Futuredontics, Inc. ("Futuredontics") California Resident Privacy Rights Notice

This California Resident Privacy Rights Notice governs the manner in which Futuredontics collects, uses, shares, maintains, protects and discloses personal information collected from and about California Residents.  Futuredontics collects personal information in a variety of ways, most prominently through its 1-800-Dentist call center and its portfolio of websites including, most notably, Futuredontics.com, 1800Dentist.com, Dentistry.com, nationaldentalreviews.org dentalreferral.com, patientactivator.com, webdirector.com and 18dreputationmonitor.com.

This Notice shall be reviewed at least annually and shall be updated in accordance with the evolving requirements of CCPA and other applicable law.

I. California Shine the Light Disclosure.

California Residents that have interacted with Futuredontics as consumers can request and obtain from us once a year, free of charge: (i) information concerning the categories of personal information, as defined in the California Shine the Light Statute, Futuredontics disclosed to third parties for direct marketing purposes in the immediately preceding calendar year; and (ii)  the names and addresses of all third parties with whom Futuredontics shared such information in the immediately preceding calendar year.

To request this information, please submit your request in writing to:

Futuredontics, Inc.

Attn: Privacy Department

11209 National Blvd, #409

Los Angeles, CA 90064

Futuredontics is not required to respond to requests made by means other than through this mailing address.  There is no cost to you in exercising your rights under this Section.

II. California Do Not Track Disclosures.

“Do Not Track” is a preference you can set on your web browser (if supported) to opt-out of online behavior tracking. Futuredontics does not recognize or respond to your browser’s Do Not Track setting.

III. California Consumer Privacy Act.

This section supplements the privacy policy of Futuredontics by comprehensively describing Futuredontics’ online and offline practices regarding the collection, use, disclosure, sharing and sale of personal information and the associated consumer rights of California Residents in relation to the California Consumer Privacy Act (“CCPA”). 

Terms referenced herein shall, as applicable, have the meaning defined in CCPA. 

1. Futuredontics Collection and Disclosure of Personal Information

1. The table below displays: (i) categories of California Resident personal information Futuredontics collects and/or discloses; (ii) examples of such information; (iii) categories of sources for the information; (iv) business/commercial purposes; and (v) with respect to disclosure, categories of third parties. These practices are currently in place and had been throughout the preceding twelve (12) months.
   

   Categories of Personal Information for Collection and/or Disclosure	Examples of Personal Information for Collection and/or Disclosure	Categories of Sources for Collection	Business/Commercial Purpose for Collection and/or Disclosure	Categories of Third Parties for Disclosure
   Identifiers	May include but is not limited to: name, address and telephone number	California Residents directly Advertising networks Social networks Operating Systems and Platforms Third-Party Dental Service Providers	Perform in accordance with our business agreements supporting provision of access to dental service Administer surveys and webinars and otherwise solicit/provide insight about our services and the dental industry Security and fraud prevention Research/Analytics Compliance /Audit/Legal Fulfill the intent of the information provision	Third-Party Dental Service Providers Third-Party Vendors supporting provision of service
   Commercial Information	May include but is not limited to: business address and business email	California Residents directly Advertising networks Social networks Operating Systems and Platforms Third-Party Dental Service Providers Third-Party Vendors supporting provision of service	Perform in accordance with our business agreements supporting provision of access to dental service. Administer surveys and webinars and otherwise solicit/provide   insight about our services and the dental industry Security and fraud prevention Research/Analytics Compliance /Audit/Legal Fulfill the intent of the information provision	Third-Party Dental Service Providers Third-Party Vendors supporting provision of service
   Geolocation Information	May include but is not limited to: IP address and precise physical location	California Residents directly Advertising networks Social networks Operating Systems and Platforms Dental Service Providers	Perform in accordance with our business agreements supporting provision of access to dental service Administer surveys and webinars and otherwise solicit/provide   insight about our services and the dental industry Security and fraud prevention Research/Analytics Compliance /Audit/Legal Fulfill the intent of the information provision	Third-Party Dental Service Providers Third-Party Vendors supporting provision of service
   Sensory Information	May include but is not limited to: audio records of customer care calls	California Residents directly Third-Party Dental Service Providers	Perform in accordance with our business agreements supporting provision of access to dental service Security and fraud prevention Research/Analytics Compliance /Audit/Legal Fulfill the intent of the information provision	Third-Party Dental Service Providers Third-Party Vendors supporting provision of service
   Internet or similar network activity	May include but is not limited to: electronic records capturing your interaction with Futuredontics websites	Advertising networks Social networks Operating Systems and Platforms	Perform in accordance with our business agreements supporting provision of access to dental service Security and fraud prevention Research/Analytics Compliance /Audit/Legal Fulfill the intent of the information provision	Third-Party Vendors supporting provision of service
   Biometric Information	May include but is not limited to:  photos of teeth and gums	California Residents directly	Perform in accordance with our business agreements supporting provision of access to dental service Security and fraud prevention Compliance/Audit/Legal Fulfill the intent of the information provision	Third-Party Dental Service Providers Third-Party Vendors supporting provision of service
   Categories of sensitive personal information identified in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)	May include but is not limited to: credit card, dental insurance provider, dental need and related aspects of medical/health history	California Residents directly	Perform in accordance with our business agreements supporting provision of access to dental service Security and fraud prevention Research/Analytics Compliance /Audit/Legal Fulfill the intent of the information provision	Third-Party Dental Service Providers Third-Party Vendors supporting provision of service
   Applicant and Employment Information	May include but is not limited to: education and employment history and information related to employment, including payroll and benefits administration.	California Residents directly Social Networks Third-Party Vendors supporting provision of service	Administer job applicant tracking and administer support and services for employees and former employees Security and fraud prevention Research/Analytics Compliance /Audit/Legal Fulfill the intent of the information provision	Third-Party Vendors supporting provision of service Government agencies

