Dentsply Sirona's External Privacy Statement - EU
Last Updated: July 1st 2020
This global Data Protection and Privacy Statement (the “Privacy Statement”) sets out how we, DENTSPLY SIRONA Inc. (a Delaware, United States corporation with its headquarters at 13320-B Ballantyne Corporate Place, Charlotte, NC 28277 USA) and all of our global affiliates (“DENTSPLY SIRONA” or “we”) handle Personal Data that we process when you visit our webpages, purchase a product, enroll in one of our email services, request information, register on the websites, enter one of our contests, participate in a promotion, loyalty or rewards program, use any of the other interactive portions of our websites, communicate with us through social media, by phone, through educational conferences, workshops, or other events, or in connection with an actual or potential business or employment relationship with us (together “data subjects”).
Questions about this privacy statement
If you have any questions or comments about this Privacy Statement, DENTSPLY SIRONA’s privacy practices, or if you would like us to update information or preferences you provided to us, please contact us at:
Email: EUprivacyoffice@dentsplysirona.com with “FAO: Data protection officer” in the subject header (the “Data Protection Contact”),
Web: www.dentsplysirona.com and use the information on the “Contact Us” page.
Types of personal data we process
1. In the European Union (EU), “personal data” is defined very broadly and includes any information relating to a natural person, who can be identified, directly or indirectly, from data that we hold about them or from data that is combined with other information. It may include data relating to our employees, customers, patients, shareholders, contractors or the staff of our suppliers, visitors to our buildings or website users.
The types of Personal Data we may hold about you include:
a) Contact information (such as name, postal or email address, and phone number);
b) Business contact information (such as job title, department and name of organization);
c) Professional information (such as experience with DENTSPLY SIRONA products or services);
d) Payment details (including payment card number, expiration date, and billing address);
e) Shipping information (including the shipping address, dental distributor and phone number);
f) Username and password for the account you may establish on our websites;
g) Content (such as photographs and comments);
h) Information you choose to provide in connection with an employment application (such as veteran status, gender and ethnicity);
i) Information about you, your physical condition or your health which may be provided to us by you or your health providers to enable us to manufacture products for you;
j) Information generated by us in the course of managing our relationship with you, such as a history of our interactions with you, your purchases from us and information about your use of our products;
k) Information in connection with your interactions with pages you visit on our websites, such as your IP address, browser type, device used to access our websites, your preferences and information you clicked on our websites; and
i) Other information (such as demographic data, and shopping behaviour and preferences).
Purposes for which we process personal data
2. DENTSPLY SIRONA needs to process Personal Data about you for a variety of purposes. DENTSPLY SIRONA will only process your Personal Data in accordance with applicable law for the following purposes:
a) Manage our business relationship with you, for example: (i) process your transaction; (ii) manage and maintain your account with us; (iii) respond to your questions and comments and provide customer support; (iv) set up a Dentsply Sirona loyalty program account; (v) allocate a Territory Sales Manager or equivalent to be your dedicated account manager;
b) Marketing, advertising and public relations, for example: (i) marketing our business and products to you; (ii) provide you with information you have requested about our company, our products and our services; (iii) provide you with information about, or samples of, our product range for marketing purposes; (iv) contact you through email, telephone or postal mail; (v) tailor your experience on our websites by providing content that is relevant to your interests and geographic region;
c) Maintenance and statistics, for example: (i) help diagnose problems with our server; (ii) compile broad statistical data; (iii) update, administer and maintain our websites;
d) Recruitment purposes, for example; (i) evaluate your interest in employment and contact you regarding possible employment with DENTSPLY SIRONA; (ii) process your application, monitor recruitment statistics and comply with government reporting requirements;
e) Compliance, legal, regulatory and ethical purposes, for example (i) enforce our Terms of Use or other legal rights; (ii) comply with applicable laws, regulations and requests from governmental agencies; (iii) comply with industry standards and our policies; and
f) Research and product development, for example we may use information about your experience of using our products to help us improve our products.
