DentalPlanit®
PRIVACY POLICY

Effective Date: November 1, 2009
IMPORTANCE OF PRIVACY PROTECTION
DENTSPLY IMPLANTS, as the owner of DentalPlanit®, recognizes the importance of protecting your privacy
and our policy is designed to assist you in understanding how your personal information is collected, stored,
used, protected and safeguarded by DENTSPLY IMPLANTS.
CONSENTThe DentalPlanit® web site, accessible via www.dentalplanit.com (“DentalPlanit®”) is operated by DENTSPLY
Implants NV, Research Campus 10, 3500 Hasselt, Belgium (“DENTSPLY IMPLANTS”).
This Privacy Policy (“Privacy Policy”) is a contract between you (“the User”) and DENTSPLY IMPLANTS andapplies to your use of the DentalPlanit ® service and any related products and services available throughDentalPlanit® (collectively “the Service”).
If you provide services via the DentalPlanit ® platform (“Service Provider”), you must subscribe to the current
Privacy Policy. All provisions for Users under this Privacy Policy shall automatically apply to you as Service
Provider, in which case “User” must be understood as “Service Provider”.
If you do not agree to be bound by the terms and conditions of this Privacy Policy, please do not use or accessDentalPlanit®.
BY CLICKING THE "I HAVE READ AND ACCEPT" CHECKBOX AND COMPLETING THEREGISTRATION PROCESS, YOU ARE STATING THAT YOU ARE WHO YOU HAVE REPRESENTEDYOURSELF TO US AS, AND HAVE LEGAL CAPACITY TO ENTER INTO THESE TERMS, AND USE
THE SERVICES, AND THAT YOU AGREE TO BE BOUND BY ALL OF THESETERMS. ADDITIONALLY, BY CLICKING THE "I HAVE READ AND ACCEPT" CHECKBOX YOUAGREE TO EXECUTE ALL LEGALLY BINDING DOCUMENTS AND CONTRACTS WITH DENTSPLYIMPLANTS.
WARRANTS AND REPRESENTATIONS
Only Authorized Users are entitled to use DentalPlanit®. “Authorized Users” are defined as oral andmaxillofacial surgeons, dentists, periodontists, prosthodontists, orthodontists, endodontists, scan centers,
conversion service providers, dental laboratories, or authorized employees, contractors, representatives, or agents
thereof.
As an Authorized User you expressly warrant and represent that you are using DentalPlanit ® for authorizedpurposes only and in compliance with all applicable laws, including applicable privacy regulations, and subject
to all terms and conditions contained in this Privacy Policy and the DentalPlanit® User Agreement.
As an Authorized User, you may be qualified as a “Covered Entity” under certain privacy regulations, such as
HIPAA (Users from US), and therefore be obliged to close a Business Associate Agreement. If required byHIPAA legislation, you acknowledge and agree that you will not disseminate patient records of any kind to any
other User without a Business Associate Agreement or other such contractual arrangement or agreement.
COOKIESWhen you access DentalPlanit®, we may place small data files called "cookies" on your computer.
We send a "session cookie" to your computer when you log in to your account. This type of cookie helps us torecognize you if you visit multiple pages on DentalPlanit® during the same session, so that we don’t need to ask
you for your password on each page. Once you log out or close your browser, this cookie expires and no longer
has any effect.

We also use longer-lasting cookies for other purposes such as to automatically log in to your account.
We encode our cookies so that only we can interpret the information stored in them. You are free to decline ourcookies if your browser permits, but doing so may interfere with your use of DentalPlanit®.
PERSONALLY PROVIDED INFORMATION
During the DentalPlanit® registration process, you are obliged to give us very limited personal information. If
you choose to provide us with additional information about yourself through an email message, form, survey,etc., we will only maintain the information as long as needed to respond to your question or to fulfill the statedpurpose of the communication. Third party contractors may have access to this information in order to provide
an initial response to your question or comment.
On occasion, we may conduct a study with respect to DentalPlanit® and its related businesses. These studies help
us to improve DentalPlanit® in order to make DentalPlanit® services more responsive to your needs. We do not
give, share, sell, or transfer any personal information to a third party unless required by law or statute.
USE OF PERSONAL INFORMATION
We may use your personal information as follows:
Administration. We may use the personal information we collect about you during the registration process inorder to provide our products and services to you and to assist you in your use of our products. This may include
setting up your access to DentalPlanit®, providing assistance or training for your use of the Service, alerting you
to product changes or maintenance periods and invoicing you or your employer for your use of DentalPlanit®.
Marketing. We may use personal information we collect about you to contact you by e-mail, post or telephonewith information about DentalPlanit®, the products you use, DENTSPLY IMPLANTS products similar to thoseyou use and events that might be of interest to you or your organization. You may ask us to refrain from doing
this by sending an email to info@dentalplanit.com.
Product development and improvement. We may use the personal information we collect about you to ask you toparticipate in surveys to improve our products. In addition, we may use the information, combined in aggregate
form with the personal information we have collected about customers of our other products.
NOTIFICATION OF CHANGESAs new features are added to DentalPlanit® regularly, this Policy may be revised. DENTSPLY IMPLANTS
reserves the right, at its sole discretion, to change, modify, add, or delete portions of this Privacy Policy at any
time without further notice. If this Privacy Policy is changed significantly, you will be notified thereof by a popup at your next visit of DentalPlanit®. You will be requested to read the amended Privacy Policy carefully andagree there upon explicitly by clicking the “I have read and accept” checkbox. As an Authorized User, you willonly be granted full access to DentalPlanit® at the condition that you agree with the amended Privacy Policy. If
you oppose against the amended Privacy Policy, your access will be automatically limited to the treatment of theexisting cases and you will not be entitled to receive or to send new requests.
DentalPlanit® may include links to third party web sites. These sites are governed by their own privacy
statements, and DentalPlanit® is not responsible for their operations, including but not limited to theirinformation practices. Users submitting information to or through these third party web sites should review theprivacy statement of these sites before providing them with personally identifiable information.
PROTECTED HEALTH INFORMATION – HIPAA COMPLIANCE
Principle
DENTSPLY IMPLANTS states to have foreseen all features reasonably possible, to enable you to use
DentalPlanit® in compliance with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).
Nevertheless, HIPAA may require you to address internal policies, procedures and practices in ways that extend
beyond the scope of the DentalPlanit® products and services.

