Privacy Statement for the Delta Dental Plans Association Website and Mobile App - Consumers

Delta Dental Plans Association (“Delta Dental”) is committed to protecting the privacy of all individuals who utilize the www.deltadental.com website (the “Web Site”) and the Delta Dental mobile application (the “Mobile App,” together with the Web Site, the “Services”). Please read the following statement to understand how we collect, use and safeguard the information you, as an individual consumer (as opposed to a provider, employer or others) may provide to us via the Services. This statement may be revised from time to time, so please revisit this page often to remain fully informed of our policies.

By using the Services, you acknowledge that you have read and understand the practices contained herein. By using any of our Services, whether by visiting the Web Site, downloading or using the Mobile App, and/or voluntarily providing your personally identifiable information to us, you acknowledge that we collect and use your information as set forth in this Privacy Statement.

APPLICABILITY OF THIS PRIVACY STATEMENT

This Privacy Statement is subject to the terms of the Web Site Terms of Use. This Privacy Statement applies only to information submitted and/or collected online through the Services, and does not apply to information that we may collect offline or other than through the Services (including through any Delta Dental social media websites or channels). In addition, this Privacy Statement is applicable regardless of the device used to access the Services (e.g., personal computer, mobile device, consumer electronics device, or any other technology or software known today or developed in the future) and to all users of Services. However, certain terms of this Privacy Statement apply only to individuals whose coverage is underwritten or administered by Delta Dental Companies (such individuals are herein referred to as “Members”) and/or who register for the Services. “Delta Dental Company” means an independent company that is member of Delta Dental Plans Association.  A complete list of the Delta Dental Companies is included at the end of this Privacy Statement.

This Privacy Statement does not apply to information about you collected by any third parties, including any of the Delta Dental Companies or by any other third party services, applications, or websites or advertisements associated with, linked to or otherwise accessible from the Services. The information collected or received by such third parties, including the Delta Dental Companies, is subject to their own privacy policies, statements, and practices and under no circumstances is Delta Dental responsible or liable for any third party’s compliance therewith.

WHAT INFORMATION DOES DELTA DENTAL COLLECT FROM YOU?

We collect a variety of personal information from and about you through the Services, including both directly from you and automatically as a result of your use of and access to the Services.

You have choices about the information we collect. When you are asked to provide information, you may decline; but if you choose not to provide information that is necessary to provide a service or feature, you may not be able to use that service or feature. For example, registering for an account is optional and requires you to provide additional information, including insurance information, your email address, and your name; similarly, if you request information about your coverage or claims through the Services (which request will go to the Delta Dental Company that administers or underwrites your dental benefits coverage) you will need to provide certain information as part of the request. In addition, as noted below in the section captioned “Cookies and Web Tracking,” it is possible to change your browser setup to block the automatic collection of certain information.

Information Collected Automatically – We use commonly-used automated information gathering tools on the Services. When you browse the Web Site and/or download and use the Mobile App, we collect information about your computer or mobile device and the network you use to access the Services, as well as information about your use of the Services. This includes software and hardware attributes of the device, unique device ID information, regional and language settings, performance data about the Services, network provider, and IP address (a number assigned to your computer when you use the Internet). In addition, information may also be collected passively in the form of log files that record website activity. For example, log file entries are generated every time a user visits a particular page or clicks an image on our website, and collects information on how many "hits" a particular web page is getting (a.k.a. "click-through data"), the dates and times that you use the Services, the pages you visit, the amount of time spent on specific pages, and other similar usage information, and general data (including the name of the web page from which you entered our Web Site). See also the section below captioned “Cookies and Web Tracking.”

Account Registration –If you choose to become a registered user of the Services, we request that you provide us your first name, last name, Member ID, social security number, date of birth, and ZIP code.

Find A Dentist – As a convenience, the Services permit you to search for participating dentists and oral health professionals (“Providers”) in your geographic area. When you choose to search for Providers, you may be asked to provide basic information regarding your dental insurance and either access to your device’s location information, your physical address, or your ZIP code in order to provide you with information regarding nearby Providers.

LifeSmile Score Risk Assessment – The Services permit you to complete a self-evaluation to receive a “dental health score,” also known as the LifeSmile Score Risk Assessment. When you use this feature through the Web Site, you are automatically redirected to a web page operated by Previser Corporation (“Previser”), an unaffiliated third-party service provider, and the information is collected directly by Previser. However, if you access this feature on the Mobile App, you are providing the requested information to Delta Dental, who, in turn, will send it to Previser. To take advantage of this feature, you are asked to enter your state of residence and your age within a range. Certain additional information is also requested for entry into this feature (See also the section below captioned “How Your Information Is Used – Sharing Information – LifeSmile Score Risk Assessment”). The LifeSmile Score Risk Assessment is also subject to a separate Terms of Use and Privacy Policy  and you should review those documents prior to using this feature.

