PACIFIC DENTAL SERVICES® LLC
THIS PRIVACY POLICY APPLIES TO OUR SITES, TRUSTED OFFICES, AND APPLICATIONS.
CCPA Privacy Policy for California Residents Last Updated and Effective On: August 14, 2023
This CCPA Privacy Policy for California Residents (“CCPA Privacy Policy” or "Policy") supplements the information contained in Pacific Dental Services’ (“PDS,” “we,” “us,” or “our”) online privacy notice at https://www.smilegeneration.com/privacy-policy/ and applies solely to consumers who are residents of the State of California (“consumers” or “you”).
We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”). The CCPA imposes specific obligations on businesses processing personal information of California residents. Terms used in this CCPA Privacy Policy, such as personal information, consumers, third party(ies) and service providers, have the same meaning as they are defined in the CCPA. Pursuant to the CCPA, Pacific Dental Services is required to provide consumers a notice, used at or before the point of collection of personal information, that identifies the categories of personal information that may be collected, indicates the purpose of such collection, and provides the consumers rights related to such information.
Notice at Collection
At or before the time of collection, you have a right to receive notices of our practices, including the categories of personal and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared and how long such information is retained. You can find those details below.
What Is Personal Information?
The CCPA provides personal information rights to California residents. The CCPA defines personal information as information that “identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular” California consumer or household. Personal information does not include publicly available information or consumer information that is deidentified or aggregate consumer information.
Categories of Personal Information We Collect About You
We collect or generate personal information about you in a number of ways depending on the product or service and the relationship we have with you. For example:
- Your contact information, such as your email, home address, ZIP code, and phone number. Such items are collected when you sign up for our contests or promotions.
- Your public information, such as comments or reviews that you post on our site. We also collect requests or questions that you publicly post.
- Your demographic information, such as your postcode, preferences and interests.
- Other information, such as your location, your IP address, the browser/device/hardware you are using, your GPS location and what pages you visit on our site. Such items are collected when you visit our digital ads.
- When you communicate with us through the sites, over the phone, via social media or other platforms, we collect the content of the communications, information about the channel in which you contacted us and we may also collect personal information about you indirectly through monitoring or other means, such as recording telephone calls and collecting phone metadata and digital information.
- When you interact with the sites or our advertisements, we collect digital information using cookies, web beacons, page tags, pixels or similar tools that we and our service providers and other third parties have set.
- When you interact with the sites via a social media platform, we collect a copy of the posts and other information, such as account ID or username.
We require this information to understand your needs and provide you with a list of dental offices for relevant referrals. Once you have selected a new dentist, we will share your information with your dentist.
For more information, see below for a list of the categories of personal information, along with some descriptions and examples that we may collect through each of the processes described above:
- Personal Identifiers: This includes first and last name, previous name, address, telephone number, unique personal identifier, and signature.
- Device and Online Identifiers and Related Information: This includes online identifiers, Internet Protocol (IP) address, email address, account user name, mobile/ wireless number, social media profile, unique device identifier and serial number, and other device information.
- Demographic Information: This includes date of birth and household income data.
- Internet, Application, and Network Activity: This includes text messages or emails sent to us, clickstream/online website tracking information, and data related to user activity (e.g., browser visits and cookies or other similar technologies).
- Location Data: We may receive information about your location and your mobile device, including a unique identifier for your device; in addition, in some instances, location information can be derived from your IP address or through your wi-fi connection.
- Sensory Data: This includes audio data, such as a recording of your voice when you call our contact center. Although you don’t have to supply any of the personal information we request, we may not be able to provide products or services to you or you may not be able to interact with our sites if you do not.
The Purposes for Which Your Personal Information is Collected or Used
We use your personal information for the following business purposes:
- To keep an internal record for our reporting and analysis purposes.
- To provide you with relevant content, materials, offers, programs and to administer your participation in our contests or sweepstakes.
- To respond to your requests or questions that you may provide via our social sites.
- To improve our sites, products, services and other marketing purposes.
- To protect our company, other patients and our assets and sites and for other security measures.
- To remain in communication with you with any products or services you requested.
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or mail.
- We may provide your information to our third-party service providers for marketing or promotional purposes.
- To target ads to you based on your past online activity.
- Customer information retention is indefinite and is shared with select third-party service providers and supported dentists.
- Supporting our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.
- Complying with contractual obligations, relevant industry standards, and our policies.
- Notifying you about changes to the sites, products and policies.
- Performing analytics concerning your use of the products and sites, including your responses to our emails and the pages and advertisements you view.
- Mitigating fraud and enhancing the security of the sites and our online services.
- Managing institutional risk.
- Operating, evaluating and improving our business (including developing new products and services; improving existing products and services; and performing accounting, auditing and other internal functions).
- Authenticating your identity, including when scheduling appointments and financial application processes through the sites as well as afterwards.
