Privacy Policy Last Updated: Feb 24, 2019

This is the Privacy Policy of the TempStars website and mobile applications (together, the “Application”), operated by Sudden Turtle Dental Consulting Inc. (together with our affiliates and subsidiaries, “TempStars”, “we”, “us”, “our” and terms of similar meaning) and our related products and services. It describes the information that we collect from you as part of the normal operation of he Application, and how we use and disclose this information. By accepting the Privacy Policy in registration or by visiting and/or using the Application, you expressly consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy.

This Privacy Policy is incorporated into and subject to our Terms of Use, www.tempstars.ca/terms In this Privacy Policy, we use the term “User” to describe different types of users of the Application, including registered users and casual browsers of the Application. How We Use Your Information We use personal information in the file we maintain about you, and other information we obtain from your current and past activities on the Application, to provide to you the services offered by the Application; resolve service and billing disputes; troubleshoot problems; bill any amounts due from you; measure consumer interest in our products and services; inform you about online and offline offers, products, services, events and updates; deliver information to you that, in some cases, is relevant to your interests, such as product news; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our Terms of Use; provide you with system or administrative messages, and as otherwise described to you at the time of collection.

We may also use personal information about you to improve our marketing and promotional efforts, to analyze Application usage, to improve our content and product offerings, and to customize the Application’s content, layout, and services. These uses improve the Application and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Application. On occasion we use email address or other contact information to contact our Users with our newsletter or other similar communication, or to ask them for their input on our services.

In general, any email or other electronic message we send you will contain a link or other instructions to permit you to unsubscribe from such email or messages, except that certain emails or messages are essential to the operation of the Application and you must cancel your account to opt out of receiving them. What Information Do We Collect? Our primary purpose in collecting personal information from you is to provide you with a safe, smooth, efficient, and customized experience. This allows us to provide services and features that most likely meet your needs, and to customize our service to make your experience safer and easier. We only collect personal information about you that we consider necessary for achieving this purpose. Once you become a registered User, we require you to provide various contact and identity information, billing information, and other personal information as indicated on the relevant forms in the Application (which vary, depending on what kind of User you are), and you are no longer anonymous to us.

Where possible, on these forms we indicate which fields are required and which fields are optional. We collect information when you register to join us by logging into an account that you already have with certain third-party sites (“TPS”) (including, but not limited to, Facebook, LinkedIn, Instagram and Twitter). For example, our Application allows you to create an account and login for the Application using your Facebook account credentials. If you are not currently registered as a user of our Application and you click on “Sign Up with Facebook,” you will first be asked to enter your Facebook credentials and then be given the option to register and join us. If you decide to create your user account by logging into a TPS account via the Application, you are using the personal information you have already provided to the TPS (such as your “real” name, email address and other information you make publicly available via the TPS) to create your user account with us. The information we collect may depend on the privacy settings you have with the TPS, so please consult the TPS’s privacy and data practices. The personal information we may collect in this way may include, but is not limited to, your name, email address, TPS sign-in or username, profile photo, and any biography you have provided to them. In addition, as you use the Application, you can from time to time enter or send to us personal information. You always have the option to not provide information by choosing not to become a User or by not using the particular feature of the Application for which the information is being collected. We use cookies and log data in various ways, as described below. We use cookies for two purposes. First, we use “persistent” cookies to save your login information for future logins to the Application. Second, we use “session ID” cookies to enable certain features of the Application, to better understand how you interact with the Application and to monitor aggregate usage by our users and web traffic routing on the Application. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Application and close your browser.