2. Types and categories of information identified in the table above are not considered personal information in relation to CCPA if such information is: (i) publicly available from federal, state, or local government records; (ii) de-identified, including ensuring that information contained within distinct internal corporate systems cannot be combined in ways that establish personal identity; or (iii) aggregated with other personal information so that any individual California Resident’s personal identity is not discernable.
3. CCPA does not apply to any personal information that is covered or otherwise protected by state-specific or federal statute, including but not limited to, the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the California Confidentiality of Medical Information Act (CMIA); and the Fair Credit Reporting Act (FRCA).
4. Rights of California Residents under CCPA are limited and/or restricted by Futuredontics’ obligations to comply with federal, state, or local law; support a civil, criminal, or regulatory investigation; respond to a subpoena or summons; cooperate with law enforcement agencies; or exercise / defend legal claims.

2. Sale of California Resident Personal Information by Futuredontics

Futuredontics does not and will not sell – and in the preceding twelve (12) months has not sold – any California Resident personal information.

In accordance with CCPA, a business – in this case, Futuredontics – disclosing California Resident personal information to a third-party is not selling such information when two conditions are met: (i) the California Resident uses or directs the business to intentionally disclose such personal information; and (ii) the third-party does not sell the personal information. 

With respect to (i), for example, California Residents, when using Futuredontics’ 1-800-Dentist service, intentionally provide personal information to call center agents so agents can identify and present best options within our network of third-party dental service providers for providing dental services/products. Such personal information is disclosed to a dental service provider only upon agreement with California Resident for the purpose of the provision of dental services/products.  Upon such disclosure, the dental service provider is free, subject to all applicable laws including consumer opt-out provisions, to use the disclosed personal information to provide and promote its dental services to the California Resident.  California Resident can contact such dental service providers directly in relation to privacy preferences.

With respect to (ii), Futuredontics ensures that third-parties to which it discloses California Resident personal information do not sell such information by entering into business agreements with third-party dental service providers and third-party vendors requiring such providers/vendors to certify that California Resident personal information will neither be sold nor otherwise retained, used or disclosed for any purpose other than the specific purpose of the provider/vendor providing the services specified under its business agreement with Futuredontics.

3. California Resident Specific Consumer Rights under CCPA with respect to Personal Information Collected, Disclosed and/or Sold by Futuredontics

