Our policies and procedures to protect your privacy are in place.
We, at the Dental Grants Program value you and take your personal privacy seriously. As such, we would like to inform you of our policies for collecting, using, securing, and disclosing your personal information. It is our intention to manage and handle information in a manner consistent with relevant privacy legislation to the extent required by law.
In this policy, here are some important terms you should know:
“Personal Information” or “Information” means information about an identifiable individual such as contact information, date of birth, age, information contained in a credit report, and financial information.
As part of the pre-qualification process, you also understand and agree to all of the following:
In this section, "you", "your", and "yours" mean the applicant. "We", "us", and "our" means the Dental Grants Program, its subsidiaries and parent companies.
"Dentist" means (the supplier of dental services to you) the dentist who receives any Information about you from us. "Information" means personal, financial, credit and other details about you that you provide to us and that we obtain from others outside the organization, including through the products and services you use.
"Third Party" means an individual or organization outside of us including those located in Canada or the United States of America.
“Permitted or required by law” or “legal and regulatory obligations” means actions that we are permitted or required to do under any laws or regulations, or any rules, codes, guidelines, expectations, or requirements of any applicable regulator.
Application for Credit
I/we understand that if I indicated that I wish to apply for Credit terms to pay monthly for the dental work not covered by the Grant, then the information submitted by me (the “Collected Information”) is being collected for the purpose of obtaining credit terms from Health Betterment Inc. (HBI) and is warranted to be true and complete.
HBI will use the Information you provide for the purpose of verifying your identity and to obtain your consumer credit bureau report as described below.
The Information that you provide will be compared against the Information contained in the consumer credit report we access to help confirm your identity. The consumer credit report will also be used to assess your application for potential credit terms that may allow you to make longer term payments for the part of your dental work that's not covered by your insurance or the grant. The credit check may affect your credit score.
Accordingly, if you have requested credit terms from us, you hereby authorize and consent to the collection of the Collected Information and to the making by HBI, its successors and assigns of whatever credit investigations and/or employment and income confirmations HBI or its successors and assigns may deem appropriate from time to time, and to the disclosure, sharing or exchange of the Collected Information and any report or information based thereon for these purposes with credit reporting agencies, and amongst HBI, its successors and assigns or any company with whom I/we have or propose to have a financial relationship.
Should you qualify for consideration of a loan from us, credit terms between 6 months and 5 years will be offered to you and HBI will confirm acceptance with your dentist. If you do not qualify for credit terms, we may invite you to provide a suitable co-signer to guarantee your loan.
Should the Information you provide not match the Information contained in your consumer credit report, you will not be able to complete the pre-qualification process for credit terms, however you will still be approved for the Grant and can complete the dental work you want done by providing the dentist with an upfront deposit and agreeing to a payment schedule that is acceptable to the dentist.
Agreement & Consent to Use of Personal Information
I/we accept this as written notice of HEALTH BETTERMENT INC (“HBI”) its affiliates, service providers and professional advisors (collectively HBI) receiving, disclosing, exchanging and using any Collected Information and any other personal information (collectively the “Personal Information”) about me/us for the purposes set out below. HBI, its affiliates and service providers may use any Information relating to me/us:
a) to establish, maintain and administer my/our account;
b) to determine my/our eligibility for credit terms offered by HBI including monitoring my/our purchase history as well as evaluating my/our credit standing;
c) to determine the suitability of benefits, services or enhancements; and/or which other product or service offers may be of interest to me/us;
d) to promote and market additional products, goods and services offered by HBI including by means of direct marketing; &
e) to comply with legal and regulatory requirements;
f) for any other purpose not prohibited by law.
I/we hereby also authorize any person who is contacted in this regard to provide such information.
I /we acknowledge that my/our consent to “Use of Personal Information” includes HBI providing the dentist who accepts the case work for which I/we are applying (the “dentist”) with HBI’S decision with respect to this application and if my/our application is accepted, my/our Account number and any other information which the dentist may reasonably require.
All information provided by me/us in connection with this application is true, accurate and complete in all respects.
I/we consent to the creation of a Personal Information file containing credit and other personal information. Only those employees of HBI whose job functions involve assessment of creditworthiness, credit applications, monitoring, processing of payments and matters relating to the purpose of the file, will have access to my/our file.
I/we understand I/we can tell you to stop using Personal Information about me/us in order to promote and market additional products, goods and services offered by HBI. I agree that my/our Social Insurance Number may be used as an aid to identify me/us with credit bureaus and others for credit history file matching and other administrative purposes.
I/we also consent to the retention of Personal Information about me/us for as long as is needed for the purposes described above, even after I/we cease to be a customer. In order to ensure the accuracy, completeness and integrity of the credit reporting system, I/we specifically consent to the continued disclosure of my/our Personal Information to credit bureaus even after the loan or credit facility has been retired.
What personal information do we collect?
The personal information we collect depends on the service you request and/or receive. We may collect personal information about you from the following sources:
Information we receive from you on applications or other forms, such as your name, address, phone number, email address and income.
Confirmation of employment.
Information we receive from other third parties, such as credit reporting agencies and other financial institutions, relating to your general eligibility for our or related services, such as those provided through third party companies.
Why do we collect your personal information?
