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Website Privacy Policy

Last Updated: 30 October 2018

SMS OpCo, LLC (“6MS”, “we”, “our” or “us”) is committed to protecting your privacy.  This Privacy Policy applies to all users of our website (including, as described below, our online portals and e-commerce tools) and explains how we collect and use the personal data regarding yourself or others that you may supply to us when visiting the 6MS website.  Our processing of your personal data, as well as personal data collected by any predecessor in interest, is subject to this Privacy Policy and any subsequent updates.

General

We only process your personal data when we have a lawful basis to do so.  For purposes of this Privacy Policy, “personal data” is defined as information that identifies, or can be used to identify, an individual.  We collect personal data from individuals interested in our services visiting our website, from prospective and current short-term orthodontics providers offering 6MS products and services (“Provider” or “Providers”), including registering accounts and obtaining services from us, and patient data provided by Providers.  Any references in this policy to “you” or “your” should be interpreted in the context in which the information is processed.

While 6MS is the controller of personal data that you provide through the website about yourself, we are the data processor for information shared with us by your Provider for the purposes of providing you with our services.  In such instances, your Provider is the controller of your data, and we store and process your personal data on behalf of your Provider.  We only process the personal data shared by your Provider based on clearly defined instructions from your Provider. 

Our legal bases for processing your personal data include your consent, fulfillment of a contractual obligation, and where we have a legitimate interest to process your personal data, provided that our interests do not outweigh your individual rights and freedoms.  Our legitimate interests include:

  • Investigating, preventing, and protecting against fraud, security risks, threats to you and others, and violations of this policy;
  • Verifying your identity and suitability for our short-term orthodontic services;
  • Protecting and defending our rights and properties, including intellectual property;
  • Complying with laws and regulations that apply to us, as well as responding to requests from law enforcement or government authorities or as otherwise required by law;
  • Improving your experiences with our products and services;
  • Understanding and improving our website, user experience, and customer relationships; and
  • Enabling our business operations.

Where we rely on your permission to process your personal data, you have the right to change, withdraw, or withhold your consent.


Personal Data Collection

We collect personal data that you choose to share with us, as well as information provided directly by your browser or device when you visit our website.  If you are a patient receiving short-term orthodontic care with 6MS products and/or services, we also collect personal data from your Provider.

Personal Data Collected from You

Emails and Communications
When you send an email or other communication to 6MS, we ask for your name, phone number, and email address, and, if you are a dentist or dentist practice, we will collect your practice name and practice address.  We also collect the content of your message or submission to us, which contains any additional information you choose to share with us. 

We collect this information when you initiate contact with us for the purpose of responding to your email or other communications.  If you have a registered Business Account, we will document this communication to your account for reference, as well as future informational and promotional communications.

Search for a Provider
When you use our “Find a Doctor” feature on our website, we will ask you to input either your zip code or a keyword to help narrow your search (e.g., Provider name, city, street name). We collect this information, upon your request, to enable our search feature to provide you with information on Providers nearest to you.

Inquire About Candidacy
When you choose to submit information via our “Am I a Candidate” form, we will collect your first name, email address, and zip code.  You also have the option of providing your last name.  We use this information to provide you with information about 6MS dentists near the zip code you provided, and, if you consent to receive additional communications from us, we will also use this information to deliver that requested content. 

In addition to this information, we ask you to answer a few simple questions regarding your teeth and your reason for potentially seeking treatment.  We collect this information to understand the type of treatment you are seeking and to tailor any subsequent communications with you.

Download Content
If you choose to download one of our informational guidance documents, we will collect your name and email address.  We will also ask you to answer one or two questions about your potential use of or interest in our products. 

If you identify yourself as a dentist or dental practice and choose to download our dentist guide, we will also ask you for additional information, including your practice address, personal or office telephone number, country, and state (if in the United States).  We also collect information regarding your potential use of or interest in our products via questions contained at the bottom of the submission form.  We collect your contact information to update you on new product innovation and, if applicable, upcoming seminar availability.  Additionally, we use your responses to our questions to ensure the content we deliver to you is of the highest relevancy.  We only collect this information upon your consent, and you can change or withdraw your consent at any time.