Legal ground for processing Personal Data
3. EU Data protection law requires us to have a legal basis before processing any Personal Data about you. The legal basis for us processing your Personal Data for the above purposes may be because: (i) you have provided your consent; (ii) it is necessary for the performance of a contract with you; (iii) the processing is necessary for our compliance with a legal obligation; or (iv) the processing is in our legitimate interests of operating and promoting our business.
4. To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your Personal Data. In some circumstances, withdrawing your consent to DENTSPLY SIRONA’s use or disclosure of your Personal Data will mean that you cannot take advantage of certain DENTSPLY SIRONA products or services.
Disclosure of Personal Data relating to data subjects
5. We intend to keep your Personal Data confidential, in compliance with our legal obligations. We do not sell, rent, trade or otherwise disclose Personal Data to third parties, other than as described in this Privacy Statement, for the purposes described above, or as we disclose to you at the time the information is collected. We may disclose your Personal Data in accordance with, and where permitted by, applicable law:
- to our subsidiaries, branches or associated offices;
- in order for us to comply with our legal obligations, e.g. where we are required to disclose certain information to tax authorities or where we are required to respond to requests by law enforcement;
- to protect the security or integrity of our business, including our databases and systems as well as the safety of our employees, customers and website visitors;
- to any of our outsourced vendors, suppliers or distributors to facilitate the provision of contracted services or goods or to provide expanded services to our customers and website visitors, for example; outsource the processing of certain interactive website functions, administering email services, running special promotions and managing any loyalty points program;
- for the purposes of facilitating a purchasing transaction with one of our distributors or dealers;
- for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event; and
- to any other third party where you have provided your consent.
Security measures used to protect Personal Data
6. DENTSPLY SIRONA takes appropriate physical, technical and organisational security measures designed to safeguard and secure any Personal Data you provide to us. Nevertheless, unencrypted transmission to DENTSPLY SIRONA via the internet is not completely secure and we cannot guarantee the security of your Personal Data during any such unencrypted transmission.
International transfer of personal data
7. We may disclose or transfer your Personal Data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out in section 2 above, in particular your Personal Data may be transferred throughout the DENTSPLY SIRONA group. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by organizational, technical, contractual and/or other lawful means.
Retention of personal data
8. Your Personal Data will be retained for the duration of our business relationship and for a period of time thereafter as required by applicable local law or where we have a legitimate and lawful purpose.
9. DENTSPLY SIRONA will retain applications of unsuccessful candidates for a reasonable period after the application process to enable us to contact you if another suitable position arises or to comply with our legal obligations.
Data subject rights
10. Data protection laws often provide individuals with numerous rights, including the right to: access, rectify, erase, restrict and object to the processing of, their Personal Data. Individuals may also have the right to lodge a complaint with the local data protection authority if they believe that their Personal Data is not being processed in accordance with applicable data protection law. If you would like to exercise any of these rights, please contact the Dentsply Sirona Privacy Office at EUprivacyoffice@dentsplysirona.com. To assist us in responding to such requests in a timely fashion, please include the phrase “Privacy Rights Request” in the title of your message.
11. Data subjects may, where permitted by applicable law, request copies of their Personal Data. This is known as a subject access request or “SAR”.
12. If you would like to make a SAR, i.e. a request for copies of the Personal Data we hold about you, and you are in a jurisdiction where applicable law grants you such rights, you may do so by writing to the Data Protection Contact whose details are provided above. The request should make clear that a SAR is being made. We may ask you to provide evidence of your identity if it is not clear.
13. Responding to a SAR can be a time consuming exercise. DENTSPLY SIRONA may be able to get the information that you require more quickly if you are as specific as possible in your request. E.g., “I would like a copy of my Personal data contained in my website member account file” or if you would like a copy of a particular document it would be helpful if the document is described carefully, including the title, creation date, author and likely place of storage. This will help us to respond to your SAR as quickly as possible. You may be asked for further details to assist us if insufficient information is provided.
