Privacy Policy

This Privacy Policy describes how PDH Protocols collects, uses and discloses information, and what choices you have with respect to the information.

When we refer to “PDH Protocols”, we mean PDH Protocols, Inc. and its wholly-owned subsidiaries.

1. Table of Contents:
2. Applicability of this Privacy Policy
3. Information We Collect and Receive
4. How We Use Information
5. Data Retention
6. How We Share and Disclose Information
7. Security
8. Age Limitations
9. EU-U.S. Data Privacy Framework
10. Changes to this Privacy Policy
11. Data Protection Officer
12. Contacting PDH Protocols

Applicability Of This Privacy Policy

This Privacy Policy applies to PDH Protocols’s subscription services, including the associated PDH Protocols mobile applications (collectively, the “Services”), www.pdhprotocols.com and other PDH Protocols websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with PDH Protocols. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of PDH Protocols’s business.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the PDH Protocols Services (“Third Party Services”), or any other third-party products, services, or businesses. In addition, a separate agreement governs delivery, access, and use of the Services (the “Customer Agreement”), including the processing of any messages, files or other content submitted through use of the Services (collectively, “Customer Data”). The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls certain aspects of their instance of the Services (their “Deployment”) and associated Customer Data, for example, how long PDH Protocols will retain Customer Data.

Information We Collect And Receive

PDH Protocols may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:

• Customer Data. Deployments are configured to send Customer Data to PDH Protocols for processing using the Services, for example, digital teeth image may be sent to PDH Protocols through the Services in order for an artificial intelligence algorithm to detect suspected conditions such as caries. Customers or individuals granted access to a Deployment by a Customer (“Authorized Users”) routinely submit Customer Data to PDH Protocols when using the Services, for example, Authorized Users may submit messages through the mobile application component of the Services to coordinate care for a patient. Customer Data includes “Protected Health Information” as defined in the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Protected Health Information is governed by the HIPAA Business Associate Agreement between the Customer and PDH Protocols and not by this Privacy Policy.
• Other Information. PDH Protocols also collects, generates and/or receives Other Information:
• Deployment and Account Information. To create or update an Authorized User account, you or your Customer (e.g., your employer) supply PDH Protocols with an email address, phone number, password, role or title, and other similar account details. In addition, Customers provide PDH Protocols (or its payment processors) with billing details such as banking information and a billing address.
• Usage Information.
• Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, PDH Protocols logs when an Authorized User logs in to the Services and other Authorized User activity within the Services.
• Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
• Device information. PDH Protocols collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
• Location information. We may receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. PDH Protocols may also collect location information from devices in accordance with the consent process provided by your device.
• Cookie Information. PDH Protocols uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services.
• Third Party Services. Customer can choose to permit or restrict Third Party Services for their Deployment. Typically, Third Party Services are software that integrate with our Services, and Customer can permit its Authorized Users to enable and disable these integrations for their Deployment. Once enabled, the provider of a Third Party Service may share certain information with PDH Protocols. For example, if a cloud storage application is enabled to permit files to be imported to a Deployment, we may receive user name and email address of Authorized Users, along with additional information that the application has elected to make available to PDH Protocols to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to PDH Protocols. When a Third Party Service is enabled, PDH Protocols is authorized to connect and access Other Information made available to PDH Protocols in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services.
• Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import (such as an address book from a device) is collected when using the Services.
• Third Party Data. PDH Protocols may receive data about organizations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
• Additional Information Provided to PDH Protocols. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with PDH Protocols. If you make a request through our Trust Center Website, you will be asked to provide your full name, email address, phone number (for 2 factor authentication), institution name, and job position. You may also provide free text information to PDH Protocols through our Websites, including our Trust Center.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as contact information, is not provided, we may be unable to provide the Services.

How We Use Information

Customer Data will be used by PDH Protocols in accordance with applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. PDH Protocols is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to an Authorized User, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.

PDH Protocols uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, PDH Protocols uses Other Information:

• To provide, update, maintain and protect our Services, Websites and business. This includes the use of Other Information to support the delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, and analyze and monitor usage, trends and other activities or at an Authorized User’s request.
• As required by applicable law, legal process or regulation.
• To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond. For example, we will use the information you provide to us to respond to Trust Center requests.
• To develop and provide algorithms, tools and additional features. PDH Protocols tries to make the Services as useful as possible for specific Deployments and Authorized Users. For example, we may improve the way we present reports to Authorized Users by using Other Information to help determine and rank the relevance of studies, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience or create new features and products. PDH Protocols may access Customer Data and Other Information including messages within the mobile application to better understand how Authorized Users use and engage with the Services.
• To send emails and other communications. We send you alerts through the mobile application when we identify a suspected condition and if you are “on call” within the mobile application. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about PDH Protocols. These are marketing messages so you can control whether you receive them.
• For billing, account management and other administrative matters. PDH Protocols may need to contact you for account management and similar reasons and we use account data to administer accounts.
• To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, PDH Protocols may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.” However, Protected Health Information is governed by the HIPAA Business Associate Agreement between the Customer and PDH Protocols and not by this Privacy Policy.