Register for a Training Seminar (Providers Only)
To offer 6MS products and services to your patients, you must complete one of our training courses.  When you choose to register for a training course, we will ask you to provide your name, practice name, practice address, practice and personal telephone numbers, email address, and orthodontic treatment experience.  We also ask you for payment information, including credit card and billing address, to pay for and complete your training course registration.

We collect this information for the purpose of registering you for our training course and completing our transactions with you.

Register for Provider Resource Center Account (Providers Only)
After successfully completing one of our training courses, you will be asked to create a Provider Resource Center Account.  As part of creating your account, we collect your name, practice name, practice address, practice telephone number, email address, practice website URL, email subscription preferences, and account username and password.  We also will collect payment information, such as credit card and billing address, to process payment and complete transactions initiated through the Provider Resource Center.

We collect this information to provide you with access to our Provider Resource Center, which enables you to submit cases, order tools and supplies, submit a course re-attendance order, and access our Provider Resource Center Knowledge Base and our Six Month Smiles Forum.

Create a Provider Profile (Providers Only)
If you provide 6MS products and services to patients, you will be able to customize your practice’s profile page on our website, which will include your name and the practice information you submitted when registering for a training seminar.  You also have the option of providing supplemental information about your practice, including the names of additional practitioners, alternative contact information, insurance plans accepted, and business hours.  Any information you choose to provide is done at your discretion, and you can modify or delete this supplementary information at any time.

Submit a Case (Providers Only)
If you are a Provider submitting a case to us, we will collect patient first and last name, age and gender; case-supporting patient photographs and radiographs; and your stated prescription elements necessary to create the custom appliance for patient treatment.

We use this information to create the appropriate custom 6MS appliance for patient treatment and, in the case of CONFIDEX™, devise a customized treatment plan for the application of the 6MS product.

Participate in Community Platforms (Providers Only)
When you participate in our Six Month Smiles Forum, we collect name, practice name, address, phone number, and email address.  We also collect the content of your messages shared through the Forum, which may contain any additional information, including personal data, you choose to share.

We only collect this information when you choose to use the Forum for the purpose of facilitating the interactive discussion features of the Forum and to provide access to feedback from peers and our independent Six Month Smiles Clinical Instructors and Mentors.

Personal Data Collected via Web-Based Technologies

Browser or Device Information 
We automatically receive and record information on our server logs from your browser, including your IP address, 6MS cookie information, and the page(s) you request.  We collect this data for the following general purposes: 

  • Customizing your user experience
  • Fulfilling your requests for products and services
  • Promoting and improving services
  • Contacting you

We also collect your IP address(es) for the purpose of analyzing website trends, administering the site, and tracking user movement for aggregate usage analysis. This website usage information enables 6MS to provide our users with an ever-improving site, service, and general offering.  Except where you have provided consent for us to use your identifiable personal data, we only use anonymous, aggregate data that cannot be used to identify you individually for our analytics research.

Cookies and Web Beacons
We may set and access 6MS session cookies on your computer to customize the user experience. “Cookies” are small files placed on your computer by your browser and are often used to make websites work, as well as provide information to the website operator.

We collect this information for the purpose of conducting analyses on our web traffic and improving your experience while visiting our website.  When you first visit our website, you will be asked to consent to our use of cookies, and you can withhold, withdraw, or change your consent at any time.  You also have the ability to decline cookies by modifying the settings in your browser.  If you decline or disable cookies, please note that certain functionalities of our website may no longer work. 

Communications you receive from us, as well as pages of our website, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that enable us to analyze email and website statistics, including visits and click-through rates.  The web beacons only collect aggregate, anonymous data and cannot be traced back to you individually.

Third-Party Cookies and Web Beacons
Some content or applications on our website are served by third parties, including content providers and application providers.  Our third-party partners may use cookies alone or in conjunction with web beacons or other tracking technologies already in your browser to collect information about you when you visit our website. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites and other online services.

We use Facebook Pixel to help us track the effectiveness of our advertising by reporting on the actions users take after viewing our advertisements displayed on Facebook.  No personal information is contained or collected as a result of these pixels.

