Overview
This Privacy Policy explains how Smile Design Vietnam Co.,Ltd,. and their affiliates (Hereinafter referred to as “Company”, “we”, “us”, “our”) collect, use, disclose, manage and protect Personal Information acquired by the Company. The term “Personal Information” refers information that identifies, relates to, or could be reasonably linked, directly or indirectly, with a particular identified or identifiable natural person. This Privacy Policy applies to Personal Information in our possession or under our control, including Personal Information in the possession of organizations which we have engaged to collect, use, disclose or process Personal Information for our purposes.

1. Compliance with laws and regulations
Our Company strictly observes applicable laws, regulations, contracts, and other standards related to the collection,use, disclosure, and protection of Personal Information. 

2. Acquisition of Personal Information
Our Company collects the following information in a lawful, fair and appropriate manner in connection with the scope of our Company’s activities such as the provision of various services, collaborations with dentists, orthodontists and/or other third-party service providers, and recruitment activities. The followings are examples of information collected by the Company, some of which are not Personal Information and are not covered by obligations and responsibilities relating to the protection of Personal Information:  

(i). Information provided from customers
a. Name, address, telephone number, e-mailaddress
b. Information such as date of birth and gender
c. If you have provided our Company with your opinions, questions, answers to questionnaires, etc., by telephone,e-mail, or by any other means, information pertaining to such contents
d. In addition to the above, all information provided to our company by customers

(ii). Information acquired from the medical institution where customers was seen
a. Information obtained from the medical institution where the customer visited in order to manufacture and sell orthodontic mouthpieces and other dental technical products that we offer, such as the customer’s name, intraoral 3D scan data, treatment information, and case photos.
b. Information obtained from the medical institution where the customer has visited in order for our Company to respond to inquiries from the customer through the medical institution, such as the customer’s name and treatment information. 

3. Consent to the collection, use, and disclosure of Personal Information
Our Company generally do not collect your Personal Information unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your Personal Information to us (your “authorized representative”) after (i) you (or your authorized representative) have been notified of the purposes for which the Personal Information is collected, and (ii) you (or your authorized representative) have provided written consent to the collection and usage of your Personal Information for those purposes, or (b) collection and use of your Personal Information without consent is permitted or required by the applicable laws. We shall seek your consent before collecting any additional Personal Information and before using your Personal Information for a purpose which has not been notified to you (except where permitted or authorized by law).  

By accessing or using our Company’s services or otherwise providing us with your Personal Information, our Company shall be entitled to assume that you understand and agree to the terms of this privacy policy and consent to the collection, use and disclosure of your Personal Information by our Company. If you do not consent to any of these terms, please do not access or use any of our services, or provide us with any of your personal information.

4. Purpose of Use
Our Company may collect and use the acquired Personal Information within the scope indicated in “Purpose of Use”.

Purpose of Use
i. Reservation, contract, and cancellation concerning customers, cooperation with reservation systems
ii. Provision of information for reservation, examination and treatment, production and delivery of dental products by us, and provision of necessary information for production and delivery of dental products by our partnering dental institutions
iii. Information on new services and campaigns
iv. Sending email newsletters and direct mail, etc.
v. Research and development on orthodontic services
vi. Creation of statistical data for marketing and sales promotion, provision of various information
vii. Conducting and tabulating surveys and questionnaires, responding to inquiries from customers and affiliated medical institutions

5. Third-party provision
Our Company outsources part of its business relating to Personal Information. Our Company considers the management of outsources to be extremely important, and when outsourcing such work, our Company selects business operators that meet the level of Personal Information protection stipulated by the applicable laws, and clarifies each other’s obligations under non-disclosure agreements, etc. In addition, the Company requests the relevant business entities to handle Personal Information appropriately, and continuously conducts supervision and audits necessary for the security management of Personal Information.

As a general rule, our Company does not disclose or provide personal data to third parties, except for affiliated medical institutions, subsidiaries, related corporations and regulatory authorities.

Notwithstanding this, Personal Information may be provided to third parties in the following cases. In addition, we will disclose and provide your Personal Information appropriately in accordance with the applicable laws and regulations.
a) With the consent of the customer
b) Cases where disclosure of Personal Information is required by a court, public prosecutors’ office, police, tax office, bar association, or other organization with equivalent authority
c) Where our Company outsources all or part of its business to a third party
d) Cases where disclosure is made to a person who has a duty of confidentiality with respect to our Company
e) Cases where disclosure is made to a person who will succeed to the business upon a succession of the business due to a merger, transfer of business, or any other cause
f) When permitted by the other laws and regulations
g) Other cases specified separately for each of our Company’s service

6. Inquiries on disclosure and deletion
If you wish to disclose and/or delete your Personal Information, we will confirm your identity and as soon as practicable disclose or delete your Personal Information except where we are not required to do so under the applicable laws.

7. Secure management of Personal Information
Our company will strictly manage Personal Information and make reasonable security arrangements to prevent unauthorized or improper access, collection, use, disclosure, copying, modification, loss, destruction, falsification, leakage or similar risks through the development and improvement of systems and introduction of appropriate administrative, physical and technical measures for the protection of Personal Information, education and enlightenment activities for employees, access control and information security measures, etc.

Our Company shall cease to retain documents containing Personal Information or otherwise remove the means by which the Personal Information can be associated with you as soon as it is reasonable to assume that the purpose for which such information was collected is no longer served by retention of the said information and retention is no longer necessary for legal or business purposes, or where otherwise required under applicable laws. We will also ensure that any Personal Information that we do not retain is disposed of, anonymized, and/or deleted in an appropriate manner.

8. Continuous improvement
Our Company will continuously review and improve its Personal Information protection management system, including this policy, in order to maintain the appropriate level of handling and protection of Personal Information in the light of requests from business partners and changes in social conditions.

9. Privacy Policy updates
We will review and improve the handling of your Personal Information as appropriate. In that case, all revisions will be notified on this webpage. Any changes to the Privacy Policy shall apply from the time our company posts them on this site.

10. Contact
If you have any questions about our privacy policy, please contact our officer at the following address:

support-vn@smiledesign.net