This policy explains how we use your personal data for our dental care services and products. It also governs the use of your data through our App, or any of our websites, including the Adent website, adent-health.com. Any reference to our App in this policy shall also include a reference to our websites.
This policy covers:
Who we are;
What personal data we hold and how we get it;
What we use your personal data for;
Sharing your personal data;
Data security and transfers; and
If you have any further questions about how we process your information, please don't hesitate to get in touch by contacting our Data Protection Officer:
Address: Data Protection Officer, Adent ApS, Refshalevej 153, 2, 1432 Copenhagen K
Who we are
Our dental care services are delivered by a single company within our group which are both registered in Denmark: Adent ApS (CVR. 40512977) provides the technology that supports our services. The registered office and principal place of business for the company is Hesseløgade 44, 4. th., 2100 Copenhagen Ø.
Your relationship is with Adent ApS. When this policy talks about 'Adent', 'us' or 'we', it means Adent ApS. We might provide your data to other companies within our corporate group, including Adent ApS, which develops and maintains our software.
What personal data we hold and how we get it
We use the following categories of personal data:
When you register with us, you complete forms and provide us with basic information about yourself, such as your name, date of birth, physical address and email address.
Dental care, health and medical information
The main type of information we hold about you is dental health and medical information: information about your dental health, related health, symptoms, treatments, medications and procedures. This includes details of your potential bookings, consultations, and appointments with one of our partner dentists, non-partner dentists, other healthcare professionals and interactions with our digital services.
We get some of this information directly from you, when you register with us and when you use our dental care services. If you book an appointment with one of our partner dentists, we will receive information about booking, and if you have given your consent, we will retrieve and store your dental care history from the dentist to provide our services. If you use our services (including our App and customer support service), and if you have given consent for us to do so, we will send the consultation notes (notes obtained through one of our services, including our App and customer support service) that we take during your use of our services to your dentist (for minors, we will share such notes, in line with medical and dental care guidelines, without such consent). Any correspondence we receive from you is uploaded electronically to your Adent Dental Health Record, and you can at any time request to be informed of the content of your Adent Dental Health Record and/or request to delete your Adent dental record.
We also collect the images you take including the way you store, organize and comment on the uploaded images. You can access images of your Dental Assessments at any time through the App, or by requesting to be informed of the content of your Adent Dental Health Record. Without your explicit consent, we are not allowed to store this type of information, and we cannot provide you with our service.
We retain recordings of our consultations (including our App and customer support service) with you, in order to provide you with an easy way to review your consultations where you wish to, so that we can ensure high-quality care is provided to you, and, with your consent, to allow us to learn from them to improve our services. These recordings are held securely in accordance with our retention policy. You can access recordings of your consultations at any time through the App, or by requesting to be informed of the content of your Adent Dental Health Record.
We may also hold information about you and your dental or related health from other apps, devices and services where you have given your consent to that data being shared with us. Examples include where you decide to share information collected from a smartwatch, an electric toothbrush or similar device with our App.
If you make any payments on the App, your credit/debit card details are processed directly by a third-party processor that will store all payment information and transaction details. We will only retain details of transactions on secure servers and we will not retain your credit or debit card information.
Technical information and analytics
When you use our App, we may automatically collect the following information where this is permitted by your device settings:
(a) technical information, including the address used to connect your mobile phone or other devices to the Internet, your login information, system and operating system type and version, browser or app version, time zone setting, operating system and platform, and your location (based on IP address); and
(b) information about your visit, including products and services you viewed or used, App response times, interaction information (such as button presses) and any phone number used to call our customer service number.
We work with partners who provide us with analytics and advertising services (for our services only and not for third party advertising). This includes helping us understand how users interact with our services, providing our advertisements on the internet, and measuring the performance of our services and our adverts. Cookies and similar technologies may be used to collect this information, such as your interactions with our services.
Information obtained from third-party services
You may choose to connect your existing accounts with other providers (such as a social media provider) to your account with us. This may, for example, make it easier to create an account with us. If you choose to do this, we will receive limited information about you from that provider, such as your email address, name, and other sign-up related details.
