Privacy Policy
This Privacy Policy describes the manner in which Dentana (“Dentana,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards Personal Information. It further describes the rights and choices available to you with respect to your Personal Information, and the means by which you may contact us with questions concerning our practices.
Dentana is a service of Esthetic Dental Designs, a dental laboratory located in Honolulu, Hawaiʻi. Dentana provides digital scan consultation, remote scan review, and related workflow support services to licensed dental practices and their clinical teams. We do not provide dental treatment, and we do not offer products or services directly to consumers or patients. Accordingly, our Site and Services are intended solely for dental professionals.
This Privacy Policy applies to Dentana’s United States operations and addresses our practices with respect to the collection, use, and disclosure of Personal Information and, specifically, Protected Health Information (“PHI”). It is intended to operate consistently with the federal Health Insurance Portability and Accountability Act of 1996, as amended (“HIPAA”), applicable Hawaiʻi law, including Hawaiʻi Revised Statutes Chapters 487J, 487N, and 487R, and other relevant state privacy legislation, including without limitation the California Consumer Privacy Act (“CCPA”).
Protected Health Information
Certain information that Dentana receives in the course of providing its Services constitutes Protected Health Information governed by HIPAA rather than by this Privacy Policy. The distinction is material and is described here in full.
Our role. Where a dental practice transmits a digital scan, case file, prescription, image, or patient record to Dentana, or where a Dentana specialist reviews such materials at the direction of a practice, Dentana receives and processes PHI on behalf of that practice. In performing such functions, Dentana acts as a Business Associate of the practice within the meaning of 45 C.F.R. § 160.103. Our creation, receipt, maintenance, use, disclosure, and transmission of PHI in that capacity is governed by the HIPAA Privacy, Security, and Breach Notification Rules and by the Business Associate Agreement executed between Dentana and the applicable practice, and not by this Privacy Policy.
Permitted uses. Dentana uses and discloses PHI solely as permitted or required by the applicable Business Associate Agreement, solely to the extent necessary to perform the Services requested by the practice, and solely as otherwise permitted or required by law. Dentana does not use or disclose PHI for its own marketing purposes, and does not sell PHI. Dentana maintains administrative, physical, and technical safeguards designed to protect the confidentiality, integrity, and availability of PHI in accordance with the HIPAA Security Rule.
Subcontractors. Where Dentana engages a subcontractor that creates, receives, maintains, or transmits PHI on our behalf, we obtain satisfactory written assurances from that subcontractor in the form of a Business Associate Agreement, as required by 45 C.F.R. § 164.308(b) and § 164.502(e).
Requests by patients. Individual rights of access, amendment, accounting of disclosures, restriction, and confidential communication with respect to PHI are exercised through the covered entity that maintains the designated record set — that is, through the treating dental practice, and not through Dentana. Dentana is not permitted to release a practice’s patient records absent that practice’s instruction. Any request directed to Dentana will be referred to the applicable practice. An individual may also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights.
Information submitted directly to Dentana. Information that an individual submits to Dentana directly — for example, through a contact form, by electronic mail, or by telephone — is not received from or on behalf of a covered entity and therefore generally does not constitute PHI. Such information is governed by this Privacy Policy. Where such information concerns an individual’s health, Dentana treats it as sensitive Personal Information, does not sell it, and does not use it for third-party advertising purposes.
Information We Collect
Dentana collects information about you through several channels, which vary according to the nature of your interaction with us and with our Site, including:
- Directly from you, when you submit it to us — for example, by completing a form on our Site, requesting a demonstration, establishing an account, downloading a resource, or contacting us by telephone, electronic mail, or otherwise.
- Automatically, through cookies, server logs, and similar technologies, when you interact with our Site and our electronic communications.
- From other sources, including dental practices with which we contract, laboratory and technology partners, service providers, referral sources, professional licensing records, and other publicly available sources. Where you submit an application for employment, we may obtain the results of a background check.
The following describes the categories of information we collect in particular contexts and the primary purposes for which we collect it.
Account Registration
Where you establish an account with Dentana, we collect your name, practice affiliation, professional role, business contact information, username, and password, together with a record of the actions you perform while authenticated to that account. The primary purpose of this collection is to establish and administer your account, to provide the Services, and to communicate with you regarding your account.
Practices, Clinical Teams, and Prospective Clients
Where you request a demonstration, an evaluation, or information concerning our Services, we collect your name, practice name, professional role, business contact information, and such information regarding your intraoral scanner, laboratory relationships, case volume, and clinical workflow as you elect to provide. The primary purpose of this collection is to evaluate and respond to your request, to determine whether our Services are suited to your practice, and to administer the resulting business relationship.
