Chapter2Dental’s Privacy Policy

Effective January 1, 2019

Chapter2Dental Technologies Inc. (“Chapter2Dental”, “us” » or “our”) is a treatment plan presentation Platform provided and made available to you by Chapter2 Technologies Inc. (“Chapter2Dental”, “us” or “our”) through the Chapter2Dental mobile phone or tablet Application (the “Application”) and the Chapter2Dental Website (collectively, the “Platform”), at www.Chapter2Dental.com.

This Privacy Policy (the “Policy”) outlines how we collect, use, disclose, manage and safeguard your personal information and personal health information (“PHI”). All employees and third-parties working with Chapter2Dental have the obligation to comply with the protections described in this Policy.

For the purposes of this Policy, “personal information” means information about an identifiable individual. “Personal health information” or “PHI” means information about an identifiable individual that relates to the individual’s dental and medical health, including the name of the patient, his dental and medical health condition and the description of the recommended dental treatments.

Chapter2Dental collects personal information and PHI when the dental healthcare professional accesses and uses our Application, the Website www.Chapter2Dental.com (the “Website”) or our other software products (collectively referred to as “the Services”) to securely send dental treatment proposals to his patients through our Platform.

By using or accessing the Services, you are agreeing to the terms of the present Policy. This Policy should be read in conjunction with the Terms and Conditions of use.

You should not use the Services unless you fully understand and agree to the Terms and Conditions of use as well as the Privacy Policy.

We take the privacy of our users seriously and are committed to safeguarding your personal information and PHI. Should you have any questions about the Policy or our privacy practices, please contact our Designated Privacy Contact with your questions, at support@Chapter2Dental.com.

The Patient Portal of the Platform

We provide to our “Customers”, dental health professionals who accept our Terms and Conditions of use, access to our Platform (Application and Website), allowing them to add, collect and share their patients’ personal and medical information. When the Customer uses the Platform, he can add personal information about his patients, such as symptoms, medical history, health observations, diagnostics, examination results and treatment recommendations.

Customers can authorize internal and external parties (“Authorized Persons”) to use the Platform in order to provide a needed service to the patient as part of a treatment proposal or follow-up treatment.

Our Customers can choose to release this information to the Patient and Authorized Persons through a “Patient Portal” that allows the information and the exchange of communications to be shared between the Patient, the Customers and the Authorized Persons.

The dental healthcare professional and his Authorized Persons are solely responsible for the use and the disclosure of the patient’s information, both online and offline. Our Customers, dental healthcare professionals, are expected to comply with the privacy legislation in their state and their country of operation and must remain committed to good data protection practices of their patients’ records and the privacy policies recommended by their professional corporation. However, Chapter2Dental has no control over the use of the information shared by your dental healthcare professional and is not responsible for the good conduct and the privacy policy of dental healthcare professionals who invite their patients to access Chapter2Dental’s Platform.

Information We Collect and Store

Chapter2Dental collects the following information when a dental healthcare professional creates an account for himself or his patient with Chapter2Dental (the “Account”) or uses Chapter2Technologies’ Services:

Registration Information

As part of the registration process:

  • The Customer, dental healthcare professional, must provide information in order to create his account, such as his full name, the name of his dental practice and its physical address, his email address and his mobile phone number.
  • The patient must provide certain information to the dental healthcare professional, such as his full name, his email address and his mobile phone number.

Website Usage Information (Dental Portal)

When you access and use the Services, we may automatically collect certain technical information about your visit, including the date, time, browser type, your internet service provider, your IP address, device information (including device identifiers), geographic location, computer and network performance data, the URL from which you are accessing our Website and your navigation history in order to customize your experience with our Services, improve our Services, as well as for statistical research purposes and to allow the dental healthcare professional and his team to follow up on their patients’ records.

Information Collected from Treatment Proposals

Data obtained from consultations will be anonymized and de-identified before being analyzed and used by Chapter2Dental for product development and research purposes.

Providing Analysis and Other Professional Services

We use the information that has been made available to us for statistical research purposes (including the information relative to your browsing activities and actions on the Portal) in order to help us, as well as our partners, to evaluate the effectiveness of our service and the popularity of the different types of treatments offered in the dental industry. When we use such data, it is de-identified, and your personal information will never be disclosed.

Use and Disclosure of Your Information

Consultations and Healthcare Services

Access to your personal information is kept in a registry, and we regularly undergo verification in order to ensure that every access is authorized and that the access to this information is only authorized when necessary.

We may disclose to third-parties your demographic and contact information (including, without limitation, your name, email addresses or phone number) by email, SMS, instant messaging or any other means as necessary, for reasons such as: verification of your identity, medical monitoring, customer support and technical assistance.

Third-Party Service Providers

We may transfer your personal information, including Personal medical information, to a third-party service provider for processing and storage. Whenever we engage a third-party service provider, we ensure that the information is properly safeguarded at all times, at a comparable level of data protection that it would have received if it had not been transferred.

Legal Issues

We may use your personal information to detect, investigate, address or prevent fraudulent or illegal activities. We reserve the right to disclose your personal information as required by law when we believe that disclosure is necessary to comply with a judicial proceeding, court order or legal process served on us and to defend us against legal claims.

PHI Access Held by Chapter2Dental

Patients have the right to access their treatment proposals on Chapter2dental’s dental treatment Portal upon the invitation of their dental healthcare professional.

Accuracy

If you identify any inaccuracies, you must contact your dental healthcare professional to allow him to update the information.

Anonymized Information

When conducting product development, research, advertising or marketing, we only use anonymized, de-identified and aggregated information.

Retaining Your Information

If you want us to delete information from your Chapter2Dental account, you must contact the dental healthcare professional who sent you an invitation to access the dental Portal. The latter will contact us. We will ensure to do so within a reasonable timeframe after receiving your request.

We will retain any information that we are required to retain under any applicable laws and regulations for the full duration of time required under those laws. We may also retain any anonymized information and continue to use this information in accordance with this Policy.

Safeguarding Your Information

Chapter2Dental is committed to information security and protects your personal information and PHI through integrated, physical, technological and administrative safeguards:

– Secure storage: Chapter2Dental stores all personal information and PHI in a data centre in Canada. It adheres to the best practices in terms of global privacy and data protection.

– Network security: Chapter2Dental has implemented network security controls to protect against unauthorized access, including segregating its internal systems from its publicly accessible systems.

– Privacy Policy and training: Chapter2Dental has implemented a written Privacy Policy. Chapter2Dental’s employees and contractors are legally bound by confidentiality clauses.

Intervention in Case of Data Violation

There is no guarantee against data violations. However, Chapter2Dental has taken reasonable measures to prevent such violations, as described above. In the event of a data breach, Chapter2Dental will:

– Notify users at the first reasonable opportunity of a data violation; and

– Immediately apply remedial measures.

Changes to This Policy

If we decide to make changes to this Policy, we will notify users by placing a notice on our Website and our Application. You must periodically check the Website and the Application for updates.

Contacting Us

To ensure meaningful consent by patients, Chapter2Dental provides information about privacy practices in this Policy, as well as through our Designated Privacy Contact, at support@Chapter2Dental.com.

If you believe that we have not adhered to this Privacy Policy, please contact our Designated Privacy Contact, at support@Chapter2Dental.com.

If we are unable to resolve the issue to your satisfaction, you can file a complaint with the Access to Information Commission in your province or territory, or with the Office of the Auditor General of Canada.