Privacy Policy | EAS - European Aligner Society

We are EAS (European Aligner Society), and when you access or use this website (www.eas-aligners.com), or our branded pages on social media services, or any of the other sites, services, features, content or applications we offer in the United Kingdom and European Union (collectively, the "Services"), or register as a member or sponsor with us, from anywhere in the European Union, Iceland, Norway or Lichtenstein, this Privacy Policy will tell you how EAS collects, uses and shares the personally identifiable information ("Personal Data") we collect about you.

We urge you to read this Privacy Policy in full, but wanted to mention a few things upfront:

When you use the Services, even if you don't have an “account” with us, we may receive some Personal Data from you through your web browser, including your IP address, the type of device you're using and other similar information, and use it to understand where and how our Services are being used, among other purposes described in this Privacy Policy. If you do set up an “account” with us, we'll collect other Personal Data from you, and use it to verify your identity, fulfil your association and for other purposes.

In this Privacy Policy, we describe the various purposes for which we use your Personal Data, as well as the legal bases supporting those purposes. As you'll read below, the legal basis on which we rely for a given use of your Personal Data may be contractual necessity (i.e., where we need to use your Personal Data to complete a contract with you), consent freely given to us (which you can withdraw at any time) and/or certain legitimate business of ours or of others, but only where we have determined that those interests are not overridden by your own interests, rights and freedoms.

You have certain rights regarding the Personal Data we collect from you, which you can learn about below.

As noted in our Terms of Service, we do not knowingly collect or solicit Personal Data from anyone under the age of 18. If you are under the age of 18, please do not access or use the Services, or attempt to send us any Personal Data. If we learn that we have collected Personal Data from an individual under the age of 18, we will delete that information as quickly as possible.

If you are based in the European Union, Iceland, Norway or Lichtenstein, EAS is the primary data controller of your information and, accordingly, is registered with the Information Commissioner's Office. EAS has a registered office at 48 London House, 172 Aldersgate Street, London EC1A 4HU, UK. You can contact us there or at office@eas-aligners.com, if you have any questions or concerns about our collection and/or use of your Personal Data. If you are using the Services outside of the areas listed in this paragraph, a different privacy policy may apply to you instead.

The Services are hosted and operated in the United Kingdom and European Union through EAS, and certain of our service providers. By using the Services, you acknowledge that any Personal Data you provide to us will be hosted on Italian servers.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including, but not limited to, any third party websites, services, products or applications (each a "Third Party Service") that you elect to access and may interact with during your use of the Services, or to individuals that we do not manage or employ. We take steps to ensure that we only work with Third Party Services that share our respect for your privacy, but we cannot take responsibility for the content, products, services or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

PERSONAL DATA YOU PROVIDE US

REGISTRATION INFORMATION

We collect your email address and the password you enter when you register as a member or for a Congress/Meeting, and we use them to verify your identity, based on our legitimate business interests in keeping your account secure and preventing fraudulent transactions.

We also use your email address:

to send you confirmations, notifications and other information regarding your membership or registrations as may be necessary to complete our contractual obligations to you. Without your email address, we wouldn't be able to provide you this information in a timely and effective manner;

to send you information and materials about our services that we think may be of interest to you, based on our legitimate business interest in marketing to individuals who have indicated an interest in our services. You can choose not to receive such information when you register an account with us, and you can decide to stop receiving this information at any time by emailing us at office@eas-aligners.com or by calling us at +44 7802202612; and

to send you information and materials about third parties with whom we partner or do business and their products and services, but only where you have given us your consent to do so.

SHIPPING AND PAYMENT INFORMATION

When you join EAS or register to participate in a Congress / Meeting through the Services, we collect your first and last name, your shipping address and your telephone number (collectively, "Shipping Information"), as well as certain payment information, including your billing address and your credit or debit card type, number, security code and expiration date (collectively, "Payment Information"), and we use this information in order to process, fulfil, confirm, or notify or inform you about your membership or registration, as may be necessary to complete a contract with you. Without this information, we would be unable to complete your transaction.

