Last Revised – February 19, 2020
The Dentists Supply Company (referred to herein as “TDSC”, “we”, “us” or “our”), a subsidiary of the California Dental Association and its affiliated organizations (collectively, “CDA”), respects the privacy of CDA members and every individual who visits the TDSC website located at https://www.tdsc.com (the “Site”) and any other website, mobile applications or public-facing online service locations that post a link to this Statement (collectively, the “Services”) or offline location that makes this Statement available to you. This Privacy Statement (“Statement”) outlines how and when TDSC collects information about you as well as your rights and choices regarding such information.
TDSC affiliated organizations include the California Dental Association, The Dentists Insurance Company, TDIC Insurance Solutions, the California Dental Association Foundation, the American Dental Association (“ADA”), constituent dental associations of the ADA, and the officially chartered component societies of the CDA.
TDSC is not responsible for the privacy policies and practices of websites other than that of the Services, and TDSC is not responsible for the failure of unaffiliated third parties, vendors and service providers, to honor their privacy obligations.
We encourage you to read this Statement before engaging in any activities with TDSC or using our Services. By engaging in any of the activities described in this Statement and/or visiting the Site, you acknowledge that you have agreed to the terms set forth in this Statement. If you do not agree, please do not visit or discontinue use of the Services.
If you are a California or Nevada resident please see the “Additional Disclosures for California Residents” and “Additional Disclosures for Nevada Residents” sections below.
2. What information do we collect and how do we collect the information?
We collect information from a variety of sources, including information provided by you voluntarily and information that we receive from other sources. Please note we may use the information we collect through any of the services, requests and features listed below for our business purposes, such as providing content or information, products and services to you, and our marketing and advertising activities. Please do not send confidential information to us directly through the Services, or by email to any of the contact email addresses listed on the Services.
Information you provide. We collect information about you when you use the Services or interact with us offline, including information you provide when you register an account, update your profile, access our content, make a purchase, participate in a promotion, contact customer support, or apply for a job.
The information we collect includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. The categories of information we collect, which includes the kinds of information we have collected in the last 12 months, include the following:
- Contact Data, including your first and last name, email address, phone number, practice name, role, and shipping and bill to address.
- Customer Licensure and Membership, including dental license number and ADA number.
- Account Credentials, including your username, password, password hints, and information for authentication and account access.
- Demographic Data, including your age, gender, and country.
- Billing Data, including your payment instrument number (such as credit or debit card number), expiration date, and security code to process your payments.
- Profile Data, including your product preferences and interests.
- Content, including content within any messages you send to us (such as feedback and questions to customer support).
- Personal Contacts Data, including the first and last name, email address, and phone number of your personal contacts. We collect data about your contacts with your consent and in order to fulfill a request by you, such as finding your contacts on the Services or inviting your contacts to join the Services. Such functionality is only intended for U.S. residents. By using this functionality, you acknowledge and agree that both you and your contacts are based in the U.S. and that you have your contacts’ consent for us to use their contact information to fulfill your request.
- Job Applicant Data, including your employment and education history, transcript, writing samples, and references as necessary to consider you for a job opening if you submit an application to us.
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
You represent and warrant that you will only provide information and use the Services acting in your capacity as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit or other legal entity, and that your communications and transactions with TDSC occur solely within the context of TDSC providing the Services to the company, partnership, sole proprietorship, nonprofit or other legal entity that you represent.
Information from service providers. TDSC uses service providers to perform certain functions associated with the Services. For example, service providers that analyze data, process transactions and payments, fulfill orders or provide customer service, may provide us with information so that we are better able to tailor our content, products and services that we believe may be of interest to you. As part of their services, these service providers collect information provided voluntarily by you or automatically when you use their sites.
Information from affiliates. We also obtain information from our affiliates. For example, when you register for the Site, we will verify your membership status with your state dental association.
Information collected automatically. We automatically collect information when you use the Services. The categories of information we have automatically collected in the last 12 months include the following:
- Service Use Data, including data about the features you use, the pages you visit, the emails and advertisements you view, the products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
- Device Connectivity and Configuration Data, including data about device identifiers such as IP address and Ad Id (e.g., IDFA or AAID), the type of Internet browser and device you use, your device’s operating software, your internet service provider, and your device’s regional and language settings.
- Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).
We use various current — and later — developed tracking technologies to automatically collect information when you use the Services, including the following:
- Log Information: Log information is data about your use of the Services, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.
