Ultradent Products, Inc. Privacy Policy

Data security and privacy is important to Ultradent Products, Inc. and its affiliates (together “Ultradent”). Ultradent is strongly committed to protecting the Personal Data of its customers, employees, partners and others who entrust Ultradent with their Personal Data. The purpose of this Privacy Policy is to, among other things, describe the practices that Ultradent follows with respect to collection, storage, use, and disclosure of the Personal Data Ultradent receives.

Applicability of this Privacy Policy

This Privacy Policy applies to all Personal Data collected, processed, and stored by Ultradent.

For purposes of this Privacy Policy, the term “Personal Data” shall mean data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available, or situations where pseudonyms are used (pseudonyms involve the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible).

Privacy Shield

Ultradent complies with the US-EU Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data that Ultradent processes that is transferred from European Union member countries (“EU”). Ultradent has certified that it adheres to the data protection principles of notice, choice and consent, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

Ultradent is responsible for the processing of Personal Data it receives and the subsequent transfers of such Personal Data to third parties acting as agents on its behalf. Ultradent complies with the Privacy Shield Principles for onward transfers of Personal Data from the EU, including the onward transfer liability provisions.

With respect to Personal Data received or transferred in accordance with the Privacy Shield Framework, Ultradent is subject to the regulatory enforcement powers of the Federal Trade Commission (“FTC”). Under certain circumstances, Ultradent may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

To learn more about the Privacy Shield program, and to view Ultradent’s certification page, please visit https://www.privacyshield.gov.

Data Collection

The information collected by Ultradent is limited to the specific data required for Ultradent to conduct legitimate business purposes and to ensure compliance with regulatory bodies and local, state, national, and international laws.

Examples of the information collected by Ultradent include, but are not limited to, an individual’s name, business name, email address, street address, telephone number, and credit card information (only when a purchase is made).

Ultradent may use certain web-based technologies to collect consumer data such as cookies (small text files stored in a user’s browser), Web beacons (electronic images that enable counting visitors who have accessed a page or certain cookies), or other similar technologies. Ultradent may also collect information from customer purchase forms, interactions with Ultradent’s customer service department, and requests for information.

Consent to Data Collection

To use Ultradent’s websites, all users, including users who are browsers, vendors, customers, merchants, and/or contributors of content, must consent to Ultradent’s collection and use of Personal Data in accordance with this Privacy Policy. Users of Ultradent’s websites provide their consent as set forth in the Data Portal for Self Service Requests and Maintenance, which is made available upon accessing Ultradent’s websites. Consent may also be given by signing a physical copy of Ultradent’s Privacy Notice and Consent Form and returning it to an Ultradent representative.

Personal Data may be transmitted internationally for the purposes identified in this Privacy Policy. This may include transfers to countries without data protection laws similar to those in place in the individual’s country of residence. By providing information to Ultradent through use of Ultradent’s websites (or through other means identified herein), the provider of the information consents to such transfers.

A user may, at any time, withdraw their consent by completing and submitting to Ultradent the appropriate consent withdrawal request using the Data Portal for Self Service Requests and Maintenance which is made available upon accessing Ultradent’s websites.

Data Uses

In general, the Personal Data that Ultradent collects allows it to provide services to its customers and employees, comply with legal obligations, resolve disputes, and enforce agreements. Ultradent’s collection of Personal Data also allows Ultradent to keep its customers, employees, and associated third parties up to date on various topics relating to Ultradent, such as the latest product announcements, upcoming Ultradent events, and to send important notices, such as communications about purchases and changes to Ultradent’s terms, conditions, and policies. Ultradent also uses Personal Data to maintain and support its products, deliver requested services and products to customers, help create, develop, operate, deliver, and improve Ultradent’s websites, products, services, content, and customer communications, and to improve marketing, advertising, and sales efforts. Ultradent may also use Personal Data to assist with the identification of users, and for internal purposes such as auditing, data analysis, and research.

Data Transfers and Sharing

Ultradent is an international organization with contracts and business relationships all over the world. Consequently, it may be necessary for Personal Data to be transferred internationally. In such cases, and where required, Ultradent will obtain an adequacy decision as outlined in the General Data Protection Regulation. In the absence of an adequacy decision, Ultradent will comply with generally accepted industry standards for safeguarding the transfer of Personal Data.

The Personal Data collected by Ultradent is not sold to other organizations. Ultradent may share Personal Data with third parties where it is necessary to perform legitimate business functions. Ultradent may also share Personal Data in the following circumstances:

  • as required or permitted by law, such as to comply with a subpoena or similar legal process;
  • when Ultradent believes in good faith that disclosure is necessary to protect its rights, protect the safety of the individual, protect the safety of others, investigate fraud, or respond to a government request;
  • in response to a lawful request by public authorities, including to meet national security or law enforcement requirements;
  • to investigate potential violations of this Privacy Policy or other applicable contract or agreement;
  • to a third party with your prior consent to do so; and
  • in the event Ultradent goes through a business transition such as a merger, acquisition by another company, or the sale of all or a portion of its assets.

Additional information regarding the safeguards employed by Ultradent may be obtained by sending an inquiry to PrivacyShield@ultradent.com.

Accessing, Updating, and Deleting Personal Data

Ultradent makes a good faith effort to provide individuals with access to their Personal Data that is collected, processed, and stored by Ultradent. Individuals may, upon reasonable request and as allowed by the US-EU Privacy Shield Framework, review their own Personal Data stored by Ultradent, correct the Personal Data if it is inaccurate, and/or delete the Personal Data to the extent permitted by applicable law and in accordance with Ultradent’s internal security and privacy policies.