All Payment Information regularly collected through the Services is encrypted and maintained using industry standard methods designed to ensure its security against loss or theft, including during transmission to our third party payment processing company ("Payment Processor"), which is currently Allied Irish Bank Merchant Services. Please note that your Payment Information is stored by our Payment Processor, not by us, and use and storage of that information by the Payment Processor is governed by the Payment Processor's applicable terms of service and privacy policy (available at: http://www.authipay.com/privacy-policy/).

We also use your Payment Information to verify your identity when you manage your account, based on our legitimate business interests in keeping your account secure and preventing fraudulent transactions. As stated above, we do not store your Payment Information – our Payment Processor does, and we must collect your Payment Information from our Payment Processor and/or from you in order to use it to verify your identity or to process and fulfil your transactions.

We use and store your Shipping Information to make it easier for you to register based on our legitimate business interest in making the Services more convenient for your continued use.

We may also use your Shipping Information to mail you information about us and our services that we think may be of interest to you, based on our legitimate business interest in marketing to individuals who have indicated an interest in EAS services.

You can always have us delete your Shipping Information at any time by emailing us at office@eas-aligners.com or calling us at +44 7802202612.

INFORMATION YOU SHARE WITH US IN COMMUNICATIONS OR INTERACTIONS

When you respond to a survey we provide you, or leave a written comment or review on the Services about us, we record that survey response, comment or review, and use the information you provide us in them, in order to assess and/or address your responses, comments or reviews regarding us, our services, based on our legitimate business interest in providing quality membership service.

COOKIE INFORMATION

When you access or use the Services, we and certain of our third party service providers automatically receive and record information from your web browser and your device using cookies and similar technologies such as pixel tags or web beacons (for the purposes of this Privacy Policy, we refer to these technologies individually and collectively as "Cookies"). Cookies are small files – usually consisting of letters and numbers – placed on your computer, tablet, phone or similar device, when you use that device to visit a website. Cookies can either be "session Cookies" or "persistent Cookies." Session Cookies are temporary Cookies that are stored on your device while you are accessing or using our Services, whereas "persistent Cookies" are stored on your device for a period of time after you leave our Services. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie.

We use Cookies to collect information regarding your internet usage, including your IP address, internet service provider, browser type and version, the pages you visit and links you click on the Services, and the page referring you to the Services and/or the page you visit when you exit the Services, as well as device-specific information if you access the Services using a mobile device, such as unique device identifiers, network information and hardware model (collectively, "Cookie Information"), in order to:

enable you to access and use our website and other features or content on the Services that you request or seek to use, based on our legitimate business interest in providing you with the Services. For example, certain Cookies enable you to log into your account or use the "shopping cart" functionality on the Services. Such Cookies are generally known as "essential cookies." You can disable these Cookies, but doing so will encumber the performance of the Services and may make certain of its features and services unavailable to you;

determine whether you have previously visited or otherwise used the Services, and if so, whether you indicated any preferences during your previous visits or use, based on our legitimate business interest in personalizing the Services for repeat visitors. Such Cookies are generally known as "functionality cookies," and are persistent Cookies. You can disable these Cookies, but doing so will impair our ability to personalize the Services for you. Our functionality cookies include, for example:

h_cart: notes the contents of your cart before checkout so that if you navigate away from your basket and return to us, we will remember what was in your cart;

h_sess: identifies you to our servers after you log in to your account;

flash: temporarily stores messages and alerts that we display on-screen to you;

h_personalization: identifies your relationship with us (e.g., whether you have previously made a purchase from us or signed up for a shave plan);

followed_incentive_code: this Cookie is delivered by us to verify that a referral link is genuine so that we can credit your account accordingly. Without this Cookie, we cannot authenticate the code and the credit cannot be applied;

h_geoip: determines from which country you are accessing the site so that we can present a country-specific experience (e.g., currency, language, products, shipping options);

h_public: stores your public user ID which helps us serve a personalized site experience;

h_mobile: determines if you are on a mobile device to serve a mobile optimized site experience;