We collect, use and disclose your personal information for the following reasons:
To communicate with or contact you (e.g., address, telephone number, email or other electronic address);
To verify your identity (e.g., date of birth, government-issued identification, occupation);
To meet legal and regulatory requirements;
To provide financial services to you or to recommend financing options, and to authorize and process your applications;
To detect and prevent fraud and help safeguard the financial interests of us, our financial partners and the dental practitioners that enroll in our program (e.g., reviewing and analyzing your transactions and other information to help us identify various types of threats and risks, such as credit, fraud and money laundering);
To develop, offer, and manage the products and services provided by our company in order to meet our clients’ needs (e.g., purchase and payment history, communication preferences and location);
To maintain adequate accounting, tax and business records;
Where applicable, to confirm details of your employment;
To assess the quality and quantity of our products and services (e.g., call monitoring, record and respond to client feedback);
To send you information on products and services that may be of interest to you.
Who sees or obtains your information?
We may provide your personal information to a third party in the following limited circumstances:
Where we have your consent (obtained prior to providing your personal information to a third party);
To consumer or credit reporting agencies to verify your current and ongoing creditworthiness, or to maintain your credit history;
To your financial institution to verify an account;
Where we are required or permitted, by law or our regulators, to do so;
To service providers (including affiliates acting in this capacity) that perform services on our behalf, such as pre-paid credit card financing, online loan underwriting, data hosting, data processing, information technology, marketing and analytics, call center, mailing, collections and billing;
In the unlikely event of a sale or lease of our business, in whole or in part, or a corporate re-organization; or
Where such third party assists us in serving you.
In such cases we will make disclosure to the extent that is necessary to accomplish the required purposes or discharge our regulatory, legal or public duty. We will endeavor to obtain from the third party receiving the information reasonable assurances that it will respect the privacy of personal information in accordance with applicable laws. As certain of our operations are conducted in Canada and the United States of America and certain of our service providers may have operations in Canada and the United States of America, your information may be sent to either country by secure electronic or other means. In the event that your information is sent outside of Canada or the United States of America, there is a remote possibility that it may be accessed by the courts, law enforcement and national security authorities of the jurisdiction where it is sent.
What are our safeguards for protecting your information?
Our security safeguards are designed and maintained to protect your personal information against loss or theft, as well as unauthorized access, use, copying, modification, disclosure or disposal. Our current methods of protection include:
Physical measures including restricted access to branches, alarm systems, and secure filing cabinets;
Technological measures for electronic transfers including our email and point of sale systems running on a VPN with a minimum of 128 bit encryption and a firewall, and our point of sale systems requiring several passwords including a sequel server;
Organizational security measures including security clearances, limiting access to a 'need to know' basis, staff training, and required confidentiality agreement; and
Investigative measures, should we have reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.
We protect personal information regardless of the format in which it is held.
Although we have various security measures in place, we cannot guarantee the absolute security of our website, or the security of information that you submit or that we send to you over the internet, since no internet transmission is ever fully/completely secure or error-free. Your use of the internet and electronic mail is at your own risk.
Should there be a breach relating to the personal information that you have provided to us, we will make an assessment as to whether the privacy breach creates a real risk of significant harm to you (includes financial loss, identity theft, negative effects on a credit record, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, or loss of property). Should we determine that the privacy breach does result in a real risk of significant harm to you, we will provide you with notification at the earliest opportunity. The notification will contain sufficient information to allow you to understand the significance of the breach and to take steps, if any are possible, to reduce the risk of harm that could result from it or to mitigate that harm. It shall also contain any other information required by law. We shall also report any breach of security safeguards to the Privacy Commissioner if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to you.
How long do we keep your information and how do we dispose of it?
The length of time we retain your information varies depending on the services you have requested and your relationship with us. We keep information for so long as it is reasonably required by us or legally necessary for us to retain such information. Your information is confidentially destroyed, deleted, erased or converted to an anonymous form when reasonably appropriate.
How do you gain access and verify your personal information?
We will provide you access to the personal information we have about you. If you require information, simply contact our Privacy Officer. We will respond to your request within thirty (30) days. Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to us, is too costly to retrieve, or cannot be disclosed for other legal reasons.
Having accurate information about you enables us to give you the best possible service. You can help by keeping us informed of any changes, for instance if you move or change telephone numbers. If you find any errors in our information about you, let us know and we will make the corrections promptly and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in our file. Requests can be made through our website or the Privacy Officer.
How are your choices handled?
Subject to legal or contractual restrictions and reasonable notice, you are free to refuse or withdraw your consent to the collection, use or disclosure of your personal information at any time. You may do so by contacting our Privacy Officer. However, once you are using our service you may not be able to withdraw your consent to our collection, use and disclosure of personal information as necessary to provide that service. You may also wish to limit the amount of personal information we collect, use or disclose about you. However, by doing so, we may not be able to provide our services or connected services to you. You may opt out of receiving marketing information via email, SMS, telephone or direct mail at any time.
Telephone calls made to us may be recorded for quality assurance and record keeping purposes. If you do not wish to have your telephone calls recorded, you have the option to conduct your business with us by writing us.
How is your privacy treated by our website?
In general, you may visit us on the web without telling us who you are or revealing any information about yourself.
We may, however, collect non-personally identifiable information from you when you visit our website or download or use or mobile app. For our website, this includes your domain name, the IP address of the web page from which you enter the site, the pages you visit on our site and the amount of time you spend there. This information is used to improve and customize the content and layout of our website or app.
From time to time we may utilize cookies or scripts on our website. You may disable these features, but by doing so, you may not be able to utilize the services we provide on our website.
We collect the e-mail addresses of those who communicate with us by e-mail and information volunteered by our visitors. The information we collect is used to improve our content and contact these visitors, if they have requested to be contacted.
How do you communicate with us?
Our Privacy Officer is your point of contact if you wish to raise any matters regarding our collection, use, storage or disclosure of your personal information. For information, questions or concerns on our privacy practices contact:
Privacy Officer: J. Zavitz
Our Privacy Officer has the decision-making authority to resolve most concerns.