Third-party cookies and web technologies are controlled by our advertising partners and not subject to this Privacy Policy.  If you have any questions about the practices of such third party, you should contact the responsible third-party directly.

Social Media
We collect information, such as email address and social media user or account name (“social media handle”), content and other data, you allow to be shared through our social media applications, tools, widgets, and plug-ins.  If you choose to post information directly to any of our official social media platforms, we will collect any personal data you choose to include in your post, such as your name, location, and photograph(s).  We will also collect the social media handle associated with the social media account you use to post to our official social media platforms.  Please note that by opting to upload content to our official social media platforms, depending on your security settings, any personal information you include in your post may be viewed by other visitors to our official social media platforms, which may include people you do not know. 

If you submit a form to 6MS through Facebook, we collect your name, phone number, address, email, and any additional information you choose to share in the form.  This information is provided with your consent when you submit the form.  We use this information to respond to your requests, as well as to provide you with future informational and promotional materials.

Additionally, if you share photographs, comments, or reviews related to 6MS services and products on your personal social media platforms or participate in a 6MS social media campaign, we may also ask you for your permission to repost or share your content on our official website and social media platforms, including Facebook and Instagram.  When you consent to our use of this information, we will collect and repost any personal data you included in your original post, such as your name, location, and photograph(s).  We will also collect the social media handle associated with the social media account to which you posted the content.  We use this information for the purpose of sharing your content and 6MS experiences with visitors of our website and social media platforms.

Personal Data Collected from Other Sources

Certification Course Registration (Providers Only)
If you are registered by someone in your practice to attend one of our training courses, we ask the person registering you to provide your name, practice name, practice address, practice and personal telephone numbers, email address, and orthodontic treatment experience.  If you will be personally paying for the training course, we also will collect payment information, including credit card and billing address, to process payment and complete your registration for the course.

We use this information for the purpose of registering you for our certification course and facilitating your Provider relationship with 6MS.

Case Submission
When your Provider submits your case for consideration of our services, we collect your full name, age, and gender; case supportive photographs and radiographs; and your customized orthodontic information of your dentition.  This information is necessary to create customized treatment plans, 3D simulations, and fabrication of 6MS appliances customized for you.  You provide this information to your Provider as part of requesting our services, and we use this information both for the purpose of evaluating your candidacy for our services, as well as providing our requested services. 

This information is collected through our Provider Resource Center, which is accessed by your Provider via our website.  We only collect this data when your Provider has initiated a case submission per your request, and we only process this data under clearly defined instructions from your Provider.  These instructions include obligations for us to maintain the confidentiality and security of your personal data.  

Your personal data will be saved to your Provider’s account until your Provider deletes the account or you request we delete your information.  If your case is denied, we delete your personal data from your Provider’s account and our case database.  A copy of all completed and canceled cases is retained for case management, quality assurance, accounting, and regulatory purposes.

Six Month Smiles Forum
Your Provider may choose to use our Six Month Smiles Forum to seek guidance about treatment plans and options from other Providers and independent Six Month Smiles Clinical Instructors and Mentors.  The Forum is only accessible to Providers via unique login credentials, and all Providers using the Forum are bound by applicable privacy laws and professional conduct obligations, including confidentiality. 

If your Provider uses the Forum for guidance regarding your specific treatment plan, your Provider may only discuss your case in generic terms and without disclosing your name. Your Provider may only use the Forum in furtherance of a legitimate treatment need and may only disclose your information in accordance with applicable laws and professional obligations. We will only process information shared via the Forum for the purpose of facilitating Provider-to-Provider communication, and any information posted to the Forum will remain on the Forum indefinitely.

Personal Data Use
How we use your personal data will depend on how you interact with our website and the personal data you have shared with us.

Respond to Your Requests
We use your personal data to respond to your requests, including communications, content downloads, and Provider searches you have initiated. If you are a prospective or current Provider, we also use your personal data to register you for training courses, and, when applicable, enable you to create an account and use our online portals and e-commerce tools.

Provide Short-Term Orthodontic Care Services
When a Provider submits a case for review, we use the personal data collected to evaluate the viability of the case. If the case is accepted, we will use the personal data to create and provide the requested services to the Provider.

