PRIVACY POLICY

Collab Dentistry Inc. (“Collab”, “we”, “our”, “us”) recognizes the importance of your right to privacy and wants you (the “User” or “you” or “your”) to be familiar with how we collect, use and disclose any personal information that individually identifies you. We also want you to understand our commitment to meeting our obligations under all applicable Canadian privacy laws.

This Privacy Policy explains how we collect, use, disclose and protect your personal information when you use our website or mobile site (collectively, the “Site”) and our services, including (i) acting as a platform for Practice Owners (“Practice Owners”) to make office space available to dental hygienists (“Hygienists”) to provide certain dental services to their Clients ; (ii) allowing Hygienists to advertise their services and handle bookings with Practice Owners; (iii) allowing the parties to review and rate one another’s services; and (iv) any other services made available through the platform to either Practice Owners and Hygienists (collectively, the “Services”). It also explains how you can contact us if you have questions about how we handle your information. We will only collect, use and disclose your personal information in accordance with this Privacy Policy.

Depending on the Service, we may provide additional or different privacy notices for specific relations you have with us or to highlight how we use your personal information for specific Services. Where we do this, it will be clear which notices apply to which relations and Services.

By using our Site and Services and supplying your personal information, you acknowledge that you have read and understood this Privacy Policy, and you agree and consent to the collection, use, disclosure and other processing of your personal information as outlined in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you are not permitted to use our Site or Services or supply your personal information to us.

1. What Personal Information do we collect?

Personal information means any information about an identifiable individual. Anonymous data means data that is not associated with or linked to any individual’s personal information or will not easily permit the identification of individuals (“Anonymous Data”). Collab Dentistry does not consider personal information to include Anonymous Data.

We collect your personal information about you when you provide it to us or use our Services. We may also collect information about you from certain third parties. In most instances, you will decide what information you provide us. In certain instances, if you choose to not provide us with personal information, you may not be able to fully utilize our Services. The types of personal information that we may collect include, but is not limited to:

• contact information such as your name, postal address, e-mail address and telephone number;
• identification information, including drivers’ licenses, practice license number
• location information, including office address and related photos;
• banking information including your account number, credit card/debit card information and other information needed for pre-authorized payments;
• information and documents to help us verify your identity and your qualifications, including • education information, employment history, registration status, and unique registration numbers with the College of Dental Hygienists of Ontario or the Royal College of Dental Surgeons of Ontario or equivalent registration information, as applicable);
• business incorporation information and registration numbers;
• insurance information;
• information we obtain about you from credit reporting agencies;
• your IP address; and
• personal information you give us that we did not request (such as personal information you voluntarily put into an email to us).

2. Purposes for Collecting Your Personal Information

We collect, use and disclose your personal information in order to provide you with our Services.  We also collect, use and disclose your personal information to comply with legal and regulatory requirements and as otherwise permitted or required by applicable laws.  We will only use the personal information that we collect for the purposes for which it was collected. We collect your personal information for the following purposes and in accordance with applicable laws:

• to set up your profile and provide you with ongoing Services;
• to verify and confirm your identity;
• to establish and maintain commercial relations with you (whether it be for advertisement purposes), including responding to your questions regarding our Services;
• to facilitate the collection of Services fees, including our set-up fees, administrative and transaction fees;
• to respond to questions that you send by email or through our Site;
• to customize the appearance of the Site displayed to you;
• to obtain your feedback regarding our Site and Services, including our surveys;
• to track behavioural information on the Site to serve similar content upon future visits;
• to support our business functions such as internal business processes, marketing and advertising; and
• to meet any legal or regulatory requirements.

3. When Do We Collect Personal Information?

We may collect your personal information when you voluntarily provide it to us by using our Site and Services or from third party sources. For example, we may ask you to provide personal information if you:

• use our Site and our Services;
• register, update or create an account on our Site and our Services;
• sign into your account;
• send us a question or comment by email or phone or otherwise contact us;
• post comments or other content on our Site and our Services;
• provide feedback to us regarding our Site and Services;
• register to receive newsletters, articles and updates about our Services; and
• otherwise participate in features of our Site and our Services that ask for personal information.