We do not link the information we store in cookies to any personally identifiable information you submit while on our Application. When you use our Application, whether as a registered user or a non-registered user, our servers automatically record information that your browser sends (“log data”). This log data may include information such as the browser type or the webpage you were visiting before you came to our Application, pages of our Application that you visit, the time spent on those pages, information you search for on our Application, access times and dates, and other statistics. We use this information to monitor and analyze use of the Application and the Application’s technical administration, to increase the Application’s functionality and user-friendliness, and to better tailor our Application to our visitors’ needs. For example, some of this information is collected so that when you visit the Application again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. We also use this information to verify that visitors to the Application meet the criteria required to process their requests. We also use Google, as a third party vendor, to serve our ads on other websites. Google uses what it calls a “DART cookie” to enable it to serve ads to users based on their visits to participating websites.

As a result of our use of Google as a vendor and the use of DART cookies, the ads that you will be served on the internet may in some cases be based on your visit to our Application. We may also use other third-party services to assist us in using and analyzing these tools and the data they provide, and in monitoring your use of the Application. Following your registration on the Application, you can review and change your information in your account area. If you disclose personal information in any posting in our forum or blog and wish to have it removed, please contact us at the support contact information listed below, and posted on the Application. Our Disclosure of Your Information We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties. The following describes some of the ways that your information may be disclosed in the normal scope of business to provide our services: Anonymized Aggregated Data. We aggregate and anonymize Application use information and disclose such information in a non-personally identifiable manner to Users and others. However, in these situations, we do not disclose any information that could be used to identify you personally.

Privacy of Communications / Conversations

While we will make an effort to honour requests to keep communications between TempStars, dental offices and other members confidential, we will exercise our judgement when relaying details and information regarding placements, reasons for cancellations, complaints, comments, feedback and other information relevant to a shift or job. Any details related to these topics may be relayed to relevant parties at our discretion, although for the most part we’ll honour requests to keep such information private. For this reason, consider any communication with TempStars to be non-confidential.

Public Display or Display to other Users

If you post on our forum or blog your username and other information you include is displayed in your postings or comments, and is therefore available to the public. All of your activities in the public areas of the forum will be identifiable to your User ID, and other people can see your published profile content. When you register through the Application and submit personal information to create a User profile or a collection, other users will see your name. If you choose to provide additional personal information in your profile, other users will see that additional personal information, including, but not limited to, your photo, location, website and biography. Providing additional personal information is voluntary. We recommend that you avoid disclosing any information you consider sensitive and confidential. In certain cases the Application allows Users to provide ratings and reviews of other Users, and such information will be published on the areas of the Application visible to registered Users. When completing and Evaluation Survey, comments designated as Public may be visible to all members of the public, regardless of whether they are registered users or not.

Regarding comments designated as Private, we make reasonable efforts to maintain the confidentiality of these comments although we make not warrant of guarantee that these comments might not be made inadvertently public. Third Party Services. We may share the information in your user account (including your personal information) with the TPSs that you have linked to your account. These TPSs have access to your personal information only for this purpose (unless the TPS has received your personal information independently of the Application) and not for other purposes. You may update certain TPS preferences, including the option to share or post your activity through your respective TPS accounts, under your account settings. Subsidiaries and Affiliates; Service Providers. We may from time to time use the services of affiliates, subsidiaries and unrelated service providers in the operation of the Application, and may disclose personal information to them in the course of our use of their services. For example, we may use the services of third-party hosting companies to host the operation of the Application. This may involve the hosting of data, including personal information, on servers operated by those hosting companies, and in some cases those servers may be located in, or data enroute to or from those servers may transit, other jurisdictions, including the United States.

We take care to use only service providers that we believe are reputable and able to live up to our and your expectations, including about the handling of confidential information. These companies are authorized to use your personal information only as necessary to provide these services to us. Please see the bottom of this policy for further information about how to direct any questions you might have about service providers outside of Canada. Legal Requests and Business Transitions; Emergencies. We may disclose any of your personal information in our possession if we believe it necessary or appropriate to do so (a) to respond to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations), (b) in response to a court order, subpoena, discovery request or other lawful request, or judicial or administrative proceeding, (c) as otherwise required under any applicable law, rule, or regulation, (d) to protect or defend our rights or property or those of other users, or (e) if we are involved in a merger, acquisition, or sale of all or a portion of our assets (you will be notified via email and/or a prominent notice on our Application of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information). Controlling Your Information Cookies.

