storage system, however, can be guaranteed to be 100% secure. When you submit personal information via a lead form on the Site (such as name, phone number, and email address), we encrypt the transmission of that information. If you have any questions about the security of your personal information, you can contact us at privacy@KeystoneDental.com. How We May Use Your Information To the extent permitted by applicable law, we may use the information collected about you for the following purposes or in the following ways: To communicate with you and to inform you of products, programs and services. To fulfill your requests and respond to your inquiries, such as to send a requested white paper. To send you important information regarding the Site, including changes to Site terms, conditions and policies. This information is important, so you may not opt out of receiving it. To allow you to voluntarily participate in contests, surveys or promotions (collectively, “Promotions”). If you participate in a Promotion, we may request certain personal information, such as your email address. You should carefully review the rules, if any, of each Promotion, because the rules for each Promotion may contain additional information about our use of personal information that you provide in connection with the Promotion. To the extent that the Promotion’s rules conflict with this Privacy Policy regarding the treatment of personal information, the Promotion’s rules will control. For our internal business purposes, such as for data analysis (including through automated systems and machine learning), benchmarking, reporting, audits, developing new products, enhancing our Site, improving Keystone Dental Services, identifying usage trends and determining the effectiveness of our promotional campaigns. To protect the security and integrity of our Site, and to prevent and to investigate fraud and other misuses. In an anonymous (or pseudonymous or de-identified), aggregated manner. In combination with other information, collected online and offline, including information from third-party sources, to help us update, expand and analyze our records, identify prospective customers and provide products and services that may be of interest to you. To comply with applicable legal or regulatory requirements and our policies, and to protect against criminal activity, claims and other liabilities. In any other ways, with your consent or as permitted under applicable law. How Your Information May Be Shared To the extent permitted by applicable law, we may share personal information as follows: With any of our current and future corporate subsidiaries and affiliates. With our third-party service providers, agents, vendors and other third parties we use to support the Site and our business. These parties include, but are not limited to, third parties providing us with services such as website hosting, data analysis, infrastructure provision, IT services, customer service, analytics and email delivery services. These third parties are authorized to use your personal information only as necessary to provide these services to us. With third parties (including third-party event sponsors) to allow them to contact you regarding products, programs, services and promotions that they believe may be of interest to you. With third parties for marketing, advertising, Promotions, contests or other similar purposes. If required by applicable law, we will share such data for advertising and marketing purposes only in an aggregate, anonymous and de-identified manner. With third-party sponsors of Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to such Promotion. You should carefully review the rules, if any, of each Promotion in which you participate, because they may contain additional important information about a sponsor’s own information collection practices. In connection with a corporate transaction, proceeding or reorganization involving the business activities for which the information is maintained. In the event that ownership of Keystone Dental or its business were to change as a result of a merger, acquisition or transfer to another company, your personal information may be shared. You will be notified via email and/or a prominent notice on our website, of any change in ownership, change in use of your personal information, and choices you may have regarding such change in use of your personal information. As we believe necessary: under applicable law, including laws outside your country of residence; to comply with any law or directive, judicial or administrative order, legal process or investigation, warrant, subpoena, law enforcement or national security investigation or as otherwise required or authorized by law; to respond to requests from public and government authorities, including outside your country of residence; to enforce our policies, terms and conditions; to protect our operations or those of any of our affiliates; to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; and to permit us to pursue available remedies or limit the damages that we may sustain. Forums. We may enable you to post information to certain parts of the Site (collectively, the “Forums”). Please note that any information you disclose through any Forum will be publicly available. We urge you to exercise discretion and caution when deciding to disclose personal information, or any other information, via any Forum. We are not responsible for the use of any personal information you disclose through any Forum. To request removal of your personal information from a Forum, contact us at privacy@KeystoneDental.com. We will let you know if we are not able to remove your personal information. Third-Party Sites and the Site. We provide links to other websites on this Site as a convenience for our users. We may also inform users about third-party services or applications that can be used in connection with Keystone Dental Services, including services from companies associated with Keystone Dental’s partners program (as further described on the Site). This Privacy Policy does not cover, and we are not responsible for, the privacy, information or other practices of any third parties, or of other websites, applications or services operated by such third parties. Your activities with, including your provision of personal information to, any such third parties or such third parties’ websites, applications or services will be governed by the privacy policy of such third parties. The inclusion of a link on the Site does not imply endorsement of the linked website by Keystone Dental. We are not responsible for the use of any personal information you disclose to or through our customers or partners or third-party sites, applications or services. Social Media Features. Our Site includes social media features, such as LinkedIn, Twitter, Facebook, and Google Plus. These features may collect information about you including, for example, your IP address and which pages you visit on our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing the social media feature. Cross-Device Tracking. When you use your mobile device to interact with the Site, we may receive information about your mobile device, including a unique identifier for your device. We and our service providers and third parties we collaborate with, including ad networks, may use cross-device/cross-context tracking. For example, you might use multiple browsers on a single device, or use various devices (such as desktops, smartphones and tablets), which can result in your having multiple accounts