We may receive personal information about you from third party sources, such as regulators and credit reporting agencies. We use this information to: (i) assist with our business operations; and (ii) to provide our Services. You authorize the collection of your personal information from these sources and, if applicable, you authorize these sources to give us your personal information for the above mentioned purposes.

If you speak with one of our representatives by telephone, the call may be recorded or monitored. We do this for the following reasons:

• to establish a record of the information that you provide;
• to take or verify instructions from you;
• to confirm your identity;
• to maintain quality service levels; and
• to assist in staff training.

4. Limiting Collection of Personal Information

We limit the collection of personal information to that which is necessary to fulfill the purposes identified in this Privacy Policy and we collect, use and disclose your personal information only in accordance with this Privacy Policy.

5. Consent, Use, Disclosure and Retention of Personal Information

Depending on the sensitivity of the personal information, your consent to our collection, use and disclosure of personal information may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction.

Your personal information will not be used without your consent for purposes other than those for which it was collected or in accordance with applicable laws. From time to time, we may wish to use personal information for new or additional purposes, in which case we will amend the Privacy Policy to include these new or additional purposes and will obtain your consent through your continued use of our Site and Services.

We may generate Anonymous Data from personal information collected through the Site and Services by removing information that makes the data personally identifiable to an individual. Such Anonymous Data includes, but is not limited to, information we collect from your use of our Site and Services. We may use this Anonymous Data and aggregated data for any reasonable purpose subject to applicable laws and regulations, and disclose such data to third parties in our sole discretion.  

We may also use and disclose your personal information to service providers, data processors and other third parties (“Third Parties”) under the following limited circumstances:

• to Third Parties that assist with our operations and Site and Services including, without limitation, for customer services, hosting Client Data, our business operations, monitoring and analyzing Site activity, and operating and maintaining the Site. Such Third Parties may only use your personal information for the purposes described in this Privacy Policy;
• when necessary to protect our safety, property or other rights, as well as those of our representatives and users of the Site, including to detect and prevent fraud;
• if we sell or transfer all or a portion of our business or assets to a related company or a third party. Your personal information will remain subject to our pre-existing Privacy Policy unless you agree to the privacy policy of the company or third party that acquires your personal information;
• with your consent; or
• as otherwise required or permitted by law.

Your personal information may be transferred to a third party or parties to be used for the same purposes described herein in connection with the due diligence for, and completion of, a business transaction, including, without limitation, a securitization or financing involving Collab Dentistry or its subsidiaries or affiliates.

We retain your personal information only for as long as we need it to fulfill the purposes for which it was collected and to comply with our legal obligations.

Data Transfers

As discussed above, we may engage Third Parties to perform certain services on our behalf and to otherwise provide the Services. These Third Parties may store, process and transfer personal information on servers located outside of Canada in jurisdictions whose data protection laws may differ from those of Canada, such as the United States of America. As a result, personal information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to the laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our Third Parties to maintain protections on personal information that are equivalent to those that apply in Canada.

6. Links to Other Sites

Our Site may contain links to other sites that are independently owned and operated by third parties, including MedStack. These other sites may have their own privacy policies and are not governed by this Privacy Policy. We are not responsible for the privacy practices of or the content on any sites owned and operated by any third parties. Other sites, to which the Site maybe linked, may collect and treat information collected differently than us. We strongly encourage you to carefully read and review the privacy policy of each site you visit.

7. Cookies, Web Beacons and Other Similar Technology

As you interact with this Site and Services, we may use automatic data collection technology and services that record and collect information that identifies your computer, tracks your use of this Site and Services and collects certain other information about you and your surfing habits. These data collection technology and services allows us to store and manage user preferences, enable content, deliver targeted advertising and collect usage data and analytics. These data collection technology may include cookies, web beacons and other similar devices on this Site and Services to enhance functionality and navigation for our visitors. Cookies and other tracking technologies are commonly used by websites and apps through which information is collected about your online activities.

