Ultradent Products, Inc. Privacy
Policy

Last Updated: February 7, 2024

Data Privacy Framework Statement

Ultradent Product’s Inc. and its affiliated U.S, entities (“Ultradent,” "we," "us," or "our") complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Ultradent has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Ultradent has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov.

Among the U.S. entities of Ultradent Products Incorporated, Oratech, LLC also adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles), including as applicable under the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Principles and is covered by Ultradent Products Incorporated's DPF submission.

At Ultradent, the security and privacy of personal data are paramount. We are dedicated to protecting the personal data of our customers, employees, partners, and other stakeholders who entrust us with such information. This Privacy Policy outlines our practices regarding the collection, storage, use, and disclosure of personal data we receive.

Applicability of this Privacy Policy

Ultradent Products, Inc. based in the United States, is responsible for personal information under its control and its affiliated entities. If you reside outside of the United States, your relationship may be with one of the following Ultradent affiliates: Ultradent do Brasil, Ultradent Products GmbH, Ultradent Italia S.R.L., Ultradent Japan KK, Ultradent (Australia) PTY Ltd, Guangzhou Ultradent Medical Instrument Co., Ltd, Ultradent Products China Ltd, Ultradent Products Malaysia SDN. BHD., or Ultradent Africa. 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.

Data Privacy Framework for EEA and UK Personal Data Transferred to the US

Ultradent complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Ultradent has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Ultradent has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov.

Ultradent acknowledges the right of EEA and UK individuals to access their personal data pursuant to the Data Privacy 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 Data Privacy Framework Principles for onward transfers of Personal Data from the EEA and UK, including the onward transfer liability provisions. Pursuant to the Data Privacy Framework, Ultradent Product’s Inc. remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.

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 Program 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-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF principles; (ii) accurately describes Ultradent’s practices and procedures regarding the collection of Personal Data; and (iii) identifies Ultradent’s participation in the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF and how to obtain additional information regarding the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF 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-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF and the appropriate collection, processing, and storage of Personal Data.

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

Data Privacy Framework Enforcement and Dispute Resolution

With respect to Personal Data received or transferred in accordance with the Data Privacy Framework, Ultradent is subject to the regulatory enforcement powers of the Federal Trade Commission (“FTC”).

In compliance with EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Program’s Principles, Ultradent is committed to resolving complaints relating to the privacy, collection, and use of Personal Data transferred to the United States pursuant to the DPF Principles. Individuals with questions or concerns about Ultradent’s use of their Personal Data and DPF inquiries 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

Ultradent has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Ultradent commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.

If you are a citizen of an EEA or UK country or are located in the EEA or UK 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 Data Privacy Framework 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 Data Privacy Framework: https://www.dataprivacyframework.gov/s/.

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.opalescence.com/privacy-management.

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 predetermined Personal Data on file to assist with the identification of users, and for internal purposes such as auditing, data analysis, and research.