1. Access Request. A California Resident may request Futuredontics to reveal certain details about the collection, disclosure and/or sale of the California Resident’s personal information within the twelve (12) month period preceding the request, subject to applicable exceptions or restrictions, if any, including the request or response conflicting with federal and/or state law. Upon receipt of such request and verification by Futuredontics of the California Resident’s identity, Futuredontics will provide to the California Resident or, as applicable, its authorized agent: (i) the elements of the table above (Section I, Part a) – Categories of Personal Information for Collection and/or Disclosure, Categories of Sources for Collection, Business/Commercial Purpose for Collection and/or Disclosure, and Categories of Third Parties for Disclosure – applicable to the California Resident’s personal information; and (ii)  the specific pieces of personal information Futuredontics collected and/or disclosed about the California Resident. 
2. Deletion Request. A California Resident may request Futuredontics to delete personally identifiable information collected and retained about the California Resident, subject to applicable exceptions or restrictions, if any, including the request or response conflicting with federal and/or state law. Personally identifiable information comprises the set of data elements within the broader category of personal information that enable identification of a unique individual. Upon receipt of such request and verification by Futuredontics of the California Resident’s identity, Futuredontics will delete such personally identifiable information from its own physical and electronic records and will notify third parties to whom such information was disclosed of their requirement to do the same.
3. Identity Verification. A California Resident’s request to access and/or delete personal information must provide information sufficient to enable Futuredontics to reasonably verify the California Resident’s identity in relation to data Futuredontics has collected and stored; and to properly understand, evaluate, and respond to the request. Futuredontics will initiate the verification process by attempting to match the identifying information provided by the California Resident to the personal information of a unique individual represented within Futuredontics’ data. The information required from a California Resident to ensure proper data matching and Futuredontics’ manner of verifying the California Resident’s identity will depend on the circumstances of the California Resident’s interaction with Futuredontics.  Futuredontics may require additional information beyond the California Resident’s initial submission to attempt to verify identity. If Futuredontics is unable to verify the California Resident’s identity, Futuredontics will deny the request and inform the California Resident of the denial on basis of failure to verify identity.  With respect to requests for access, if Futuredontics is able to verify identity to a reasonable level of certainty allowing for release of data categories and/or specific pieces of non-sensitive personal information, but not able to verify identity to the higher level of certainty required to release sensitive personal information (including anything related to health care), Futuredontics will respond by relaying data categories and/or non-sensitive personal information and informing California Resident of denial to release sensitive personal information on basis of failure to verify identity to heightened standard of certainty.
4. Agent Authorization. A California Resident may designate an authorized agent to act on the California Resident’s behalf concerning any access and/or deletion request. The agent will be recognized as authorized if the agent submits to Futuredontics a valid power of attorney in accordance with California Probate Code. Absent such submission, the California Resident must verify identity directly with Futuredontics and must confirm directly with Futuredontics that the agent has been duly authorized by California Resident through written directive. Futuredontics will deny a request from an agent purporting to represent a California Resident when the conditions above are not met.
5. Submission of Request(s). Verifiable requests to access and/or delete personal information from California Residents or their authorized agents shall be submitted to Futuredontics by either:
   • calling Futuredontics at the following toll-free telephone number: 855-325-1859;
   • sending email to Futuredontics at ccpa@fututuredontics.com; or
   • filling out and submitting the Futuredontics online form located here: marketing.1800dentist.com/ca-privacy-rights.

   A request from a California Resident to access specific pieces of personal information must include a written and signed declaration certifying, under penalty of perjury, that the California Resident is the person whose personal information is the subject of the request. 

6. Response to a California Resident’s Request. Futuredontics endeavors to respond to a California Resident’s request within forty-five (45) days of receipt. Access requests cover personal information Futuredontics has collected, disclosed and/or (if applicable) sold in the twelve (12) month period preceding the request (delete requests cover full history).

   Futuredontics will acknowledge a California Resident’s request within ten (10) business days of receipt and provide information concerning how the request will be processed and when the California Resident should expect a response, except in instances where Futuredontics has already granted or denied the request.  If Futuredontics requires additional time, up to an additional forty-five (45) day, to comply, Futuredontics will inform California Resident in writing of the reason for and expected length of the extension.

   If Futuredontics is unable to respond to all or part of a request, Futuredontics will explain the reasons it cannot comply.  For example, Futuredontics is prohibited under the CCPA from disclosing a California Resident’s Social Security number, driver’s license number or other type of government-issued identification; financial account number; any health insurance or medical identification number; an account password or related security questions and answers; or unique biometric data in response to an access request.  Any part of a request that can be complied with, will be. 

   Futuredontics will deliver its response via mail or electronically to the California Resident provided that, if the response references any personal information, the transmission will be electronic and encrypted. 

   Futuredontics does not charge a fee to process or respond to a California Resident’s request unless it is excessive, repetitive or manifestly unfounded, in particular because of a repetitive character, i.e., more than twice in a twelve (12) month period for any individual California Resident.  If Futuredontics determines that the request warrants a fee, Futuredontics will inform a California Resident why it made that decision and provide California Resident with a reasonable cost estimate before completing the request.

4. Non-Discrimination.

Futuredontics will not discriminate against California Residents for exercising their CCPA rights.

5. Contact Information.

If California Resident has any questions or concerns in relation rights under CCPA, please relay to Futuredontics by either:

• calling Futuredontics at the following toll-free telephone number: 855-325-1859; or
• sending email to Futuredontics at ccpa@fututuredontics.com.

IV. Privacy Rights Notice Amendments

Futuredontics reserves the right to amend this California Resident Privacy Rights Notice at its discretion and at any time.  When amended, Futuredontics will publish the revised Notice, marked with the date of amendment.  California Resident’s ongoing interaction with Futuredontics indicates acceptance of the current California Resident Privacy Rights Notice.

This document was last updated on December 24, 2020.

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