Privacy Shield Privacy Statement

 

Ultradent Product’s Inc. and its affiliated U.S, entities (“Ultradent,” “we,” “us,” or “our”) 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 information from European Union member countries. Ultradent Product’s Inc. has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.Data security and privacy is important to Ultradent Products, Inc. and its affiliates, including Oratech, LLC (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

Please note that if you reside outside of the United States, your relationship may be with one of the following Ultradent affiliates: Ultradent do Brasil, Ultradent Italia S.R.L., Ultradent Japan KK, Ultradent (Australia) PTY Ltd, Guangzhou Ultradent Medical Instrument Co., Ltd, Ultradent Products China Ltd, or Ultradent Products Malaysia SDN. BHD. This Privacy Policy applies to all Personal Data collected, processed, and stored by Ultradent and its affiliates.

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, address, phone number, e-mail address, user ID, and password. In the employment context, Personal Data also includes an individual’s name, address, phone number, e-mail address, user ID and password, as well as country of birth, marital status, emergency contact information, salary information, terms of employment, and job qualifications (such as educational degrees earned).. 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).

Personal Data may be transferred internationally, including to, and from, the United States.  This may include transfers to countries without data protection laws similar to those in place in your country of residence.  By voluntarily sharing your Personal Data with Ultradent, you understand that your Personal Data may be stored and processed in, and outside of, the United States.

Privacy Shield For EEA Personal Data Transferred to the US

Ultradent complies with the EU-US 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 Economic Area member countries (“EEA”) into the US pursuant to the Privacy Shield. Ultradent has certified that it adheres to the data protection principles of notice, choice, accountability for 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.  To learn more about the Privacy Shield program, and to view Ultradent’s certification page, please visit https://www.privacyshield.gov.

Ultradent acknowledges the right of EEA individuals to access their personal data pursuant to the Privacy Shield Framework.  Individuals may view and edit their Personal Data by logging into their account profile or by contacting Ultradent as described below.

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 EEA, including the onward transfer liability provisions.

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.

Renewal and Verification

Ultradent will renew its EU-US 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 EU-US 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 EU-US Privacy Shield Framework and how to obtain additional information regarding the EU-US 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 EU-US Privacy Shield Framework and the appropriate collection, processing, and storage of Personal Data.

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

Privacy Shield Enforcement and Dispute Resolution

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”).

In compliance with EU-US 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 using the contact information provided below.

Via Email:  Privacyde@Ultradent.com

Via Post:  Ultradent Products, Inc.
Attn: Legal Department
505 West Ultradent Drive
South Jordan, UT 84095

If Ultradent is unable to resolve a question or complaint, individuals in the EEA may contact or submit a complaint to the Council of Better Business Bureaus, Ultradent’s third party independent dispute resolution provider. Please visit www.bbb.org/EU-privacy-shield/for-eu-consumers  for more information about how to file a complaint. This service is provided free of charge to you.

Ultradent commits to cooperate with the panel established by the EU data protection authorities) and comply with the advice given by the panel with regard to human resources data transferred from the EEA in the context of the employment relationship.

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

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Helga Block
Postfach 20 04 44
40102 Düsseldorf

 

Under certain circumstances, you may invoke binding arbitration to resolve a Privacy Shield related dispute. In order to invoke arbitration, you must take the following steps prior to initiating an arbitration claim: (1) raise your complaint directly with Ultradent and provide Ultradent the opportunity to resolve the issue; (2) make use of the independent dispute resolution mechanism, in this case the Council of Better Business Bureaus; and (3) raise the issue through your relevant data protection authority and allow the U.S. Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see the U.S. Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).

Data Collection

The information collected by Ultradent is limited to the specific data required for Ultradent to pursue its legitimate interests (including to establish and maintain relationships with its customers, provide products and services, and to administer its business) 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. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of Ultradent’s website. Certain web browsers may allow you to enable a “do not track” option that sends signals to the websites you visit indicating that you do not want your online activities tracked. This is different than blocking cookies as browsers with the “do not track” option selected may still accept cookies. Ultradent currently does not honor “do not track” signals. If Ultradent does so in the future, this Privacy Policy will be updated accordingly.

Marketing

Ultradent may contact you periodically by e-mail or social media to provide you with information regarding events, products, services and content that may be of interest to you. If applicable law requires that Ultradent receive your explicit consent before sending you certain types of marketing communications, Ultradent will only send you those types of communications after obtaining your explicit consent.

A user may, at any time, withdraw their consent by completing and submitting to Ultradent the appropriate consent withdrawal request using the Privacy Management Links Data Portal for Self Service Requests and Maintenance at https://www.ultradent.com/en-us/pages/privacy-management.aspx.

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.

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. If this practice should change in the future we will update this policy to reflect that and provide individuals with opt-out or opt-in choice, as applicable  Ultradent may share Personal Data with third parties where it is necessary to perform legitimate business functions (including, for example, with affiliates, companies that provide Ultradent with technical support and assistance with respect to Ultradent’s websites, financial institutions who process payments for orders placed by customers, suppliers and other third parties who facilitate delivery of the products or services customers have ordered).  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;
  • 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 contacting Ultradent as described below.

GDPR Rights and Recourse for EEA Individuals

Ultradent makes a good faith effort to provide individuals with access to their Personal Data that is collected, processed, and stored by Ultradent.  Individuals in the EEA have certain data subject rights which may be subject to limitations and/or restrictions. These rights include the right to request access to and rectification or erasure of their Personal Data, obtain restriction of processing or to object to processing of their Personal Data, ask for a copy of their Personal Data to be provided to them, or to a third party. If you wish to exercise any of these rights, please send Ultradent your request to the contact details provided below. Individuals in the EEA also have the right to lodge a complaint about the processing of their Personal Data with the appropriate Data Protection Authority (“DPA”). EEA individuals wishing to find out more about the area DPA’s may do so by going to http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. Ultradent will handle all requests as required by applicable law and in accordance with Ultradent’s internal security and privacy policies.

For California Individuals

California Civil Code Section 1798.83 permits users of this website who are California residents to request certain information regarding Ultradent’s disclosure of Personal Data to third parties for direct marketing purposes. To make such a request, please contact Ultradent as described below.

For All Individuals Whose Personal Data We Handle<

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 view and edit their Personal Data by logging into their account profile or by contacting Ultradent. To request erasure of Personal Data, individuals must submit a written request using the contact information below.

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.

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 EU-US 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 Ultradent using the contact information provided below.

Contact Ultradent

For any questions, comments, complaints or suggestions about this Privacy Policy, you may contact Ultradent as follows:

If you are located in the EEA, please contact Ultradent’s Data Protection Officer at Privacyde@Ultradent.com.

If you are located outside the EEA, please contact Ultradent at Privacy@Ultradent.com.

All questions, comments, complaints or suggestions about this Privacy Policy may also be submitted to Ultradent by mail using the following address:

Ultradent Products, Inc.
Attn: Legal Department
505 West Ultradent Drive
South Jordan, UT 84095

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 periodically review this Privacy Policy, 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.