GLOBAL DATA PRIVACY POLICY

 

1. About Brasseler USA

Brasseler USA is a leading ISO Certified healthcare company, providing quality instrumentation to healthcare professionals for use in restorative dentistry, endodontics, oral surgery and oral hygiene. Over the past 40 years, Brasseler USA has developed a reputation as an innovative market leader in diamonds, carbides, polishers, endodontics, hand instruments, and handpieces.

Today, Brasseler USA offers the most comprehensive assortment of instruments and handpieces under one brand in the world. For more information, please visit www.BrasselerUSA.com.

You can find our contact details at the last section of this policy.

 

2. Overview

At Brasseler USA, your privacy is important to us. We process personal data in different contexts and we do so by fully respecting your privacy and your other rights and freedoms, as part of our unwavering commitment to ethical and responsible practices.

This Global Data Privacy Policy (“Policy”) sets forth the principles that govern our treatment of personal data across Brasseler USA worldwide. As used herein, “Brasseler USA” includes Peter Brasseler Holdings, LLC; Brasseler U.S.A. Dental, LLC; Brasseler U.S.A. Medical, LLC, and their subsidiaries. All employees and those with whom we share personal data must adhere to this Policy.

Brasseler USA is committed to protecting the information that our employees, clients, prospects, suppliers, and vendors have entrusted to us. We collect and use personal data in order to perform our business functions and provide quality health care products and services to our customers.

Consistent with our values, we treat any personal data that we obtain in accordance with the data privacy principles of transparency, purpose limitation, data minimization, data quality, integrity and confidentiality, accountability, and privacy by design.

This Policy applies to all personal data in any format or medium, relating to all employees, clients, vendors and others who do business with Brasseler USA.

 

3. Types of Personal Data We Collect and Use

We recognize personal data as any information related to an identified or identifiable individual. Depending on the context of your interactions with Brasseler USA, we collect and use different types of personal data from employees, contractors, candidates, clients, prospect clients and vendors.

Types of personal data we collect from:

 

4. Our Policy Towards Children

Our services are not directed to children. We do not knowingly collect personal data from children. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us. If we become aware that a child has registered for a service and has provided us with personal data, we will delete such information from our files.

 

5. Sources of Personal Data

Brasseler USA receives and uses various types of personal data in order to conduct our day to day business activities. We apply the data minimization principle in the collection and use of personal data ensuring that we only collect information that is necessary and by fair means, and providing notice and requiring consent when necessary.

Some of this data is collected directly from you in the following situations when:

Sometimes we also obtain data from third parties, in the following situations:

 

6. Uses and Purposes of Personal Data

The purposes for which we collect and use your personal data may vary depending on the type of relationship you have with us, such as if you are one of our employees, clients, or a website user. Brasseler USA always collect and use personal data according to the purpose limitation principle. The use of personal data for new purposes should always guarantee consistency and your privacy expectations, otherwise we will request your authorization.

 

7. Legal Basis for Data Collection and Use

Brasseler USA only collects and uses personal data when there is a fair and legal basis for its collection and use, for instance, when the collection of personal data is necessary to enter into a contract, to meet our legitimate interests, to comply with legal obligations or when we have your authorization.

The information we collect when we enter into a contract or business relationship with you, except if we indicate otherwise, is mandatory to develop our contractual relationship and to comply with legal obligations. For instance, some tax laws, labor, anti-fraud or compliance laws require organizations to collect certain information that may vary depending on the local regulations. Without the required mandatory information, we would not be able to work with you.

Marketing activities are usually based on your consent or to an existing business relationship with us. However, you can opt-out of these communications anytime and free of charge.

When we use your personal data for our legitimate interests, we always conduct a balancing test in order to ensure that data subject rights are not overridden.

Finally, when we have access to personal data on behalf of our clients, in our role as data processors, there is always a written contract regulating the service, including specific instructions for the data processing and safeguards.

 

8. Retention Periods

Brasseler USA applies the storage limitation principle in order to retain personal data in our records only for the length of time required to fulfill the purpose for which the data was collected. We do not keep personal data for longer than is necessary, and what is necessary depends on specific circumstances such as regulations requiring to retain information for a certain period of time and limitation periods of legal claims.

The retention period depends on the context in which we process data:

 

9. Disclosures to Third Parties and Processing Activities

At times, Brasseler USA engages third party contractors, service providers, and other vendors to help us accomplish our business objectives. There are other circumstances where we are required by law to disclose personal data to third parties such as public bodies or judicial authorities.

