PRIVACY POLICY

This Privacy Policy describes how your information is collected, used, and disclosed when you visit the Smile CDR website (the “Site”). This website is operated by Smile CDR Inc. (doing business as Smile Digital Health) of 622 College St, Suite 401, Toronto, ON M6G 1B4 (“we”, “our”, “us”).

Smile Digital Health is committed to protecting the privacy and security of its users. We treat all collected information with complete confidentiality and work to collect the minimum amount of data necessary.

What information do we collect?

Smile Digital Health gathers two basic types of information through the Site: “user submitted information” and “site collected information.”

User Submitted Information: You are not required to register or provide personal information in order to access the Site, though certain functionalities (such as requesting information) may require the inclusion of personal information. User submitted information may include your contact information (such as your name, phone number, and email address) or other relevant details (your organization) if you submit a request for additional information or a demonstration.

Site Collected Information: When you visit and interact with the Site, Smile Digital Health and third parties Smile Digital Health uses (namely Google Analytics and our web hosting provider) may collect information from three sources: server log files, cookies, and “pixel tags”. This information contains your Internet Protocol (IP) address, browser information, and metadata such as the date and time a page was visited, and any actions (clicks) taken on a page.

How do we collect personal information?

Smile Digital Health collects and maintains personal information sent via online forms and email addresses published on our website. We will use this information to contact you regarding products and services for which you have expressed interest.

Smile Digital Health also uses industry standard online technologies, such as:

“Cookies”: data that a web server transfers to a computer for record-keeping purposes. Cookies are an industry standard used by most web sites and help facilitate users’ ongoing access to and use of a particular web site. Cookies do not cause damage to your computer systems or files, and only the web site that transferred a particular cookie to you can read, modify or delete said cookie.

We use “cookies” to track user patterns on its Site, but Smile Digital Health will not use cookies to learn the identity of its users, nor will we attempt to track users after they leave the Site. Further, cookies will not be used by Smile Digital Health to gather specific personal information about individual users.

For more information about cookies, and how to disable cookies, visit  http://www.allaboutcookies.org.

“Log files”: Your IP address is an identifying number that is automatically assigned to your computer by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. Smile Digital Health tracks user IP addresses for the purposes of systems administration, demographic profiling, and traffic logging, but Smile Digital Health will not use IP addresses to try to identify individual users of the Site. Collecting IP addresses is standard practice on the internet and is carried out automatically by many websites.

Pixel tags”, “web beacons”, “clear GIFs” or similar means (collectively, “pixel tags”) compile aggregate statistics about Site usage and response rates. Pixel tags allow us to count users who have visited certain pages of the Site.

How do we use the user submitted personal information?

Smile Digital Health uses information submitted directly by users of the Site for one of three purposes:

1. Monitoring of test server: We maintain a list of test server users’ email addresses to provide them with updates regarding server features, alert them of account expiry, or other information relevant to their use of the test server.

2. Replying to inquiries submitted via the Site’s contact form or company email addresses published on the Site: We use the information you provide about yourself to reply to the inquiry.

3. Web hosting provider: The personal information we gather through forms or company email addresses published on the site is stored in our secure web hosting provider’s system. In accordance with our legitimate business interests, we may also use your contact information for commercial purposes to inform you by means of direct marketing about our products and upcoming events. We always provide the option to opt-out of these messages.
   
   

How do we use the site collected personal information?

The information we collect through use of the Site is used to better design our website. We analyze this information in order to enhance website security, track the popularity of certain pages of the Site, the success of our email notifications, traffic levels on the Site, and other usage data, all of which helps us to improve the Site.

When do we disclose site collected information?

We use Google Analytics to help us understand how our customers use the Site - you can read more about how Google uses your Personal Information here: https://policies.google.com/technologies/partner-sites

You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

We also use a web hosting provider to gain insights into how visitors use the site. Our web hosting provider uses cookie to track the Site’s visitors and contacts. The web hosting provider’s software leaves behind a cookie on visitors’ computers that helps them identify visitors on future visits.

For more information on cookies, please see our cookie policy.

When do we disclose user submitted personal information?

We may share your personal information (such as name, employer, or contact information) to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

We do not sell your personal information. We do not share your personal information for targeted advertising.

Your rights when we process your personal information under EU, CAN, or California law

If you are a European Union, Canadian, or California resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise any of these rights, please contact us through the contact information below.

We will not discriminate against you for exercising any of your rights.

Additionally, we note that we are processing your information in order to fulfill contracts we might have with you, or otherwise to pursue our legitimate business interests listed above. Additionally, if you are a European Union resident, please note that your information will be transferred outside of Europe, including to Canada and the United States.

What happens if a breach of your information occurs

Smile Digital Health will follow breach notice requirements outlined in applicable regional legislation or contractual agreements, whichever is stronger.

Smile Digital Health adheres to ISO/IEC 27018. A breach notification log will be maintained and designed to satisfy requirements.

Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Contact Us

For more information about our privacy practices, if you have questions, would like to exercise a right under GDPR, PIPEDA, or CCPA, or if you would like to make a complaint, please email us at privacy@smiledigitalhealth.com or send a letter to 622 College Street Suite 401, Toronto, ON M6G 1B4