Privacy Policy

Privacy Policy - Last updated: August 12, 2020 

At NewSmile, we take your privacy seriously and we want you to know what information we collect and how we collect the information. We also want you to know how we use and share your information. In addition to the following privacy policy, we encourage you to view our Terms of Use on our website. The following applies to NewSmileLife.ca and other websites under our control (collectively, the “Website”).

What Information we Collect

We do not collect personally identifiable information unless you provide such information. The following information may be collected through your use of the Website:

Contact information such as name, mailing address, email address and telephone. 
Date of birth User name, account number, and password. Medical history (if needed per dental professional’s request). 
Browser information (IP addresses, browser type, internet service provider (ISP), referring and exit pages, platform type, date/time of visit, and number of clicks on the Website).

How We Collect Your Information

 Log Files: Any time you visit the Website, our servers will gather information from your browser as noted above. We gather this information to analyze trends, administer the Website, tack visitor movement, prevent fraud, and better enhance the Website.

 Cookies: We use “cookies” to keep track of some information while you visit the Website.

 Cookies are very small files placed on your computer which allow us to track users on the Website and distinguish new and repeat visitors. We are also able to save your user preferences and trends. Cookies allow us to properly operate the Website. If you reject cookies in your browser, you may experience less than optimal functionality of the Website. Cookies are not linked to any personally identifiable information.

Web Beacons: We use web beacons to further personalize the Website for our customers and to collect limited information regarding our customers while they visit the Website. Web beacons are small transparent graphic images that are often used in connection with cookies. We may also use web beacons in email communications with you to help us better understand the behaviour of our customers. We do not link web beacons to personally identifiable information.

Sign-up Information: We collect various items of information when you sign up on the Website. This information is used to process orders and help provide you with our services. This is information you provide to us in response to various questions we may ask.

Emails and Telephone Calls: We require an email address to communicate with you. The email will be used for transaction related communications as well as promotional or advertisement purposes. Emails that we send you may contain code to allow us to track your use of the email to help us better understand how to communicate with our customers. If you do not wish to receive emails from us, you may indicate by sending a request to privacy@newsmilelife.ca. We may send you emails regarding the products and/or services you order from us without offering you the option to opt-out of such emails. We may also contact you by telephone to discuss the services and/or products to better assist you with your smile:)

 How We Use Your Information

In general, we use your information to:

Provide the products and/or services you request from us. 

Manage our relationship with you as our customer. 

Provide information about the products and/or services. 

Deliver advertisements. 

Better understand the effectiveness of our advertising efforts. 

Manage our business.

 

Disclosure of your information to third parties

Disclosure to Dental Professionals: In order to provide the services and/or products, we will provide your information to our trusted dental professionals. They will use the information solely to assess your fit for the product and/or services and to develop a plan to improve your smile:). Our trusted dental professionals will never share, sell or transfer your information for any use other than as stated herein.

Disclosure to Trusted Third Parties: We may share your information with trusted third party service providers. These parties provide various services to NewSmile  to allow us to operate our business and include, without limitation, website hosting service providers, data storage service providers, etc. Your information will be treated as private and confidential by these third parties.

Disclosure by Law: We may have to disclose your information to third parties as required by law. Any such request must be deemed reasonable upon a request from law enforcement or a legal process requiring us to disclose your information.

By providing your information to us and agreeing to the Terms of Use, you expressly consent to any transfer of your information as described in this Privacy Policy, the Terms of Use, and/or the Website. 

Personal information we collect 


When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”. We collect Device Information using the following technologies: 
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. 


- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. 


- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site. Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information”. 

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information. 



How do we use your personal information? 


We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to: 


- Communicate with you; 


- Screen our orders for potential risk or fraud; and 


- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services from ourselves or affiliates. We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns). On ads served by AdRoll for our advertisers, look for an AdChoices logo (the blue triangle) in the corner of the ad. Click the logo to learn more about interest-based advertising, who served the ad, and manage your ad options. You can also opt out of seeing personalized ads from AdRoll (and other companies) using the NAI opt out tool here.  Please note you will still see ads even if you opt out, but they will not be personalized by AdRoll. For more information please see our privacy notice here.

Sharing you personal Information 


We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. 

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights. 



Behavioural advertising 


As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. 

You can opt out of targeted advertising by using the links below: 
- Facebook: https://www.facebook.com/settings/?tab=ads 
- Google: https://www.google.com/settings/ads/anonymous 
- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads 

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/. 



Do not track 


Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser. 



Your rights 


If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States. 



Data retention 


When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information. 



Changes 


We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. 



Minors 
The Site is not intended for individuals under the age of 18 years old. 

HIPPA

We intend to comply with all requirements of the Health Insurance Portability and Accountability Act (“HIPPA”). We will maintain the privacy and confidentiality of your health information as required by HIPPA and all regulations provided by HIPPA.

Updating and Accessing your Information

You may update your information anytime by logging into your account and providing new, updated, or additional data. If you wish to stop using your account, you may deactivate or delete it (don’t worry, you can always reactivate your account). If you deactivate or delete your account we will continue to provide any and all products and/or services you have previously ordered unless we agree with you in writing to discontinue such products and/or services. If you deactivate or delete your account, we will retain your information but it will not be shared with any third parties unless required by law. All information in a deleted or deactivated account will only be used for internal research and NewSmile marketing purposes. We will retain all information for a commercially reasonable time or as required by law. 

