PRIVACY POLICY

Last Updated: November 15, 2024

This Privacy Policy describes how Aspen Dental Management, Inc. and our subsidiaries and affiliates (collectively, “Company”, “we”, “us”, or “our”) collect, use, and share your personal information in connection with Company -owned and -operated websites or digital properties that link to this Privacy Policy and our related email, phone, and other electronic communications, social media pages, and marketing activities (collectively, the “Site”), and the rights and choices available to individuals with respect to their personal information.

This Privacy Policy does not apply to the protected health information that you may provide to Company in connection with Company’s provision of dental or healthcare services. For more information about our privacy practices relating to those activities, please review the relevant Notice of Privacy Practices provided to you. If there are any inconsistencies between that notice and this Privacy Policy, the Notice of Privacy Practices will control.

Company reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the top of this Privacy Policy. Your continued use of the Site following posting of changes constitutes your acceptance of such changes.

Please click on the links below to visit the relevant section of our Privacy Policy:

1. COLLECTION OF PERSONAL INFORMATION

2. USE OF PERSONAL INFORMATION

3. SHARING OF PERSONAL INFORMATION

4. SECURITY OF PERSONAL INFORMATION

5. YOUR CHOICES

6. OTHER WEBSITES AND SERVICES

7. INTERNATIONAL TRANSFERS OF PERSONAL DATA

8. CHILDREN’S PRIVACY

9. ADDITIONAL INFORMATION AND RIGHTS UNDER APPLICABLE U.S. STATE PRIVACY LAWS

10. CONTACTING US

1. COLLECTION OF PERSONAL INFORMATION

1.1 Categories of Personal Information Collected. The table below describes the categories of personal information (with non-exhaustive examples) that we may collect about you. We may also collect other personal information that is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

1.2 Sources of Personal Information. We obtain the categories of personal information listed above from a variety of sources, including the following:

• Personal Information You Provide. Company collects personal information when you voluntarily submit it to us. For example, we may collect or receive personal information from a user that uses our appointment scheduling service, provides information to our call center in order to schedule an appointment or consultation; signs up to receive promotional communications; participates in one of our surveys; posts a review on our services; submits a request to our customer service team; interacts with our social media pages; or otherwise interacts with us or other users through the Site.

• Automatically Collected Personal Information. We, our service providers, and our advertising partners may automatically log information about you, your computer, or mobile device, and your activity over time on our Site and on other sites and online services, such as the online identifiers, online activity information, and device information described in the table above. Like many online services, we use cookies and similar technologies to facilitate some of the automatic data collection described above, such as:
  
  

Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, remembering the items you place in your shopping cart, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.

Session-replay technologies, which are third-party software used to record a video replay of users’ interactions with the Site. The video replay may include users’ clicks, mouse movements, scrolls, mobile app touches, typing, and other activity taken during the session. We use these replays for research and development purposes, such as to help us troubleshoot problems with the Site, understand how users interact with and use the Site, and identify areas for improvement.

• Personal Information Obtained from Third Parties. In addition to the personal information that we collect from you directly and automatically, Company may receive personal information about you from other third party sources. For example, we receive personal information from our service providers, advertising partners, our network of affiliated dental practices, or companies that provide personal information to supplement what we already know about users. We may merge or combine such personal information with the personal information we collect from you directly or automatically.

• Referrals. Users of the Site may have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so.

2. USE OF PERSONAL INFORMATION

Company uses personal information for various purposes, including those set forth below and as otherwise described in this Privacy Policy or at the time of collection:

• To Provide Our Site and Related Services. For example, we use personal information to monitor and help diagnose problems with the Site, to administer the Site, and to enhance the Site for your optimal experience; customize content that may be of interest to you; and provide you with information about our Services. This could include fulfilling your requests for consultations or products or services. It could also include processing purchases or other transactions. For example, if you share your personal information to request a quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to arrange a consultation, we will use such information to assist in scheduling.