h_signed_once: remembers if you have logged in before to default your login option to login instead of create account;

h_user: identifies you as being logged-in;

h_dc: remembers if you applied a discount code to apply that discount at checkout;

h_gdpr_cookie_agree: remembers if you agree to being tracked via Cookies; and

multi_step_builder_state: remembers your progress in completing the checkout experience for a subscription;

learn about the pages on our website and on Third Party Services that you visit, and thus enhance our understanding of your interests and preferences, so that we can serve you with advertisements for our products or services that we believe may be of interest to you (on the Services and elsewhere), based on our legitimate interest in marketing to individuals we believe may be interested in our products and services. Such Cookies are generally known as "retargeting and advertising cookies," and are persistent Cookies. Through these Cookies, we collect information about your online activity after you leave our Services. We use a number of third parties to help deliver these Services, including, for example, Google. Please see the section below titled "Additional information about interest-based advertisements" for more information; and

understand how visitors use the Services, such as by collecting information about the number of visitors to our website, what pages visitors view on our website and how long visitors are viewing pages on the website, based on our legitimate business interest in improving and maintaining the accessibility and functionality of our Services. Such Cookies are generally known as "performance/analytical cookies," and are persistent Cookies. Through these Cookies, we may collect information about your online activity after you leave our Services. We also use these Cookies to help us measure the performance of our advertising campaigns, based on our legitimate business interest in improving our advertising campaigns and the content on the Services to better market to individuals who we think may be interested in our products and services. We use a number of third parties, as described below, to help deliver these Services. Our performance/analytical cookies include, for example:

h_eph_sess: a short-lived unique identifier that we use to see if you arrive to our website and whether this could be linked to any offline advertising like TV or radio advertisements;

h_custype: lets us know if you have purchased from us in the past, so that we can show you relevant information on our website;

ga: Google Analytics session information, a third party Cookie served by Google; and

gid: Google Analytics user identifier, a third party Cookie served by Google.

Some Cookies are placed by a third party on your device and may provide Cookie Information to that third party as well as to us, that indicate your browsing habits (such as your visits to our website or other Services, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether you have visited or used certain Third Party Services, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. For example, as indicated above, we use certain Google services including Google Analytics, which uses Cookies to analyse how users use our Services. Following a request by us, Google will use this information for the purpose of measuring your activity on our Services, compiling statistical reports on overall website activity for us and providing other services relating to such activity and internet usage. You can learn more about Google Analytics and their cookies here. If you are on the web, you can also opt out of Google Analytics by installing Google's opt-out browser add-on. We do not control third party Cookies.

Your browser may offer you a "Do Not Track" or "DNT" option, which allows you to signal to operators of Third Party Services that you do not wish such operators to track certain of your online activities over time and across different websites. However, because we collect browsing and persistent identifier data, our Services do not support DNT requests at this time, which means that we may collect information about your online activity both while you are using the Services and after you leave them. You should also know that certain Third Party Services may not support DNT requests either – you should check their respective privacy policies for more information.

You can decide whether or not to accept most Cookies. Most browsers allow you to delete Cookies and have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allowing you to decide whether to accept each new Cookie in a variety of ways. To explore what Cookie settings are available to you, look in the "preferences" or "options" section of your browser's menu. You can always choose to stop us from collecting your Cookie Information by turning off the Cookie feature on your browser or by ceasing to use the Services. However, if you do prevent us from collecting your Cookie Information, you should know that some of the Services may not work properly.

If you'd like to know more about Cookies, including information about how to manage, disable and delete them, you can visit

- http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm

- https://ico.org.uk/for-the-public/online/cookies/

- http://www.youronlinechoices.com/uk/

- http://www.allaboutcookies.org/.

WHO WE SHARE YOUR PERSONAL DATA WITH

We only share your name and email address within companies we work with during Congresses and Meetings. Your data is never shared with other third party vendors, service providers and agents.

PUBLIC INFORMATION

If you post information or content publicly on or through the Services (including when you submit comments or reviews), or post content publicly elsewhere, including on your social media accounts, that relates to us or the Services, we may receive but do not share that public information with third parties.

