Consumer Health Data Privacy Policy
Last Updated: July 22, 2024
This Consumer Health Data Privacy Policy (this “Policy”) supplements Dentsply Sirona Inc.’s (“Dentsply Sirona”) Privacy Notice at www.dentsplysirona.com/privacy and applies to the collection of “consumer health data” subject to the Washington My Health My Data Act (“MHMDA”) collected through our website at www.dentsplysirona.com, www.byte.com, www.suresmile.com and www.wellspect.us. This Policy does not apply to information or practices that are not subject to the MHMDA, such as publicly available information, personal health information governed by the Health Insurance Portability and Accountability Act of 1996 and related regulations (“HIPAA”), personal information governed by the Fair Credit Reporting Act, or job applicant and employee information.
1. The Categories of Consumer Health Data We Collect
The data we collect depends on the context of your interactions with Dentsply Sirona. Due to the broad definition of “consumer health data” under MHMDA, many of the categories of data we collect could also be considered consumer health data. We may collect the following categories of “consumer health data”:
- Individual health conditions, treatment, diseases, or diagnosis;
- Diagnostic testing, treatment or medication
- Health-related surgeries and procedures
- Social, psychological behavioural, and medical interventions;
- Bodily functions, vital signs, symptoms, or measurements of the information described in this Section 1;
- Data that identifies a consumer seeking healthcare services, such as internet, network, or other electronic activity relating to your interaction with our websites or advertisements;
- Information processed to associate or identify a consumer with the data described above that is derived or extrapolated from non-health information.
2. Purposes of Collection and How Dentsply Sirona Uses Consumer Health Data
Generally, we may collect and use the consumer health data that we collect for the purposes set forth below:
- As reasonably necessary to provide you with the products or services you have requested;
- To provide support in connection with the use of our products and services;
- To communicate with you;
- To establish and manage your account;
- To administer the services and our relationship with you;
- To send you updates about Dentsply Sirona and the products and services we offer;
- To prevent, detect and investigate security incidents;
- To conduct performance analytics, identity verification and authorisation, site and application optimisation, and quality control;
- To protect against malicious or illegal activity;
- To ensure the appropriate use of our products and services;
- To improve our products and services and to develop new products and services;
- For short-term transient use of online identifiers;
- For quality and safety assurance;
- For internal research and development to evaluate the effectiveness of our products and services;
- For purposes of marketing, advertising, and product promotion, including to contact you regarding our programmes, products, and services, surveys, and topics that be of interest or useful to you and measuring or understanding the effectiveness of non-personalised advertising; and
- To comply with our legal and regulatory obligations.
3. The Categories of Sources From Which We Collect Consumer Health Data
In general, we may collect consumer health data from the following categories of sources:
- Directly from you;
- Those authorised to provide personal information on your behalf, such as your guardian, healthcare provider, or authorised representative;
- Health insurance companies and other payors;
- Payment processors and other financial institutions;
- Your devices;
- Data analytics partners; and
- Advertising networks.
4. The Categories of Consumer Health Data That We Share
We may share any of the consumer health data categories listed above with the following categories of third parties and affiliates:
- Affiliate and subsidiary companies of Dentsply Sirona, Inc. (complete list available here)
- Government entities
- Regulators
- Operating systems and platforms
- Distributors and/or dealers
- Third parties we, our affiliates, or subsidiaries are or may be acquired by, merged with, financed by, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. We may also share certain personal information as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructurings, to lenders, auditors, and other advisers, including attorneys and consultants, as part of due diligence or as necessary to plan for a transaction;
- Advisers and agents
- Business partners, processors, service providers, and contractors that help us provide products and services to you and to our Dentsply Sirona affiliates.
We instruct these affiliates and third parties to only use consumer health data as permitted by our contacts with them and consistent with applicable law.
We may also disclose your consumer health data as permitted by applicable law, including:
- With your consent;
- To prevent, detect, protect from, or respond to security incidents, identity theft, fraud, harassment, or malicious or deceptive activities;
- To a third part acquiring our assets if we sell our business or otherwise as part of a merger, acquisition, bankruptcy, or other transaction involving a third party taking control or our assets or business;
- To investigate, report or take legal action to protection our rights, property and safety and the rights, property and safety of others;
- To protect your or others’ vital interests, including health and safety.
5. Your Privacy Rights
MHMDA provides consumers with the following rights:
- Know/Access: The right to confirm whether Dentsply Sirona collects, shares, or sells your consumer health data and the right to access such consumer health data;
- Withdraw consent: The right to withdraw consent from Dentsply Sirona’s collection and sharing of your consumer health data; and
- Deletion: The right to have your consumer health data deleted.
Exercising Your Privacy Rights
Requests to Know/Access and Delete
To make a request to know/access or delete your consumer health data, please email us at privacy@dentsplysirona.com. Before completing your request, we may need to verify your identity or your authority to make a request on behalf of another person. We may send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity, depending on the type of your request.
Requests to Withdraw Consent
- Collection: To opt out of Dentsply Sirona’s collection of your consumer health data, email your request to privacy@dentsplysirona.com. Please note that if you withdraw your consent to Dentsply Sirona’s collection of your consumer health data, we may be limited in the manner in which we can provide our services to you.
- Sharing: To opt out of Dentsply Sirona’s sharing of your consumer health data with third parties and affiliates, please send an email with your request to privacy@dentsplysirona.com.
If your request to exercise a right under the MHMDA is denied, we will provide instructions for how you can appeal our decision. If your appeal is unsuccessful, you can file a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.
