Opencare Privacy Policy

Last updated July 21, 2020

1. INTRODUCTION

Opencare Ltd (“Opencare”, “we”, “us”) has created this privacy policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information through our website located at www.Opencare.com (the “Website”) as well as to personal information we collect and use when we provide services on behalf of our dental practice customers (“Practice Users”). This Privacy Policy applies to all of the products, services (as more particularly described in our Terms of Use), and websites offered by Opencare or our related, affiliated and/or subsidiary companies (collectively the “Services”).

The privacy of our customers is of great importance to us. By visiting our Website and/or using the Services in any manner, you acknowledge that you have read the practices and policies outlined in this Privacy Policy and you understand that your Personal Information will be collected, used and disclosed in accordance with this Privacy Policy.

2. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy describes our collection, use and disclosure of information about identifiable individuals, including information which can be used to identify an individual (“Personal Information”). Personal Information does not include any anonymized information which we may create or derive from information (including Personal Information) you provide to us.

Personal Information may be collected about our Practice Users and prospective customers, visitors to the Website, and end users of the Services. You can choose not to provide us with certain Personal Information, but by doing so, you may not be able to take advantage of many of the features and functionality of our Services.

We may also collect Personal Information about patients of our Practice Users on behalf of the Practice User. This Privacy Policy does not apply to the practices of companies that we do not own or control, including Practice Users. Our Practice Users are responsible for maintaining their own privacy policies governing the collection, use and disclosure of Personal Information and for ensuring that they have obtained the necessary authorizations and consents for any Personal Information made available to us for use in accordance with this Privacy Policy. If you have any questions regarding the privacy practices of a particular Practice User, please contact the Practice User directly.

3. COLLECTION AND USE OF PERSONAL INFORMATION AND OTHER DATA

How we collect personal information

Opencare collects Personal Information in the following general ways:

  • Opencare collects Personal Information you choose to submit to us through the Services, such as your name, email address and other Account Information.
  • When you access or use the Services, Opencare may automatically receive and record information on our server logs from your browser, including your IP address, cookies, and the pages you request. IP addresses are automatically reported by your browser each time you view a web page. Your IP address is stored by Opencare when you register with Opencare. For more information, see Section 5.
  • If you call us, we keep a record of the date and time of the call.
  • We also collect and use personal information as a service provider or data processor on behalf of our Practice User clients, including billing information and insurance information that we collect directly from our Practice Users
We collect and use Personal Information for the following purposes:
To create your Opencare account

In order to use certain Services (such as to book an appointment), users may be required to create a valid Opencare account (an “Account”). When you register for the Services, Opencare collects your name, email address, birth date, zip or postal code, and if you are a Practice User, your business phone number and business address (“Account Information”).

Generally, Opencare uses the Account Information to authenticate access to the Account and provide access to the Services. In particular, we will use your email address to contact you with dentists located near you. We may also use this information to better understand, improve and personalize the delivery of our Services and related products and services, to conduct our business, to develop analytics and aggregated data that allow us to improve our Services and related products and services, or to correspond with you including to send technical notices, updates, security alerts and support and administrative messages on our own behalf or on behalf of Practice Users.

We also use information to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities.

To match you with a dental practice

If you request to connect with a dental practice, we may collect your postal code and responses to questions about your dental health and dentist preferences in order to match you to Practice Users that match your criteria.

If you book an appointment with a Practice User through the Services, Opencare will have access to information about your use of the Services such as dental appointments made, geo-location data and information exchanged between you and the Practice User that is combined with your Account Information. We use this information in order to provide Services, such as suggesting and matching users with local dental practices and appointment scheduling, as well as to confirm appointments have been completed so that we may bill our Practice Users.

To provide services to our Practice Users

Opencare makes its Website and the Services available to Practice Users for a variety of uses, as described in our Terms of Use. In order to provide the Services to our Practice Users, Opencare collects certain Personal Information such as contact and registration information from the dental practice employee signing up on behalf of the Practice User.

For Practice Users who register to appear on our Practice Marketplace, we will collect Personal Information related to the dental practice, including business contact name, email, phone number, address, as well names of practitioners and their specialties. We collect this Personal Information to match Practice Users with prospective patients.

When Practice Users engage Opencare to provide Revenue Cycle Management (RCM) Services, we collect and analyze data related to our Practice User customers (including their patients) on their behalf, such as: Providers, Provider Schedules, Operatories, Operatory Events, Operatory Schedules, Appointments, Patient name and contact information, Patient Insurance Plans, Appointment Finances, Appointment Procedure Codes, Insurance Companies, Insurance Claims, Fee Schedules, Treatment Plans, Recall, Patient Communications.

In this role, Opencare is a data processor, processing data upon instruction from such Practice User in order to provide the RCM Services. This data is shared only with the Practice User.