What we use your personal data for
The purposes for which we use your personal data and the legal grounds on which we do so are as follows:
We obtain and use your personal details and financial details in order to establish and deliver our contract with you.
We obtain and use your medical information because this is necessary for dental care purposes, including Dental Health Assessments and the provision of Dental Health Plans. This includes the information and images collected through our App, customer support service consultations with you (such as notes and recordings), our digital services, and dental care history from your dentist and previous dentists if you have given us consent to do so (in the same way that any dental practice would receive your dental care history if they become your dentist). It may also include sharing information with other healthcare professionals as necessary for the provision of care to you, such as your dentist, specialist referral services (examples include dental services providing braces and dental implants, etc.), hospitals, accident and emergency services, pathology service providers, and diagnosis centres chosen by you for the purpose of any radiology and other imaging request forms.
Where you have provided your explicit consent, we will use your dental care information (always having removed personal identifiers, such as your name, address and contact details) to improve our dental care products and services, and our artificial intelligence system, so that we can deliver better dental care to you and other Adent users. This dental care and related medical information (de-identified in the way described above) may include your dental care and medical record (both records received and created by us), transcripts and recordings of your consultations, and your interactions with our artificial intelligence services, such as our symptom checker and image assessment services. This does not involve making any decisions about you - it is only about improving our products, services and software so that we can deliver a better experience to you and other Adent users, and help achieve our aim of making dental healthcare accessible to everyone. Strict confidentiality and data security provisions apply at all times.
We may obtain and use data about your precise location where you give your consent (through providing us access to your location), for example, to help direct you to a local dentist. We may also derive your approximate location from your IP address.
We use your email address and/or phone number to contact you with occasional updates and marketing messages where you have not opted out, based on our legitimate interest in marketing our services to you and subject to your right to opt-out at any time.
Based on our legitimate interest in managing and planning our business, we may analyse data about your use of our products and services to, for example, troubleshoot bugs within the App, forecast demand of service and to understand other trends in use, including which features users use the most and find most helpful, and what features users require from us. This does not involve making any decisions about you - it is only about improving our App so that we can deliver better services to you. Strict confidentiality and data security provisions will apply at all times.
Where necessary, we may need to share personal and financial details for the purposes of fraud prevention and detection.
We also store your medical information, such as notes from consultations, recordings of our consultations with you and your interactions with our digital services, for safety, regulatory, and compliance purposes. For example, we may need to review your information and, where necessary, make disclosures in compliance with reasonable requests by regulatory bodies including the Danish Health Data Authority, Danish Agency for Patient Complaints, or as otherwise required by law or regulation.
In order to support the research on dental health and detection methods, we may use your data, pseudonymized (without a direct link to your identity) or anonymized (without us being able to identify you at all), for research purposes. This may include sharing your data with carefully selected third party research institutions. By uploading your images in the App, you explicitly consent to the images being processed for the purposes of the provision of the services and to be used anonymously for the purposes of research and testing of our services. As such, your images may be reviewed by our employees or third-party consultants who work for us and who are bound by strict confidentiality. We will ask for your consent to process your data anonymously for research purposes.
Where necessary for safety, regulatory and/or compliance purposes, we may audit consultations and your other interactions with our services. Strict confidentiality and data security provisions will apply at all times to any such audit and access.
We may use non-personal data (data from which an individual cannot be identified) to improve our products and services.
Sharing your personal data with others
We may share your personal data with members of our corporate group and our partners (such as a dentist you choose to book an appointment with and/or visit). This is to help us deliver our services to you.
We may share your personal data with companies we have hired to provide services on our behalf, including those who act as data processors on our behalf, acting strictly under contract in accordance with Article 28 GDPR. Those data processors are bound by strict confidentiality and data security provisions, and they can only use your data in the ways specified by us.
We may share with our commercial partners aggregated data that does not personally identify you, but which shows general trends, for example, the number of users of our service.