If you decide at any time that you no longer wish to accept cookies from our Application, you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Note: The service does not currently employ TPS login/sign-up, but if that becomes an option you may decide at any time that you no longer wish to have your TPS account linked to your account with us, you will be able to de-link the TPS account in your user account settings on the Application. Your Use of Other Persons’ Information By entering into our Terms of Use, you agree that, with respect to the personal information of other persons that you collect, use and disclose on the Application, you have all necessary consents and rights to collect, use and disclose that information as described in this Privacy Policy from time to time, and you agree that the indemnity you give to us in the Terms of Use applies to any non-compliance by you with the foregoing. Security We strive to protect your personal information although we cannot warrant the security of any information you transmit to us. More information about security is available on the Application and in our Terms of Use. Other Information Collectors Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you.

To the extent that you disclose your information to other parties through the Application, different rules may apply to their use, collection and disclosure of the personal information you disclose to them.

Since we do not control the information use, collection or disclosure policies of third parties, you are subject to their privacy policies. We encourage you to ask questions before you disclose your personal information to others. Correcting and Updating Your Personal Information To review, delete and update your personal information to ensure it is accurate, you may login into your account to make the changes, or you may contact us at help@tempstars.ca Data Retention We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Additional Policy Information If you click on a link to a third-party site, you will leave the Application and go to the site you selected. If you elect to use a third-party product or service in conjunction with ours, you yourself enter into a license agreement with the third party for use of their product or service and their use of your data. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services.

If you visit a third party website that is linked to the Application, you should read that site’s privacy policy before providing any personal information. With your consent we may post your testimonial along with your name. If you want your testimonial removed please contact us at help@tempstars.ca. Our Web site includes Social Media Features, such as the Facebook and Twitter buttons and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Application. Your interactions with these Features are governed by the privacy policy of the company providing it.

Notification of Privacy Statement Changes

Your resume and photo are stored on our servers and are accessible by all member dental offices. Uploaded resumes and photos must not be considered private or confidential and may become part of the public domain. If you do not agree to these terms regarding resumes and photos, do not upload a photo or resume to your account. You may remove your resume or photo at any time by accessing your profile in the app and tapping “Remove resume” and/or “Remove photo” respectively. Remember to save your changes.
We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on this Application prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Regarding Resumes Uploaded and Submitted

1. In an effort to help protect your privacy
2. To minimize the occurrence of “off-platform” arrangements. Most dental offices use TempStars as intended, but there are some unscrupulous offices that post a shift, collect resumes through Custom Offers, then cancel the posting and contact the hygienists directly from the resume contact information, to avoid the placement fee. This is a violation of our Terms of Service. To avoid this, when you upload your resume, we remove contact information.

GDPR Compliance Additions – applying to anyone living in, visiting or travelling through or accessing our services, site or marketing materials from the EU.

Regarding Status, Star Ratings and Usage Records

We may track and aggregate your usage of our website and application and use and display this information to others using our service. This includes, but is not limited to, the amount you have used TempStars service, your track record and profile summary information pertaining to your usage of TempStars. For example, other users of TempStars may view your Star Rating, number of shifts completed and other statistics related to your profile and track record with TempStars. This is used to help other TempStars users make informed decisions about whether to engage with you on the platform.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This privacy notice is divided into the following sections.

1. THE DATA WE COLLECT ABOUT YOU
2. HOW IS YOUR PERSONAL DATA COLLECTED
3. HOW WE USE YOUR PERSONAL DATA
4. DISCLOSURES OF YOUR PERSONAL DATA
5. DATA SECURITY
6. DATA RETENTION
7. YOUR LEGAL RIGHTS

1. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Treatment Data includes information about the treatment you wish to receive from us. This information could include ‘health data’ which is a special category of personal data and therefore requires us to take extra steps to ensure it is adequately protected.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

With the exception of Treatment Data, we do not collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

The TempStars website logs IP addresses and browser types to provide you with the best possible user experience and allow us insight into consumer behaviour. You can browse our site without entering any personal information, and therefore remain anonymous during your visit. However, the enquiry form asks for personal information such as name, postal address, email address and telephone number to enable us to send out the requested information, and make any future visits to our site easier.

2. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:

1. analytics providers such as Google based inside OR outside the EU;
2. advertising networks based inside OR outside the EU
3. search information providers such as Google or Bing based inside OR outside the EU.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers or aggregators Experian based inside and outside the EU.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside and outside the EU.

3. HOW DO WE USE THE INFORMATION THAT YOU PROVIDE TO US?

Broadly speaking, we use personal information for purposes of administering our business activities, providing the products and services you requested, to process your payment, to monitor the use of the service, our marketing and promotional efforts and improve our content and service offerings, and customize our site’s content, layout, services and for other lawful purposes. These uses improve our site and better tailor it to meet your needs.

When you use our “Job Board” and apply for permanent, contract or mat leave positions, the dental office receives: 1. your resume (that you uploaded) 2. your year and school of graduation 3. your TempStars star rating 4. the number of TempStars placements you have completed 5. the percentage of completed placements that rated “Happy” or “Very Happy” 6. whether you temped at the office you’re applying to, and if so, how they rated you.

Furthermore, such information may be shared with others on an aggregate basis. Personally identifiable information or business information will not be shared with parties except as required by law. Occasionally, we may also use the information we collect to notify you about important changes to our website, new services, and special offers we think you will find valuable. You may notify us at any time if you do not wish to receive these offers by emailing us at the link provided on the newsletter.

What Are Cookies?

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a Website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Browsers are usually set to accept cookies. However, if you would prefer not to receive cookies, you may alter the configuration of your browser to refuse cookies. If you choose to have your browser refuse cookies, it is possible that some areas of our site will not function as effectively when viewed by the users. A cookie cannot retrieve any other data from your hard drive or pass on computer viruses.

How Do We Use Information We Collect from Cookies?

As you visit and browse our website, the site uses cookies to differentiate you from other users. In some cases, we also use cookies to prevent you from having to log in more than is necessary for security. Cookies, in conjunction with our web server’s log files, allow us to calculate the aggregate number of people visiting our website and which parts of the site are most popular. This helps us gather feedback to constantly improve our Website and better serve our clients. Cookies do not allow us to gather any personal information about you and we do not intentionally store any personal information that your browser provided to us in your cookies.

What are Dynamic Ads?

Dynamic Ads are ads that are personalized in real-time to the user. Unlike static ads that show the same content on every impression, Dynamic Ads enable the advertiser to display a unique creative for different users. Dynamic Ads are the only feasible way to scale up the number of creatives per campaign and to personalize them on each impression.

What is ReTargeting?

The main goal of ReTargeting Ads is to re-engage site visitors after they have left the site. Dynamic ReTargeting Ads are generated based on the actual products or offers viewed on the advertiser’s site. For example if you’ve visited a retailer’s website and viewed a specific product, you might receive a banner ad containing that product. Rather than showing the same ad to every visitor,Sudden Turtle Dental Consulting Inc. Dynamic Ad Application will select the most relevant ad copy based on the user’s activity on the site.Sudden Turtle Dental Consulting Inc. ReTargeting Platform works when an advertiser places our tag on his website. The tag embeds a third party cookie on the browser of users visiting the site. Using Real Time Bidding (RTB) Ad Exchanges, it is then possible to focus media buying efforts against those visitors. It is important to note that the cookie itself does not contain any personal identifying information. Our Personalized ReTargeting ads intelligently match the right offering to each visitor based on his previous activities on the site. Each advertiser using Sudden Turtle Dental Consulting Inc. services is responsible to limit the number of ad impressions shown to each user in order to ensure that viewers are not overly exposed to specific ads.