- Web Beacons (“Tracking Pixels”): Web beacons are small graphic images, also known as "internet tags" or "clear gifs," embedded in web pages and email messages. Web beacons may be used to count the number of visitors to the Services, to monitor how users navigate the Services, and to count content views. Pixels are used in combination with cookies to track activity on a particular browser on a particular device. We may incorporate pixels from separate entities that allow us to track our conversions, bring you advertising both on and off the Services, and provide you with additional functionality, such as the ability to connect our Services with your social media account.
- Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Services. It is temporarily downloaded onto your device from our web server or another entity with whom we work, is active only while you are connected to the Services, and deleted or deactivated thereafter.
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, please see “Analytics and Advertising” and “Your Rights and Choices” below.
Information from other sources: TDSC also collects information from other sources. The categories of other sources from which we have collected information, including but not limited to in the last 12 months, include the following:
- Data brokers or resellers from which we purchase data to supplement the data we collect.
- Social Networks when you engage with our content, reference our Services, or grant us permission to access information from the social networks.
- Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
- Publicly-available information, including data in the public domain.
3. How do we use information?
TDSC collects and uses your information for business and commercial purposes in accordance with the practices described in this Statement. Our business and commercial purposes for using information, including but not limited to in the last 12 months, include the following: (a) to respond to your requests for information about TDSC and the products and services we make available to you (communications may come from TDSC or affiliated organizations); (b) to process your orders for products and services; (c) to provide you with communications about TDSC and its offerings; (d) for purposes included in this Statement; (e) to improve the content, appearance and utility of the Services and for internal business purposes; (f) to conduct research, including focus groups and surveys; (g) to provide you with advertisements and communications in any form about TDSC (and affiliated organizations) and its offerings, products, services, promotions, rewards, and events we think you might be interested in (for information about how to manage these communications and marketing efforts, please see “Your Rights and Choices” below); (h) to track your use of the Services for internal research purposes and to enhance our product messaging to you; or (i) for any other business or commercial purposes at your direction or with your consent.
Marketing or promotional purposes. We also use your information to provide you with marketing or other promotional communications via email. If, at any time, you would like to stop receiving these promotional e-mails, you may follow the opt-out instructions contained in any such e-mail. Please note that by opting out, you may prohibit TDSC from informing you of offerings that may be of interest to you. It may take up to ten business days for us to process opt-out requests. Please note you cannot opt-out of non-promotional emails, such as those about your account, your application or any products or services you have requested or received from us, for other customer service purposes, or TDSC’s ongoing business relations.
Mobile device information. We use your information collected automatically through your mobile device to provide you with location-based services and other personalized content. Most mobile devices allow you to customize various privacy settings, such as location services. For more information about how to do this, please contact your mobile service provider or the manufacturer of your mobile device to learn how to adjust the settings on your device. Please note that if you choose not to provide us with this information through the mobile version of the Services, you may not be able to use all of the Services’ features.
Disposal of information. In accordance with our routine record keeping, we delete certain records that contain information you have submitted through the Services. We are under no obligation to store such information indefinitely and disclaim any liability arising out of, or related to, the destruction of such information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons. We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account, please contact us at firstname.lastname@example.org. We will retain and use your information, in accordance with applicable privacy laws, as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, or comply with applicable privacy laws.
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For additional information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
4. How do we share the information we collect?
TDSC shares information we collect in accordance with this Statement. The categories of entities to whom we disclose information, including in the last 12 months, include the following:
Affiliates. We share your information with affiliates for marketing and/or other business, administrative or operational purposes.
Service providers. We share your information with service providers that provide certain services to us, including, but not limited to, payment card processing, shipping, product fulfillment, email distribution, market research or promotions management. These service providers have access to your information in order to perform their functions on our behalf. However, we contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the service for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purposes except as prohibited by applicable law.
Business transfers. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or our assets, or assets related to the Services, information, information about how the Services are accessed and used, and any other information that we have collected about the users of the Services may be disclosed to such entity as one of the transferred assets. Also if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
Security and compelled disclosures. TDSC shares information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, safety or security of us, the Services or anyone else.
Promotions. When you voluntarily enter a sweepstakes, contest, or other promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.
Public Forums. We share information you make public through the Services, such as information in your profile or that you post on public boards. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below.
Facilitating Requests. We share information at your request or direction, such as when you choose to share information with a social network about your activities on the Services.
With your permission. At your direction or request, we share your information with notice to you and your consent.
TDSC does not generally sell information as the term “sell” is traditionally understood. However, to the extent the California Consumer Privacy Act is interpreted to include advertising technology activities such as those disclose in the “Analytics and Advertising” section as a “sale,” we will comply with applicable law as to such activity. TDSC discloses the following categories of personal information for commercial purposes: contact information and identifiers such as cookies, demographic information, service use data, internet or other electronic network activity information such as IP Address, and profile information such as inferences. California residents should review the “Additional Disclosures for California Residents” section to learn how to opt out.