• To Improve Our Site and Related Services. We use personal information to understand and analyze the usage trends and preferences of our users to make our Site better, diagnose technical issues, prevent fraud, schedule appointments more efficiently, refine our product and services offerings, and develop new features and functionality. As part of these activities, we may create de-identified or aggregated information from personal information we collect. We may use de-identified or aggregated information and share it with third parties for our lawful business purposes, including to analyze and improve our Site and related services and to promote our business.

• To Respond to Your Requests or Questions. We use personal information to provide you with support and to respond to your requests for customer support, including to investigate and address your concerns and monitor and improve our responses. This may also include responding to your feedback.

• To Determine Your Eligibility and Set Up Your Account. We may use your personal information, including information about you gathered from third party sources, to verify your identity or determine your eligibility for some of our products, services, and promotions. For example, this may include verifying your age, date of birth, and place of residence. If you set up an account on the Site, we may use the registration information you provide in relation to that account creation to create, maintain, customize, and secure your account.

• For Marketing and Advertising. We use your personal information to provide you with Company-related marketing and promotions about our products, services, or Site. In addition, we also contract with third-party advertising companies and social media companies to help us advertise our business. These companies may use cookies and similar technologies to collect information about you (including the online identifiers, device data, and online activity data described above) over time across our Site and other sites and services or your interaction with our emails and use that information to serve ads that they think will interest you, to monitor and analyze the effectiveness of marketing activities, and to track your entries, submissions, and status in any promotions. These might be third party offers we think you might find interesting. You can learn more about your choices for limiting interest-based advertising, in the “Advertising Choices” section below.

• To Secure the Site. We use personal information to maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, business, and other users. This may include to prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

• To Communicate with You. We communicate with you about your account or our relationship. We may also contact you about this Privacy Policy or the terms of use that govern the Site or our related services.

• As Required by Law. We use personal information to respond to requests from law enforcement and as required by applicable law, court order, or government investigation.

• For Other Compliance and Protection Purposes. We may use your personal information to protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); to audit our internal processes for compliance with legal and contractual requirements and internal policies; and to enforce the terms and conditions that govern the Site or its related services.

3. SHARING OF PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy, Company may share your personal information in the following circumstances. Where required by applicable law, Company will obtain your consent or authorization before sharing such personal information.

3.1. Related Companies. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us).

3.2. Service Providers. We may share your personal information with third parties who perform services for or on our behalf or help us run our business. Among other things service providers may help us perform website hosting, maintenance services, database management, web analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, or any other use set out in this Privacy Policy.

3.3. Advertising Partners. . We may share personal information with third parties who we partner with for advertising campaigns and we participate in interest-based advertising. This means that our advertising partners may use technology (e.g., a cookie) to collect information about your activity on the Site and other online services to help us advertise our services, or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.

3.4. Affiliated Dental and Healthcare Practices. We may jointly offer events, promotions, or any other product or service offerings with our network of affiliated dental and healthcare practices. The personal information that you submit through an event, promotion, or other product or service offering offered with any of our network of affiliated dental or healthcare practices may be combined and transmitted with the registration information related to your account. Third party partners or clients may collect information directly from you, which may be combined with personal information disclosed by us. If you decide to request, enter into, or participate in an event, promotion, or other product or service offering that is offered by us and identified as a joint effort with an affiliated dental or healthcare practice, the information that you provide may be shared with us and with them.

3.5. Professional Advisors. We may share personal information with persons, companies, or professional firms providing Company with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.

3.6. Business Transaction Participants. If we sell all or part of our business, make a sale or transfer of assets, or are otherwise involved in a corporate divestiture, merger, consolidation, acquisition, reorganization, dissolution, sale, or other disposition of all or any portion of the business or assets of, or equity interests in the business (including any affiliate), whether as part of a bankruptcy, liquidation, or similar proceeding, we may transfer your personal information to third parties as part of that transaction, including at the negotiation stage.

3.7. Authorities and Relevant Third Parties. We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal process, to comply with relevant laws, or for the compliance and safety purposes described in the “Use of Personal Information” section above.

4. SECURITY OF PERSONAL INFORMATION

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

5. YOUR CHOICES

You can make the following choices regarding your personal information:

5.1. Access or Update Your Personal Information. If you have registered for an account with us, you may review and update certain account information by logging into your account. You may also contact us using the contact information provided at the end of this Privacy Policy.