Remote Scan Consultation Sessions
Where your practice initiates a Dentana consultation session, we collect connection and session metadata, including the date, time, and duration of the session, the practice and individual initiating it, the Dentana specialist assigned to it, the systems and scanner platform involved, and a summary of the matters reviewed. A session is established only upon request by authorized personnel at your practice; Dentana does not initiate a connection to your systems independently. Specialist access is limited in scope to the review requested and terminates upon conclusion of the session. Any patient information observed in the course of a session constitutes PHI and is governed by the Protected Health Information section above.
Sessions may be recorded for quality assurance and training purposes; notice of recording is provided at the outset of any recorded session.
Contractors, Consultants, Vendors, and Business Partners
We collect the name, business contact information, and such other information as is reasonably necessary regarding our contractors, consultants, vendors, laboratory partners, and business partners, and their respective employees and subcontractors, with whom we interact. The primary purpose of this collection is to manage our business relationships and to conduct ordinary business administration.
Inquiries, Comments, and Feedback
Where you contact us, whether by form submission, electronic mail, telephone, or social media, we collect your name, electronic mail address, telephone number, information regarding your practice, and the contents of your communication together with any materials you transmit. We use this information to respond to and follow up on your inquiries, comments, reviews, and other requests.
Resource Downloads and Subscriptions
Where you request a resource made available by Dentana or subscribe to our communications, we collect your name and electronic mail address, together with a record of the resources requested. We use this information to deliver the requested materials and, subject to your choices described below, to provide related communications.
Billing
Where you subscribe to a paid Service, we collect billing contact information and transaction records. Payment card and bank account details are collected and processed by our third-party payment processor; Dentana receives transaction confirmation and a truncated payment identifier and does not store complete payment card numbers.
Job Applicants
Where you apply for a position with us, we collect the information necessary to evaluate your application and, where applicable, to retain you as an employee. This may include your name, electronic mail address, telephone number, résumé or curriculum vitae, employment and educational history, professional credentials, and certain voluntary information such as gender, race or ethnicity, veteran status, and disability status, in each case only where you elect to provide it. Where you become an employee, we may additionally collect your Social Security number, the provision of which is required for employment. We collect this information to process your application and to communicate with you regarding it.
Cookies and Similar Tracking Technologies
When you visit our Site, we collect certain information concerning your browser and device. Examples include device type, browser type, internet protocol (“IP”) address, unique device identifiers, the general location of your device, operating system, internet service provider, and other technical information concerning your device (collectively, “Device Information”). We also collect information concerning your interactions with our Site. Examples include pages visited, links selected, dates and times of access, referring website, information entered into our online forms, and identifiers associated with browser cookies, web beacons, and similar technologies deployed on our Site (collectively, “Usage Data”). Further detail is set out under the heading Cookies and Similar Tracking Technologies below. We employ such technologies for a number of purposes, including:
- to present relevant advertising concerning our Services;
- to understand the manner in which you interact with our content;
- to improve your experience of our Site;
- to retain your preferences, so that you need not configure them on each visit;
- to identify and resolve errors; and
- to evaluate the performance of our Site.
Cookies and Similar Tracking Technologies
When you visit our Site, we and our third-party service providers employ cookies and other similar technologies to collect Device Information and Usage Data. The categories of technology we may employ include the following.
Cookies. Cookies are small files transmitted by a website to your device through your web browser, which enable the website to recognize that browser and to record and retain certain information. Most web browsers permit you to reject or delete cookies through their settings. Please note that electing to remove or reject cookies may affect the availability and functionality of our Site.
The following describes the categories of cookies we employ and the purposes for which we employ them.
Necessary or Essential. These cookies are necessary to provide the services available through the Site and to enable you to use certain of its features. They assist in authenticating users and in preventing fraudulent use of accounts. Without these cookies, the services you have requested cannot be provided, and we employ them only for that purpose.
Functional. These cookies enable us to retain the choices you make in using the Site, such as your login details or language preference. Their purpose is to provide a more personalized experience and to avoid the need for you to re-enter your preferences on each visit.
Analytics. These cookies enable us, among other things, to count visits and identify traffic sources, so that we may measure and improve the performance of our Site. We may additionally employ third-party session replay software, which permits us to observe how visitors navigate the Site. Analytics cookies may be set by us or by a third party. We currently employ Google Analytics 4 to assist us in analyzing your use of the Site. Information concerning Google’s collection and processing of data is available at policies.google.com/technologies/partner-sites, and information concerning how to opt out of the use of your information by Google Analytics is available at tools.google.com/dlpage/gaoptout.