When a request is made to Ultradent with regard to Personal Data, and before Ultradent processes the request, the individual making the request is required to identify themselves and to identify the information requested to be accessed, corrected, or removed. In making modifications to their Personal Data, individuals are required to provide truthful, complete, and accurate information. When receiving a request in accordance with this provision, Ultradent will take into consideration, among other things, the burden or expense of providing the requested access, the potential risks to the individual’s privacy, and whether the rights of persons other than the individual making the request would be violated. Ultradent will respond to requests within a reasonable timeframe.

Individuals may edit their Personal Data by logging into their account profile or by contacting Ultradent directly by phone or email. To request erasure of Personal Data, individuals must submit a written request addressed to Privacyshield@Ultradent.com.

Security

Ultradent has implemented processes and physical and technical safeguards to protect against unauthorized access to Personal Data collected and stored by Ultradent, and to prevent unauthorized use, alteration, corruption, or disclosure of that Personal Data. Personal Data stored by Ultradent is maintained behind firewalls. Ultradent’s servers are located within facilities that are subject to physical security measures including user authentication passwords and other similar means, each designed to prevent unauthorized access. With respect to certain categories of Personal Data, Ultradent also uses secure encryption technology to further safeguard the Personal Data received.

Ultradent restricts access to Personal Data to its employees, contractors, and agents who have need to access that information in order to operate Ultradent’s business in a manner consistent with this Privacy Policy. All such personnel are required to treat Personal Data in a manner consistent with this Privacy Policy. Ultradent follows generally accepted standards to protect the Personal Data, both during transmission and once it is received.

Ultradent will cooperate with and rely on the advice of EU data protection authorities (DPAs) with regard to human resources data that is transferred from the EU in the context of an employment relationship.

While Ultradent believes that its policies and practices regarding information security and integrity are reasonable, Ultradent cannot guarantee that the security and/or integrity of Personal Data will not be breached or that such Personal Data will not be subject to unauthorized access, alteration, corruption, or disclosure. Ultradent reviews its information security policies and practices periodically and may update them as it determines reasonably necessary to achieve information security and integrity consistent with industry standards.

Data Retention

Ultradent will make reasonable efforts to ensure that the Personal Data it collects is not excessive for the purposes for which it was obtained and that it is kept only for the period necessary to accomplish the permitted purpose as outlined in this Privacy Policy, unless a longer retention period is required or permitted by local, national, and/or international laws and regulations.

Responsibilities and Management

Ultradent’s internal Data Protection Office oversees Ultradent’s information security program, including its compliance with the US-EU Privacy Shield Framework. Ultradent’s designated Privacy Officer is responsible for reviewing and approving any material changes to Ultradent’s information security program. Any questions, concerns, or comments regarding this Privacy Policy may be directed to PrivacyShield@ultradent.com.

Renewal and Verification

Ultradent will renew its US-EU Privacy Shield certifications annually, unless Ultradent subsequently determines that it no longer needs such certification or decides to employ a different adequacy mechanism. Prior to re-certification, Ultradent will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Personal Data are accurate and that Ultradent has appropriately implemented these practices. As part of the verification process, Ultradent will:

  • review the Privacy Policy publicly posted on Ultradent’s website to ensure the policy (i) complies with the US-EU Privacy Shield principles; (ii) accurately describes Ultradent’s practices and procedures regarding the collection of Personal Data; and (iii) identifies Ultradent’s participation in the US-EU Privacy Shield Framework and how to obtain additional information regarding the US-EU Privacy Shield program and Ultradent’s information security program;
  • confirm that individuals whose Personal Data is collected by Ultradent are made aware of the process whereby they can submit comments, suggestions, questions or complaints, and the process for addressing and resolving any questions or complaints, including the availability of independent dispute resolution, as applicable (Ultradent may do so through its publicly-posted Privacy Policy or through some other means); and
  • review the processes and procedures used by Ultradent for training Ultradent personnel about Ultradent’s participation in the US-EU Privacy Shield Framework and the appropriate collection, processing, and storage of Personal Data.

Ultradent will prepare an internal verification statement on an annual basis.

Enforcement and Dispute Resolution

In compliance with US-EU Privacy Shield principles, Ultradent is committed to resolving complaints relating to the privacy, collection, and use of Personal Data. Individuals with questions or concerns about Ultradent’s use of their Personal Data can contact Ultradent at PrivacyShield@ultradent.com.

If you are a citizen of an EU country or are located in the EU, and did not receive a timely acknowledgement to your complaint, or if your complaint was not satisfactorily addressed, then you may contact the below third-party dispute resolution provider for further assistance:

Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit
Husarenstraße 30
53117 Bonn
Tel. +49 228 997799 0; +49 228 81995 0
Fax +49 228 997799 550; +49 228 81995 550
e-mail: poststelle@bfdi.bund.de
Website: http://www.bfdi.bund.de/

Under certain conditions, more fully described on the US-EU Privacy Shield website, you may invoke binding arbitration through the American Arbitration Association when other dispute resolution procedures have been exhausted. For more information visit http://go.adr.org/privacyshieldfund.html.

Questions

For any questions, comments, or suggestions about this Privacy Policy, or to request a copy of your Personal Data or to request corrections, erasure, or restriction of data processing relating to your Personal Data, please contact Ultradent at PrivacyShield@ultradent.com.

Changes to this Privacy Policy

Ultradent reserves the right to update this Privacy Policy from time to time. In the event this Privacy Policy is amended, Ultradent will make such amendments available by posting a notice on its website, through email communications, or by some other means. Please review this Privacy Policy periodically and especially before providing Personal Data to Ultradent. Your continued use of Ultradent’s websites after changes have been made to this Privacy Policy indicates your agreement with the terms of the revised Privacy Policy.


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