5.2. Opt-Out of Promotional E-mails. You may unsubscribe from receiving promotional e-mails from us by clicking the “unsubscribe” link in the e-mail or by contacting us using the contact information provided at the end of this Privacy Policy. If you decide not to receive promotional e-mails, we may still send you service-related communications, such as those about your account, to fulfill orders for products and services you have requested, or service notices.

5.3. Opt-out of text messages. We may offer communications via text messages sent by us or any of our service providers, such as when we send you text messages to confirm your appointment, respond to your inquiries, or for promotional purposes. To stop receiving text messages from us, reply STOP to any text message you receive from us, or email us your request and mobile telephone. Note that we may send you a message to confirm receipt of your STOP request.

5.4. Cookies. Most browsers let you remove or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Site and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

We use Google Analytics to help us understand user activity and patterns on the Site. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing a browser plugin available here.

5.5. Advertising Choices. Some of our advertising partners are members of the Network Advertising Initiative (NAI) and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital Advertising Alliance (DAA). You can obtain more information about these companies’ information collection practices, and opt-out of receiving interest-based advertising from participating NAI and DAA members at http://www.networkadvertising.org/managing/opt_out.asp and/or the DAA’s website at optout.aboutads.info. Mobile app users may opt out of receiving interest-based advertising in mobile apps provided by participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available at https://www.youradchoices.com/appchoices. You can also limit collection of your information for interest-based ads by blocking third party cookies in your browser settings or using privacy plug-ins or ad blocking software that help you block third party cookies. In addition, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for targeted online advertising purposes. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Some of the third party advertising companies we work with offer their own opt-out options that you can use to limit their use of your information for interest-based advertising, such as Google (info and opt-out). Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above. Even after using these opt-out mechanisms, you may receive interest-based advertising from other companies.

5.6. Do Not Track. . Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to a “Do Not Track” signal. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

5.7. Declining to Provide Information. We may need to collect personal data to provide certain services. If you do not provide the information requested, we may not be able to provide those services.

6. OTHER WEBSITES AND SERVICES

The Site may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

7. INTERNATIONAL TRANSFERS OF PERSONAL DATA

We are based in the United States of America, and we have service providers in the United States and potentially other countries. Your personal data may be collected, used, stored, and transferred in these countries or other locations outside of your home country. Privacy laws in the locations where we handle your personal data may not be as protective as the privacy laws in your home country. By providing your personal data, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.

8. CHILDREN’S PRIVACY

Our Site is not directed to individuals under 18 years old, and you may not use the Site or our services unless you are at least 18 years old. If you think we have received personal information from a minor under the age of 18, please contact us using the contact information at the bottom of this Privacy Policy.

9. ADDITIONAL INFORMATION AND RIGHTS UNDER APPLICABLE U.S. STATE PRIVACY LAWS

Certain U.S. states, including California, Colorado, Delaware, and New Jersey provide users with additional rights under their privacy laws. This section applies only to residents of those states (whose laws are in effect) and provides additional information regarding how we process personal information of such residents, and their privacy rights under applicable law. For purposes of this section, “personal information” means “personal data” or “personal information” as such term is defined under applicable state privacy law but does not include information exempted from the scope of such law.

9.1. Personal Information Collected and Purposes of Collection and Use. The categories of personal information we collect, or have collected in the 12 months preceding the “Last Updated” date of this Privacy Policy, the sources of collection, and the purposes for which we collect and use such information are listed in the section above titled “COLLECTION OF PERSONAL INFORMATION.” Further descriptions of the identified purposes, are described in the section titled “USE OF PERSONAL INFORMATION.” The categories of third parties with whom we may share personal information are described in the section titled “SHARING OF PERSONAL INFORMATION.”

Company does not knowingly collect sensitive personal information under applicable state privacy law and, further, does not collect or use sensitive personal information for the purpose of inferring characteristics about individuals.

