We at DeCare Dental Insurance Ireland DAC, trading as DeCare Dental, respect your right to privacy and comply with our obligations under the General Data Protection Regulation (No. 2016/679) (“GDPR”) and the Data Protection Acts 1988 to 2018 (together “Data Protection Laws”). The purpose of this Privacy Statement is to outline how we process any personal data.
In this Privacy Statement “The Company”, “We”, “Us” and “Our” refers to DeCare Dental Insurance Ireland DAC. Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites. Personal data will be processed by or on behalf of DeCare Dental Insurance Ireland DAC, who is the ultimate data controller.
DeCare Dental Insurance Ireland DAC is a registered dental insurance underwriter and administrator and is a 100% owned subsidiary of DeCare Dental LLC. Our company registered offices are at DeCare Dental Insurance Ireland DAC, IDA Business Park, Claremorris, Co Mayo – company registration number 383762. DeCare Dental Insurance Ireland DAC, trading as DeCare Dental, is regulated by the Central Bank of Ireland.
If you have any queries regarding any matters relating to the processing of your personal data, please do not hesitate to contact us by posting your query to Data Protection Officer DeCare Dental Insurance Ireland DAC, IDA Business Park, Claremorris, Co Mayo, by calling: +353(0)94 93 78608 (Monday – Thursday 8:30am to 5pm, Fri 8:30am to 4pm) or by emailing: firstname.lastname@example.org / email@example.com
While you may make a complaint in respect of our compliance with Data Protection Laws to the Data Protection Commission, we ask that you contact us in the first instance to give us the opportunity to address your concerns.
2. Types of Information Collected
You don’t have to provide us with any personal information, but if you don’t provide certain information that we need then we may not be able to proceed with your application for one of our products or with a claim that you make. We will let you know what information is required to proceed with your application or claim. The information we collect may be categorised as follows:-
This is data that identifies you or can be used to identify or contact you and may include your title, name, address, email address, birth date, telephone number (mobile and/or landline), occupation, policy numbers, claims data, claims payment details including e.g. Debit Card or Credit Card details (“Personal Data”).
To prevent fraud and to ensure that any payments or refunds can be paid to you, we keep your bank details for the duration of your Policy. If you give us your credit card details then we will process payments using Secure Sockets Layer (SSL) security but we will not keep a record of your card details on our servers. In the event that you have opted to pay for your annual policy on a monthly basis, your card details will be stored by our payments provider (Global Payments / RealEx) in order to facilitate monthly deductions, you will not pay any surcharges on instalment payments, and the prices are the same whether your pay monthly or annually.
Special Category Data
Special Category Data means Personal Data relating to:
(a) racial or ethnic origin, political opinions or religious or philosophical beliefs;
(b) membership of a trade union;
(c) genetic data;
(d) biometric data for the purpose of uniquely identifying a natural person;;
(e) health; or
(f) a natural person’s sex life or sexual orientation.
Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of our website.
How do we collect your Personal Data?
Where possible, we will collect Personal Data directly from you. On occasion we may receive information about you from other people or sources. For example:
- It was given to use by someone applying for an insurance product on your behalf (e.g. your employer);
- From a dentist in respect of a claim or clinical information; and
- From experts or professionals during the claims process e.g. legal representatives, dental professionals etc.
3. Purposes for which we hold your Information
We use the Non-Personal Data gathered from visitors to our website in an aggregate form to get a better understanding of where our visitors come from and to help us better design and organise our website.
In order for us to provide our services to you we require certain Personal Data from you. This Personal Data is processed by us for the following purposes:
Purpose of Processing
Lawful Basis under GDPR
|Administration purposes such as processing applications and claims and providing quotes.||Such processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract, for the purpose of complying with our legal obligations, and where you have consented to providing certain Special Category Data in respect of an application or claim.|
|Identity verification purposes.||Such processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract and for the purpose of complying with our legal obligations.|
|Administering insurance contracts including making changes to contracts, responding to queries and processing a cancellation.||Processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract.|
|Enforcing and defending our rights.||We have a legitimate interest in ensuring that our products and services and our website are used in accordance with our terms and conditions of use and policies. This interest includes where necessary, for the purpose of establishing, exercising or defending a legal claim, a prospective legal claim, legal proceedings or prospective legal proceedings; and, where necessary, for the purpose of complying with our legal obligations.|
|Training, quality monitoring or evaluating the services we provide, including through seeking data subjects’ views.||Such processing is necessary for our legitimate interests. This interest is to improve our products, services and processes.|
|For direct marketing purposes.||Such processing is based on consent of data subjects.|
|To comply with laws and regulations.||This processing is necessary to comply with our legal obligations.|
|Website services, including for troubleshooting, data analysis, and survey purposes.||We have a legitimate interest in operating a website and for related purposes.|
|Statistical information that cannot be related back to individuals to help us improve the services we offer.||We have a legitimate interest in operating a website and for related purposes.|
You should also be aware that when you visit our websites, we collect certain information that does not identify you personally, but provides us with “usage data” such as the number of visitors we receive or what pages are visited most often. This data helps us to analyse and improve the usefulness of the information we provide at these websites.
