Data Privacy Policy

Affinity Dental Clinics is committed to protecting the personal information of our patients. In the course of providing you with quality dental services, we will ask for information about you and your health. Sometimes, we may also require and receive information from other providers who have been or are involved in providing you with the dental care you need. Our data privacy policy describes the type of personal information we use and collect, why we need the information, how we keep it and what we do with it. Our entire team is responsible for keeping your personal information secured. Only those who are involved in your treatment have access to your information such as Dentists and other dental professionals involved with your care and treatment, and the reception staff responsible for scheduling your appointments, processing your payments and managing your records.

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the patients voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2 We will only collect patients information that is necessary to fulfill the following purposes:

• To verify identity;

• To verify creditworthiness;

• To identify [client, customer, member] preferences;

• To understand the [financial, banking, insurance] needs of our [clients, customers, members];

• To open and manage an account;

• To deliver requested products and services

• To provide [medical, dental, counselling services;

• To ensure a high standard of service to our [clients, customers, members];

• To meet regulatory requirements; 

1.3 When you visit our Website, we automatically collect the information sent to us by your computer, mobile device or other equipment that provides access. This information includes, but is not limited to:

• Information from your interaction with our Website, including, but not limited to, device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from www.affinitydentalclinics.com, referring URL, ad data, IP address and standard web log information; and

• Information we collect through cookies, web beacons and similar technologies.

1.4 We collect and store any information you enter onto our Website, or use our Contact Form, or use our Appointment Request Form. This information includes, but is not limited to:

• Information that you provide to us when you use our Contact Form

• Information that you provide to us when you use our Appointment Request Form

• Additional information that you may provide to us through social media sites or third party Services;

• Information about your location and the location of your device, including your device’s unique identifier information if you have enabled this service on your mobile device

1.5 We may receive or collect additional information about you from third parties and add this to our account information. This information includes, but is not limited to: demographic data, navigation data, additional contact data and additional data about you from other sources, such as public authorities, to the extent permitted by the law.

Policy 2 – Consent

2.1 We will obtain patients consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be provided [e.g., orally, in writing, electronically, through an authorized representative] or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the patients voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a patients is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the patients does not opt-out.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), patients can withhold or withdraw their consent for Affinity Dental to use their personal information in certain ways. A patient’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the patients in making the decision.

2.5 We may collect, use or disclose personal information without the patients knowledge or consent in the following limited circumstances:

• When the collection, use or disclosure of personal information is permitted or required by law;

• In an emergency that threatens an individual’s life, health, or personal security;

• When the personal information is available from a public source (e.g., a telephone directory);

• When we require legal advice from a lawyer;

• For the purposes of collecting a debt;

• To protect ourselves from fraud;

• To investigate an anticipated breach of an agreement or a contravention of law

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose patients personal information where necessary to fulfill the purposes identified at the time of collection [or for a purpose reasonably related to those purposes such as:

• To conduct client, customer, member surveys in order to enhance the provision of our services;

• To contact our patient directly about products and services that may be of interest;

3.2 We will not use or disclose patients personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell patients lists or personal information to other parties [unless we have consent to do so].

3.4 By visiting our Website, or by using our Contact Form, or by using our Appointment Request Form, you agree that we may use your personal information for the following purposes:

• To personalize, measure, and improve our content and ads;

• To contact you, by e-mail, push notification, text message (SMS) or by telephone, to inquire about our Services for the purpose of targeted marketing activities, retargeting campaigns, updates, and promotional offers, or for any other purposes as set forth in this Personal Information Protection Policy.

3.5 By visiting our Website, we may place Cookies (data files on your phone or mobile device’s drive) or web beacons (electronic images that are placed in a web page’s code) or similar technologies. We use cookies to help us identify you as a user, to provide you a better experience on our Website, to remain present via retargeting campaigns, to measure promotional effectiveness and to ensure trust and safety on our Website.

Policy 4 – Retaining Personal Information

4.1 If we use patients personal information to make a decision that directly affects the patients, we will retain that personal information for at least one year so that the patients has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain patients personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that patients personal information is accurate and complete where it may be used to make a decision about the patients or disclosed to another organization.

5.2 Patients may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the patient’s correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of a patients personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2 The following security measures will be followed to ensure that a patients personal information is appropriately protected: the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access;

6.3 We will use appropriate security measures when destroying a patients personal information such as shredding documents, deleting electronically stored information.

6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 – Providing Patients Access to Personal Information

7.1 Patients have a right to access their personal information, subject to limited exceptions.

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

7.3 Upon request, we will also tell patients how we use their personal information and to whom it has been disclosed if applicable.

7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the patients of the cost and request further direction from the patients on whether or not we should proceed with the request.

7.6 If a request is refused in full or in part, we will notify the patients in writing, providing the reasons for refusal and the recourse available to the patients.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual

8.1 The Privacy Officer or designated individual is responsible for ensuring Affinity Dental’s compliance with this policy.

8.2 Patients should direct any complaints, concerns or questions regarding Affinity Dental’s compliance in writing to the Privacy Officer.