Last Revised – December 15, 2020
This Privacy Statement (“Statement”) outlines how and when The Dentists Insurance Company (referred to herein as “TDIC”, “we”, “us” or “our”), a subsidiary of the California Dental Association and its affiliated organizations (collectively, “CDA”) collects information about you, and informs you how TDIC may use and disclose such information. This Statement applies to your use of the TDIC website located at www.tdicinsurance.com and any other websites, mobile applications or online service locations that post a link to this Statement (collectively, the “Sites”), or offline location that makes this Statement available to you.
TDIC affiliated organizations include the California Dental Association, TDIC Insurance Solutions, the CDA Foundation, the American Dental Association, and the officially chartered component societies of CDA.
- What information do we collect?
We collect information from you through the Sites by “direct means” and “automatic means.” We also collect information about you from other sources.
- Information collected by direct means.
We collect information you provide directly via the Sites or when you interact with us offline. For example, we collect information when you register on one or more of the Sites or otherwise submit information electronically to us through the Sites. We also collect information when you purchase or otherwise obtain or request goods and services online from TDIC or its service providers through the Sites. In addition, we collect information when you participate in any of our online features, such as our forums or blogs, submit advertisements to our classified listing or comments to our Sites, or engage in any email correspondence or other communications by means of the Sites. We also collect information when you sign up for and attend a risk management seminar.
The information we collect includes information that identifies, relates to, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. The following are categories of information we collect and have collected in the last 12 months:
- Contact Data, including your first and last name, postal address, billing address, email address, and telephone number, Drivers’ and other license numbers and social security numbers.
- Billing Data, including your payment card information (such as credit or debit card number, expiration date, and security code) to process your payments.
- Customer Licensure and Membership, including your American Dental Association member number, California dental license number, and license type.
- Account Credentials, including you username, password, password hints, and information for authentication and account access.
- Demographic Data, including your age, gender, and country.
- Profile Data, including your product preferences and interests.
- Content, including content within any messages you send to us (such as feedback and questions to customer support).
- Personal Contacts Data, including first and last name, email address, and phone number of your personal contacts. We collect data about your contacts with your consent and in order to fulfill a request by you, such as finding your contacts on the Sites or inviting your contacts to use our products or services. Such functionality is only intended for U.S. residents. By using this functionality, you acknowledge and agree that both you and your contacts are based in the U.S. and that you have your contacts’ consent for us to use their contact information to fulfill your request.
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
Information once aggregated or de-identified is not subject to this Statement and we use it without obligation to you except as prohibited by applicable law.
You represent and warrant that you will only provide information and use the Sites acting in your capacity as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit or other legal entity, and that your communications and transactions with TDIC occur solely within the context of TDIC providing the Sites to the company, partnership, sole proprietorship, nonprofit or other legal entity that you represent.
- Information collected by automatic means.
We automatically collect information when you use the Sites. The categories of information we have automatically collected in the last 12 months include the following:
- Service Use Data, including data about features you use, the pages and information you accessed on our Sites, the emails and advertisements you view, the products and services you view and purchase, the time of day you browse, the total time spent on our Sites, and your referring and exiting pages.
- Device Connectivity and Configuration Data, including data about device identifiers such as IP address and Ad Id (e.g., IDFA or AAID), the type of Internet browser and operating system you are using, your internet service provider, data regarding network connected hardware, and your device’s regional and language settings.
- Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).
We use various current – and later – developed tracking technologies to automatically collect information when you use the Sites, including the following:
- Log Information: Log information is data about your use of the Sites, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.
- Web Beacons (“Tracking Pixels”): Web beacons are small graphic images, also known as "internet tags" or "clear gifs," embedded in web pages and email messages. Web beacons may be used to count the number of visitors to the Sites, to monitor how users navigate the Sites, and to count content views. Pixels are used in combination with cookies to track activity on a particular browser on a particular device. We may incorporate pixels from separate entities that allow us to track our conversions, bring you advertising both on and off the Sites, and provide you with additional functionality, such as the ability to connect our Sites with your social media account.
- Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Sites. It is temporarily downloaded onto your device from our web server or another entity with whom we work, is active only while you are connected to the Sites, and deleted or deactivated thereafter.
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, please see “Analytics and Advertising” and “Your Rights and Choices” below.
- Information from other sources.
TDIC may collect more extensive information from you through activities outside of the Sites, the extent of which may depend on your additional activities as a member of TDIC, and the extent of additional goods and services you may acquire from or through TDIC. Such information may include, but not be limited to, drivers’ and other license numbers, social security numbers, purchasing information and results of surveys in which you choose to participate. The categories of other sources from which we have collected information, including but not limited to in the last 12 months, include the following:
- Insurance Entities from which we receive insurance underwriting decisions or claims adjustment.
- Data brokers or resellers from which we purchase data to supplement the data we collect
- Social Networks when you engage with our content, reference our Sites, or grant us permission to access information from the social networks.
- Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
Publicly-available information, including data in the public domain.
- How do we use information?
TDIC collects and uses your information for business and commercial purposes in accordance with the practices described in this Statement. Our business and commercial purposes for using information, including but not limited to in the last 12 months, include the following:
- to manage our Sites and process your orders for products and services and payments to TDIC;
- to respond to your requests for information about TDIC and the products and services we make available to you, and provide customer service;
- to send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
- to prevent and address fraud, breach of policies or terms, and threats or harm;
- to monitor and analyze trends, usage, and activities;
- to conduct research, including focus groups and surveys;
- to provide you with advertisements and communications in any form about TDIC (and affiliated organizations) and its offerings, products, services, promotions, rewards, and events we think you might be interested in (for information about how to manage these communications and marketing efforts, please see “Your Rights and Choices” below);
- for purposes included in or consistent with this Statement; and
- for any other business or commercial purposes at your direct or with your consent.
- How do we share the information we collect?
We share information we collect in accordance with this Statement. The categories of entities to whom we disclose information, including in the last 12 months, include the circumstances:
- Service providers. We share your information with service providers that provide certain services to us, including but not limited to, hosting, operating and maintaining the Sites, shipping purchases or sending other materials from TDIC, and to provide to TDIC services consistent with our statements under this Statement and any other applicable agreement between you and TDIC. These service providers have your information in order to perform their functions on our behalf. However, we contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the service for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purposes except as prohibited by applicable law.
- Security and compelled disclosures. TDIC to protect the rights, property and safety of TDIC, its affiliates, business associates, members and Site visitors or others We also share information to comply with the law or with a legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements;
- Business transfers. We may disclose information we have collected to relevant parties in the event of a bankruptcy, merger, acquisition, joint venture or other business transaction involving TDIC;
- Affiliates. We share your information with our affiliates for marketing and/or other internal business purposes;
- Partners. We share information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities; and
- Facilitating Requests. We share your information at your request or direction, such as when you choose to share information with a social network about your activities on the Sites.
- With your permission. At your direction or request, we share your information with notice to you and your consent.
TDIC does not generally sell information as the term “sell” is traditionally understood. However, to the extent the California Consumer Privacy Act is interpreted to include advertising technology activities such as those disclosed in the “Analytics and Advertising” section as a “sale,” we will comply with applicable law as to such activity. TDIC discloses the following categories of personal information for commercial purposes: contact information and identifiers such as cookies, demographic information, service use data, internet or other electronic network activity information such as IP Address, and profile information such as inferences. California residents should review the “Additional Disclosures for California Residents” section to learn how to opt out.
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
- Sweepstakes, Contests, and Promotions
We may offer sweepstakes, contests, surveys, and other promotions (each, a “Promotion”) jointly sponsored or offered with other entities. When you voluntarily choose to enter a Promotion, we share your information as set out in the official rules that govern the Promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
- Who is eligible to use and submit information to the Sites?
The Sites are made available for exclusive use by dentists, those practicing in the allied dental health professions and those professionals with related interests.
- How can you ask questions about our Statement and access your information?