CHANGE OF OWNERSHIP OR CONTROL

If we are acquired by or merge with another company, go out of business or enter bankruptcy, or sell some or all of our assets, your Personal Data may be sold or transferred in connection with the transaction in question. If such events do take place, this Privacy Policy will continue to apply to your Personal Data.

LAWS AND SAFETY

We also reserve the right to access, read, preserve and disclose your Personal Data as we reasonably believe is necessary to:

satisfy any applicable law, regulation, legal process or governmental request;

enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof or thereof; or

protect our rights, property or safety, and those of our users, customers and the public.

However, nothing in this Privacy Policy is intended to limit your rights and remedies regarding your Personal Data, including your right to register a complaint with your local data protection authority.

HOW WE PROTECT YOUR PERSONAL DATA

We seek to protect your Personal Data using appropriate technical and organizational measures, taking into account the nature of the applicable Personal Data and processing activity. For example, all Payment Information regularly collected through the Services is encrypted and maintained using industry standard methods designed to ensure its security against loss or theft, including during transmission to our Payment Processor. However, we cannot and do not guarantee or warrant that such techniques will prevent unauthorized access to Personal Data or other information about you that we collect and store. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of such information at any time.

You can help us prevent unauthorized access to your account with us and your Personal Data by selecting and protecting your password appropriately and limiting access to your device and browser by signing off after you have finished accessing your account.

WHAT YOUR RIGHTS ARE TO YOUR PERSONAL DATA, AND HOW YOU CAN EXERCISE THEM

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request with respect to these rights, you can email office@eas-aligners.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous, inaccurate or extremely impractical, if it jeopardizes the rights of others or if it is not required by law, but in those circumstances we will still respond to notify you of such a decision. In some cases, we may need you to provide us with additional information, which may include Personal Data, as necessary to verify your identity and the nature of your request.

RIGHT OF ACCESS

Where permissible, you can request more information about the Personal Data we hold about you and you can request a copy of your Personal Data. If you have an active account with us, you can also access your Personal Data by visiting your account settings on our website.

RIGHT OF RECTIFICATION

If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such Personal Data. You can also correct some of this Personal Data directly by visiting your account settings on our website.

RIGHT OF ERASURE

Where permissible, you can request that we erase some or all of your Personal Data from our systems. You can also delete your account with us at any time by emailing us at office@eas-aligners.com or calling us at +44 7802202612.

RIGHT TO WITHDRAW CONSENT

If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent to this processing at any time, which you can do by emailing us at office@eas-aligners.com or calling us at +44 7802202612. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

RIGHT TO OBJECT TO PROCESSING AND TO RESTRICT PROCESSING

Where permissible, you can let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as marketing to you (to name one example), and you can also ask us to restrict further processing of your Personal Data.

RIGHT OF PORTABILITY

Where permissible, you can ask for a copy of your Personal Data in a machine-readable format, and you can also request that we transmit the data to another controller where technically feasible.

RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. Please visit http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm for more information.

OUR PERSONAL DATA RETENTION POLICY

We retain your Personal Data for as long as you have a working account with us, or as otherwise necessary to provide you with the Services. In some cases we retain Personal Data for longer, if doing so is necessary to pursue our legitimate business interests (but only if those interests are not overridden by your own interests, rights and freedoms), comply with our legal obligations, resolve disputes or collect fees owed, conduct audits, or if doing so is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we dispose of your Personal Data securely, but may retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

As stated above, you can request us to erase some or all of your Personal Data from our systems, and you can delete your account with us at any time, by emailing us at office@eas-aligners.com or calling us at +44 7802202612.

ANY QUESTIONS OR CONCERNS?

If you have any questions or concerns regarding how we collect, use, protect or share your Personal Data, including, for example, about our legitimate business interests or the legitimate business interests of others that we describe above, please send a detailed message to office@eas-aligners.com. We will make every effort to resolve your concerns.

EFFECTIVE DATE: 25 May 2018