Pacific Smiles Group Limited (“PSG”) and Adent ApS (“Adent Health”) are proud to offer our dental care services and products, including the Pacific Smiles Dental app for Android and iOS (“the apps”).
PSG and Adent Health separately deliver parts of the services to you. PSG is the provider of the network of dental clinics accessed through the apps (“Your Dentist”). The apps are powered by technology developed and maintained by Adent Health.
This policy explains how we use your personal data. We want to help you understand how we work with your data so that you can make informed choices and be in control of your information. We invite you to spend a few moments understanding this policy. We may update this policy from time to time and, if we make any material changes, we will notify you when we do so. We will provide you with the opportunity to review such changes. Your continued use of our products and services after we have notified you will be subject to the terms of the updated policy.
Who we are
The data controller and responsible for your personal data is Adent ApS (CVR. 40512977) Knabrostræde 20, 3, 1210, Copenhagen K. ('Adent', 'us', 'we' or ‘our’).
What personal data we hold and how we get it
We use the following categories of personal data:
When you register with us you are asked to provide us with basic information about yourself, such as your name, date of birth, phone number, and email address.
Dental care, health and medical information
When you make use of our Services and Products you will have the opportunity to provide us with information about yourself and your dental related lifestyle, including dental and related health and medical information, and images of your teeth and mouth, including the way you store, organize and comment on the uploaded images.
It is entirely your own decision which data you want to provide and upload in our App, and through our Web Widgets.
We only collect and process this information to provide you with the Dental Health Assessments you request, to let you establish Dental Health Plans and dental wellness routines and otherwise to let you make use of the facilities offered in our App, including to organise and hold the information in order to make it available to you.
You will have the opportunity to connect to Your Dentist and to exchange information with Your Dentist in the context of digital consultations. It is entirely your own decision whether you wish to connect to and exchange information with Your Dentist. If you do so we will process the information on the identity of Your Dentist, the number and dates of digital consultations, and the information you provide to and receive from Your Dentist. This information may include sensitive information such as information about your dental health, related health, symptoms, diagnoses, treatments, medications and procedures etc.
If you make any payments on the App, your credit/debit card details are processed directly by a third-party processor that will store all payment information and transaction details. We will only retain details of transactions on secure servers and we will not retain your credit or debit card information.
Technical information and analytics
When you use our App and our Web Widgets, we may automatically collect the following information where this is permitted by your consent:
(a) technical information, including the address used to connect your mobile phone or other devices to the Internet, your login information, system and operating system type and version, browser or app version, time zone setting, operating system and platform, and your location (based on IP address); and
(b) information about your visit, including services you viewed or used, App response times, interaction information (such as button presses) and any phone number used to call our customer service number.
We work with partners who provide us with analytics and advertising services (for our services only and not for third party advertising). This includes helping us understand how users interact with our services, providing our advertisements on the internet, and measuring the performance of our services and our adverts. Cookies and similar technologies may be used to collect this information, such as your interactions with our services.
What we use your personal data for
Processing of information by Adent is done in compliance with applicable regulation, and in order to fulfil the below-mentioned purposes. The table below summarises the purpose and the legal basis for this.
The above is elaborated on here:
We obtain and use your personal details and financial details in order to establish and deliver our contract with you.
We obtain and use your dental and related health information because this is necessary for dental care purposes, including Dental Health Assessments and the provision of Dental Health Plans. This includes the information and images collected through our App, our Web Widgets, customer support service, our digital services. The legal basis for processing non-sensitive data is GDPR art. 6(1)(b). Processing is necessary for the performance of a contract with you. Processing of Health data is based on your explicit consent, c.f. GDPR art. 9 (2)(a).
We only collect and process this information to facilitate your possibility to have remote digital consultations with Your Dentist. The legal basis for processing non-sensitive data is GDPR art. 6(1)(b). Processing is necessary for the performance of a contract with you. Processing of Health data is based on your explicit consent, c.f. GDPR art. 9 (2)(a).
Improve the quality of service: Where you have provided your explicit consent, we will use your dental care information (always having removed personal identifiers, such as your name, address and contact details) to improve our dental care products and services, and our artificial intelligence system, so that we can deliver better dental care to you and other Adent users. This does not involve making any decisions about you - it is only about improving our products, services and software so that we can deliver a better experience to you and other Adent users, and help achieve our aim of making dental healthcare accessible to everyone. Strict confidentiality and data security provisions apply at all times.
We may obtain and use data about your precise location where you give your consent (through providing us access to your location), for example, to help direct you to a local dentist. We may also derive your approximate location from your IP address.
We use your email address to contact you with occasional updates and marketing messages where you have not opted out, based on our legitimate interest in marketing our services to you and subject to your right to opt out at any time.
Based on our legitimate interest in managing and planning our business, we may analyse data about your use of our products and services to, for example, troubleshoot bugs within the App, forecast demand of service and to understand other trends in use, including which features users use the most and find most helpful, and what features users require from us. This does not involve making any decisions about you - it is only about improving our App, Web Widgets, and Websites so that we can deliver better services to you. Strict confidentiality and data security provisions will apply at all times.