We engage with third party contractors, service providers and other vendors for certain services. If the engagement involves the transmission of personal data, Brasseler USA requires the service provider to treat that data consistent with this Policy. A contract to protect the personal data should be executed before any data is disclosed.

In certain circumstances, Brasseler USA may be required to disclose personal information when required by law, when required to protect our legal rights, or in an emergency situation where the health or security of an individual is endangered.

We may also disclose personal data in the context of any sale or transaction involving all or a portion of the business.

 

10. Security

Brasseler USA is committed to the security, confidentiality and integrity principle. We take commercially reasonable precautions to keep all information obtained from our online visitors secure against unauthorized access and use and we periodically review our security measures. We are committed to processing your data in a secure manner and have put in place specific technical and organizational measures to prevent the personal data we hold from being accidentally or deliberately compromised.

Brasseler USA uses Go Daddy Secure Certificate Authority – G2 for its sites’ security certificates. Please be aware that these protection tools do not protect information that is not collected through our website, such as information provided to us by e-mail.

We also conduct information risk assessments, we ensure that our staff understands the importance of protecting personal data, and we are responsibly managing access rights within the company. We include both physical security and IT security in our overall data security approach. We are diligent in selecting vendors that process personal data on our behalf so that they also ensure appropriate technical and organizational measures to protect the data.

Brasseler USA makes reasonable efforts to notify individuals and regulatory authorities, as required by law, if we reasonably believe that personal information has been stolen, disclosed, altered or infringed by an unauthorized person. We create and maintain a breach notification and reporting protocol.

We also endorse the concept of privacy by design which is an approach to projects that promotes privacy and data protection compliance from the outset. This means considering the privacy and security implications for any new project or process throughout its lifecycle.

 

11. Your Data Protection Rights and Choices

If you reside or otherwise find yourself in the territory of Europe, Brasseler USA is committed to facilitate the exercise of your rights granted by the European data protection law. Otherwise you can contact us at any time to discuss your privacy concerns.

Privacy rights under the European regulation:

Transparency and the right to information: we provide notice to our employees, customers, suppliers, vendors and others of how we use personal data in our day-to-day operations at the time of collecting personal data, or as soon thereafter as possible. We also publish this privacy notice for a greater transparency.

Right to access, rectification, restriction of processing, and erasure: we provide data subjects with access to their own personal data where required by applicable law. In addition, we will rectify their personal data when it is incorrect and inaccurate, and we will ensure the right to erasure and to restriction of processing when these rights are not compatible with local regulations.

Right to object and withdraw consent at any time: for all marketing materials, you can opt-out anytime, and free of charge. The right to object for other processing activities will be balanced in order to ensure that it is not incompatible with local regulations or the legitimate interests of Brasseler USA.

Right to data portability: based on your specific situation, we provide data subjects with the right to obtain and reuse your data across different services and includes transferring of your data to you, another controller or a trusted third party.

Right to lodge a complaint with a supervisory authority

These requests should be submitted as follows:

Right to lodge a complaint with a supervisory authority: you can have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of the alleged infringement.

 

12. International Transfers of Personal Data

If you are located outside the United States and you interact with our website or provide us personal data, then your personal data may be transferred to the United States. If you are based in the European Economic Area or Switzerland, please be informed that the United States is not in the list of countries that the European Commission considers adequate to the protection of personal data. However, we provide appropriate safeguards for your data in the US as we transfer it based on Standard Contractual Clauses we entered with third parties.

 

13. Changes to this Notice

We reserve the right to modify this Privacy Statement and related business practices at any time. We will duly inform you of any changes.

Changes in this privacy policy will be notified to you via upon written request via e-mail sent to info@brasselerusa.com. We will give you the opportunity to express your consent for processing your data for different and new purposes, or we will in any case inform you about the legal basis of such processing other than consent. The time stamp you see on the policy will indicate the last date it was revised.

14. Contact information

At Brasseler USA we are committed to apply this privacy policy and the accountability principle. For this reason, if you have any privacy concern or questions about how your personal data is used, please feel free to contact us.

If you have any concerns or questions about how your personal data is used, please contact us at:

Brasseler USA
One Brasseler Blvd.
ATTN: Customer Service
Savannah, Georgia 31419
United States of America
E-mail: info@brasselerusa.com
Phone: +1 912 925 8525

We will promptly respond and do everything possible to address your concern.

Last Updated: April 30, 2018