Targeting or Advertising. These cookies may be set through our Site by us or by our advertising partners. They may be employed to collect information over time and across websites in order to develop a profile of your interests and to present relevant advertisements on our Site or on other websites.
Health-related pages. Dentana does not deploy third-party advertising or marketing analytics technologies on pages through which health information is submitted, on pages accessible only upon authentication, or in connection with remote consultation sessions. Such technologies are deployed only on our general-audience marketing pages.
Web Beacons. A web beacon, also referred to as a pixel tag or clear GIF, is a small graphic image placed on a web page or within an electronic communication which may be used, among other purposes, to count the users who have visited a page or selected a link, to record whether an electronic message has been opened, and to compile related statistics, including the relative popularity of particular content and the verification of system and server integrity.
Web Logs. When you visit and interact with our Site, we record certain information, including browser type, operating system, IP address, domain name, click activity, referring website, and a date and time stamp. This information assists us in monitoring our networks and the usage of our Site.
Browser signals. Dentana honors the Global Privacy Control (“GPC”) signal, where transmitted by your browser, as a request to opt out of targeted advertising.
How We Use Information
In addition to the purposes and uses described above, we use information in the following ways:
- To provide, administer, maintain, evaluate, and improve our Site, our Services, and our Service offerings.
- To establish and administer your account.
- To contact you: to contact you by electronic mail, telephone, text (SMS) message, or other equivalent form of electronic communication, in order to provide information you have requested from Dentana, information relating to Services you have engaged, scheduling and case status information, billing communications, updates and information regarding our Services and other offerings, and for any other purpose relating to Dentana’s business.
- To provide you with news, offers, and general information concerning other Dentana Services and offerings that may be of interest to you, unless you have elected not to receive such information.
- To manage your requests: to attend to, manage, and respond to your requests.
- To conduct analytics, including through the use of aggregated or de-identified information.
- To train our personnel and to develop internal quality assurance and clinical education materials, using de-identified information.
- To detect and protect against malicious, deceptive, fraudulent, or unlawful activity, including violations of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of our company, our clients, our personnel, or others.
- To debug, identify, and repair errors impairing the intended functionality of our Site and Services.
- To comply with our legal, regulatory, tax, accounting, and professional obligations, to establish or exercise our rights, and to defend against legal claims.
- For internal administrative purposes and to manage our business relationships.
- For business transfers: we may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, financing, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us concerning users of our Site is among the assets transferred.
- For other purposes to which you may consent from time to time.
How We Share Information
In addition to the specific circumstances described elsewhere in this Privacy Policy, we may disclose Personal Information in the following circumstances.
- Service Providers. We may share your information with service providers. Among other things, service providers may assist us in administering our Site, providing technical and remote-support infrastructure, delivering electronic communications, processing payments, conducting research and analytics, and performing other services relating to the operation of our business. Service providers are permitted to use such information only to perform services on our behalf and are bound by contract. Where a service provider creates, receives, maintains, or transmits PHI on our behalf, we obtain a Business Associate Agreement from that service provider.
- Dental Practices. Where we perform Services on behalf of a dental practice, we share case, session, and status information with that practice, which is our client.
- Laboratory and Fulfillment Partners. Where a case is fulfilled in whole or in part by a partner laboratory, we share the information reasonably necessary to complete that case, pursuant to written agreement and, where PHI is involved, pursuant to a Business Associate Agreement.
- Affiliates. We may share information with our corporate affiliates, including any parent company, sister company, subsidiary, joint venture, or other entity under common control.
- Professional Advisors. We may share information with our attorneys, accountants, auditors, and insurers, in each case subject to duties of confidentiality.
- Business Partners. We may share your information with our business partners in order to offer you certain services or promotions. Your telephone number will not be shared or sold to business partners or affiliates for their direct marketing or promotional purposes.
- Legal Process and Compliance with Law. We may disclose information in response to a subpoena, warrant, or court order, in connection with any legal process, or in order to comply with applicable law. We may also disclose information in order to establish or exercise our rights, to defend against a legal claim, or to investigate, prevent, or take action regarding suspected unlawful activity, suspected fraud, threats to the safety of any person or property, or violations of our policies.
- Business Transfers. We may share or transfer your Personal Information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another entity.
- With Your Consent. We may disclose your information to other third parties where we have your consent or direction to do so.
