Dentsply Sirona's External Privacy Statement - People’s Republic of China
Last Updated: August 2022
This Data Protection and Privacy Statement(the “Privacy Statement”) sets out how we, DENTSPLY SIRONA DENTAL SOLUTIONS(SHANGHAI) CO., LTD and China affiliates “DENTSPLY SIRONA” or “we”) process Personal Data when you visit our webpages or online platforms (together the“Sites”), purchase our products, interact with our social media accounts onthird-party platforms (“Social Media Accounts”), participate in our trainingcourses, contests, promotions, or loyalty or rewards programs, submit jobapplications to us, or otherwise communicate or interact with us (altogetherreferred to as our “Services”).
If you have any questions or comments aboutthis Privacy Statement, DENTSPLY SIRONA’s privacy practices, or if you wouldlike us to update information or preferences you provided to us, please contactus at:
Web: https://www.dentsplysirona.com/zh-cnand use the information on the “Contact Us” page.
Types ofpersonal data we process
1.Under data protection laws and regulationsof People’s Republic of China (“PRC” or “China”), “Personal Data”includes any information, recorded in electronic or other forms that can byitself or in combination with other information be used to identify a naturalperson. For purposes of this Privacy Statement, Personal Data may includedata relating to our job applicants, customers, patients, shareholders,contractors or the staff of our suppliers, visitors to our buildings or ourSites and Social Media Accounts.
When you access or use our Services, we maycollect the following types of PersonalData about you:
a) Contact information (such as name,postal or email address, and phone number);
b) Business contact information (such asjob title, department and name of organization);
c) Professional identification and license information;
d) Payment details (including payment cardnumber, expiration date, and billing address);
e) Shipping information (including theshipping address, dental distributor and phone number);
f) Username and password for the accountyou may establish on our Sites;
g) Content you post or publish on our Sitesor to our Social Media Accounts (such as photographs and comments);
h) Information you choose to provide inconnection with an employment application (such as veteran status, gender andethnicity);
i) Information about you, your physical conditionor your health which may be provided to us by you or your health providers toenable us to manufacture products for you;
j) Information generated by us in thecourse of managing our relationship with you, such as a history of ourinteractions with you, your purchases from us and information about your use ofour products;
k)Information in connection with your interactions with pages you visit on our websites,such as your IP address, browser type, device used to access our websites, yourpreferences and information you clicked on our websites. For more information read the “Cookies andautomatic collection technologies” section of this Privacy Statement;
i) Otherinformation (such as demographic data, and shopping behavior and preferences);
l) with your consent, we may collectsensitive personal information about you such as your medical or healthinformation. In this instance, we will separately notify you and obtain yourconsent prior to collecting the sensitive personal information.
m) any other Personal Data you choose toprovide to us.
Purposes for which we process personal data
2. DENTSPLY SIRONA processes Personal Dataabout you in order to provide you our Services. DENTSPLY SIRONA may also processyour Personal Data forthe following purposes:
a) Manage our business relationship with you, for example: (i) processyour transaction; (ii) provide you with our products and/or Services; (iii)manage and maintain your account with us; (iv) respond to your questions and commentsand provide customer support; (v) set up a Dentsply Sirona loyalty programaccount; (vi) allocate a Territory Sales Manager or equivalent to be yourdedicated account manager;
b) Marketing, advertising and public relations, for example: (i)marketing our business and products to you; (ii) provide you with informationyou have requested about our company, our products and our services; (iii)provide you with information about, or samples of, our product range formarketing purposes; (iv) contact you through email, telephone or postalmail; (v) tailor your experience on our Sites by providing content that isrelevant to your interests and geographic region;
c) Maintenance and statistics, for example: (i) help diagnose problemswith our server; (ii)compile broad statistical data; (iii) update, administer andmaintain our Sites and Social Media Account;
d) Recruitment purposes, for example; (i) evaluate your interest inemployment and contact you regarding possible employment with DENTSPLY SIRONA;(ii) process your application, monitor recruitment statistics and comply withgovernment reporting requirements;
f) Research andproduct development, for example we may use information aboutyour experience of using our products to help us improve our products.
