DRAGONTOOTH PRIVACY POLICY
Last Updated: August 6, 2019
1. SUMMARY
This Privacy Policy describes the data we collect, how we collect it, and how we use it when you access and use the DragonTooth service and the related website, content, and products (the “Services”), operated and owned by DragonCore Canada Inc. (the “Company”, or “we” or “us”) in connection with the DragonTooth application (whether accessed via a website or mobile application, hereinafter referred to as the “Application”). Your usage of the Services is governed by this Policy and by the Terms and Conditions of Use, both of which are available on our website at www.DragonTooth.ca
When you use DragonTooth, we recognize that you are trusting us with your information. As such, it is important that we explain our privacy practices and that you take the time to review them. If you have any questions or concerns, our contact information is available on this page.
2. THE DATA WE COLLECT
When you use the Services, the Company may collect the following data either directly through user submission or automatically as part of the functioning of the Services or Application (together, referred to as “Personal Data”):
• Contact information, such as your address, first and last name, your phone number, and your email address;
• Location information, which data may be continuously or periodically tracked via GPS, I.P. Address, or similar location tracking technology or marking methods, or via voluntary disclosure of your address or general locations, such as city, region, province, etc…
• Your banking or financial information, including credit card numbers and bank account information;
• Professional and business information, including licensing numbers, work history, personal resumes, employee/employer information, and other details necessary to complete the user profile for dental professionals (“Professional Users”) and business users (“Clinic Users”);
• Other information necessary to identify and authenticate the identity of users, details of such data may be amended from time to time.
Your data is collected in order to establish your account and user profile (your “Account”), under which you will interact with the Services and the Application. Not all data will be collected from every user, depending on the type of user – whether a Professional or Clinic User – and on the nature of their engagement with the Services. You hereby agree that the collection of this data is reasonable and that you are voluntarily submitting or providing such data.
Some aspects of your Personal Data may, at our discretion, be anonymized or obscured as part of the Service, such as information that may be relevant to your relationship with us but not with other users. By way of example, payment method information submitted by a Clinic User is not relevant to the Professional User, and vice versa. As such, you acknowledge and understand that the Company retains some discretion as to what may be displayed on the Services, but in any event, all information submitted as part of your Account shall be deemed to be Personal Data.
3. HOW AND WHEN WE USE, SHARE, AND DISCLOSE YOUR DATA
We use your Personal Data in order to improve and develop our Services, process payments (including processing through any third-party payment companies, such as Stripe, our current payment processor), analyze usage, provide support, and for the purposes of marketing by the Company. The Company will not share your Personal Data without your express permission except as provided for under this Policy.
Communication
We may use your Personal Data and contact information to contact you regarding your usage of the Services and to send marketing materials from time to time that we deem to be relevant to you. By using the Services, and by express agreement when you sign up, you consent to receive such marketing communications until such consent is revoked or otherwise terminated by you or by your discontinuance of your Account.
Data Sharing
Certain pieces of Personal Data may be shared with affiliates and business partners in order to provide or enhance the Services. Your Personal Data will be anonymized in such event unless specifically required by our third-party partners, such as payment processors or technology providers.
Permitted Disclosures
Your Personal Data may also be disclosed in order to comply with any legal or regulatory obligation or, in the case of a dispute, in order to defend the Company, its affiliates and business partners, or other users’ rights and interests (“Permitted Disclosure”). In the event of a Permitted Disclosure of Personal Data, the Company will only disclose identifying information where necessary or otherwise where required by law to do so.
Transfers of User Data Ownership/Management
In the event that the Company enters into a business transaction, such as a merger, amalgamation, purchase, or sale, it may be necessary for the Company to transfer ownership and management of the Personal Data to another entity or person. You hereby agree and understand that such a transfer shall be permissible and that any successor entity or person shall abide by the terms of this Policy or a successor Policy.
4. COOKIES AND WEB TECHNOLOGIES
“Cookies” are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. Cookies are used for various functional aspects of web services and websites you access every day.
The Company uses cookies and similar technologies for purposes such as:
Authenticating users and user profiles;
Remembering user preferences and settings within a web browser;
Determining and measuring the popularity or functionally of certain aspects of the Services;
Delivering and measuring the effectiveness of adds placed on the Services by Professional or Clinic Users;
Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our Services; and
The functioning of third-party services, including but not limited to payment processors and platforms, which may rely on cookies themselves in order to operate, including such functions as authenticating users and tracking usage.
You have the right to choose whether or not to accept the use of cookies within the Services. However, cookies are an integral part of the operation of the Services and as such you should be aware that your refusal to use cookies will impact the functionality and availability of the Services and the Application. Most browsers accept cookies by default, but those setting can generally be changed by accessing your system preferences either within the browser or within the system setting application of your operating system.
5. DATA STORAGE AND RETENTION
The Company requires user Personal Data in order to provide the Services, and retains such data for as long you maintain your Account and continue to use the Services. The Personal Data shall be physically stored and transmitted on the servers of the I.T. provider contracted by the Company for the provision of its Services and the Application. You should be aware that some Personal Data may be transmitted through other jurisdictions, such as the United States, and you hereby consent to such transmission. The Company shall make every reasonable effort to ensure that the service providers used by the Company are reputable and commercially well recognized and that these providers shall comply with all applicable laws and with this Policy.
The Company retains certain data, including transaction, location, device and usage information, for the minimum time frame required by the relevant laws, in connection with regulatory, tax, insurance and other requirements, in the places in which it operates. Once such information is no longer necessary to provide the Services, handle support issues, or enhance the Services, the Company will take steps to prevent access to or use of such data for any purpose other than compliance with these requirements.
You may request deletion of your Account at any time by contacting the Company. Following such request, the Company will delete the information that it is not required to retain. In certain circumstances, the Company may be unable to delete your Account, such as if there is an outstanding credit or debit on the Account or an unresolved claim or dispute relating to your Account. Upon resolution of the issue preventing deletion, the Company will delete your Account and Personal Data as described herein.
6. UPDATES TO THIS PRIVACY POLICY
We may occasionally update this Privacy Policy. If we make significant or material changes, we will notify you of the changes through electronic communication or via a notice posted in the Application. To the extent permitted under applicable law, by using the Services after such notice is given, you are deemed to have consented to the updates in this Policy.
We strongly recommend that you periodically review this Policy for the latest information on our privacy practices and policies. We will, upon request, make prior versions of this Policy available for review.
7. COMPLIANCE WITH LAWS
The Company provides the Services in a number of provincial and federal jurisdictions. Our Policy and practices are governed by the Government of Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), which applies to the collection, use, or disclosure of personal information in the course of commercial activity in Canada. For the purposes of PIPEDA, Personal Data, as defined under this Policy, shall be deemed to be “personal information.”
The Company shall comply with the code for protection of personal information, which is contained in Schedule 1 of PIPEDA. If you are concerned with any of our practices or have any questions about how the Company ensures compliance, please contact us. Please also be advised that you have a right to make a complaint to the Office of the Privacy Commissioner of Canada in the event that the Company does not adequately address your concerns.
The Company shall otherwise comply with all laws in the jurisdictions within which it operates and will, as applicable, update this Policy as changes in law and practices occur over time.
The Company does not provide the Services within the European Union or within any member state of the E.U., as such the Company makes no representations or warranties that the Services and this Policy are in compliance with the European Data Protection Regulations (“GDPR”).
8. QUESTIONS & CONTACT INFORMATION
If you have any questions or concerns about this Policy, or about the Company or Services in general, please email us at info@DragonTooth.ca.