If you have questions or concerns about this Statement, our data practices, our compliance with applicable law, or if you wish to modify, verify, correct, delete, or update any of your information collected through the Sites, please contact us at:
1201 K Street, 17th Floor
Sacramento, CA 95814
email [email protected]
You may also contact us by telephone at 800.733.0633.
If you have a disability and would like to access this Statement in an alternative format, please contact us using the contact information directly above.
- Social Media and Technology Integrations
The Sites contain content from and offer parts of the Sites through websites, locations, platforms, and services operated and owned by separate entities. In addition, our Sites integrate technologies operated or controlled by separate entities into parts of our Sites. Some examples include:
- Links. Our Sites include links that hyperlink to websites, platforms, and other services not operated or controlled by us.
- Liking, Sharing, and Logging-In. We may embed pixel or SDK on our Sites that allows you to “like” or “share” content on, or log-in to your account through social media. Remember that the social media network may independently collect information about you through integration. Also, if you choose to engage in such integration, we may receive information from the social network that you have authorized to share with us.
- Brand Pages and Chatbots. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on Facebook Messenger) is treated in accordance with this Statement. Also, if you publicly reference our Sites on social media (e.g., by using a hashtag associated with TDIC in a tweet or post), we may use your reference on or in connection with our Sites.
- Voice-Activated Skills. We may offer skills through Alexa, Google Home, and other voice-activated platforms, and use the voice processing and other technologies discussed in the “Information collected by automatic means” section above. Any information you provide to us when you engage with our skills is treated in accordance with this Statement.
- Analytics and Advertising
We use analytics services, such as Google Analytics, to help us analyze your access to and use of the Sites, compile statistic reports on the Sites’ activity, and provide other services relating to Sites activity and Internet usage. Similarly, we work with ad serving services, advertisers, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of this process, we may incorporate tracking technologies into our Sites (including our website and emails) to track your activities across time and services, for purposes of associating the different devices you use, and sending you relevant ads and other content after you have left the Sites (“Interest-based Advertising).
We also use audience matching services to reach people (or people similar to people) who have visited our Sites or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to a technology service or incorporating a pixel from a technology service into our own Sites, and the technology service matching common factors may share your email address with Facebook as part of our use of Facebook Customer Audiences. Some technology services, such as LiveRamp, may provide us with their own data, which is then uploaded into another technology service for matching common factors between those datasets.
For further information on tracking technologies and your rights and choices regarding them, please see “Information collected by automatic means” above and “Your Rights and Choices” below.
- Your Rights and Choices
- Account Information.
You may access, update, or remove certain information that you have provided to us through your account by visiting your account settings or sending an email to [email protected] We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and comply with applicable privacy laws.
- Tracking Technologies Generally.
- Cookies and Pixels. Most browsers accept cookies by default. With most Internet browsers, you can erase cookies from your device’s hard drive, block cookies or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions. Browsers offer different functionalities and options so you may need to set them separately.
- Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to required us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Please be aware, however, that some features and programs of our Sites may be unavailable to you if cookies are erased or blocked, or you disable or remove other tracking technologies.
- Analytics and Advertising Tracking Technologies.
The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Some of the advertisers and service providers that perform advertising-related services for us and our partners participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). TDIC is not responsible for effectiveness of, or compliance with, any other entities’ opt out options or programs or the accuracy of their statements regarding their programs.
To opt out of using your data for Matched Ads, you should be able to hover over the box in the right corner of such a Facebook ad and find out how to opt-out with us from such list. If you opt-out with us from Facebook matched list ad services, we will remove the matching information from that Facebook list, however, this will not take effect immediately and if you have multiple emails or other accounts you may have to opt-out separately for each one. Alternatively, to opt out you can contact us at [email protected] and specify that you wish to opt out of matched ads. We will request that the applicable technology service not serve you matched ads based on your information we provide to it.
You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devises) or “Opt out of Interest-Based Ads” (for Android devices).
Please note that if you opt out of using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or accuracy of any company statements regarding their opt out options or programs.