Dental Care Cost Estimator – The Services permit you to receive cost estimates for certain common categories of dental treatment. To take advantage of this tool, you are asked to enter your ZIP code and the type of treatment sought. Use of this tool is also subject to a separate Terms of Use, and you should review that document prior to using this tool.

Contact Us – The Services also permit you to contact a Delta Dental Company via email. Please note that the email functionality provided by the Services is not a completely secure and confidential means of communication. It is possible that your email communication may be accessed or viewed by another internet user while in transit to us. If you wish to keep your communication private, do not use the email functionality. In such case, please contact the applicable Delta Dental Company by phone. Should you contact Delta Dental via email (support@deltadental.com or legal@deltadental.com), your email address and any other information you provide in such email will be collected and retained in accordance with this Privacy Statement. Such emails may not be secure and you may not want to include any personal information in such emails.

Mobile App – Individuals who download or use the Mobile App should note that the Mobile App permits the collection, communication, and storage of information in ways not typically available through web-based applications.

  • Location Services – If you permit the Mobile App to use location services (including global positioning system or “GPS”), depending on the settings on your mobile device, we may collect the precise or general location information provided by your device. If you want to deactivate this feature, you can deactivate location services and GPS functionality on your mobile device or remove the permission for the Mobile App to access location services. Please refer to your device manufacturer or operating system instructions for instructions on how to do this.
  • Additional Requests for Information and Access – When you download and/or use the Mobile App, we will ask for permission to access and/or to provide to you additional information or functionality, including the right to provide certain contact information directly to your Contacts folder, to provide “push” notifications, and to obtain access to photos if you wish to use photos to identify enrollees on your account.
  • Local Storage – The Mobile App may store certain information locally on your device depending on how you use it. If you use the “Remember Me” feature to assist you with logging into your account, your username will be stored locally. Users also have the option to save their member ID card to the Mobile App for easy access; this ID card contains your name, group name, plan name, and sometimes your Member ID number. You are responsible for securing your devices and any information, including personal information and/or individually identifiable health information (if any), stored on or accessible from the device, as well as any backup copies of such information that may be created by you or your device’s settings or applications. Locally-stored information is typically deleted if you uninstall the Mobile App or clear the Mobile App’s application data through your device’s settings, although it may be stored in device backups even after uninstallation or deletion of the Mobile App or its application data.

Cookies and Web Tracking - In order to personalize and enhance your experience on the Services, we may also automatically collect information through “cookies.” Cookies are small strings of text that are sent by the Services to your browser and then stored by your browser on your computer’s hard drive or other device. We also use cookies to help diagnose problems with our servers, to administer the Services, and to gather broad demographic information. Where a code in the cookie file enables the Services to label you as a particular user, including identifying you by name or other personal information, such cookie files are encrypted in order to protect your information. Most web browsers automatically accept cookies, but it is possible to change your browser setup so that it does not accept cookies. However, rejecting cookies may prevent you from taking advantage of certain portions, functionality or features of the Services.

Do Not Track  We do not engage in the collection of personal information about your online activities over time and across third party websites or online services. Accordingly, we do not currently process or comply with any web browser’s “do not track” (DNT) signal or other mechanisms that provide consumers with the ability to exercise choice regarding the collection of personal information about your online activities over time and across third party websites.

Finally, we may collect data that is not considered “personal information.” To the extent such data is stored or associated with personal information, it will be treated as personal information; otherwise, such data may be used or distributed at our discretion.

HOW IS YOUR INFORMATION USED?

Our Use of Information. We collect, retain, and use personal information with your consent; as required or permitted by law; for legitimate business purposes; to perform functions or activities on behalf of, or provide services to, the Delta Dental Companies and affiliates; and/or as necessary to complete any transaction or provide you with information or services you have requested or authorized. These uses include, without limitation: to provide you with information regarding Delta Dental, the Delta Dental Companies and affiliates and/or our/their products and services; to provide you information regarding dental health Providers in your geographic area; to provide the functionality of or obtainable through the Services; to respond to an inquiry from you or address a request submitted by you (including contacting you directly to request additional information to process your inquiry or request); to allow you to manage your benefits, including obtaining information regarding your benefits and/or claims submitted; to provide certain contact information directly to your Contacts folder; to provide “push” notifications; to access photos so that you may identify enrollees on your account; for Delta Dental’s proper management and administration or to fulfill our legal responsibilities; to perform data aggregation services in order to provide analysis relevant to the health care operations of the Delta Dental Companies; to create de-identified data; to operate and improve our services (including benefits offerings and services provided by the Delta Dental Companies); to operate or improve the Services; to monitor visitor traffic patterns and usage of the Services in order to assess overall Services activity, track interest in particular portions of the Services, and troubleshoot technical concerns; to gather and analyze data for our internal studies so we can constantly improve the Services; to comply with applicable laws, regulations and rules, and requests of relevant law enforcement and/or other governmental agencies; to enforce our Terms of Use; and/or to protect the rights, property, or safety of Delta Dental, our users, and others.