Special Notice to California Residents. Your California Privacy Rights

California Consumer Privacy Act (CCPA)

While this Privacy Policy comprehensively describes how NewSmile Technology and uses personal information about you, the CCPA provides some California residents the opportunity to exercise specific rights relating to data transparency, outlined below. 

Right to Know

At your request, NewSmile Technology will inform you of the categories of personal information we collect about you and the purposes for which those categories of personal information are used for the 12-month period preceding your request, including the following:

  • The categories of personal information we have collected about you;
  • The categories of sources from which your personal information is collected;
  • The business or commercial purpose for collecting or selling your personal information;
  • The categories of third parties with whom we share your personal information; and
  • The specific pieces of personal information we have collected about you.

Right to Delete

You also have the right to request that NewSmile Technology deletes any personal information about you that we have collected from you. NewSmile Technology will respond to a verifiable request from you to delete your data, except in circumstances where it is necessary for us to maintain your personal information in order to:

  • Complete the transaction for which your personal information was collected, provide a good or service requested by you or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug our systems to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
  • If you have provided informed consent, engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research;
  • To enable solely internal uses that are reasonably aligned with your expectations your relationship with us; or
  • Comply with a legal obligation.

To submit a requests under your right to know and right to delete, you must email privacy@newsmilelife.ca. You may also contact us by sending a written request to CCPA Care C/O NewSmile Technology, Ltd., 651 N Broad St, Suite 206 Middletown, New Castle, Delaware 19709. From the time NewSmile verifies the request, we will respond within 45 days, and if additional time is needed, we will communicate extensions with you. 

Other Rights

You have the right not to be discriminated against for exercising any of the rights listed above. NewSmile does not disclose personal information to third parties for their own direct marketing purposes.

Under 18: California Eraser Law Request

If you use our Site or Application when you are under the age of 18, you may request that we remove your User Contributions under certain circumstances. We do not advertise or market any goods and services that are identified as being inappropriate for children under the age of 18.

California law permits minors under the age of 18 to request the removal of her/his User Contributions, subject to certain exceptions.

If you are under the age of 18 and living in California, you may contact us by sending a written request to Customer Care C/O NewSmile Technology, Ltd., 651 N Broad St, Suite 206 Middletown, New Castle, Delaware 19709, or emailing us at privacy@newsmilelife.ca, (if you contact us in writing, via email, please use the subject “California Eraser Law Request”). We may not remove your User Contributions that we are required to retain under any federal or state law, or that have been provided to a third party. While we will do our best to remove a minor’s information upon a valid request, we cannot ensure the complete or comprehensive removal of your User Contributions from our Site or Application, or any information that has been republished, copied, downloaded, or reposted by any third party, and we cannot guarantee that any such information may not be accessible to users of the Internet in the future. We do not advertise or market any of the products or services identified in California Business and Professionals Code Section 22580(i) to users who we have actual knowledge are under 18 years of age.

Do Not Track Signals

We may use automated data collection technologies to track you across websites. We currently do not honour do-not-track signals that may be sent by some browsers.

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honour such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us. 

Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your personal information. You can help protect your personal information and other information by keeping your password to our Application and Site confidential.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and health information will be encrypted when being communicated between us and you. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site or the Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information on the Site or in Application like message boards and other areas where you may post photographs, videos or other content. The information you share in public areas may be viewed by any user of the Site or Application.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or from our Application or Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site, the Application, or the operating system of your computer or mobile device.

Changes to Our Privacy Policy

We will post any changes to our Privacy Policy on our Site or in the Application. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Site’s or Application’s home page/screen. If we make material changes to how we treat our users’ personal information, we will provide notification through a notice on the Site’s or Application’s home page/screen. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Site or the Application and this Privacy Policy to check for any changes.

If you are a resident of California, in addition to the rights set forth in this Privacy Policy:

We will not share any personal information about you with third parties to the extent prohibited by applicable California law or to the extent your prior consent to share is required by applicable California law; and 
You have the right to request information from us regarding the manner in which we share certain categories of information with third parties for their direct marketing purposes. California law gives you the right to send us a request at a designated address (privacy@newsmilelife.ca) to receive the following information: 
the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year; 
the names and addresses of the third parties that received that information; and 
if the nature of the third party’s business cannot be determined from their name, examples of products or services marketed.

We may provide this information in a standardized format that is not specific to your situation. Requests may be sent to privacy@newsmilelife.ca

Special Notice to Vermont Residents

Vermont law places additional limits on sharing information about Vermont residents so long as they remain residents of Vermont. In accordance with Vermont law, we will not share information we collect about Vermont residents to companies outside of NewSmile except: (1) as permitted by law; (2) to companies that perform marketing or other services on our behalf; (3) name, contact, transaction, and experience information to our trusted dental professionals; or (4) with the authorization or consent of the Vermont resident. We also will not share non-transactional information about Vermont residents received from others within the NewSmile family of companies except with the authorization or consent of the Vermont resident.

Privacy Policy Changes

We may update this privacy policy at anytime. If we make material changes, we will notify you via email or by notice on the Website. Please review this page periodically for updates and changes to the privacy policy.

Contact Information

You can contact us about this privacy policy or any other matter at the email address below:

NewSmile 

505-318 Homer St.

Vancouver, BC V6B 2V2

Email: privacy@newsmilelife.ca