Some of the Personal Information received by Opencare in connection with the Services may be provided by Practice Users who are health care providers that are subject to health information data protection laws and regulations. In the United States, this includes rules issued under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH), that govern the use and disclosure of certain individually identifiable health-related Personal Information (“Protected Health Information”) by covered entities and their business associates. When we receive Protected Health Information, we may do so as a “Business Associate” of the health care provider under an agreement that, among other things, generally prohibits us from using or disclosing the Protected Health Information in ways that are not permissible by the health care provider itself, and requires us to implement certain measures to safeguard the confidentiality, integrity, and availability of the Protected Health Information. When we act as a Business Associate, we may be subject to certain laws and regulations, including certain HIPAA rules, that govern our use and disclosure of Protected Health Information and that may be more restrictive than otherwise provided in this Privacy Policy.

In Canada, Opencare is a service provider and may act as a service provider, information manager or electronic service provider under applicable privacy legislation, including Ontario’s Personal Health Information Protection Act (PHIPA) regulations.

To contact prospective Practice Users and partners

We collect names, email addresses and other business contact information about individuals who we consider to be prospective Customers and business partners (“Prospects”). Opencare uses third-party service providers in order to collect, store and process Personal Information about Prospects. We use these third-party service providers to identify Prospects and locate contact information to contact Prospects about our products and services.

To send marketing communications

With your consent, we use your email address or mobile phone number as well as other information on an optional basis to help us tailor our communications to you. You will receive email or text message communications from us regarding our products, services and initiatives (including collaborations and partnerships). If you do not wish to receive these communications, you can unsubscribe from such promotional e-mails at any time by clicking on the unsubscribe link in any of our e-mail communications or you can reply STOP to any of our text messages.

Alternatively, you can opt-out of receiving marketing communications by contacting us at the contact information provided in the “Contact Us” section below. Please note that you may continue to receive transactional or account-related communications from us, such as technical notices, security alerts and support and administrative messages.

If you participate in our referral program to refer a friend or family member to Opencare, we collect your name and email address as well as the name and email address of your friends and family member. We use this information for the purposes of sending the referral link to your friends and family member and tracking your rewards, and do not use your friend or family member’s information for any other purpose without their consent. Please ensure that you only provide information about individuals with whom you have a personal or family relationship, and who would want to receive the communication about Opencare.

To solicit reviews and referrals

If you have an Opencare Account, Opencare may use your contact information to solicit reviews and referrals for our services.

If you post a review about Opencare or a dental practice, we collect your name and the review. Your name and other personal information will not be published with the review; however your review will be publicly available on the Website. Please exercise caution before sharing any personal information, and review our Terms of Use for more about posting reviews.

To improve our products and services

Opencare uses demographic information collected about our users for our own business purposes, including forecasting demand for our products and services, improving our products and services and creating a personalized experience through targeted offers. Personal Information is not shared with third parties for these purposes.

To offer contests and promotions

If you enter a contest or participate in a promotion or event, we may collect your name, address, email address, phone number, and any additional information or content required for the contest or promotion. We use this information to administer the contest or promotion, including to deliver a prize to you.

To assist you when you contact us

When you contact us with a comment, question or complaint through email, telephone, or message features available on the Services, you may be asked for information that identifies you, such as your name, address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and service offerings.

To assess your application for employment

If you apply for a job with us, we may collect certain personal information about you (such as information that would be contained in a resume, cover letter, or other employment-related materials). We use this information for the purpose of processing and responding to your application.

4. MINORS

Opencare does not knowingly solicit or collect data from children nor knowingly market to anyone under the age of majority in their jurisdiction of residence. If you are under the age of 13, you are explicitly not authorized to use this Services. If you become aware that your child has provided us with Personal Information without your consent, please contact us at info@opencare.com. If we become aware that a child under the age of majority in their jurisdiction of residence has provided us with Personal Information, we will take reasonable steps to remove such information from our systems and terminate the applicable account.

5. WEBSITE INFORMATION

In general, you can visit our Website without telling us who you are or creating an account. However, like many internet and mobile services, we may automatically gather certain information about our Services traffic and store it in log files. This information includes mobile device identifiers, browser type, IP address, mobile or internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer the Services, to understand users’ movements around the Services. We may link this automatically collected data to Personal Information. Device identifiers may be tied to Personal Information to troubleshoot access issues.

Log Files

Opencare may automatically gather certain information about our Service’s traffic and store it in log files. This information includes mobile device identifiers, browser type, IP address, mobile or internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer the Services, to track users’ movements around the Services, and to gather demographic information about our user base.

We also store in our log files information identifying users who have accessed data that we store about patients, and any changes they make to such data. We use this information to comply with legal obligations relating to such data and to keep a record of such changes. We may also use it to improve our Services, where such use is permitted by law.

Cookies and other tracking technologies

Opencare requires authentication and authorization in order to process Account access. As such, we use cookies throughout the Services to authenticate users. You may turn off cookies in your browser though, in doing so, some or all of our Service features may not work.

A cookie is a small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device. We assign a different cookie to each device that accesses our Website.

We use cookies to recognize devices and provide a personalized experience on our Website, and to authenticate your device in order to provide you access to your Account and facilitate your use of our Services. Accordingly, Opencare uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Opencare to process your online transactions and requests. Session cookies help us make sure you are who you say you are after you’ve logged in and are required in order to use the Services.