Where necessary, we may need to share personal and financial details for the purposes of fraud prevention and detection.
We also store your dental and related health information, such as notes from Dental Health Assessments, Digital Consultations with you and your interactions with our digital services, for safety, regulatory, and compliance purposes. For example, we may need to review your information and, where necessary, make disclosures in compliance with reasonable requests by regulatory bodies including the Danish Health Data Authority, Danish Agency for Patient Complaints, or as otherwise required by law or regulation.
In order to support the medical research on dental health and detection methods, we may use your data, pseudonymized (without a direct link to your identity) or anonymized (without us being able to identify you at all), for research purposes. This may include sharing your data with carefully selected third party research institutions. By uploading your images in the App, or through our Web Widgets, and having confirmed your Informed Consent, you explicitly consent to the images being processed for the purposes of the provision of the services and to be used anonymously for the purposes of research and testing of our services. As such, your images may be reviewed by our employees or third-party consultants who work for us and who are bound by strict confidentiality. We will ask for your consent to process your data anonymously for research purposes.
We may use non-personal data (data from which an individual cannot be identified) to improve our products and services.
Personal data from registered practitioners
In addition, we collect personal data of dental professionals and practitioners from the moment you register to become a member of our Services. Such information may include: e-mail address, first name, name, practice name and address, certified legal entity identification numbers, phone number, fax number, time zone, gender, academic status, Adent services used and settings, language, place/event you first met our team, training date, messages, activities on the Adent platform, or in other ways use our Services and Products.
This information is processed by Adent in compliance with applicable regulation, and in order to fulfil the below-mentioned purposes.
Sharing your personal data with others
We allow you to share your personal data with our partners (such as a dentist you choose to book an appointment with and/or visit).
We may share your personal data with companies we have hired to provide services on our behalf. Such service providers act as data processors on our behalf, acting strictly under a data processor agreement in accordance with Article 28 GDPR. Those data processors are bound by strict confidentiality and data security provisions, and they can only use your data in the ways specified by us. Our data processors provide secure cloud hosting, secure video conferencing facilities, and the option to develop and maintain our App, and Web Widgets.
We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of our services or the physical safety of any person.
Except as described above, we will never share your personal information with any other party without your consent.
We will destroy or de-identify your personal information once it is no longer required for the purpose or purposes for which it was collected.
If you terminate our Services and delete your account, we will retain your personal information for a period of 12 months, after which we will delete your data.
Documentation of e-marketing consent will be retained for 24 months or as required by law. We will retain the images you have uploaded prior to termination in an anonymous form only, for the purposes of medical and commercial research, and for advancing and testing of the Services to the benefit of others.
We retain your dental care and related medical records in accordance with national best practice guidance - in particular, the latest advice and recommendations provided by the Danish Patient Safety Authority on their website, https://en.stps.dk/en/. The below is a summary of our retention policy, but we may retain records for other periods as required by law or regulation.
Dental health records
Retention period: Dental care health records are retained for at least 10 years after death or after the patient has permanently left the country unless the patient remains in the European Union. In the case of a child, if the illness or death could have potential relevance to adult conditions or have genetic implications for the family of the deceased, the advice of clinicians should be sought as to whether to retain the records for a longer period. Electronic patient records (EPRs) must not be destroyed or deleted, for the foreseeable future.
Data storage, security and transfers
We store all your personal health data - including your dental care information, information on Dental Health Assessments, information on any dental plan you choose to use with our services, medication information and any other related health information - on secure servers. We may also store the data in a secure cache, not accessible from other apps without your explicit consent, on your personal mobile device or the device you choose to log in with.
Where you have chosen a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Adent does not store or handle your password. Authentication with our services is processed via a third party authentication provider that has certification for compliance with the security management best practices and security controls specified by ISO 27001. If you have registered yourself as a Dental Clinic in our App we store your Clinic Secret Key encrypted in secure data storage.
We do not store any credit or debit card information. Payments are processed via a third-party payment provider that is fully compliant with Level 1 Payment Card Industry (PCI) data security standards. Any payment transactions are encrypted using SSL technology.
Whenever we rely on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at firstname.lastname@example.org The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. If you withdraw your consent you may not be able to use the services of our App.
You also have specific rights under the GDPR and DPA to:
Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Be aware that you may always access your Dental Health Assessments and your active Dental Care Plans through the App
Ask us to rectify or erase information we hold about you
Ask us to restrict our processing of your personal data or object to our processing; and
Ask for your data to be provided on a portable basis.
Please contact us at email@example.com if you wish to exercise any of the above rights.
You may also contact The Danish Data Protection Agency (DPA/Datatilsynet, the data protection regulator in Denmark): Carl Jacobsens Vej 35, 2500 Valby, telephone: 0045 3319 3200 (local rate).
For any questions or concerns, you can contact us by sending an email to firstname.lastname@example.org.