or profiles across these various contexts and devices. Cross-device/cross-context technology may be used to connect these various accounts or profiles and the corresponding data from the different contexts and devices. International Data Transfers The Site, and the features and functionality of the Site, may be provided using resources and servers located in various countries around the world, including the United States and other countries. Therefore, personal information about users of the Site may be transferred, processed and stored outside the country where you access the Site, including to countries where the level of data protection may not be deemed adequate by the local legal or regulatory authority in the country of origin of the data. By using the Site, you consent to this transfer. We will protect the privacy and security of personal information we collect in accordance with this Privacy Policy, regardless of where it is processed or stored. Other Important Notices Regarding Our Privacy Practices Opt-Out. If you no longer wish to receive marketing-related emails from us, or you prefer that we not share personal information about you in the future with our affiliates and/or with third parties, you may opt out by following the “unsubscribe” instructions in the latest such message you have received or by contacting us at privacy@KeystoneDental.com. Please specify whether you are opting out of receiving messages from us or from us sharing your information with our affiliates and third parties. We will endeavor to comply with your request as soon as reasonably practicable. If you opt out as described above, we will not be able to remove your personal information from the databases of third parties with whom your personal information has already been shared. If you wish to cease receiving marketing-related emails from such third parties, please contact them directly. Retention Period. To the extent permitted by applicable law, Keystone Dental will retain personal information about you for the period of time appropriate for us to fulfill the purposes outlined in this Privacy Policy or as necessary to comply with our legal obligations, resolve disputes or enforce our agreements, whichever is longer. Use of the Site by Children. The Site is not directed to children under the age of 16 (who reside in the EU, the European Economic Area or Switzerland) and children under the age of 13 (who reside in the United States). Children under the applicable minimum age should not provide personal information through the Site. If you become aware that a child has provided us with personal information, please contact us at privacy@KeystoneDental.com. User Rights You may request, and we will provide you with, information about whether we hold any of your personal information. You may request access to, or correction or deletion of your personal information, by contacting us at privacy@KeystoneDental.com. We will respond to your request within a reasonable timeframe. Additional Notice for Certain European Residents The following Additional Notice applies only to residents of the European Union, the European Economic Area and Switzerland who visit the Site. Personal Data and Processing. For the purposes of this Additional Notice: “Personal Data” means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person. “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Purposes and Legal Bases for Processing Personal Data. Keystone Dental processes data for the purposes as set forth in this Privacy Policy, including providing the Site and other services to users as explained in the How We May Use Your Information and How Your Information Is Shared sections. Our lawful bases for the Processing of Personal Data are: (i) consent and/or (ii) any other applicable lawful bases, such as our legitimate interest in engaging in commerce, offering products and services of value to the users of the Site, preventing fraud, ensuring information and network security, direct marketing and complying with industry practices. Compelled Disclosures. Keystone Dental may be required to disclose Personal Data in response to lawful requests by public authorities, including disclosures necessary to meet national security or law enforcement requirements, or pursuant to judicial orders. Additional Rights for European Residents. As a resident of the EU or a country following substantially-similar legislation regarding the protection of Personal Data, you may have one or more of the following additional rights available to you: Access. To request a copy of the Personal Data we have collected about you by contacting us at privacy@KeystoneDental.com. Rectification & Erasure. To request that we correct or delete any Personal Data about you that is incomplete, incorrect, unnecessary or outdated. Objection. To object, at any time, to Personal Data about you being Processed for direct marketing purposes. Restriction of Processing. To request restriction of Processing of Personal Data about you for certain reasons, such as, if you consider Personal Data about you collected by us to be inaccurate or if you have objected to the Processing in accordance with your rights under Data Protection Laws and Regulations. Data Portability. To request and receive the Personal Data we have collected about you in a commonly used and machine-readable form. Right to Withdraw Consent. If Personal Data about you is Processed solely based on your consent and not for any other lawful basis, to withdraw your consent at any time, without affecting the lawfulness of our Processing based on such consent before it was withdrawn, including Processing related to existing contracts for Keystone Dental Services. Right to Lodge a Complaint with a DPA. If you believe our Processing of Personal Data about you is inconsistent with the applicable data protection laws, to lodge a complaint with your local supervisory data protection authority (“DPA”). To exercise any of the above-listed rights (with the exception of the right to lodge a complaint with a DPA, which you may do directly to a DPA), please contact us at privacy@KeystoneDental.com. We will process any requests in accordance with applicable law and within a reasonable period of time. We may need to verify your identity before processing your request. Additional Notice for Canadian Residents Canadian residents may have additional rights under Canadian law. Please see the information provided by the Office of the Privacy Commissioner of Canada for additional details. You, and we, confirm that it is our wish that this Privacy Policy and all other related policies be drawn up in English. Changes to this Privacy Policy We may update this Privacy Policy to reflect changes to our information and privacy practices. If we make any material changes, we will notify you by posting a notice on the Site prior to or simultaneously with the change becoming effective. Your continued use of the Site after any such modification constitutes acceptance of any such modified Privacy Policy. We encourage you to review this page periodically for the latest information on our privacy practices. The date of last revision is shown at the top of this Privacy Policy. How to Contact Us If you have any questions regarding this Privacy Policy, please contact us by email at privacy@KeystoneDental.com, or call +1 781-328-3300, or write to: Attn: Privacy Team Keystone Dental Inc. 154 Middlesex Turnpike Burlington, MA 01803 Please be sure to include sufficient information so we can understand and respond to your specific question or request.
