Invisalign Australia - Privacy Policy

Introduction 

Your privacy is very important to Align Technology, Inc. and its affiliates including Invisalign Australia Pty Ltd (ACN 098 357 736) (“Align”, "we", "us" and "our"). This Privacy Policy explains how we collect, protect, use and share Personal Information (i.e. information about an identified or identifiable natural person). 

Align designs, manufacturers and markets the Invisalign system and iTero intra-oral scanners, OrthoCAD services, Smile Consult and the My Invisalign Smile app, (the "App") (collectively, the "Sites") 

In general, you can visit our Sites without telling us who you are  however, our websites make use of cookies which you can read about in our Cookies & Ads policy.  

There are times, however, when we may seek information from you, about yourself or someone you know (such as a family member or patient or someone you consider might be interested in our products or services). It is our intent to let you know before we collect such Personal Information from you on the Internet, in person or through third parties and to obtain your consent to process such information where required by law.  You must only share Personal Information of another person with us if you have obtained their consent and permission to do so. 

By accessing our Sites, you consent to our collection, use, disclosure, transfer and processing of Personal Information in accordance with this Privacy Policy.  

Information we collect from you 

We collect Personal Information of 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, including for example, when you sign up to receive news alerts from us or to undergo a smile assessment. We also collect Personal Information from our service providers, contractors, job applicants and employees.  

If you are a patient (or parent or guardian of a patient) such information may include your name, address, telephone number, email address, date of birth or age, gender, income information and physician information, photographs and other information you choose to provide.  If you are a patient, we will also collect sensitive health information from you in connection with the services we provide to you (either directly through our Sites, or indirectly through your treating dentist or orthodontist), including your dental records, information regarding your teeth and treatment, and images of your teeth. Users of the App may also have information about their aligner wear, aligner stage, scheduled appointments, and treatment progress collected. 

If you are a dentist, orthodontist or Invisalign Provider, we will collect information such as your name, contact details, details about your qualifications and professional registration details, practice or employer details and information about your use of or interest in our products and services. We also retain attendance and other records relating to training courses that you complete with us online and in-person.  If you are a service provider or contractor, we will collect information such as your name, contact details, payment details and such other information as is required to facilitate our commercial relationship with you.  

If you are job applicant we will collect information such as your name, contact details, details of any qualifications you hold and information you disclose to us in a cover letter, curriculum vitae or interview. We will also conduct pre-employment checks which we may obtain from third parties. 

We will also collect information about your use of our Sites as described in the Cookies and Ad policy.  

What do we do with the information we collect? 

If you are a patient, we use your Personal Information for a variety of business purposes, including: 

  • to set up and otherwise manage your member account(s) in our Sites. 

  • to allow you to use, purchase, book and/or download products and services. 

  • to provide you with information about our products, services, news and events we believe may be of interest to you. 

  • to current or potential patients with details of Invisalign providers 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 registered healthcare practitioners, such as dentists or orthodontists with information on actual or prospective patients. 

  • to analyse use of our services and products, develop new services and products, and customise our products, services and other information we make available 

 

We use a robust combination of data sources (including demographic information, activity on our websites and order history.) to get a full picture of our product and marketing efforts. This data is only for our efforts and we do not share your Personal Information with other businesses for them to use for purposes other than their work with us.  

If you are a dentist, orthodontist or Invisalign Provider, we will use your personal information to administer Invisalign training courses, assess your suitability to become and remain an Invisalign Provider and to maintain and facilitate our commercial relationship with you while you are an Invisalign Provider.  

If you are a contractor or service provider, we will use your personal information for the purposes of facilitating our commercial relationship including to perform our own due diligence prior to engaging you to perform services for us and to pay you for services provided to us. 

If you are a job applicant, we will use your personal information for the purpose of assessing your application for employment. We may also retain your personal information in circumstances where your application is not successful.  

With whom do we share your Personal Information? 

We partner with other businesses including marketing and public relations agencies, and online video-conferencing platform providers, such as Zoom Video Communications, Inc.] to assist us in our marketing, communications, and sales efforts, and if you are a patient, dentist, orthodontist or Invisalign Provider we may share your Personal Information with those businesses for these purposes. These partners are not permitted by us to use your information for any purpose other than doing business with Align. 

In addition, any information we collect, including Personal Information, may be disclosed as part of any potential or actual purchase, reorganisation, merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of insolvency, bankruptcy or receivership, in which case Personal Information could be transferred to third parties as one of our business assets. 

We may also disclose your Personal Information: if we believe that doing so is required by law, court order or legal process; under the discovery process in litigation; to enforce our legal rights, policies or contracts; to collect amounts owed to Align; when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or if in good faith we believe that disclosure is otherwise necessary or advisable necessary. 