How Can I Remove Myself from Being ReTargeted?

Sudden Turtle Dental Consulting Inc. makes removing our tracking cookie easy for any user who wishes to do so. Users that don’t want to see TempStars ads should simply email help@tempstars.ca

IP Addresses

IP addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data known as traffic data so that data (such as the Web pages you request) can be sent to you.

What About Legally Compelled Disclosure of Information?

We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights. We may also disclose account information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Service or to protect the safety of our users and the Public.

What About Other Websites Linked to Our Website?

We are not responsible for the practices employed by websites linked to or from our website or the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our website. Please remember that when you use a link to go from our website to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites, which have a link on our website, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding.

Your Consent

By using our website and/or application, you consent to our collection and use of your personal information as described in this Privacy Policy. We reserve the right to amend this Privacy Policy at any time with or without notice.

Our Commitment To Data Security

Please note that your information will be stored and processed on our computers in the Canada. The laws on holding personal data in Canada may be less stringent than the laws of your Country of residence or citizenship. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

Choice/Opt-In/Opt-Out

This site allows visitors to unsubscribe so that they will not receive future messages. After unsubscribing we will discontinue sending the particular messages as soon as technically feasible.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

1. In an effort to help protect your privacy
2. To minimize the occurrence of “off-platform” arrangements. Most dental offices use TempStars as intended, but there are some unscrupulous offices that post a shift, collect resumes through Custom Offers, then cancel the posting and contact the hygienists directly from the resume contact information, to avoid the placement fee. This is a violation of our Terms of Service. To avoid this, when you upload your resume, we remove contact information.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased good or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

OPTING OUT

You can ask us to stop sending you marketing messages at any time following the opt-out links on any marketing message sent to you or by contacting us at any time using the details given above.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

COOKIES & WEBTRACKING

i. WHAT ARE COOKIES?

Our site uses cookies to keep track of progress and to provide our visitors with a tailored user experience. With the help of cookies, we can present you with customised content and adverts that will be of more interest to you. We also use cookies to remember your passwords for you so you don’t have to re-enter them each time you visit the site. You have the option of setting your browser to reject cookies. However, if certain cookies that track your details are rejected then we won’t be able to pre-fill any data on the site or direct you to the correct stage on your next visit.

ii. COOKIE UPDATE

Sudden Turtle Dental Consulting Inc. uses cookies to make the website easier for you to use and to ensure you get the best experience. If you choose to continue without changing these settings, you consent to this, but should you want to, you can change your settings at any time.

We will only read or write cookies for the preference level set, cookies set prior to you changing your settings will still be on your computer and you can remove them using your browser settings.

We use a cookie to remember your cookie preferences this has a couple of consequences

• If you delete all your cookies you will have to update your preferences with us again.
• If you use a different device, computer profile or browser you will have to tell us your preferences again.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. Such third parties consist of:

• IT
• Advisors
• Authorities:

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

Sudden Turtle Dental Consulting Inc. will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

A Special Note About Children

Children are not eligible to use our services unsupervised and we ask that children (under the age of 14) do not submit any personal information to us. If you are a minor, you can use this service only in conjunction with permission and guidance from your parents or guardians.

Acquisition or Changes in Ownership

In the event that the website (or a substantial portion of its assets) is acquired, your information would be considered part of those assets, and may be part of those assets that are transferred.

Policy Modifications

We may change this Privacy Policy from time to time. If/when changes are made to this Privacy Policy, we will email users who have given us permission to do so. We will post any changes here, so be sure to check back periodically. However, please be assured that if the Privacy Policy changes in the future, we will not use the personal information you have submitted to us under this Privacy Policy in a manner that is materially inconsistent with this Privacy Policy, without your prior consent.

Questions? It is our goal to make our privacy practices easy to understand. If you have questions, concerns or if you would like more detailed information, please email our privacy officer at membership@influencingdentistry.com