Legal ground for processing Personal Data
3. By continuing to use our Sites andServices, you acknowledge the terms of this Privacy Statement. The legal basisfor us processing your Personal Data for the above purposes may be because: (i)you have provided your consent; (ii) it is necessary for the performance of acontract with you; or (iii) the processing is necessary for our compliance witha legal obligation.
4. To the extent provided by applicablelaw, you may withdraw any consent you previously provided to us with respect tothe processing of your Personal Data. In some circumstances, withdrawing yourconsent to DENTSPLY SIRONA’s use or disclosure of your Personal Data will meanthat you will be unable to take advantage of certain DENTSPLY SIRONA productsor Services.
Disclosure of Personal Data relating to data subjects
5. We do not sell, rent, trade, share, orotherwise disclose PersonalData to third parties, other than as described in this Privacy Statement, or aswe otherwise describe to you at the time the information iscollected. Generally, we may disclose your Personal Data in the followingcircumstances:
· to our subsidiaries, affiliates, branchesor associated offices;
· in order for us to comply with our legalobligations, e.g., where we are required to disclose certain information to taxauthoritiesor where we are required to respond to requests by law enforcement;
· to protect the security or integrity of ourbusiness, including our databases and systems as well as the safety of our employees,customers and individuals that interact with us;
· to any of our outsourced vendors, suppliersor distributors to facilitate the provision of contracted services or goods orto provide expanded services to our customers other visitors of our Sites andSocial Media Accounts. For example, we may share your Personal Data to suchthird parties when we outsource the processing of certain interactive websitefunctions, administering email services, running special promotions andmanaging any loyalty points programs;
· forthe purposes of facilitating a purchasing transaction with one of ourdistributors or dealers;
· for the purposes of a joint venture,collaboration, financing, sale, merger, reorganization, change of legal form,dissolution or similar event; and
· to any other third party where you haveinstructed us to do so or provided your consent.
Security measures used to protect Personal Data
6. DENTSPLY SIRONA takes reasonable physical, technicaland organizational security measures designed to safeguard and secure any Personal Data you provide to us.Nevertheless, transmission of data over the Internet, including via emailcannot be 100% secure, and therefore, you understand that we cannot guaranteeabsolute security of your Personal Data.
International transfer of personal data
7. We may disclose or transfer certain of yourPersonal Data to entities in another country or region outside the country inwhich your Personal Data was originally collected. We will engage in these transfers only to theextent such transfer is necessary to fulfill a contract, to provide the Services,or as otherwise directed by you. In these circumstances, we will obtain yourconsent, and we have implemented international data transfer agreements basedon the Cyberspace Administration of China’s Standard Contractual Clauses tocover our international data transfers. .
Retention of personal data
8. Your Personal Data will be retained forthe duration of our business relationship and thereafter as required byapplicable local law or where we have a lawful purpose.
9. DENTSPLY SIRONA will retain applicationsof unsuccessful candidates for a reasonable period after the applicationprocess to enable us to contact you if another suitable position arises or tocomply with our legal obligations.
Data subject rights
10. PRC data protection laws andregulations provide individuals with numerous rights, including the following:
· the right to be informed of the processingof their Personal Data,
· the right to consult or obtain a copy oftheir Personal Data,
· the right to make decisions regarding the processingof their Personal Data,
· the right to restrict or refuse theprocessing of their Personal Data,
· the right to request rectification orsupplementation of their Personal Data,
· the right to request deletion of theirPersonal Data, and
· the right to request an explanation of thisPrivacy Statement.
If you would like to exercise any of theserights, please contact the Dentsply Sirona Privacy Office at [China-PRC-PrivacyOffice@dentsplysirona.com. To assist us in responding tosuch requests in a timely fashion, please include the phrase “Privacy RightsRequest” in the title of your message. We may ask you to provide evidence ofyour identity to verify your identity. Responding to certain requests can be a time-consumingexercise. DENTSPLYSIRONA may be able to get the information that you require more quickly if youare as specific as possible in your request. E.g., “I would like a copy of myPersonal Data contained in my website member account file” or if you would likea copy of a particular document it would be helpful if the document isdescribed carefully, including the title, creation date, author and likelyplace of storage. This will help us to respond to your request as quicklyas possible. We may ask you for additional details to assist us in processingyour request.
