Last updated: May 24, 2018
Previous version: October 5, 2016
INTRODUCTION
Align Technology, Inc. and its affiliates (“Align”, "we", "us" and "ours") are committed to protecting your information (in this Privacy Statement, “information” refers to the personally identifiable information, considered personal data, that you provide or we collect on, about, or from you through our websites).
Align designs, manufacturers and markets the Invisalign® system and iTero® intra-oral scanners and OrthoCAD services and the My Invisalign Smile app, which enables users to track and share progress whilst undergoing Invisalign treatment by uploading images, sharing stories, creating appointment reminders and receiving notifications (the "App"). The following discloses how we collect, use and share the information we gather on our websites and our App (the "Sites").
In general, you can visit our Sites without telling us who you are or revealing any personal information about yourself. There are times, however, when we may seek information from you, about yourself or someone you know, such as name, email address and/or home address. It is our intent to let you know before we collect such personal information from you on the Internet and to get your consent to process such information where required.
By using our Sites, you consent to our collection, use, disclosure, transfer and processing of personal data in accordance with this Privacy Statement.
Information we collect from you
What do we do with the information we collect?
Who do we share your personal information with?
Cookies and Advertisements
Children's Privacy
Links to other sites
Marketing and Do Not Contact
Social Media
International data transfers
Security
Your Rights
Updates
Contact Us
Information we collect from you
We collect the following kinds of personal information and sensitive information about customers, patients (former, potential and current), patients' parents/guardians, physicians, and website visitors when you register to become a member of our Sites or via on-line forms or when you download and use the App, for example, when you sign up to receive news alerts from us or to undergo a smile assessment:
- Contact details such as your name, address, phone number, and email address.
Information to help us treat you such as age, gender, and health information regarding your teeth, including images of your teeth and face. We will notify you of such purposes at the time that we request to collect personal data or sensitive information from you and will only collect the information that is strictly necessary to fulfil those purposes.
Where we collect health information or other kinds of sensitive data via our Sites, we will ask for your explicit consent.
We will also collect information about your use of our Sites as described in the section "Cookies and Advertisements" below.
On occasions you may choose to provide us with personal data about other people so that, for example, we can contact them with information about us. You must only share their personal data with us if you have obtained their consent and permission to do so.
What do we do with the information we collect?
The personal information we gather from your use of our Sites or provided by you may be used:
- To set up and otherwise manage your member account in our Sites.
- To allow you to use, purchase, book and/or download products and services such as for example the purchase of cleaning supplies.
- To provide you with information about our products, services, news and events.
- To provide details of physicians and their practices and submit contact requests to them.
- To invite you to take part in our surveys or become a member of a fan club (where applicable).
- To gather demographic information about user trends, such as age, gender, and general income levels.
- To provide certified physicians with information on actual or prospective patients.
- To analyze use of our services and products, develop new services and products, and customize our products, services and other information we make available.
- To use content uploaded to the App to share via social media and make copies of your content to advertise Invisalign on the Internet, on TV, in publications or in any other medium. We will never display your name in any promotional material we create, but you should be aware that other people may still recognise you from your photograph.
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. Where we have entered into a contract with you, such as to provide you with our Invisalign goods and services, we will process your information to perform that contract. In other circumstances we may process your information for the legitimate business interests of Align such as marketing or improving our products and services, provided that these interests are not overridden by your rights. We will make it clear to you at the time of collection what our legitimate interests are.
We do use a robust combination of data sources (online, orders, customers, etc.) to get a full picture of our product and marketing efforts. This data is only for our efforts and we do not share your information with other businesses for them to use for purposes other than their work with us.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Who do we share your personal information with?
We partner with other businesses to assist us in our marketing, communications, storage, and sales efforts, and may share information about you for these purposes. These partners are not allowed to use your information for any purpose other than doing business with Align. A list of our current service providers is available by contacting privacy@aligntech.com:
We may also share your information with other Align companies to carry out the purposes described in "What do we do with the information we collect?" A list of our group of companies is available by contacting privacy@aligntech.com.
In addition, any information we collect, including personal information, may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of insolvency, bankruptcy or receivership in which personal information could be transferred to third parties as one of our business assets.
We may also disclose personal information about you if we believe that doing so is legally required or is necessary to protect our property or other legal rights (including but not limited to enforcement of our agreements or the rights of property of others).
We may also share your information if you consent to us doing so.
How long do we keep your information?
We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with Invisalign goods and services or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
Some of this information may be collected using cookies and similar tracking technology. Please refer to Cookies & Ads for further information
At Align, we do not intend to collect any information from children under the age of thirteen (13), unless the information is collected from a parent or guardian. While we cannot stop a child from accessing the Sites, we do not collect any personal information without making it clear that the person providing the information must be at least 13 years old. If you have questions about our Sites collecting information from children, please contact us at Privacy@aligntech.com.
Please note that the age threshold mentioned above may vary depending on applicable legal requirements in your country. If this is the case, we will indicate it accordingly at the time of collection.