Public areas
14. This website may make chat rooms, careers, message boards, and/or news groups available to its users at various times. Please remember that, unless otherwise stated, any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information in these areas. Do not use these areas to post personal information about third parties or discuss information about specific, identifiable patients.
Links to other websites
15. Our websites may contain links to other websites. DENTSPLY SIRONA is not responsible for the privacy practices or the content of unaffiliated third-party websites. To help ensure the protection of your privacy, we recommend that you review the privacy policy of any website you visit via a link from our websites.
Updates to our privacy statement
16. We may at any time in our sole discretion revise or update this Privacy Statement. We will indicate at the top of the Privacy Statement when it was most recently updated. All changes are effective immediately when they are posted and apply to all access to and use of the websites thereafter. If you object to any modification, your sole recourse is to stop using the websites and providing us with Personal Data.
Cookies/tracking statement
17. In order to collect certain data described in this Privacy Statement, we may use cookie technology on our websites.
A cookie is a small text file which is sent to your browser and stored on your computer's hard drive, mobile phone or other device. Session cookies make it easier for you to navigate our websites and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use our websites, and enhance your user experience. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the services and features offered through our websites may not function properly if your cookies are disabled.
The following are examples of cookies that may be used on our websites:
a) Strictly necessary cookies. These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for, like saving your job application, adding products to a cart or checking out, cannot be provided.
b) Performance / analytic cookies. These cookies collect data about how visitors use our websites, including the country from which the visitor is accessing the websites. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. Provided you have filled out the contact form on our website, these cookies may be used to contact you for a sales call.
c) Functionality cookies. These are used to recognise you when you return to our websites. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
d) Targeting/Advertising Cookies: These are used to deliver ads which are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They remember that you have visited the website and this information may be shared with other organizations, e.g., advertisers. We use these cookies only if you have consented.
18. Our websites also use social and video plugins such as those provided by Facebook, Twitter, Instagram, LinkedIn or YouTube.
When you visit a page of our websites that contains a social, video or other plugin, your browser establishes a direct connection to the server for that plugin and provides them with the information that you have accessed on the corresponding page of our websites. If you are logged into that service as well, your visit can be connected to your account with that service. Therefore, if you interact with the plugins, for example by clicking “Like,” or entering a comment, the corresponding information is transmitted from your browser directly to that party. Your interaction with those services are governed by their applicable privacy policy and other policies which can be located on their websites.
19. When you visit our websites, we may allow some third parties (such as advertising networks and data analytics companies) to collect Personal Data about your online activities over time and across different websites. For example, session recording tools, record your preferences and track your use of the websites. To find out more about your choices with respect to these tracking technologies, see “Your Choices.”
Your Choices
20.If you no longer wish to receive promotional emails, you may unsubscribe at any time by clicking the “unsubscribe” link in the promotional emails sent to you or by contacting the Data Protection Contact whose details are provided above. If you have an account with us, you may also unsubscribe from promotional emails through your account. Please note that even if you opt-out of receiving promotional emails from us, we may continue to send you non-promotional emails.
21. If you have an account with us, you may make changes to your Personal Data by logging into your account and making changes there.
22. If necessary to comply with applicable law, we will ask for your consent to place cookies on your device. Once your consent has been provided, this consent message will not appear again when you revisit our websites. If you, or another user of your computer, wish to withdraw your consent at any time, you can do so by altering your browser settings or by contacting the Dentsply Sirona Privacy Office at EUprivacyoffice@dentsplysirona.com. You can find more information about cookies at: www.allaboutcookies.org and http://www.youronlinechoices.com/uk/.
23. Regular cookies generally may be disabled or removed using tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies or other tracking technologies. For information on disabling Flash cookies, visit this page.
Please be aware that if you disable or remove these technologies, some part of our websites may not work and when you revisit our websites your ability to limit browser-based tracking technologies is subject to your browser settings and limitations. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, our websites currently do not recognize when they receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” visit http://www.allaboutdnt.com.