This California Privacy Notice supplements the information in our general Privacy Policy and applies solely to residents of the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA"), and other applicable California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Categories of Personal Information We Collect
In the preceding twelve (12) months, we have collected the following categories of personal information from California consumers:
- Identifiers. Real name, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver's license number, or other similar identifiers.
- Customer Records. Information that identifies, relates to, or could reasonably be linked with a California resident, including name, signature, address, telephone number, insurance policy number, bank account number, credit or debit card number, and medical information.
- Protected Classifications. Characteristics protected under California or federal law, such as age, marital status, medical condition, sex, gender, and familial status (collected only as necessary to provide coverage or administer claims).
- Commercial Information. Records of insurance products purchased, plan selections, enrollment history, and payment history.
- Internet or Network Activity. Browsing history, search history, information on your interaction with our website, member portal, or advertisements.
- Geolocation Data. Approximate location derived from IP address.
- Sensory Data. Audio recordings of calls to our customer service line (where permitted and with notice).
- Professional or Employment Information. Employer name and group coverage affiliation, where applicable.
- Inferences. Inferences drawn from any of the above to create a profile reflecting preferences or characteristics.
- Sensitive Personal Information. Social Security number, driver's license number, account log-in credentials, precise geolocation, racial or ethnic origin, mail or email contents not directed to us, genetic data, and health information, including information concerning a consumer's health, mental health, and diagnosis or treatment.
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you when you enroll in a plan, create a member account, submit a claim, contact customer service, or otherwise interact with our website or services.
- From your dental, vision, or other healthcare providers in connection with claim submission and coordination of benefits.
- From your employer, plan sponsor, or group administrator (for group coverage).
- From third-party business partners, including payment processors and identity-verification services.
- Automatically from devices and services you use to access our website or portal (cookies, log files, analytics providers).
Business and Commercial Purposes
We use the personal information we collect for one or more of the following business or commercial purposes:
- To enroll you in coverage, administer your plan, and adjudicate claims.
- To communicate with you about your coverage, benefits, billing, and account activity.
- To process payments and provide receipts.
- To comply with legal, regulatory, and contractual obligations, including HIPAA and California insurance laws.
- To detect, investigate, and prevent fraud, unauthorized access, and other illegal activity.
- To maintain, improve, and secure our website, member portal, and services.
- To send service-related notices and, where permitted, marketing communications.
- To fulfill any other business purpose disclosed at the time of collection or otherwise permitted under the CCPA.
Disclosure of Personal Information
In the preceding twelve (12) months, we have disclosed the categories of personal information listed above for one or more business purposes to the following categories of recipients:
- Our underwriter, Renaissance Life & Health Insurance Company of America (and its New York affiliate), for the purpose of issuing and administering coverage.
- Dental and vision providers within our network, for the purpose of coordinating care and processing claims.
- Service providers and contractors acting on our behalf (including payment processors, IT vendors, cloud-hosting providers, analytics providers, and customer-support platforms), bound by contract to protect and limit their use of the information.
- Government agencies, regulators, or law-enforcement authorities, where required by law or legal process.
- Parties to a corporate transaction, such as a merger, acquisition, or sale of assets.
No Sale of Personal Information
We do not sell your personal information for monetary consideration and we do not share your personal information for cross-context behavioral advertising, as those terms are defined under the CCPA. We have not sold or shared the personal information of consumers in the preceding twelve (12) months, and we do not have actual knowledge of selling or sharing the personal information of consumers under 16 years of age.
Your California Privacy Rights
Subject to certain exceptions, the CCPA provides California residents with the following rights:
- Right to Know. You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which the information was collected, the business or commercial purpose for collecting it, and the categories of third parties with whom we share it.
- Right to Delete. You have the right to request that we delete personal information we have collected about you, subject to certain exceptions (for example, where the information is necessary to complete a transaction, comply with legal obligations, or detect security incidents).
- Right to Correct. You have the right to request that we correct inaccurate personal information we maintain about you.
- Right to Opt-Out of Sale or Sharing. You have the right to direct us not to sell or share your personal information. As noted above, we do not sell or share personal information.
- Right to Limit Use of Sensitive Personal Information. You have the right to limit our use and disclosure of sensitive personal information to those uses necessary to perform the services reasonably expected by an average consumer, or as otherwise permitted by the CCPA.
- Right to Data Portability. When you request a copy of the personal information we hold about you, you may request that it be provided in a structured, commonly used, and machine-readable format.
- Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. This means we will not deny you goods or services, charge different prices, or provide a different level of quality because you exercised your rights.
How to Exercise Your Rights
To exercise any of the rights described above, please submit a verifiable consumer request to us by one of the following methods:
- Email: privacy@thedentalvision.com (please write "California Privacy Request" in the subject line)
- Toll-free phone: (800) 963-4596
- Mail: The Dental Vision Institute, Attn: California Privacy Request, 321 Northlake Blvd, North Palm Beach, FL 33408
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. Your request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will confirm receipt of your request within ten (10) business days and respond to verifiable consumer requests within forty-five (45) days of receipt. If we require more time (up to an additional forty-five days), we will inform you of the reason and extension period in writing.
Authorized Agents
You may designate an authorized agent to submit requests on your behalf. To do so, the agent must provide written proof of authorization signed by you. We may also require you to verify your identity directly with us and confirm that you have provided the agent permission to submit the request.
"Shine the Light" Disclosure
Under California Civil Code Section 1798.83, California residents who have provided personal information to a business with whom they have an established business relationship may request information once per calendar year about the business's sharing of that personal information with third parties for direct marketing purposes. As noted above, we do not share personal information with third parties for their direct-marketing purposes.
Children Under 16
We do not knowingly sell or share the personal information of California residents under the age of 16 without affirmative authorization. Information about minor dependents enrolled as beneficiaries under a parent or guardian's plan is collected, used, and disclosed solely for the purpose of administering coverage and adjudicating claims.
Retention
We retain each category of personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, to comply with our legal and regulatory obligations (including HIPAA and applicable insurance-law record-retention requirements), to resolve disputes, and to enforce our agreements.
Changes to This Notice
We reserve the right to amend this California Privacy Notice at our discretion and at any time. When we make changes, we will update the "Last updated" date at the top of this notice and, if the changes are material, provide additional notice on our website. Your continued use of our website or services following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
The Dental Vision Institute
Attn: California Privacy Officer
321 Northlake Blvd
North Palm Beach, FL 33408
Email: privacy@thedentalvision.com
Phone: (800) 963-4596