Our Sites may contain links to other websites merely as a convenience. Align is not responsible for the privacy practices or the content of such other websites, and inclusion of links does not mean we endorse the information or company. This means that if you connect to another site through our Sites, we are not responsible for and we cannot control what they do with your information.
Also, you may have the opportunity to share your information with other websites, such as social media sites. We may provide a convenient link to let you do this easily, but we are not responsible for and we cannot control their website or your posts/sharing. You are encouraged to review the privacy policies and information collection practices of these other websites and social media sites.
We may send you information about us from time to time if you have given us your consent (where required).
Align provides you the opportunity to request to stop receiving electronic communications from either Align or our partners by withdrawing your consent. If you do not want to receive communications from us, please tell us when we collect your information or write us at any time remove@aligntech.com and make sure to include your country location. You may also use the convenient unsubscribe feature included with emails. Please allow us enough time to process your request.
Keep in mind, this withdrawal of consent does not apply to necessary communications, such as responding to an inquiry, and is revoked if you later request information from us, for example, if you sign up to receive news alerts from us.
User Generated Content. If you are a user of Facebook, Twitter or other social media sites with public account settings and you hash-tag using one of our public campaigns, such as #unbraceyoursmile, or one using our product name, such #invisalign, #invisalignteen, or #invisalignTalk, we will be able to pull your reviews of our products from the social media sites and post them on our Sites. This is so that we can share your opinions about our products with the visitors of our Sites. Before being posted in our Sites, your comments will be reviewed by us. Please do not use these hashtags if you do not wish that your reviews are made available on our Sites.
By posting or otherwise making available any Content on a public social media platform about your Invisalign experience, and responding “yes” if we ask for your permission to re-post content on our owned channels, such as Facebook (http://facebook.com/invisalign), Pinterest (http://pinterest.com/Invisalign), Google+ (http://google.com/+Invisalign), YouTube (http://youtube.com/invisalign & http://youtube.com/invisalignteen), Twitter (http://twitter.com/invisalign), Instagram (http://instagram.com/invisalign & http://instagram.com/invisalignteen) Tumblr (http://invisalignteen.tumblr.com/), and others, you represent and warrant that you are thirteen (13) years of age or older and that you agree to the terms and conditions listed on our page on those websites.
If a parent, guardian, or anyone else becomes aware of user generated content shared from an individual under the age of thirteen (13), please email us at InvisalignTakedown@GoldPR.com.
Align operates globally and we may therefore transfer your personal information to other countries where Align operates, including countries other than your country of residence. Your personal data may also be stored on our servers which are located outside your country of residence. However, we will continue to protect your information in accordance with this Privacy Statement and our Binding Corporate Rules.
In addition to the commitments in this Privacy Statement, Align has set out a Binding Corporate Rules (BCR) program which establishes Align's approach to the protection and management of personal information globally. Our BCR policy may be accessed in the link provided in the previous paragraph.
Where we transfer your information outside of the EEA to our service providers and partners, we do so on the basis of the standard contractual clauses approved by the European Commission (Align’s Binding Corporate Rules) or the Privacy Shield.
Our Sites have security measures in place to try to protect against the destruction, loss, misuse and alteration, unauthorised disclosure or access of the information under our control. Our web portals, such as the Invisalign Doctor Site, transmit patient information (including any personal data) securely via HTTPS. These portals require customer accounts and are not available to the general public.
If you have rights concerning access, disclosure, amendment, or deletion (as determined by applicable law), you may contact us at the address or email listed below.
For example, in California, individuals may request once per calendar year a list of disclosures we make to third parties for their direct marketing efforts. It is not our practice to sell or lease any personal information to other companies for their direct marketing.
In connection with Align companies in Europe, Individuals may contact us regarding their rights to:
- Access, correct, update or request deletion of their personal information
- Object to processing of their personal information, ask us to restrict processing of their personal information or request its portability.
- Opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided below.
- Withdraw your consent at any time, if we have collected and processed your personal information with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- Complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
In Singapore, you may generally request for us to provide you with information about the ways in which your personal data that is in our possession or under our control has been or may have been used or disclosed by us within a year before the date of the request. Any access request may be subject to a fee to meet our costs in providing you with details of the personal data we hold about you, and we will notify you of what such fee will be after receiving your access request.
These are just examples and your particular rights may not be listed here as an example.
We may update this statement from time to time. When we do, we will list the last updated date at the beginning of the statement. Notice of such update and/or modification will be provided on our Sites or to you directly if required by law. We encourage you to periodically review this statement to stay informed about how we collect, use and share personal information. If you do not agree to these changes, please do not continue to use the Sites.
If you have any questions about this privacy statement, the practices of our Sites, your information, or your rights regarding your information, or your dealings with our Sites, please contact:
Global Headquarters
Align Technology, Inc.
Attention: Privacy Office
2560 Orchard Parkway
San Jose, CA 95131
Privacy@aligntech.com
EU Headquarters
Align Technology Switzerland GmbH
Attention: Privacy Office
Suurstoffi 22
6343 Rotkreuz
Switzerland
Privacy@aligntech.com
You may also contact the Align local entity that is responsible for the use of your information. Details are available here.