Like most commercial website owners, we may use what is known as “cookie” technology. A “cookie” is an element of data that a website can send to your browser when you link to that website. It is not a computer program and has no ability to instruct it to perform any step or function. By assigning a unique data element to each visitor, the website is able to recognize repeat users, track usage patterns and better serve you when you return to that site. The cookie does not extract other personal information about you, such as your name or address.
5. Disclosure of Information to Third Parties
We may provide Non-Personal Data to third parties, where such information is combined with similar information of other users of our website. For example, we might inform third parties regarding the number of unique users who visit our website, the demographic breakdown of our community users of our website, or the activities that visitors to our website engage in while on our website. The third parties to whom we may provide this information may include potential or actual advertisers, providers of advertising services (including website tracking services), commercial partners, sponsors, licensees, researchers and other similar parties.
We may also share Personal Data:
- Including Special Category Data with your dentist for the purpose of processing your claim;
- With our bank for the purpose of processing the payment your claim;
- With other insurers to verify your cover;
- With trusted third parties for the purpose of distributing policy documentation and other communications and for the purpose of managing claims.;
- With our parent company and other group companies for the purposes of payment of your claim and efficient administration such as audit, system developments etc.; and
- Including Special Category Data with our legal advisers and appropriate authorities where necessary such as the Dental Council, An Garda Síochána and the Revenue Commissioners.
Personal Data (including Special Category Data) may be transferred to third parties outside of the EEA, including our parent company based in the USA, for administrative purposes. This is only done in accordance with Data Protection Laws such as in accordance with the standard contractual clauses adopted by the European Commission.
We will disclose your Personal Data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order or other statutory or legal requirement or to protect our rights or the rights of third parties.
6. Sale of Business
We may buy or sell assets which may involve the transfer of your information. We will transfer such information if we are acquired by or merged with another entity. You will be notified in the event of any such transfer.
Your Personal Data is held on secure servers hosted by DeCare Dental and Realex. Our internet service provider is Magnet and Airspeed. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we take all reasonable steps (including appropriate technical and organisational measures) to protect your Personal Data.
8. Data Subject Rights
Data Protection Laws provide certain rights in favour of data subjects (the “Data Subject Rights”). Data Subject Rights include the right of a data subject to:
● receive detailed information on the processing of Personal Data (as per transparency obligations on controllers) which we have provided through this Privacy Statement;
● access Personal Data;
● rectify or erase Personal Data (i.e. right to be forgotten);
● restrict processing;
● data portability;
● object to the processing of your Personal Data for marketing purposes or for any purpose where processing is necessary for the purposes of our legitimate interests;
● withdraw consent where we rely on consent for processing your Personal Data; and
● object to automated decision making (including profiling).
These Data Subject Rights will be exercisable by you in respect of Personal Data subject to limitations as provided for under Data Protection Laws. You may contact us or make a request to exercise any Data Subject Right by sending a written request to the Data Protection Officer, DeCare Dental Insurance Ireland, Ltd. IDA Business Park, Claremorris, Co Mayo, Ireland. Your request will be dealt with in accordance with Data Protection Laws.
9. Data retention
We will keep Personal Data only for as long as the retention of such Personal Data is deemed necessary for the purposes for which that Personal Data are processed (as described in this Privacy Statement) unless we are required to retain your Personal Data for a longer period (e.g. in the event of legal proceedings or investigations).
This Privacy Statement is kept under regular review and therefore is subject to change.
DeCare Dental Insurance Ireland DAC,
IDA Business Park
Last Edited on 13/07/2021