Note that our use, sharing, and processing of individually identifiable health information is described below in the “Individually Identifiable Health Information” section.

Sharing InformationWe do not sell or rent your personal information to third parties for their marketing use. Howeversome of the above uses involve sharing collected personal information with third parties, including service providers, business associates, affiliates, and the Delta Dental Companies. We share personal information with your consent; as required or permitted by law; for legitimate business purposes; as necessary to complete any transaction or provide you with information or services you have requested or authorized; to perform functions or activities on behalf of, or provide services to, the Delta Dental Companies; for our proper management and administration or to fulfill our legal responsibilities; to perform data aggregation services in order to provide analysis relevant to the health care operations of the Delta Dental Companies; and/or to create de-identified data; in each case as provided in this Privacy Statement. Examples include:

  • Booking Appointments through Brighter, Inc. – As a convenience, the Services provide links that permit you to book appointments with participating Providers through a separate platform operated by Brighter, Inc. (“Brighter”), a third-party vendor. Providers who do not display links to the Brighter platform have simply not signed up for the service or do not have any appointments times available within the next six weeks, and a Provider’s lack of, or failure to display, a Brighter link on the Services does not imply anything about the Provider. If you elect to take advantage of this functionality by clicking a link on the Services, the Services will notify you that you will be transferred to a third-party page. Certain personal information (including your first and last name, username, email, date of birth, and, optionally, your mobile phone number) will be shared with Brighter and the selected Provider. If you consent, you will be transferred to Brighter’s platform, which is subject to Brighter’s own Terms of Use and Privacy Policy. Delta Dental does not endorse or recommend any Provider, and has no access to or control over your or any Provider’s activity on Brighter’s platform. As a result, we have no responsibility for Brighter’s platform, the use thereof, or the information entered therein.
  • LifeSmile Score Risk Assessment – When you take the LifeSmile Score Risk Assessment Survey (the “Survey”), you are asked to provide your state of residence and age within a range. When you access this functionality from the Web Site, you do so through a third-party page where information is collected directly by Previser; however, if you access this functionality from the Mobile App, you are providing the information to Delta Dental, who, in turn, will send it to Previser. Other information requested by the Survey is collected directly by Previser and is not associated with other information that you may provide to us. Use of the LifeSmile Score Risk Assessment Survey is governed by the Previsor’s own Terms of Use and Privacy Policy. See also the information described below in the “Individually Identifiable Health Information” section.
  • Analytics – We use and share information with third party analytics service providers, such as Google Analytics, in order to provide us and/or third parties who work for or are affiliated with us (including the Delta Dental Companies) with information about the use of the Services and third party websites or applications, and to better understand how the Services are used. Such information will not include your name, address, Member ID, or similar information.

Also, we may share in aggregate, statistical form, non-personal information regarding the visitors to the Web Site, traffic patterns, and Services usage with our partners, the Delta Dental Companies, affiliates or advertisers. We may also share, on an identifiable basis, that you have used, and information regarding your usage of, certain features of the Services with the appropriate Delta Dental Company. In addition, we will disclose information we maintain, including personal information: (i) when permitted or required to do so by law, or may disclose such information in response to a request from a law enforcement agency or authority or any regulatory authority; (ii) to protect the integrity of the Services or the interests, rights, property, or safety of Delta Dental and its affiliates, our users, the Delta Dental Companies and others; or (iii) to enforce our Terms of Use.

RETENTION OF COLLECTED INFORMATION

We retain personal information collected through the Services for a reasonable period of time consistent with the purpose for the collection (e.g., to provide the services you request), or for other essential purposes including compliance with applicable laws, dispute resolution, and business operations. These retention periods can vary significantly depending on the type of information collected and the context.

MODIFICATIONS AND CORRECTIONS TO COLLECTED INFORMATION

We strive to maintain the accuracy of any personal information that may be collected from you, and will use our commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is not accurate. It is your responsibility to ensure that such information is accurate, complete and up-to-date. You may obtain from us, by email, the information in our records, although we may request certain reasonable additional information to help us authenticate such requests.

