The nature of our business requires a relationship of trust and discretion with our customers. Clinical Research Dental Supplies and Services Inc. (hereafter, “CRD,” “we,” “our” or “us”) is committed to the responsible collection, processing, protection and sharing of all personal information. This policy applies to visitors and customers (hereafter, “you”) of CRD operated websites, social media accounts and other Services (hereafter, our “Services”).
You have certain rights and choices regarding your personal information. For more information, please refer to the Your Choices and Rights section of the Policy.
I. COLLECTION OF PERSONAL INFORMATION
“Personal Information” is defined as any factual or subjective information, recorded or not, about an identifiable individual. For our purposes, this information includes the following:
• Personal details such as your name and occupation
• Contact details such as addresses, telephone numbers, fax numbers and email addresses
• Account information such as account settings and preferences
• Transaction records such as purchase history, event attendance and service inquiries
• Social media data such as account names
• Professional records such as a dental license identification number
• Billing information such as payment card information
• Communications records such as support requests or general inquiries
• Other information as voluntarily provided during a prior interaction with us
Directly Collected Personal Information: Personal information collected directly by CRD is for the specific purpose of fulfilling the Services you have requested, paid or otherwise. We restrict the amount of personal information collected to the minimum required to fulfill said Service. For example, to fulfill an order for physical products we will require details such as your business address and payment method but will never ask for your patient records. Please be aware that any personal information that you submit voluntarily through an optional form field, email or other mechanism may be retained by CRD.
Information obtained directly from you is collected through actions such as online account registrations, customer service inquiries, purchase transactions, course registrations, seminar correspondence, tradeshow correspondence, surveys, contests and product evaluations. All collection methods will explicitly explain the intended uses of the personal information being collected as well as obtain the appropriate level of consent from you. Consent may be written, oral or implied. CRD will always obtain further consent in the event that we wish to use previously acquired personal information for an additional purpose other than what was previously agreed to. You may refuse or withdraw your consent at any time. However, please note that this may inhibit CRD’s ability to provide you with certain Services.
Device Information Collection: When you visit a CRD owned property, we automatically collect certain non-personally identifiable information related to your device. This information includes, but is not limited to, your device hardware and software, web browser, IP address, region and language of preference.
We collect Device Information with the following technologies:
• Log files: These files track actions occurring on the website and collect data including your IP address, browser type, ISP, browsing behaviour and date/time stamps. These files are kept primarily for security and analytics purposes.
• Web beacons, tags and pixels are electronic files used to record how you browse our digital properties. Theses technologies are primarily leveraged for security, analytics and advertising purposes.
Personal Information Collected from Third Parties: We receive personal information from third parties such as our manufacturing partners, continuing education partners, distribution partners, social media networks and publicly-available sources. In all cases CRD will ensure that the third party involved is obtaining the proper consent for both the lawful collection and sharing of your data. CRD will never access personal information from third party unless it is for the specific purpose of facilitating our Services.
II. USE OF PERSONAL INFORMATION
The intended use of personal information will be explained during the collection of said information. Any changes to the intended use of personal information will require your notification and further consent.
We use personal information for the following purposes:
• Fulfillment of Services: The delivery or return of product as requested by you, the fulfillment of continuing education as requested by you and the processing of payments related to our services.
• Authentication of account credentials: As necessary to ensure the security of your account(s) with us.
• Communications: To provide important status updates, respond to your inquiries and provide general customer service related to the use of our Services.
• Marketing: To communicate changes to our Services, limited time promotions and any other purchase opportunity that we believe may be of interest to you. All CRD marketing communications are compliant with CASL. You may opt-in or opt-out at any time.
• Improvement of our Services: Your feedback helps us to better understand the value that our Services are providing. Information collected through customer service channels, surveys, digital analytics tools and other sources help us identify ways to continually improve your experience with CRD.
• Tailor your experience with our Services: By leveraging previously collected personal information to streamline your experience with our Services. For instance, we can prepopulate certain fields during an online purchase checkout.
• Provide more relevant advertising: By using personal information to serve you more relevant marketing communications recommending certain products, courses or content that is more likely to be relevant to your needs.
Anonymous and Aggregate Information: Sometimes we will collect information anonymously, for example, through a survey with no personal information collection or a digital analytics tool that collects information via anonymous cookies. In other cases, we will combine multiple sources of data while simultaneously removing all pieces of personally identifiable information for purposes such as financial analysis, trend forecasting or the development of marketing content. Information that was collected anonymously or is subsequently anonymized may be used for any purpose that we see fit.
III. ACCURACY OF PERSONAL INFORMATION
CRD will make every reasonable effort to maintain the accuracy of all personal information kept on file, however, it is impossible to maintain perfect accuracy without violating other sections of this policy related to consent. You are responsible for notifying us if you notice any inaccuracies in the personal information that you have on file with us. You may be required to answer specific questions to verify your identity or provide documentation to validate your change request. Further information concerning access to, changes to or requesting the deletion of your personal information can be found within the Your Choices and Rights section of this policy.
IV. SHARING OF PERSONAL INFORMATION
CRD will only share personal information with third parties where necessary to fulfill the Services being provided to you. In each case, only the personal information required by the third party to fulfill their specific obligation will be provided.
We may share personal information for the following reasons:
• Logistics partners: to facilitate the delivery of product and other physical communications.