- SMS and Text Messaging Data. Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. All of the categories set forth above exclude text messaging originator opt-in data and consent; such information will not be shared with any third party.
Limitations on Our Use and Disclosure
Notwithstanding any other provision of this Privacy Policy, Dentana observes the following limitations. Where we intend to modify any of them, we will provide notice prior to the modification taking effect.
- No sale of Personal Information. Dentana does not sell Personal Information and has not sold Personal Information within the twelve (12) months preceding the effective date of this Privacy Policy.
- No solicitation of client patients. Dentana does not use patient information processed on behalf of a dental practice to market Dentana Services to that practice’s patients, to solicit those patients, or to refer those patients to any other provider. Dentana does not provide dental treatment and does not maintain a direct-to-patient offering.
- No competitive disclosure of practice information. Dentana does not disclose a practice’s case information, case volume, patient information, or clinical workflow information to any other dental practice or to any laboratory for competitive purposes. Case information is transmitted to a fulfillment partner solely as necessary to complete the case for which it was submitted, pursuant to written agreement.
- No commercial model training. Dentana does not use client case data or scan data to develop, train, or improve artificial intelligence or machine learning models for sale or licensing to third parties. Where aggregated or de-identified information is used to improve the quality of our own Services, such information is de-identified in a manner that does not permit reasonable re-identification of a practice or an individual.
Your Choices
Depending on your state of residence, you may make the following choices regarding your Personal Information. Dentana extends the choices described below to all individuals who contact us, without regard to residence.
Access to Your Personal Information. You may request access to your Personal Information and details regarding our collection, use, and disclosure of it. In certain circumstances, you may also request to receive a copy of your Personal Information in a readily usable format.
Changes to Your Personal Information. You may request that we correct information that is inaccurate or incomplete. Please note that we may retain historical information in our backup files as permitted by law.
Deletion of Your Personal Information. You may request that we delete your Personal Information. Where required by law, we will grant a request to delete information. Please note, however, that in many circumstances we are required to retain Personal Information in order to comply with our legal obligations, to resolve disputes, to enforce our agreements, or for other permitted business purposes.
Opt-Out of Sharing for Targeted Advertising. You may opt out of tracking-based targeted advertising by selecting the “Do Not Sell or Share My Personal Information” link on our Site, or by transmitting the Global Privacy Control signal from your browser. Please note that if you change browsers or devices, or clear your browser cache, you may need to exercise this preference again. You may also opt out of other forms of targeted advertising by submitting a request as described below.
Limitation on Use of Sensitive Information. You may request that we limit the use of information concerning health to that which is necessary to provide the Services you have requested.
Promotional Communications. We may use your information to send you newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any or all of these communications by following the unsubscribe instructions in any message we send, or by contacting us. Where you elect not to receive promotional communications, we may nonetheless send you service-related communications concerning your account, your cases, and your billing.
Please note that not all of the rights described above are absolute, and they do not apply in all circumstances. In certain cases we may limit or deny a request because the law permits or requires us to do so, because the information constitutes PHI held pursuant to a Business Associate Agreement and the request is properly directed to the applicable dental practice, or because we are unable to adequately verify your identity. We will not discriminate against any individual who exercises a privacy right under applicable law.
Submitting Requests
You may exercise the rights described above by contacting us as set forth under Contact Information below. As required by law, we will require you to verify your identity before we process your request. We may verify your identity by telephone or electronic mail. Depending upon the nature of the request, we will ask for information such as your electronic mail address and telephone number, and we may ask you to provide a signed declaration confirming your identity. We will respond within forty-five (45) days, and will notify you if an extension of an additional forty-five (45) days is required.
Authorized Agents
You may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. Where you have been designated as an authorized agent to submit a request on behalf of another individual, you must provide a copy of that individual’s signed written authorization at the time the request is submitted. Please note that we may deny a request from an authorized agent who does not submit proof of authorization. Where an individual holds a power of attorney or is a legal guardian, appropriate documentation should be provided.
Appeals
Where we decline to act on your request, you may appeal by responding in writing to our determination within a reasonable period. We will respond to an appeal in writing within sixty (60) days. Where an appeal is denied, you may contact the office of the Attorney General of your state of residence.
California Residents
The categories of Personal Information we collect, the sources of that information, the purposes for which it is used, and the categories of recipients to whom it is disclosed are described in the sections above. Dentana does not sell Personal Information and does not share Personal Information for cross-context behavioral advertising, as those terms are defined under the CCPA. Dentana does not knowingly collect or sell the Personal Information of individuals under sixteen (16) years of age. For purposes of California Civil Code Section 1798.83, Dentana does not disclose Personal Information to third parties for those parties’ own direct marketing purposes.