A cookie is a small data file that is placed on your computer or other electronic device so that your device will “remember” information when you visit a site.  

Web beacons and tags are small strings of code that are used in conjunction with a cookie and allow us to record activity on our Site.  Internet tags, graphic tags and similar web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies.  

We may use web beacons on this Site to count users and to recognize users by accessing our cookies. Being able to access our cookies allows us to personalize this Site and improve your experience at our Site. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. Information tracked through these mechanisms includes, but is not limited to: (i) your IP address; (ii) the type of web browser and operating system being used; (iii) the pages of the Site a user visits; and (iv) other sites a user visited before visiting our Site. Web beacons may also be used to deliver to you interest-based advertising.

We may also employ cookies and action tags (also known as single pixel gifs or web beacons) to collect information about your use of, and activities on, our Site for our use and also for use by third parties that serve advertisements about Collab Dentistry on other sites you may visit.  In addition to the information about your visits to our Site, Third Parties may also use the information about your visits to other sites to target advertisements for services available from Collab Dentistry.

You can configure your internet browser so that you are notified when cookies are stored. You can then decide in each individual case whether you want to accept cookies or you decide to refuse to accept any cookies. If you do not accept cookies, your use of our Site may be restricted in some or all ways. You can delete cookies that are already stored on your hard disk at any time.  You will find more details on how to do this in the operating guide for your Internet browser program.

As described above, you may be able to set your browser to refuse cookies. If you refuse cookies, you may still receive online advertising, but it may be less personalized.

8. Third Party Analytics

Our Site uses third party analytics services such as Google Analytics, a web analytics service of Google. Google Analytics uses cookies to analyze how you use our Site. The information generated by the cookie about your use of our Site (including your IP address) is sent to a Google server in the U.S. and stored there. Google will use this information to evaluate your use of our Site, compile reports on Site activity for our Site operators and to provide other site activity-related internet services. Additionally, Google may transfer this information to a third party when required by law or in the case of a third party processing information on Google's behalf. In no case will Google use your IP address in connection with any other information held by Google. You can set your internet browser to prohibit the installation of cookies, although some features and functions of our Site may then be unusable. By using our Site, you consent to the processing of data about you collected by Google in the manner described and for the above-mentioned purpose. The consent for collection and storage of data can be withdrawn at any time in the future by clicking on the following link: https://tools.google.com/dlpage/gaoptout?hl=en. Given the debate concerning the use of analytical tools using full IP addresses, our Site uses the "Anonymize IP" function of Google Analytics that works with a shortened form of IP addresses to avoid direct personal identification.

We also use the cookies to carry out frequency assessments, page usage assessments and marketing assessments. For these assessments, we use this cookie information without a link to your personal information, so it is completely anonymous.

9. Security

We maintain reasonable technical, physical and organizational security safeguards to protect your personal information against loss, theft, and unauthorized access. Any personal information that you provide to us is exchanged on a secured server. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.

We take reasonable steps to verify your identity before granting you access to your account on our Site; however, you are solely responsible for maintaining the secrecy of your username, password and any other account information. We also take reasonable steps to ensure that our employees are aware of the importance of maintaining the confidentiality of personal information and that unauthorized persons do not gain access to personal information that we have disposed of or destroyed.  

10. Individual Access and Accuracy of Personal Information

You may request access to your personal information which we may hold at any given time by contacting us at the contact information set forth below, and we will respond within the time periods provided for under applicable laws. We will need to verify your identity before providing you with the personal information we hold about you. There is no cost for such access request unless you require copies of records. We may not be able to provide you with access to your personal information if the information cannot be separated from the personal information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide you with access to your personal information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so.

You may request to update and change your personal information at the contact information set forth below. We will endeavor to correct or complete any personal information which you advise us is inaccurate or incomplete. Where appropriate, the amended information will be transmitted to third parties having access to such information.