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
5. Social Media and Technology Integrations.
The Services contain content from and offer parts of the Services through websites, locations, platforms, and services operated and owned by separate entities. In addition, our Services integrate technologies operated or controlled by separate entities into parts of our Services. Some examples include:
- Links. Our Services include links that hyperlink to websites, platforms, and other services not operated or controlled by us.
- Liking, Sharing, and Logging-In. We may embed pixel or SDK on our Services that allows you to “like” or “share” content on, or log-in to your account through social media. Remember that the social media network may independently collect information about you through the integration. Also, if you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us.
- Brand Pages and Chatbots. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on Facebook Messenger) is treated in accordance with this Statement. Also, if you publicly reference our Services on social media (e.g., by using a hashtag associated with TDSC in a tweet or post), we may use your reference on or in connection with our Services.
- Voice-Activated Skills. We may offer skills through Alexa, Google Home, and other voice-activated platforms, and use the voice processing and other technologies discussed in the “Information collected automatically” section above. Any information you provide to us when you engage with our skills is treated in accordance with this Statement.
6. Analytics and Advertising.
We use analytics services, such as Google Analytics, to help us analyze your access to and use of the Services, compile statistic reports on the Services’ activity, and provide other services relating to Services activity and Internet usage. Similarly, we work with ad serving services, advertisers, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of this process, we may incorporate tracking technologies into our Services (including our website and emails) to track your activities across time and services for purposes of associating the different devices you use, and sending you relevant ads and other content after you have left the Services (“Interest-based Advertising”).
We also use audience matching services to reach people (or people similar to people) who have visited our Services or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to a technology service or incorporating a pixel from a technology service into our own Services, and the technology service matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Services and may share your email address with Facebook as part of our use of Facebook Custom Audiences. Some technology services, such as LiveRamp, may provide us with their own data, which is then uploaded into another technology service for matching common factors between those datasets.
TDSC does not generally sell information as the term “sell” is traditionally understood. However, to the extent the California Consumer Privacy Act is interpreted to include Matched Ads, we will comply with applicable law as to such activity. California residents should review the “Additional Disclosures for California Residents” section to learn how to opt out.
For further information on tracking technologies and your rights and choices regarding them, please see “Information collected automatically” above and “Your Rights and Choices” below.
7. Your Rights and Choices.
A. Account Information.
You may access, update, or remove certain information that you have provided to us through your account by visiting your account settings or sending an email to email@example.com. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and comply with applicable privacy laws.
B. Tracking Technologies Generally.
- Cookies and Pixels. Most browsers accept cookies by default. With most Internet browsers, you can erase cookies from your device’s hard drive, block cookies or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions. Browsers offer different functionalities and options so you may need to set them separately.
- Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Please be aware, however, that some features and programs of our Services may be unavailable to you if cookies are erased or blocked, or you disable or remove other tracking technologies.
C. Analytics and Advertising Tracking Technologies.
The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Some of the advertisers and service providers that perform advertising-related services for us and our partners participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). TDSC is not responsible for the effectiveness of, or compliance with, any other entities’ opt out options or programs or the accuracy of their statements regarding their programs.
To opt out of of using your data for Matched Ads, you should be able to hover over the box in the right corner of such a Facebook ad and find out how to opt-out with us from such list. If you opt-out with us from Facebook matched list ad services, we will remove the matching information from that Facebook list, however, this will not take effect immediately and if you have multiple emails or other accounts you may have to opt-out separately for each one. Alternatively, to opt out you can contact us at firstname.lastname@example.org and specify that you wish to opt out of matched ads. We will request that the applicable technology service not serve you matched ads based on information we provide to it.
You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devises) or “Opt out of Interest-Based Ads” (for Android devices).
Please note that if you opt out of using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or accuracy of any company statements regarding their opt out options or programs.
You can “opt-out” from receiving certain promotional communications from TDSC, which may prohibit TDSC from informing you of certain offerings that may be of interest to you. To opt-out of receiving certain promotional communications (emails and push notifications) from us at any time by (i) for emails, following the instructions as provided in emails to click on the unsubscribe link or by sending an email to us at email@example.com with the word UNSUBSCRIBE in the subject field of the email; and (ii) for push notifications, adjusting the permissions in your mobile device. Please note that your opt out is limited to the email address or device used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing, or TDSC’s ongoing business relations.