Users of the App whose treating dentist or orthodontist enrolls them in, and who accept, the Remote Care function of the App may also have information about their aligner wear, aligner stage, scheduled appointments, and treatment progress shared with their treating physician(s). To un-enroll in the Remote Care feature of the App, please contact your treating dentist or orthodontist or privacy@aligntech.com

You may access a list of current sub-processors that Align uses for various services here

CCTV at Invisalign Centres 

Our Invisalign Centres use closed circuit television (CCTV) to monitor and record activities in those Centres in order to provide a safe and secure environment for our employees and Centre visitors.  Video surveillance is being used to deter any form of aggressive, harmful or unlawful behaviour and to assist in identifying offenders. Should an incident occur, the recordings may be reviewed and used to assist with investigations or enquiries.  Circumstances under which recordings will be shown to a third party include: 

•unlawful acts (where footage may be shared with police or law enforcement authorities or insurers); 
•occupational health and safety complaints (where footage may be shared with investigators or insurers ); and 
•when otherwise required by law (e.g. court order). 

Online Tracking 

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Align does not recognise or respond to browser-initiated DNT signals. 

Children’s Privacy 

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 are a parent or guardian and believe your child under 13 has provided us Personal Information which you would like to review or request be deleted, or 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. 

Social Media 

By posting or otherwise making available any content about your Invisalign experience on a public social media platform, 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), YouTube (http://youtube.com/invisalign), Twitter (http://twitter.com/invisalign), Instagram (http://instagram.com/invisalign &  http://instagram.com/invisalignlive), and others, you represent and warrant that you are eighteen (18) years of age or older and that you agree to the terms and conditions listed on our page on those websites. 

If you are a user of Facebook, Twitter or other social media sites with public account settings and you apply a hashtag that is used in one of our public campaigns, such as #8MillionSmiles, or that incorporates any of our product names, such as #Invisalign, #InvisalignLive, or #InvisalignSmile -- we will make a copy of your post. and We may then post them on our Sites so that we can share your opinions about our products with the visitors of our Sites. Before being posted on our Sites, your comments will be reviewed by us. Please do not use these hashtags if you do not wish for your reviews to be made available on our Sites. 

If you are a parent, guardian, or anyone else becomes aware of user-generated content shared from an individual under the age of eighteen (18), please email us at Invisaligncare@aligntech.com. 

See the full Invisalign Social Media Guidelines here (https://www.facebook.com/ invisalign/app/207367005987498/). 

Links to other sites 

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. 

Marketing and Do Not Contact 

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 opt-out of 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. 

International data transfers 

Align operates globally and may therefore transfer your Personal Information to other countries in which Align operates which include Singapore, the United States of America and the United Kingdom. The full details of the entities in the Align Corporate Group and the countries they are located in is available here: http://investor.aligntech.com/index.php/static-files/3edcedc9-4451-4bd0-a8ad-151a6a94bf87. Your Personal Information may also be stored on our servers, which may be located outside of Australia. However, we will continue to protect your information in accordance with this Privacy Policy and our Binding Corporate Rules. By providing us your Personal Information, you agree to such transfers, processing and/or storage anywhere in the world, including the countries list above. 

Security 

The security of all Personal Information provided to Align is important to us, and Align endeavors to take reasonable steps designed to protect your Personal Information. 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 Information) securely via HTTPS. These portals require customer accounts and are not available to the general public. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Align strives to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to Align, and you do so at your own risk. 

Your Rights 

You may seek access to and correction of your personal information held by us by  contacting us at the address or email listed below. 

Further, if you have concerns that we have not met our obligations to you as required by the Privacy Act 1988 (Cth) and Australian Privacy Principles, you may contact us and make a complaint at the address and/or email listed below. You will need to provide us with sufficient details regarding your complaint as well as any supporting evidence and/or information. Once we have received this information, it will be reviewed promptly and we will provide you with our response to your complaint within 30 days.   

You may also make a complaint to the Office of the Australian Information Commissioner: https://www.oaic.gov.au/privacy/privacy-complaints/ 

Updates 

We may update this Privacy Policy from time to time as we deem necessary in our sole discretion. When we do, we will revise the last updated date at the beginning of the Privacy Policy. Notice of such update and/or modification will be provided on our Sites or as otherwise required by applicable law. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use and share Personal Information. Your continued relationship with Align after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy take effect immediately after being posted or otherwise provided by Align. 

Contact Us 

If you have any questions about this Privacy Policy, the privacy practices of our Sites, your information, your rights regarding your information, or your dealings with our Sites, please contact: 

Global Headquarters 
Align Technology, Inc. 
Attention: Privacy Officer 
2820 Orchard Parkway  
San Jose, CA 95034  
Privacy@aligntech.com 

You may also contact the Align local entity that is responsible for the use of your Personal Information. Details are: 

Invisalign Australia Pty Limited 

Attention: Privacy Officer 

Suite 2.02/6-8 Herbert Street 

St. Leonards NSW 2065 

Privacy@aligntech.com  

Last updated: 22 July 2020.