Enhance Website and User Experience
We use the information regarding the use of our website to analyze and administer the site and track user movement for web analytics purposes.  This website usage information enables 6MS to provide you with an ever-improving site, service, and general offering.  Except where you have provided consent for us to use your identifiable personal data for our analytics research, we only use anonymous, aggregate data that cannot be used to identify you individually.

Manage Account (Providers Only)
If you are a Provider and have created a Provider Resource Center Account, we will use your personal data to administer your account, including enabling you to submit cases for evaluation, and to allow you to access the Provider Resource Center, submit orders for tools and supplies, submit orders for course re-attendance, and submit payment for such order types. If necessary, we will also use your personal data to verify your identity and provide you with access to your account should you become locked out or forget your login and password.

Provide Searchable Provider List (Providers Only)
If you are a Provider, we include your name, practice name, practice address, and practice telephone number in our “Find a Dentist” searchable, online database of Providers.  We use this information and database for the purpose of matching you with prospective patients in your area.

Conduct Marketing and Advertising
Personal data is used to coordinate the best offers and information to both inquiring patients and to current or interested Providers. Email and other materials delivered from 6MS are sent strictly as part of an opt-in process or in response to communications you have initiated with us. You may change your consent for receiving such communications by clicking the “Unsubscribe” link at the bottom of any electronic marketing communications received from us. You may also contact us at 6MSDataProtectionOffice@sixmonthsmiles.com to request that we remove you from our marketing communications

Meet Legal and Regulatory Obligations
In certain circumstances, we may be required to disclose your personal data, including your health information, to regulators or as otherwise required by law.  We will only share the information we are required to disclose by law and only when we are required to do so.

Security and Fraud Prevention
When necessary, we will use your personal data, including email communications, to preserve the security of our website, systems, and personal data in our control. If necessary, we will also use your personal data to investigate possible fraud, to identify violations of this Privacy Policy and our terms and conditions, and to prevent any attempted harm to our users.

Personal Data Sharing and Disclosure
We share your personal data when you have granted us permission to do so, when it is necessary to fulfill our obligations to you, or when it is in the legitimate interest of our business to do so, provided that our interests do not outweigh your individual rights and freedoms.

Support Vendors
When necessary, we share your data with third-party vendors working on our behalf to provide specific business support services, including payment processing, website hosting and management, personalized case treatment planning, and digitization of tooth models.

Website Analytics Companies
We share anonymous, aggregate information regarding visitors to our website with third-party website analytics companies.  These companies use this aggregate data, which has been stripped of any personally identifying information about you, to provide us with insight regarding our web usage patterns.  As we only share anonymous, aggregate data, this information cannot be traced back to you individually by either us or the website analytics vendors. 

We use Google Analytics to provide us website usage and analytic reports, which necessitates us sharing your anonymous, aggregate data.  You may choose not to share your data with Google by installing the Google Analytics opt-out browser add-on, which instructs your browser not to provide your website usage data to Google Analytics. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout to install the browser add-on.

Please note that installing the Google Analytics opt-out browser add-on will only disable the use of Google Analytics and will not prevent data from being sent to the website itself or to other web analytics services.

Marketing and Advertising Partners
From time to time, we may send emails or other electronic communications to Providers on behalf of our marketing and advertising partners when we believe our partners offer products or services that we think may provide value to you.  At no time do we share your email address with our partners, and you can unsubscribe from these communications at any time by clicking the “Unsubscribe” link at the bottom of the email or other electronic communication.  You may also contact us at 6MSDataProtectionOffice@sixmonthsmiles.com to request that we remove your email address from our marketing communications. 

Additionally, we use tools provided by Facebook to display internet-based advertisements to you when you are using Facebook.  We do not share any of your personal information with Facebook.  Rather, the tools enable us to convert your email address to a unique number Facebook uses to match to unique numbers Facebook generates from email addresses of its users.  

You have choices over the use of your information for these purposes and can visit https://www.facebook.com/ads/website_custom_audiences/

Legal Requirements
As required by law, regulation, or legal process, we will share your personal data with government authorities, enforcement officials, or third parties as necessary to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.

