Supplementary Wellspect Privacy Notice for Informed Consent

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This Wellspect Privacy Notice is a supplement to the information contained in the Dentsply Sirona Privacy Notice, and describes how Wellspect (collectively,  “Wellspect,” “we,” “our,” or “us”) collects, uses, discloses and otherwise processes the personal data of individual patients, in particular who have given their consent to:

1. Request a product sample, receive support, and/or order products, and/or;
2. Receive direct marketing communications, and/or;
3. Product development, and/or;

Data controller

The primary data controller of your personal data will be the applicable Wellspect business (part of Dentsply Sirona Group) with whom you have interacted, who will be responsible for processing your personal data for the purposes you have provided consent for. 
For a list of Wellspect companies and international locations, see here.

Personal data and data processing

Personal Data Collected Directly from You. We will process your personal data for the following purposes (where relevant):

Provide requested product sample and/or service

Direct marketing

Product and service improvement activities

Personal Data Collected from Third Parties. We may collect data about you from third-party sources such as healthcare providers, or other third parties, as follows:

• Orders and prescription information. To provide you with these services and/or products, we may process information about orders and related prescriptions for medical devices that we receive from national healthcare service providers, so that we can dispense the medical device to you as an end user of Wellspect products. In connection with product deliveries, we process personal data such as your name, personal contact information, age to determine reimbursement, and health information, including prescription information and details of the medical device ordered. In the UK, this may also include your NHS number, gender (information about male/female catheters) and prescription habits.

We do not conduct automated decision-making that produces legal or similarly significant effects for the processing of this personal data.

Recipients of your personal data

Wellspect affiliates and employees of Wellspect. Your personal data may be shared with our employees who need access to perform their work duties. We may disclose the personal data we collect to other Wellspect affiliates who will use and disclose this personal data in accordance with the Wellspect Privacy Notice and the Dentsply Sirona Privacy Notice. A list of Wellspect companies and their locations can be found here.

Vendors and service providers. We may disclose the collected personal data to our vendors and service providers who perform functions on our behalf or provide us with service, including:

• storing of and managing personal data for delivering prescribed and other products,
• storing of and managing personal data for keeping product development registers,
• storing of and managing personal data for direct marketing purposes,

Independent data controllers. We also share your personal data with certain entities which process your personal data as independent controllers. The fact that the entity is an independent controller means that we do not determine how the personal data disclosed to the company will be processed by such company. Recipients of your personal data as independent data controllers are:

• In case of Peer Support, your selected peer consultant.
• Distributors that Wellspect uses.

Third country transfers

In connection with the processing of your data, your personal data may be transferred to and processed in other jurisdictions where we, our affiliates and our service providers operate. As some of these jurisdictions may not provide levels of data protection equivalent to those in your home jurisdiction, we will, as required by applicable law, ensure that your privacy rights are adequately protected by organisational, technical, contractual and/or other lawful means. Additional information about these transfers can be found in the Dentsply Sirona Privacy Notice, available at https://dentsplysirona.com/privacy.

Security

We have implemented safeguards intended to protect the personal data we collect from loss, misuse, unauthorised access, disclosure, alteration and destruction. Additional information can be found in the Dentsply Sirona Privacy Notice, available at https://dentsplysirona.com/privacy.

Your rights in respect to your personal data.

You have several rights under your local privacy laws that allow you to exercise certain rights in relation to the personal data we hold about you, subject to certain conditions and exceptions. Additional information about these rights can be found in the Dentsply Sirona Privacy Notice, available at https://dentsplysirona.com/privacy.

Children’s data and individuals with limited legal capacity

We may provide these services and/or products to children under the age of 18 and to individuals who have limited legal capacity, and in such cases will, in line with applicable law, provide notice to and obtain consent on the child’s or individual’s behalf from a parent, legal guardian, or other authorised representative acting on behalf of these individuals.

Contact Us

Wellspect welcomes your questions and comments about your privacy or this Notice. Please contact us at privacy@dentsplysirona.com. Additional details about the Data Protection Officer can be found in the Dentsply Sirona Privacy Notice, available at https://dentsplysirona.com/privacy.