If you wish to make any changes to personal information you have provided to us through the Services, you may do so at any time by contacting the applicable Delta Dental Company that underwrites or administers your dental benefits coverage. Certain personal information may also be changed by logging into your account via the Services and updating such information.

COMMUNICATIONS OPT OUT

You may opt out of receiving materials or other communications from us by following the opt-out link or other unsubscribe instructions provided in any email received, or by contacting us as provided at the end of this Privacy Statement. You may also be able to customize the communications you receive from us through preferences in your user account if you have registered for such an account, such as by activating or deactivating push notifications through your mobile device’s settings. If you do business with us, you may not opt out of automated notifications based on business transactions (e.g., e-commerce).

CHILDREN

In compliance with the Children’s Online Privacy Protection Act, 15 U.S.C. §§ 6501-06 and 16 C.F.R. §§ 312.1-312.12, we do not permit children under 13 years of age to become registered users of the Services, and we do not knowingly collect information from children. By using the Services, you represent that you are 13 years of age or older.

THIRD PARTY WEBSITES

Delta Dental may reference or provide links to third party websites and services, including those of the Delta Dental Companies, and we are not responsible for and do not control the content, security, or privacy practices employed by such third-party services (including those of the Delta Dental Companies). This Privacy Statement does not apply to any such third-party services; please refer to the privacy statements or policies for such third-party services for information about how they collect, use, and process personal information.

PROTECTING YOUR PERSONAL INFORMATION

Because security is important to both Delta Dental and you, we employ reasonable safeguards designed to promote the security of our systems and protect your personal information from unauthorized destruction, use, modification, or disclosure. Personal information is protected using various physical, administrative and/or technical safeguards in transit and at rest.

However, it is important to note that no method of safeguarding information is 100% secure. While we try to ensure the protection of your personal information, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure and we cannot warrant that information you transmit utilizing the Services is secure. The email functionality provided by the Services is not a completely secure and confidential means of communication. It is possible that your email communication may be accessed or viewed by another internet user while in transit to us. If you wish to keep your communication private, do not use such email functionality. In such case, please contact the applicable Delta Dental Company by phone.

BUSINESS TRANSFER

Delta Dental may, in the future, sell or otherwise transfer some or all of its assets to a third party. Your personal information we obtain from you via the Services may be disclosed to any potential or actual third party purchasers of such assets and/or may be among those assets transferred.

INDIVIDUALLY IDENTIFIABLE HEALTH INFORMATION

Delta Dental considers your individually identifiable health information to be private and confidential. Except as otherwise permitted or required by law, Delta Dental collects, uses, and discloses your individually identifiable health information consistent with the terms of applicable HIPAA business associate agreements with the Delta Dental Companies. Applicable HIPAA business associate agreements generally permit Delta Dental to use and disclose your individually identifiable health information (1) to perform functions or activities on behalf of, or provide services to, the Delta Dental Companies, in connection with their role in underwriting  dental benefit coverage and administering dental benefit programs and claims, or as otherwise permitted or required by law including HIPAA; (2) for Delta Dental’s proper management and administration or to fulfill its legal responsibilities; (3) to perform data aggregation services in order to provide analysis relevant to the health care operations of the Delta Dental Companies; or (4) to create de-identified data. Where your dental coverage benefits are underwritten or administered by a Delta Dental Company, Delta Dental collects, uses, and discloses your individually identifiable health information consistent with the HIPAA Notice of Privacy Practices pertaining to your dental plan.  Your Delta Dental Company can be found by using the “Find your Delta Dental” tool at the end of this Privacy Statement.

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes.

INTERNATIONAL USE

Your personal information may be stored and processed in any country where we have facilities or where we have engaged a service provider, and by your use of the Services you acknowledge that we may transfer information to countries outside of your country of residence, which may have different data protection rules than in your country.

EFFECTIVENESS AND CHANGES TO OUR PRIVACY STATEMENT

This Privacy Statement is effective as of September 24, 2018. We reserve the right, at any time, to modify, alter, or update this statement, and any such modifications, alterations, or updates will be effective upon posting. In the event we modify this Privacy Statement, your continued use of the Services will signify your acceptance of the modified Privacy Statement.

 

QUESTIONS?

Questions regarding this Privacy Statement should be directed to legal@deltadental.com. Delta Dental may also be contacted directly at the following address and phone number:

Delta Dental Plans Association

1515 West 22nd Street, Suite 450

Oak Brook, IL 60523

Phone: (630) 574-6001

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