Security and Fraud Prevention Efforts
When necessary, we will share your personal data to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations or suspected violations of this Privacy Policy, our agreements or arrangements with you or other policies in effect from time to time to which you are subject, or as otherwise required by law.

Sale of Business
We reserve the right to transfer your personal information in the event we sell or transfer all or a portion of our business or its assets.  In such event, your personal data will continue to be governed by this Privacy Policy.

Your Choices and Rights

EU Data Subject Rights
If you are an EU data subject, we provide you with choices about the collection, use, and disclosure of your personal data.  You may exercise these rights by contacting us in writing by electronic mail, postal mail, or commercial courier at the address or email address provided at the end of this Privacy Policy under the heading “Contact Information.”  Unless explicitly stated otherwise, we will respond to your request as soon as possible, but at the latest within one month. 

Your rights include: 

  • Accessing your personal data to know what information we have collected about you and how it has been shared;
  • Requesting the deletion of all or some of your personal data;
  • Changing or correcting inaccurate or outdated information;
  • Objecting to, limiting, or restricting use of all or some of your personal data; and
  • Requesting a copy of your personal data, including in a portable format.

You also have the right to lodge a complaint with your supervisory authority if you believe we have violated your privacy rights or applicable laws and regulations.

California Privacy Rights
If you are a resident of the State of California and you have provided your personal data to us, you have the right to request a list of all third parties to which we have disclosed your personal data for direct marketing purposes.  If you exercise your right to submit such a request to us, we will send you the following information:

  • The categories of information we have disclosed to any third party for any third party’s direct marketing purposes during the preceding year; and
  • The names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.

You may make such a request by contacting us in writing by electronic mail, postal mail, or commercial courier at the address or email address provided at the end of this Privacy Policy under the heading “Contact Information” with a preference on how our response to your request should be sent.

California law also requires that we disclose how we respond to “do-not-track requests” from our users.  At this time, we do not currently respond to “do-not-track” requests from our users’ browsers.

Other Important Information

Cross-Border Data Transfers
We process data both inside and outside the United States. It is important to know that data protection laws in the United States may not be as strong as those in your country.  Where we transfer your personal data from the European Economic Area (“EEA”) to a location outside the EEA, we will only transfer your data if an appropriate level of protection for your personal data is guaranteed, such as where we have contractual obligations to protect or transfer data with certain safeguards in place. To ensure the continued protection of your personal data while in our care, we take appropriate organizational and technical measures.  In addition, we may transfer your personal data if one of the legal exceptions for such transfer can be invoked, such as with your consent or in execution of an agreement you have with us.

Third-Party Websites
This website may contain links to websites owned or operated by third parties, including the practice websites of Providers.  This Privacy Policy applies only to our websites and not to any third-party websites.

Security
We have implemented organizational and technical safeguards for protecting the personal data you share with us.  These measures include internet standard 128 bit encryption of information submitted via our web portals, managed firewall protocols for all network traffic, and qualified, secured credential access of all data storage systems.  Additionally, all 6MS personnel are routinely trained on general commerce data security measures.

Data Retention
Unless stated otherwise, we retain all personal data and other information collected for 10 years. If you would like your personal data deleted earlier than the 10-year retention period, you may exercise your right to request the deletion of your data at any time.

Children Under the Age of 16
We do not knowingly collect personal data from individuals under the age of 16, unless the personal data is submitted by a Provider for use of our services and with parental consent. Our website is not intended for anyone under the age of 16, and no one under the age of 16 may provide information on this website.

Privacy Policy Changes
6MS may update or revise this policy at any time, at its sole discretion. Any changes to our privacy policy will apply to your personal data from the “Last Updated” date at the top of the privacy policy and will not affect previous uses of your personal data. You can find the most current version of our privacy policy at any time by clicking on the “Privacy Policy” link at the bottom of our website. If we make material changes to our privacy policy, we will notify you of those changes by either sending an email message to the email address you most recently provided to us or by prominently posting a notice on our website.

Contact Information
Data Protection Officer
6270 Morning Star Dr. Ste. 120
The Colony, TX 75056
1-866-957-7645
6MSDataProtectionOffice@sixmonthsmiles.com