Consumer Health Data Privacy Policy
Last updated: March 31, 2024
This Consumer Health Data Privacy Policy applies only to Washington and Nevada residents (referred to herein collectively as “consumers”) and supplements the information in our general Privacy Policy. If there are any inconsistencies between our general Privacy Policy and our practices as described in this Consumer Health Data Privacy Policy, this policy will control. If you are not a resident of Washington or Nevada, this Consumer Health Data Privacy Policy does not apply to you and you should not rely on it.
This Consumer Health Data Privacy Policy describes how Aspen Dental Management, Inc. and our subsidiaries and affiliates (collectively, “Company”, “we”, “us”, or “our”) may collect, use, and disclose personal information that is considered “consumer health data” under applicable state law in connection with Company owned and operated websites or digital properties that link to this Consumer Health Data Privacy Policy and our related email, phone, and other electronic communications, and marketing activities (collectively, the “Site”), and the rights and choices available to consumers with respect to their consumer health data.
“Consumer health data” refers to such term as defined under Washington and Nevada privacy laws, as applicable, and generally refers to personal information that is linked or reasonably linkable to a consumer and that identifies the consumer’s past, present, or future physical or mental health status. Consumer health data does not include protected health information that you may provide to Company in connection with Company’s provision of dental or healthcare services. For more information about our privacy practices relating to those activities, please review any Notice of Privacy Practices provided to you. If there are any inconsistencies between that notice (to the extent provided) and this Consumer Health Data Privacy Policy, the Notice of Privacy Practices will control.
1. COLLECTION OF CONSUMER HEALTH DATA
We collect the following categories of consumer health data directly from consumers through our Site (specifically, website or call center) in connection with scheduling a requested appointment or as part of completing a quiz to assess what solution may fit your needs prior to scheduling an appointment:
Individual health conditions or status, such as dental condition (e.g., broken tooth, tooth pain, painful or bleeding gums).
Medical interventions or health-related procedures, such as dental history or solutions (e.g., previous implants, dentures, or aligners or braces).
Data that identifies a consumer seeking health care services, such as responses to your current dental situation, what is most important when choosing dental implants, and how soon you plan to be ready to get dental implants or another solution, in addition to the data listed above.
2. USE OF CONSUMER HEALTH DATA
We use the consumer health data identified above to fulfill your request to schedule a consultation appointment, to understand and communicate with you about your dental history and future interest in dental solutions, to customize content that may be of interest to you, and to provide you with information about our products and services. Where consumers utilize our call center to schedule a consultation, we and our service provider may record or monitor such calls for quality assurance and training purposes. We may also use the consumer health data identified above for internal reporting and analysis.
3. DISCLOSURE OF CONSUMER HEALTH DATA
We may disclose consumer health data to the following entities or persons as necessary to provide the requested scheduling services:
Related Companies. We may disclose consumer health data to companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us and are co-branded), specifically, The Aspen Group (Team TAG Services, LLC) and Aspen Dental (Aspen Dental Management, Inc.), for the purpose of internal reporting and analysis.
Service Providers. We may disclose consumer health data to third parties who perform services for or on our behalf to provide our scheduling services, such as our website host, and database management.
Affiliated Dental and Healthcare Practices. We disclose your contact information, reason for the appointment, and appointment date and time with the Aspen Dental practice that you select.
Business Transaction Participants. If we sell all or part of our business, make a sale or transfer of assets, or are otherwise involved in a corporate divestiture, merger, consolidation, acquisition, reorganization, dissolution, sale, or other disposition of all or any portion of the business or assets of, or equity interests in the business (including any affiliate), whether as part of a bankruptcy, liquidation, or similar proceeding, we may transfer your personal information, including consumer health data, to third parties as part of that transaction, including at the negotiation stage.
We do not permit third parties to collect your consumer health data over time and across different Internet websites or online services when you schedule an appointment through our webform or complete an online quiz or assessment.
4. RIGHTS REGARDING CONSUMER HEALTH DATA
Washington and Nevada residents may have the following rights concerning their consumer health data. You may submit these requests through our webform available by clicking here: Your Privacy Choices. Please note, these rights are not absolute and, in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.
Access. Request we confirm whether we are collecting, sharing, or selling your consumer health data and to access such data.
Third Parties Sold or Shared. Request we provide a list of all third parties and affiliates with whom we have shared or sold your consumer health data, to the extent applicable.
Delete. Request we delete your consumer health data.
Where we rely on your consent to collect or share your consumer health data, you may at any time withdraw your consent to our collection and sharing of your consumer health data (i.e., request we cease collecting, sharing, or selling your consumer health data), to the extent applicable, as described in the notice provided to you at the time you initially consented.
If we decline to take action on your request, you may appeal such refusal by emailing us within a reasonable period of time after we sent you our decision.
5. CHANGES TO THIS PRIVACY POLICY
Company reserves the right, at any time, to modify this Consumer Health Data Privacy Policy. If we make revisions that materially change the way we collect, use, or disclose consumer health data, we will post those changes in this Consumer Health Data Privacy Policy or as may otherwise be required under applicable law. You should review this Consumer Health Data Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Consumer Health Data Privacy Policy at the top of this page. Your continued use of the Site following posting of changes constitutes your acceptance of such changes.