11. Electronic Communications

As part of signing up to receive the Services, you may have also opted in to receive email communications from us. PIPEDA requires more businesses (and other organizations) to be accountable for the collection, use and disclosure of personal information, including electronic addresses, in the course of commercial activities.

If you opted-in to receive such communications, we may use the information to: communicate with you regarding our products, Services and promotions; advertise and market our products, Services and promotions; provide you with other information that you request; and/or improve our product and service offerings.

You will always have the opportunity to "unsubscribe" from receiving any of our e-mail or other communications at any time through the unsubscribe link/ mechanism contained in our emails and / or other communications. We  will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us. We provide an on-going opportunity to unsubscribe or opt-out of contact by us by accessing our Site or by e-mail to admin@collabdentistry.com.

If you decide to unsubscribe, we will only contact you (i) for the purposes allowed under applicable law; (ii) to send you notices of changes to our Privacy Policy; or (iii) to receive Service-related messages.

12. Changes to this Privacy Policy

We reserve the right to change or replace this Privacy Policy at our sole discretion at any time. By signing this Privacy Policy, you agree to check back from time to time to ensure that you are aware of any updates to or changes in this Privacy Policy. We will post the most current version on our Site and we will indicate at the top of this page the date this Privacy Policy was last revised. Your continued access or use of this Site after any such changes constitutes your acceptance of the Privacy Policy as revised.

13. Personal Information about Clients

Hygienists and Practice Owners remain the health information custodians of personal information which they collect from their respective Clients. We do not collect, use or disclose the personal information of Clients, except to provide specific Services to Hygienists, including if they choose to access and store the personal information of Clients using the MedStack platform in connection with the use of our Site or if they choose to use our Site or administrative personnel to submit insurance claim forms on behalf of Clients. We do not retain or store any personal information relating to Clients. If you decide to use our Services, you are agreeing that you will be solely responsible for obtaining the proper consent of Clients to collect, use and disclose their personal information for the purposes of using our Services.  Users are responsible for ensuring that Clients understand the relationship between the User and Collab Dentistry and are aware that Collab Dentistry is a for-profit corporation providing a technology platform and is not responsible for safeguarding or protection of personal health information of Clients. Any reviews of Hygienists or Practice Owners made by you through the use of our Services shall not contain any personal information relating to Clients. Please refer to sections 13 and 14 of our Terms and Conditions for indemnification provisions relating to personal information of Client’s.

14. Your Consent to the Terms of this Privacy Policy

By using our Services and providing us with your personal information, you agree that Collab Dentistry may collect your personal information and you voluntarily consent to the collection, use, disclosure and transfer of your personal information in accordance with this Privacy Policy and all applicable laws. If you do not agree with any terms of this Privacy Policy, please do not use our Site or our Services or provide us with any personal information.  If you do not understand the nature, purpose and consequences of us collecting, using and disclosing your personal information, please do not use our Site or our Services or provide us with any personal information. Please contact us at the contact information set forth below so that we can address your questions or concerns. Individuals can request the deletion of their personal information and Collab Dentistry will destroy or delete all personal information unless the information is necessary to achieve the lawful purposes for which it was collected.

Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the purposes identified in this Privacy Policy at any time by giving our Chief Privacy Officer reasonable prior written notice at the contact information set forth below. If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you or continue to provide you with certain services or information that may be of value to you. However, you may not be permitted to withdraw your consent to certain necessary collections, uses and disclosures of your personal information (for example, Collab Dentistry needs to maintain reasonable business and transaction records).

15. How to Contact Us

We welcome your feedback. If you have questions, comments or concerns about this Privacy Policy, or would like to do any of the following:

• see your personal information that you have already sent us so that you can correct, update or delete it from our files;
• ask that we not send you electronic communications or otherwise contact you; or
• report any violation of this Privacy Policy,

Please contact us at admin@collabdentistry.com and we will endeavor to get back to you promptly.