We also allow other companies that are presenting advertisements on some of our pages to set and access their cookies on your computer. Please note that ad networks’ use of cookies or web beacons, and that of any other third-party that has a link available on any Site, is subject to their own privacy policies and not this privacy policy. Advertisers or other companies do not have access to our cookies.

If you prefer, you can turn off cookies in your web browser by changing your browser’s security settings. Please note, however, some features of our Products and Services may not function properly if your browser’s cookies are disabled. You may be able to set your browser to notify you when you are sent a cookie. This gives you the choice to decide whether or not to accept it.

Interest-Based Advertising

We work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our Website and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. For example, the third-party technologies may collect and share personal information with third party insurers who want to advertise a particular dental insurance product to users. This information may also be used to evaluate the effectiveness of our online advertising campaigns.

Opting-out of Interest-Based Advertising: For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.

You can opt out of targeted advertising from third parties by using the links below:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.

To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.

At this time, this Service does not support Do-Not-Track signals. However, you can follow the instructions above to opt-out of interest-based advertising.

Analytics

We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at the following links:

Third Party Links

Our Website may contain links to other websites that Opencare does not own or operate, including Practice User websites. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

6. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION

Opencare processes and stores data collected by Opencare, including Personal Information, on cloud servers located in the United States and Canada. Opencare also transfers data to the third-party service providers described in Sections 3.3 and 5.2 who may not be based in the region you are located in but we take steps reasonably necessary to ensure that the data is subject to appropriate safeguards, such as where applicable, relying on contractual commitments from our service providers.

Personal Information may be accessible to law enforcement and governmental agencies in Canada, the United States and other jurisdictions in which your Personal Information is stored (if applicable) under lawful access regimes or court order.

7. DISCLOSURE OF PERSONAL INFORMATION

Dental Practices

If you request a booking with a particular dental Practice User, we will share your name, email address, contact information, preferred appointment times and all answers provided to questions during the booking process with that practice in order to facilitate your appointment with that dentist.

Service Providers

We may from time to time employ third parties to perform tasks on our behalf and we may need to share Account Information and other Personal Information with them to provide certain services. We do not authorize such third parties to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. The third parties we currently engage include third party companies and individuals employed by us to facilitate our services, including the provision of maintenance services, hosting services, database management, Web analytics, payment processing, email and content marketing services, advertising services, sales productivity services, and general improvement of the Services.

Marketing

We may also share aggregated, non-identifiable data to conduct our business, improve the delivery of our Services, to develop analytics, and to enable us and our partners to improve and promote our products and services.

If you are located in the United States, we may sell your information to third parties in lead generation marketing initiatives. For example, we may provide contact information to third party insurers who want to advertise a particular dental insurance product to users. If you use Opencare services but don’t schedule an appointment through Opencare, we may, from time to time, sell your Personal Information to third party partners who wish to communicate with you about dental health related products and services. If you do schedule an appointment through Opencare, that information is considered Protected Health Information, and we will not sell that to third parties. Opencare does not knowingly sell the personal information of minors under eighteen (18) years of age without affirmative authorization.

Referrals

If you are referred from an existing user, the user will be notified that you booked an appointment through Opencare. This allows us to keep track of referral and administer our referral rewards programs. For more information about our Refer a Friend program, please review the program terms at https://www.opencare.com/terms/referrals.

Business Transfers

If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other prospective or complete change of control, Personal Information may be made available or otherwise transferred to the prospective or new controlling entity, in accordance with applicable law.

With Your Consent

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.

Legal Compliance

We, and our affiliates and Service Providers may disclose your Personal Information to third parties without your consent in response to a warrant or other legally valid inquiry or order, for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

We may also disclose Personal Information if we believe it is necessary to investigate potential violations of our Terms of Use, or to enforce those Terms of Use.

8. RETENTION

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or to meet our legal or regulatory obligations.

9. ACCESS, CORRECTION AND ACCURACY

You have the right to access, correct and update inaccuracies in the Personal Information we hold about you. Upon receipt of your written request, we will provide you with access to or a copy of your Personal Information, although in certain limited circumstances where permitted under law, we may not be able to make all relevant personal information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

If we receive a request from an individual to access or update personal information we have collected on behalf of a particular Practice User in the course of providing the Services, we will direct that individual to the relevant Practice User. We will assist our Practice User clients wherever possible in responding to individual access requests.

10. OPT-OUT CHOICES

To “opt-out” of (1) any consents previously given to us, (2) receiving communications from us, or (3) having Personal Information disclosed to third parties, send an e-mail to privacy@opencare.com. To opt-out of interest-based advertising from Opencare, please see the “Interest Based Advertising” section above. Please note that we may continue to use and retain your Personal Information as necessary in order to provide Services to you.

11. TERMS OF USE

Please also visit our applicable Terms of Use, which establish the use, disclaimers, and limitations of liability governing the use of our Services.

12. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date at the top of this page. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or Website or sending you an email prior to the change becoming effective.

13. CONTACT US

If you have questions regarding our Privacy Policy or the manner in which we or our service providers treat your personal information, or to request access to our collection of your personal information, please contact us at: info@opencare.com.

If you have any questions regarding the privacy practices of a particular Practice User, please contact the Practice User directly.