How We Protect Information
We maintain administrative, technical, and physical safeguards appropriate to the nature and sensitivity of the information we hold, including access controls, encryption of information in transit, role-based system access limited to those with a legitimate need, vendor diligence, and periodic training of personnel on privacy and information security.
No method of transmission over the internet, and no method of electronic storage, is fully secure. While we use reasonable efforts to protect your Personal Information from unauthorized access, use, or disclosure, we cannot guarantee its security.
In the event that we are required by law to inform you of a breach of the security of your Personal Information, we may notify you electronically, in writing, or by telephone, to the extent permitted by law.
How Long We Retain Information
We retain your Personal Information only for so long as is necessary to fulfill the purposes described in this Privacy Policy, including for purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law.
In determining the appropriate retention period, we consider the volume, nature, and sensitivity of the information, the potential risk of harm from its unauthorized use or disclosure, the purposes for which we obtained it and whether those purposes may be achieved by other means, and applicable legal requirements.
Upon expiration of the applicable retention period, records containing Personal Information are destroyed by shredding, erasure, or other means rendering the information unreadable or indecipherable, in accordance with Hawaiʻi Revised Statutes Chapter 487R.
Hawaiʻi Disclosures
Dentana is located in Honolulu and conducts its operations subject to Hawaiʻi law in addition to applicable federal law.
Constitutional Right to Privacy. Article I, Section 6 of the Constitution of the State of Hawaiʻi recognizes an express right to privacy and imposes an affirmative obligation on the Legislature to protect it. Dentana conducts its practices with regard to that standard.
Security Breach of Personal Information (HRS Chapter 487N). In the event of a security breach involving unencrypted or unredacted Personal Information, Dentana will provide notice to affected Hawaiʻi residents without unreasonable delay, consistent with the requirements of HRS § 487N-2. Hawaiʻi law applies to records maintained in physical as well as electronic form. Where a single incident requires notification of more than one thousand (1,000) persons, Dentana will additionally provide written notice to the Hawaiʻi Office of Consumer Protection and to the nationwide consumer reporting agencies.
Social Security Number Protection (HRS Chapter 487J). Dentana does not publicly post or display Social Security numbers, print Social Security numbers on materials mailed to an individual except where permitted by law, or require an individual to transmit a Social Security number over an unsecured connection or to use one as a credential for access to an online service. Social Security numbers are collected only where required for employment or tax purposes.
Destruction of Personal Information Records (HRS Chapter 487R). Dentana takes reasonable measures to protect against unauthorized access to or use of Personal Information in connection with its disposal, as described under How Long We Retain Information above.
Unfair or Deceptive Practices (HRS Chapter 480). The representations set forth in this Privacy Policy are binding upon Dentana.
The State of Hawaiʻi has not enacted a comprehensive consumer data privacy statute. Dentana extends the choices described under Your Choices above to Hawaiʻi residents on the same terms afforded to residents of states that have enacted such legislation.
Children’s Privacy
Our Site and Services are directed to dental professionals and are not directed to children. We do not knowingly collect Personal Information from children under thirteen (13) years of age. Where we become aware that we have collected such information, we will delete it. Information concerning a minor patient received from a dental practice constitutes PHI and is governed by the Protected Health Information section above.
Third-Party Applications and Websites
For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate, including those of dental practices, laboratory partners, and scanner manufacturers. The websites and third-party content to which we link may maintain separate privacy notices or policies.
Please note that we have no control over the privacy practices of websites or services that we do not own or operate, and that a link does not constitute an endorsement of any third party’s privacy practices. We encourage you to review the privacy policy of any third-party website or application for details concerning that party’s practices.
Users Outside the United States
Dentana operates in the United States and its Site and Services are intended for users located in the United States. Information collected by Dentana is stored and processed within the United States. Where you access our Site from outside the United States, you do so on your own initiative and are responsible for compliance with applicable local law.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time in order to reflect changes to our practices, our technology, applicable legal requirements, and other factors.
Where changes are made to this Privacy Policy, they become effective upon publication. You may refer to the “Last Updated” legend at the top of this page to determine when this Privacy Policy was last revised. Where we make a material change to our use of Personal Information already collected, we will provide notice by electronic mail or by prominent notice on our Site prior to the change taking effect. Prior versions are retained and available upon request.