8. How do we protect your information?
TDSC maintains reasonable administrative, physical, and technical security safeguards designed to prevent unauthorized intrusion to the Services and the loss, theft, misuse and unauthorized access, disclosure, alteration, destruction, or acquisition of information by unauthorized persons. However, we cannot guarantee that your communications with us will be completely secure or free from unauthorized access by third parties. You use the Services and provide us with your information at your own risk.
The Services are intended for a general audience, and is not directed at children under thirteen (13) years of age. TDSC does not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe TDSC has collected such information from your child in a manner not permitted by law, please email us at firstname.lastname@example.org or send a letter to 1201 K Street, 16th Floor Sacramento, CA 95814 (Attention: Legal). We will remove such data to the extent required by applicable laws.
In California, we do not knowingly “sell” the personal information of minors under 16 years old.
10. International Transfer.
We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Services from outside of the U.S., please be aware that information collected through the Services may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Services or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Statement.
11. Additional Disclosures for California Residents.
A. Shine the Light.
Customers who are California residents may request (i) a list of the categories of personal information that we have disclosed to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. If you would like to request this information, please email your request to email@example.com. In your request, please specify that you’re making a “California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year. Please allow 30 days for a response.
B. Right to Know and Delete.
Consumers who are California residents (and not representatives of businesses, whether those businesses are our customers or others) have the right to know certain information about our data practices in the preceding 12 months. In particular, they have the right to request the following from us:
- The categories of personal information we have collected about them;
- The categories of sources from which the personal information was collected;
- The categories of personal information about them that we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold; and
- The business or commercial purpose for collecting or selling the personal information.
In addition, in certain circumstances California consumers have the right to delete the personal information we have collected from them.
To exercise any of these rights, California consumers should call our toll-free number at (888) 253-1223, or email us at firstname.lastname@example.org. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
If personal information about you has been processed by us as a service provider on behalf of a customer and you wish to exercise any rights you have with such personal information, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of the customer on whose behalf we processed your personal information. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.
C. Do Not Sell My Personal Information.
To the extent TDSC sells your personal information as the term “sell” is defined under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information . You may also submit a request to opt-out by calling our toll-free number at (888) 253-1223, or emailing us at email@example.com.
We participate in the IAB CCPA Compliance Framework for Publishers & Technology Companies (“IAB Framework”). This means that where you exercise your right to opt-out of the sale of your personal information by clicking Do Not Sell My Personal Information , to the extent we sell your personal information in order to deliver ads tailored to your interests, we will notify downstream participants of the IAB Framework that receive personal information about you to only use your personal information for those specific and limited purposes that are permitted under the IAB Framework.
Please note that the scope of the IAB Framework opt-out may only apply to personal information from the specific browser or device from which you opt-out. In addition, exercising your right to opt-out of the sale of your personal information does not mean that you will stop seeing ads or that you will stop seeing interest-based ads. To learn more about interest-based advertising across sites and additional opt-out choices, please see the “Analytics and Advertising” and “Your Rights and Choices” sections above and the links set forth therein. Where you opt-out of the sale of purposes of the CCPA, but do not opt-out of interest-based advertising more generally, you may continue to receive ads tailored to your interests based upon personal information not sold by us, sold to other IAB participants at least 90 days before you opted out, or sold by other sources from which you have not opted out. We are not responsible for any downstream participants’ compliance with the IAB Framework or the accuracy of their privacy policies or statements regarding their opt-out options or programs.
D. Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
E. Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.
12. Additional Disclosures for Nevada Residents.
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at firstname.lastname@example.org.
13. Changes to this Statement.
This Statement is the sole authorized statement of TDSC’s practices with respect to the collection of information and the subsequent use and disclosure of such information. Any summaries of this Statement generated by third party software or otherwise shall have no legal effect, are in no way binding upon TDSC, shall not be relied upon in substitute for this Statement, and neither supersede nor modify this Statement.
TDSC reserves the right to revise and reissue this Statement at any time. You should bookmark and periodically review this page to ensure that you are familiar with the most current version of this Statement. You can determine when this Statement was last revised by checking the “Last Revised” legend at the top of the Statement. Any changes will be effective immediately upon posting of the revised Statement. Your continued use of the Services indicates your consent to the Statement then posted. If the changes are material, we may provide you additional notice to your email address.
14. How can you ask questions about this Statement or update your information?
If you have any questions or concerns about this Statement, our data practices, our compliance with applicable law, or if you wish to modify, verify, correct, delete, or update any of your information collected through the Services please contact us at email@example.com.
If you have a disability and would like to access this Statement in an alternative format, please contact us at (888) 253-1223 or firstname.lastname@example.org.
We referenced a few additional tracking technologies here that may be associated with your services. Please review these technologies, and if you do not foresee using some of these technologies, or if you think we are missing any, please revise accordingly.