Where you access our services through your dentist, health insurance provider or any of our commercial partners (including your employer) we may share with such partner your name, date of birth, email address, policy number, location, and the fact you have registered/used the service (and any other similar information). We will not without your consent share any details relating to the content of your consultation with us or your dental health/medical records. With your consent, we may share the date of the consultation (consultation using either our App and customer support service), details of your assessment, a related prescription, pharmacy location, whether or not you had a referral made and other similar information about your use of our services.
We will, where necessary for your treatment or care, share your information with your other health and social care providers. For example, your dentist and other dental care bodies, specialist referral services, hospitals, accident and emergency services, pathology service providers, diagnosis centres were chosen by you for the purpose of radiology and other imaging requests, and other health and care bodies. This may include sharing information with such services for safeguarding purposes in accordance with our legal obligations.
We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of our services or the physical safety of any person.
Except as described above, we will never share your personal information with any other party without your consent.
We will destroy or de-identify your personal information once it is no longer required for the purpose or purposes for which it was collected.
If you terminate our Services and delete your account, we will retain your personal information for a period of 12 months, after which we will delete your data. We will retain the images you have uploaded prior to termination in an anonymous form only, for the purposes of medical, clinical and commercial research, and for advancing and testing of the Services to the benefit of others.
We retain your dental care and related medical records in accordance with national best practice guidance - in particular, the latest advice and recommendations provided by the Danish Patient Safety Authority on their website, https://en.stps.dk/en/. The below is a summary of our retention policy, but we may retain records for other periods as required by law or regulation.
Dental health records
Retention period: Dental care health records are retained for at least 10 years after death or after the patient has permanently left the country unless the patient remains in the European Union. In the case of a child, if the illness or death could have potential relevance to adult conditions or have genetic implications for the family of the deceased, the advice of clinicians should be sought as to whether to retain the records for a longer period. Electronic patient records (EPRs) must not be destroyed or deleted, for the foreseeable future.
Retention period: Records on maternity (including information we collect on current or prior pregnancy) are retained for at least 10 years after the birth of the last child.
Records relating to persons receiving treatment for a mental disorder within the meaning of mental health legislation
Retention period: If and when we collect information on treatment for a mental disorder that is relevant to your dental health, these records are retained 10 years after the date of the last contact.
Data storage, security and transfers
We do not store your personal health data on your mobile device. We store all your personal health data - including your dental care information, information on dental assessments, information on any dental plan you choose to use with our services, medication information and any other related health information - on secure servers.
Where you have chosen a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Adent does not store or handle your password. Authentication with our services is processed via a third party authentication provider that has certification for compliance with the security management best practices and security controls specified by ISO 27001.
We do not store any credit or debit card information. Payments are processed via a third-party payment provider that is fully compliant with Level 1 Payment Card Industry (PCI) data security standards. Any payment transactions are encrypted using SSL technology.
Your data may be processed or stored via destinations outside of Denmark and the European Economic Area, but always in accordance with data protection law, including mechanisms to lawfully transfer data across borders, and subject to strict safeguards. For example, we work with third parties who help deliver our services to you, whose servers may be located outside Denmark or EEA.
As indicated above, whenever we rely on your consent to process your personal data, you have the right to withdraw your consent at any time by accessing the privacy settings in the App.
You also have specific rights under the GDPR and DPA to:
Wherever we process data based on your consent, withdraw that consent at any time. You can do this by sending an email to firstname.lastname@example.org
Understand and request a copy of the information we hold about you. Notes obtained in relation to your dental assessments can be accessed via the App. For other information, you can make a request by email;
Ask us to rectify or erase information we hold about you, subject to limitations relating to our obligation to store medical records for prescribed periods of time;
Ask us to restrict our processing of your personal data or object to our processing; and
Ask for your data to be provided on a portable basis.
You may also contact The Danish Data Protection Agency (DPA/Datatilsynet, the data protection regulator in Denmark): Borgergade 28, 5, Denmark, 1300 Copenhagen K, telephone: 0045 3319 3200 (local rate).
For any questions or concerns, you can contact us by sending an email to email@example.com