11. If you no longer wish to receive promotionalemails, you may unsubscribe at any time by clicking the “unsubscribe” link inthe promotional emails sent to you or by contacting the Data Protection Contact whose detailsare provided above. If you have an account with us, you may also unsubscribefrom promotional emails through your account. Please note that even if youopt-out of receiving promotional emails from us, we may continue to send younon-promotional emails.
12.If you have an account with us, you may make changes to your Personal Data bylogging into your account and making changes there.
13. Our Sites and Social Media Accounts may utilizepublic chat rooms, message boards, and/or news groups. Please remember that,unless otherwise stated, any information you submit or post in these public areasbecomes available for the public to view and you should exercise caution when submittingor posting your Personal Data in these public areas. Do not use these public areasto post Personal Data about third parties or discuss information aboutspecific, identifiable patients.
Third-party websites and our Social MediaAccounts
14. Our Services may contain links to otherthird-party websites. DENTSPLYSIRONA is not responsible for the privacy practices or the content ofunaffiliated third-party websites. We recommend that you review the privacypolicy of any such third-party websites.
15. When you interact with our Social MediaAccounts through a social media platform, please be aware that the social mediaplatform is a third-party website that we do not own or control, and we are notresponsible for the privacy practices or content of such social media platforms.We encourage you to review the privacy policies of such social media platformsbefore using such platforms to interact with our Social Media Accounts.
Cookies and automatic collection technologies
A cookie is a small text file which issent to your browser and stored on your computer's hard drive, mobile phone orother device. Sessioncookies expire when you close your browser and are generally used to assist innavigating our Sites. Persistent cookies remain after your close your browser andcan be used to help understand how you use our Sites and enhance your userexperience.
The following are examples of cookies thatmay be used on our websites:
a) Strictly necessary cookies. These cookies are essential for enablingyou to move around the Sites and use their features. Without these cookies, certainaspects of our website will not function properly.
b) Performance / analytics cookies. Thesecookies collect data about how visitors use our Sites, including the countryfrom which the visitor is accessing the websites. They allow us to perform analytics aboutvisitors of our Sites.
c) Functionality cookies. These are used to enable certainfunctionalities on our Sites. For example, these cookies help to recognize youwhen you return to our Sites. These cookies also enable us to personalize ourcontent for you, greet you by name and remember your preferences (for example,your choice of language or region). Without these cookies, certain services youhave asked for, like saving your job application, adding products to a cart or checking out, will not functionproperly.
d) Targeting/Social Media Cookies: These are used to deliver adswhich are more likely relevant to you and your interests. They are also used tohelp measure the effectiveness of the advertising campaigns. When you visit our Sites, we may allow somethird parties (such as advertising networks and data analytics companies) tocollect PersonalData about your online activities over time and across different websites.
17.Yourbrowser settings may allow you to automatically transmit a “Do Not Track”signal to websites and online services you visit. However, there is noconsensus among industry participants as to what “Do Not Track” means in thiscontext. Like many websites and online services, our Sites currently do not recognizewhen they receive a “Do Not Track” signal from a visitor’s browser. To find outmore about “Do Not Track,” visit http://www.allaboutdnt.com.
18. Third-party plugins. Our websitesalso use social and video plugins.
Information about minors
19. Our Services are not directed at and wedo not proactively collect Personal Data of directly from minors under the ageof 14. If we collect Personal Data about minors under the age of 14, we do so withthe consent of a parent or legal guardian and will process such Personal Dataconsistent with legal consent of the parent or legal guardian or wherenecessary to protect the child. If we discover that we have collected PersonalData of a minor without verifiable prior consent from a parent or legalguardian, we will take steps to delete the relevant data as soon as possible.
Updates to our Privacy Statement
20. We may at any time in our solediscretion revise or update this Privacy Statement. We will indicate at the topof the Privacy Statement when it was most recently updated. All changes areeffective immediately when they are posted and apply to all access to and useof the Services thereafter.If you object to any modification, you should stop using the Services and stopproviding us with Personal Data.