• Continuing education partners: To facilitate the successful delivery of continuing education content, any required communications before or after the event and other tertiary services (e.g. lodging).
• Manufacturing partners: To respond to your inquiries or market new products or services related to previously purchased products or services.
• Technology providers: To facilitate the successful operation of our digital properties, enable various features, send communications, analyze data and detect or prevent potentially fraudulent activity. 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 may also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
• Payment processing: To transact purchases that use a credit or debit card with our payment processor.
• In the event of a corporate transaction: To facilitate an acquisition, merger or divestiture of assets.
• To protect rights and property: If we believe in good faith that there is a threat to our rights, property, integrity of our Services or our employee’s safety.
• Legal compliance: 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.
• At your request: We will share your personal information on file with you or with a named third-party subject contingent upon your consent.
V. INTERNATIONAL TRANSFERS OF INFORMATION
Information about you may be transferred to, or accessed by, entities located around the world. Some of these entities may be located in countries that do not provide an equivalent level of protection for personal information as your home country. We have put in place measures to limit the amount of personal information transferred outside of Canada. Where the transfer of personal information outside of Canada is required to facilitate our Services, we have put in place safeguards to provide adequate protections, in accordance with the applicable Canadian legal requirements.
VI. STORAGE AND PROTECTION OF PERSONAL INFORMATION
CRD has taken and continues to invest in the appropriate precautions to safeguard your personal information from unauthorized access, disclosure, theft, use or tampering. These precautions include physical security measures to protect both digital and physical files, training to ensure employees understand their responsibilities with respect to protecting your personal information and technical solutions to prevent unauthorized access to your personal information. While no data protection system can ever be considered completely secure, we consider the measures we have implemented appropriate for the types of personal information that we hold.
When your payment card is used to purchase any of our Services the transmission is protected by modern cryptographic protocols. CRD does not store your payment card information. We use third party payment processors who become the controllers of this information. They are required to demonstrate that they are taking the proper precautions and maintaining the appropriate compliances (e.g. PCI DSS) on an ongoing basis.
As a consumer of our Services, you also play a role in keeping your personal information secure. You should never share your personal account information with anyone and as a best practice you should routinely rotate your password(s). If you have any reason to believe that your account has been compromised you should contact us immediately.
We will retain your personal information for as long as your account is active with us and for a period of time thereafter. We retain this information for the purposes of business analysis, audits, legal compliance and in the event that you wish to recommence the use of our Services. CRD will only retain your information for as long as it is necessary to fulfill the purposes for which it was collected, or as required by law.
Cookies are a small text file created by a website and stored within your browser either temporarily for that session alone or longer term until they expire or are purposefully deleted. Cookies allow a website to provide a more personalized and convenient browsing experience. For instance, they can maintain the items you had previously placed in your shopping cart if you leave our webstore and then return at a later time.
During your visits to other websites, we or our advertising partners may use certain anonymized cookie data collected from our websites to serve you with targeted advertisements that we believe will be of interest to you.
For more information about cookies, and how to disable cookies, visit https://www.allaboutcookies.org.
VIII. LINKS TO OTHER WEBSITES
Our Services contain links to other websites or services not owned or controlled by CRD, including links to the websites of our manufacturing, logistics, continuing education and media partners. This Policy only applies to the information collected by our Services. We have no control over these third-party websites, and your use of third-party websites and features are subject to the privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Services. Your use of third parties' websites linked to our Services is at your own risk, so we encourage you to read the privacy policies of any linked third-party websites.
IX. CHILDREN’S PRIVACY AND PARENTAL CONTROLS
Our Services do not aim to solicit any personal information from children. If you are under the age of 18, you are not authorized to use our Services. If you become aware that your child or a child under your care has provided us with personal information without your consent, please contract us to have these records deleted.
X. YOUR CHOICES AND RIGHTS
Email: If you no longer wish to receive email marketing and promotions from us, you may click the “unsubscribe” link found at the bottom of such emails to opt-out of future email marketing communications as per CASL. Please note that this opt-out only applies to marketing communications and that you will still receive all service-related communications such as purchase confirmations, purchase shipment notices, course registration confirmations, responses to inquiries, etc.
Cookies and Targeted Advertising: For more information about cookies and how to disable cookies you can visit https://www.allaboutcookies.org. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.You can opt out of targeted advertising by using these links:
• Facebook: https://www.facebook.com/settings/?tab=ads
• Instagram: https://help.instagram.com/615366948510230
• LinkedIn: https://www.linkedin.com/psettings/advertising
• 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: https://optout.aboutads.info/
Access to, Correction of and Deletion of Your Personal Information Records: You may request to review your personal information, if any, on file with CRD at any time by contacting us. If there are reasons why your access is denied, you will be advised of those reasons either orally or in writing dependent on your method of contacting us. Upon access, you may further request that this information be corrected, altered or deleted. We will take every reasonable effort to accommodate your request but each step of this process can take up to ten business days. In the rare case that more than ten days is required to process your request you will be notified in writing, including an updated timeline. Please note that changing or deleting your records may restrict your ability to further use our Services and that some records cannot be completely deleted for legal or compliance reasons until a certain amount of time has elapsed.
XI. CHANGES TO THIS POLICY
XII. HOW TO CONTACT US
If you have any questions about this Policy or the way in which your personal information has been used, please contact us using one of the following methods:
Mail: Clinical Research Dental, 167 Central Ave., Suite 200, London, Ontario, Canada N6A 1M6