Data Retention

PDH Protocols will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Typically, PDH Protocols will retain Customer Data and Other Information for the duration of a Customer’s subscription term in the Customer Agreement. PDH Protocols may retain Other Information after you have deactivated your account for the period needed for PDH Protocols to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

How We Share And Disclose Information

This section describes how PDH Protocols may share and disclose Information.

• Customer’s Instructions. PDH Protocols will solely share and disclose Customer Data in accordance with the Customer Agreement, a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
• Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users. For example, an Authorized User’s email address or phone number may be displayed with their Deployment profile in order to use the Services, for example to enable rapid communication between the medical team and the company.
• Customer Access. Owners, administrators, Authorized Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include, for example, your employer using Service features to export logs of Deployment activity, or accessing or modifying your profile details.
• Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Customer Data and Other Information and support our business. These third parties may, for example, provide virtual computing and storage services.
• Corporate Affiliates. PDH Protocols may share Customer Data and Other Information with its corporate affiliates and subsidiaries.
• During a Change to PDH Protocols’s Business. If PDH Protocols engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of PDH Protocols’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Customer Data and Other Information may be shared or transferred, subject to standard confidentiality arrangements.
• Aggregated or De-identified Data. Subject to the Customer Agreement, we may disclose or use aggregated or de-identified Customer Data and Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective PDH Protocols customer the average response time to alerts within a typical Deployment.
• To Comply with Laws. If we receive a request for information, we may disclose Customer Data and Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of PDH Protocols or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
• With Consent. PDH Protocols may share Customer Data and Other Information with third parties when we have consent to do so.

Security

PDH Protocols takes security of data very seriously. PDH Protocols works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology..

Age Limitations

To the extent not prohibited by applicable law, PDH Protocols does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

EU-U.S. Data Privacy Framework

PDH Protocols, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. PDH Protocols Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

With respect to personal data received or transferred pursuant to the Data Privacy Frameworks, PDH Protocols Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

PDH Protocols Inc.’s accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, PDH Protocols Inc. remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Data Privacy Framework Principles, unless PDH Protocols Inc. proves that it is not responsible for the event giving rise to the damage.

Pursuant to the Data Privacy Frameworks, EU and UK individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to privacy@PDH Protocols. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@pdhprotocols.com.

In compliance with the Data Privacy Framework Principles, PDH Protocols commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Frameworks. European Union, and the United Kingdom with DPF inquiries or complaints should first contact PDH Protocols by email at privacy@pdhprotocols.com.

PDH Protocols, Inc. has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.

If your complaint involves human resources data transferred to the United States from the European Union or the United Kingdom in the context of the employment relationship, and PDH Protocols, Inc. does not address it satisfactorily, we commit to cooperate with the panel established by the EU data protection the United Kingdom in the context of the employment relationship, and PDH Protocols, Inc. does not address it satisfactorily, PDH Protocols Inc. commits to cooperate with the panel established by the EU data protection authorities (DPA Panel) and the UK Information Commissioner’s Office, and to comply with the advice given by the DPA panel [or ICO, as applicable] with regard to such human resources data. To pursue an unresolved human resources complaint, you should contact the state or national data protection or labour authority in the appropriate jurisdiction. Complaints related to human resources data should not be addressed to the BBB NATIONAL PROGRAMS.

Contact details for the EU data protection authorities can be found at https://edpb.europa.eu/about-edpb/board/members_en.

UK individuals can also file a complaint with the ICO at https://ico.org.uk/make-a-complaint/uk-extension-to-the-eu-us-data-privacy-framework-complaints-tool/.

Changes To This Privacy Policy

PDH Protocols may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

Data Protection Officer

To communicate with our Data Protection Officer, please email privacy@pdhprotocols.com.

Contacting PDH Protocols

Please also feel free to contact PDH Protocols if you have any questions about this Privacy Policy or PDH Protocols’s practices, or if you are seeking to exercise any of your statutory rights. You may contact us at privacy@pdhprotocols.com or at our mailing address below:

PDH Protocols, Inc.

Attention: Chief Executive Officer

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Last Update: July 30, 2024