You can “opt-out” from receiving certain promotional communications from TDIC, which may prohibit TDIC from informing you of certain offerings that may be of interest to you. To opt-out of receiving certain promotional communications by following the instructions as provided in emails to click on the unsubscribe link or by sending an email to us at [email protected] with the word UNSUBSCRIBE in the subject field of the email. Please note that your opt out is limited to the email address or device used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing, or TDIC’s ongoing business relations.
The Sites are intended for a general audience and not directed to children under thirteen (13) years of age. TDIC does not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act (“COPPA”)) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe TDIC has collected such information from your child in a manner not permitted by law, please email us at [email protected] or send a letter to 1201 K Street, 16th Floor Sacramento, CA 95814 (Attention: Legal), and we will remove such data to the extent required by applicable laws.
In California, we do not knowingly “sell” the personal information of minors under 16 years old.
- International Transfer
We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Sites from outside of the U.S., please be aware that information collected through the Sites may be transferred to, processed, stored and used in the U.S. and other jurisdictions. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Sites or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing and storage of your information in the U.S. and other jurisdictions as set forth in this Statement.
- Additional Disclosures for California Residents.
- Shine the Light.
Customers who are California residents may request (i) a list of the categories of personal information that we have disclosed to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. If you would like to request this information, please email your request to [email protected] In your request, please specify that you’re making a “California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year. Please allow 30 days for a response.
- Right to Know and Delete.
Consumers who are California residents (and not representatives of businesses, whether those businesses are our customers or others) have the right to know certain information about our data practices in the preceding 12 months. In particular, they have the right to request the following from us:
In addition, in certain circumstances California consumers have the right to delete the personal information we have collected from them.
- The categories of personal information we have collected about them;
- The categories of sources from which the personal information was collected;
- The categories of personal information about them that we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold; and
- The business or commercial purpose for collecting or selling the personal information.
To exercise any of these rights, California consumers should submit a request through our online form, call our toll-free number at 800.733.0633, or email us at [email protected]. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
If personal information about you has been processed by us as a service provider on behalf of a customer and you wish to exercise any rights you have with such personal information, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of the customer on whose behalf we processed your personal information. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.
- Do Not Sell My Personal Information.
To the extent TDIC sells your personal information as the term “sell” is defined under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information on our website. You may also submit a request to opt-out by calling our toll-free number at 800.733.0633, or emailing us at [email protected].
We participate in the IAB CCPA Compliance Framework for Publishers & Technology Companies (“IAB Framework”). This means that where you exercise your right to opt-out of the sale of your personal information by clicking Do Not Sell My Personal Information, to the extent we sell your personal information in order to deliver ads tailored to your interests, we will notify downstream participants of the IAB Framework that receive personal information about you to only use your personal information for those specific and limited purposes that are permitted under the IAB Framework.
Please note that the scope of the IAB Framework opt-out may only apply to personal information from the specific browser or device from which you opt-out. In addition, exercising your right to opt-out of the sale of your personal information does not mean that you will stop seeing ads or that you will stop seeing interest-based ads. To learn more about interest-based advertising across sites and additional opt-out choices, please see the “Analytics and Advertising” and “Your Rights and Choices” sections above and the links set forth therein. Where you opt-out of the sale of purposes of the CCPA, but do not opt-out of interest-based advertising more generally, you may continue to receive ads tailored to your interests based upon personal information not sold by us, sold to other IAB participants at least 90 days before you opted out, or sold by other sources from which you have not opted out. We are not responsible for any downstream participants’ compliance with the IAB Framework or the accuracy of their privacy policies or statements regarding their opt-out options or programs.
- Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
- Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.
- Additional Disclosures for Nevada Residents
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at [email protected].
- Changes to this Statement
TDIC reserves the right to revise and reissue this Statement at any time. Any changes will be effective immediately upon posting of the revised Statement. Your continued use of our Sites indicates your consent to the Statement then posted. If changes are material, we may provide you additional notice to your email address. You should bookmark and periodically review this page to ensure that you are familiar with the most current version of this Statement. You can determine when this Statement was last revised by checking the “Last Revised” legend at the top of the Statement.