- Quality control and training purposes.
Any information collected is disclosed to you here and is used as permitted or required by law. We also abide by the set of rules prescribed to us by Google AdWords: https://support.google.com/adwordspolicy/answer/143465.
We may also use your personal information for any other purpose that we disclose at the time you provide, or when we collect, your information and other purposes permitted by applicable law. We may also use data that we collect on an aggregate or anonymous basis for various business purposes, where permissible under applicable laws and regulations.
We are required to identify the categories of personal information we share with third parties for operational purposes. We disclose the following categories of personal information for operational purposes: personal identifiers; device and online identifiers and related information; demographic information; internet, application, and network activity; location data; sensory (audio data)
The Source of The Personal Information We Collect About You
- When you sign up for things automatically like a contest or a promotion or when you register to any of our sites.
- Through tracking tools, such as cookies, tags and other technologies.
- Our partners, such as Smile Generation Financial, My Smile Dental Plan™, and our trusted dental offices will provide us with information that you voluntarily give them. We may also use information associated with your social media account, e.g., your name, username, email address, gender, profile picture, etc. We may also collect information about your friends or family if you share any of our social content using web tools.
- Any information that you provide to a third party with whom we have a contractual relationship, e.g., social media, digital display media (banner ads), and any other advertising partners.
Sharing of Your Personal Information
We share personal information as set forth below:
- Our third-party service providers, including Google, show our ads on sites across the internet.
- Please be aware that third-parties may use cookies, web beacons, and similar technologies to collect or receive information from our website and use that information to provide measurement services and target ads.
- Additionally, please be aware that Facebook may also use cookies, web beacons, and similar technologies to collect or receive information from our website and use that information to provide measurement services and target ads.
Selling of Your Personal Information
California law requires that we describe certain disclosures of personal information where we receive valuable consideration. California law treats such disclosures as “sales” even if no money is exchanged.
To the extent that PDS “sells” your personal information (as the term “sell” is defined by the CCPA), you have the right to opt-out of that “sale” going forward. See the section titled “Do Not Sell or Share My Personal Information” below for more information.
Amount of Time Your Personal Information is Retained
We retain personal information for various periods depending on the nature of the personal information, the purposes for its collection and use, and based on our legal and ethical obligations. Generally, we retain personal information only for so long as necessary to fulfill the purposes for which we collected it. 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.
Rights to Your Personal Information
You have a number of legal rights when it comes to your Personal Information under the CCPA. Without being discriminated against for exercising these rights, you have the right to request that we disclose what personal information we collect from you, the purposes for which we disclose your personal information, the right to request that we delete that information, the right to correct inaccurate personal information and to opt-out of the sale or sharing of your personal information, subject to certain restrictions.
Right to Know
You have the right to request that we disclose what categories of your personal information we collect, use, or sell and the purposes for which the personal information is disclosed. You may request access to the specific pieces of personal information that we have collected from you. (“Right to Know”)
Right to Delete
You have the right to request that we delete your personal information, subject to certain limited exceptions. For example, we may retain an archived copy of your records consistent with applicable law. (“Right to Delete”)
Right to Correct
You have the right to request that we correct inaccurate personal information that we collect about you, considering the nature of the personal information and the purposes of the processing of the personal information. (“Right to Correct”)
To exercise any of the privacy rights detailed above submit a CCPA request form or call 888-508-2033.
Right to Opt-Out of the Selling or Sharing of Your Personal Information
You have the right to opt-out of the “sale” or “sharing” of your personal information with third parties who are not our service providers (as those terms are defined under the CCPA and CPRA). To exercise this right, click the “Do Not Sell/Share My Information” link on the bottom of the webpage where your information is being collected.
Right to Limit Use and Disclosure of Sensitive Personal Information
You have the right to request that we limit our use and disclosure of your “sensitive personal information,” (as that term is defined under the California Consumer Privacy Act (the CCPA)) to certain permissible purposes. However, we process sensitive personal information only as permitted by the CCPA, and we don’t use sensitive personal information to infer characteristics about you. Accordingly, we do not offer an option to limit further processing of Sensitive Personal Information.
How Will you Verify My Identity If I Make a CCPA Request?
In order to verify your identity, we will collect your:
- Name
- Date of Birth
- Telephone Number
- Address
We will use this information to verify your identity using reasonable methods in order to process your rights request. These methods may include matching information you provided to us with information already maintained by us or through the use of a third party identify verification service.
We cannot respond to your request or provide you with personal information if we are not able to verify your identity or authority to make the request or confirm the personal information relates to you.
You are not required to have an account with us to make a verifiable request.
Contact, Questions or Complaints
We take your privacy seriously and invite you to contact us at the email address below also with any further questions or concerns you may have regarding your privacy or our collection, storage and use of your Personal Information:
Email: [email protected]