9.2. How Personal Information is Disclosed, “Sold,” or Used for “Sharing/Targeted Advertising.” Each of the categories of personal information listed in the “COLLECTION OF PERSONAL INFORMATION” section above is disclosed, or may have been disclosed in the 12 months preceding the “Last Updated” date of this Privacy Policy, to operate our business or for another business purpose as described in this Privacy Policy or at the time of collection to the parties identified in the section titled “SHARING OF PERSONAL INFORMATION.”

We may (or have in the 12 months preceding the “Last Updated” date of this Privacy Policy) also “sell” your personal information to a third party in exchange for monetary or other valuable consideration, or process it for “sharing” / “targeted advertising” in the manner described in the section titled, “For Marketing and Advertising,” each as further detailed in the table below. For a description of the categories of third parties mentioned in the table, see the section titled, “Sharing of Personal Information.” We do not knowingly “sell” or use for “sharing”/“targeted advertising” the personal information of consumers under 18 years of age. To exercise your right to opt out of “sales” or “sharing”/“targeted advertising,” see “How to Exercise Your Privacy Rights” below.

9.3. Retention of Personal Information. We will retain each of the categories of personal information listed above for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

9.4. Your Privacy Rights. As a resident of one of the identified states, in addition to the rights described in the “YOUR CHOICES” section above, you have some or all of the rights listed below. However, these rights are not absolute, and in certain cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

• Know. You can request that we confirm whether we process your personal information and to describe how we have collected and used your personal information, including:

  • The categories of personal information that we have collected.

  • The categories of sources from which we collected personal information.

  • The business or commercial purpose for collecting, selling, or sharing personal information.

  • The categories of third parties with whom we disclose personal information.

  • A copy of the personal information that we have collected about you.

• Access. You can request to obtain a copy of personal information in a portable and, to the extent technically feasible, readily usable format.

• Delete. You can ask us to delete the personal information that we have collected from you.

• Correct. You can ask us to correct inaccurate personal information that we maintain about you.

• Opt-out of “sales” and “sharing”/“targeted advertising.” If we “sell” or use your personal information for “sharing”/“targeted advertising,” you can opt-out.

• Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.
  
  

9.5. How to Exercise Your Privacy Rights. You may request to exercise the privacy rights described above as follows:

• Right to know/access, delete, or correct. You can request to exercise know, access, deletion, or correction rights by:

  • Visiting Your Privacy Choices; or

  • Calling 888-987-8698

• Right to opt-out “sales” or “sharing”/“targeted advertising” relating to the use of cookies. You can request to opt-out your personal information from “sales” or “sharing”/“targeted advertising” relating to the automatic collection of data on the Site by cookies and similar technologies by clicking the cookie icon on the sitewide footer or broadcasting the Global Privacy Control (GPC) signal. Note that due to technological limitations, if you visit our Site from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to this screen to select your preferences or rebroadcast the GPC signal.

• Right to opt-out of other “sales” or “sharing”/“targeted advertising.” You can request to opt-out your personal information from other “sales” or “sharing”/“targeted advertising” by completing our interactive webform available on the Privacy Rights Request Portal, or calling 888-987-8698.
  
  

9.6. Authentication Process. We reserve the right to confirm your residence to process your requests and may need to confirm your identity to process your requests. This is a security measure to, for example, help ensure we do not disclose information to a person who is not entitled to receive it. The identity verification process may vary depending on how you submit your request. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

9.7 Authorized Agents. Where applicable state privacy law permits, you may designate an authorized agent to submit a request on your behalf using the method described above. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf.

9.8 Right to Appeal. If we decline to take action on your request, where applicable law requires, you may appeal such refusal by emailing us within a reasonable time period after we send you our decision.

9.9 Additional Notice to California Residents (Shine the Light). If you direct us not to “sell” or “share” your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.

9.10 Notice to Nevada Residents. Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal data. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal data for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information provided at the end of this Privacy Policy.

10. CONTACTING US

If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at:

Aspen Dental Management, Inc.
Attn: Privacy Officer
281 Sanders Creek Parkway
East Syracuse, NY 13057
Toll-Free Number: 888-987-8698