IT IS THE AUTHORIZED USER’S SOLE RESPONSIBILITY TO ACT FULLY IN ACCORDANCE WITH
ALL LAWS, SPECIFICALLY THE PRIVACY REGULATIONS, SUCH AS HIPAA UNDER US LAW.
You acknowledge that DENTSPLY IMPLANTS merely stores patient records that have been obtained withpatient’s consent in accordance with all applicable laws and that DENTSPLY IMPLANTS is acting only as acustodian of these records.
While DENTSPLY IMPLANTS continues to provide the Authorized Users with product upgrades andinformation that will assist in becoming compliant, DENTSPLY IMPLANTS encourages the Authorized Usersto gain knowledge of the applicable privacy regulations, such as HIPAA under US legislation.
The Health Insurance Portability and Accountability Act (HIPAA) was enacted in 1996 under US law, tosafeguard the privacy of patient health records. Following is a summary of HIPAA rules and regulations, asprovided fully on the United States of America Department of Health and Human Services (HHS) website:
Patient Protection
The new privacy regulations ensure a national floor of privacy protections for patients by limiting the ways that
health plans, pharmacies, hospitals and other covered entities can use patients' personal medical information. The
regulations protect medical records and other individually identifiable health information, whether it is on paper,in computers or communicated orally. Key provisions of these new standards include: Access To Medical Records. Patients generally should be able to see and obtain copies of their medical
records and request corrections if they identify errors and mistakes. Health plans, doctors, hospitals,clinics, nursing homes and other covered entities generally should provide access to these records
within 30 days and may charge patients for the cost of copying and sending the records.
 Notice of Privacy Practices. Covered health plans, doctors and other health care providers must provide
a notice to their patients how they may use personal medical information and their rights under the new
privacy regulation. Doctors, hospitals and other direct-care providers generally will provide the noticeon the patient's first visit following the April 14, 2003, compliance date and upon request. Patients
generally will be asked to sign, initial or otherwise acknowledge that they received this notice. Healthplans generally must mail the notice to their enrollees by April 14 and again if the notice changes
significantly. Patients also may ask covered entities to restrict the use or disclosure of their information
beyond the practices included in the notice, but the covered entities would not have to agree to thechanges.
 Limits on Use of Personal Medical Information. The privacy rule sets limits on how health plans andcovered providers may use individually identifiable health information. To promote the best quality
care for patients, the rule does not restrict the ability of doctors, nurses and other providers to share
information needed to treat their patients. In other situations, though, personal health information
generally may not be used for purposes not related to health care, and covered entities may use or share
only the minimum amount of protected information needed for a particular purpose. In addition,
patients would have to sign a specific authorization before a covered entity could release their medical
information to a life insurer, a bank, a marketing firm or another outside business for purposes not
related to their health care.
 Prohibition on Marketing. The final privacy rule sets new restrictions and limits on the use of patient
information for marketing purposes. Pharmacies, health plans and other covered entities must firstobtain an individual's specific authorization before disclosing their patient information for marketing.
At the same time, the rule permits doctors and other covered entities to communicate freely withpatients about treatment options and other health-related information, including disease-management
programs.
 Stronger State Laws. The new federal privacy standards do not affect state laws that provide additional
privacy protections for patients. The confidentiality protections are cumulative; the privacy rule will set
a national "floor" of privacy standards that protect all Americans, and any state law providing additional
protections would continue to apply. When a state law requires a certain disclosure -- such as reporting
an infectious disease outbreak to the public health authorities -- the federal privacy regulations would
not preempt the state law.
 Confidential communications. Under the privacy rule, patients can request that their doctors, healthplans and other covered entities take reasonable steps to ensure that their communications with thepatient are confidential. For example, a patient could ask a doctor to call his or her office rather thanhome, and the doctor's office should comply with that request if it can be reasonably accommodated.
 Complaints. Consumers may file a formal complaint regarding the privacy practices of a covered healthplan or provider. Such complaints can be made directly to the covered provider or health plan or toHHS' Office for Civil Rights (OCR), which is charged with investigating complaints and enforcing theprivacy regulation. Information about filing complaints should be included in each covered entity's
notice of privacy practices. Consumers can find out more information about filing a complaint at
http://www.hhs.gov/ocr/hipaa or by calling (866) 627-7748.

Health Plans and Providers
The privacy rule requires health plans, pharmacies, doctors and other covered entities to establish policies andprocedures to protect the confidentiality of protected health information about their patients. These requirements
are flexible and scalable to allow different covered entities to implement them as appropriate for their businessesor practices. Covered entities must provide all the protections for patients cited above, such as providing a noticeof their privacy practices and limiting the use and disclosure of information as required under the rule. Inaddition, covered entities must take some additional steps to protect patient privacy:
 Written Privacy Procedures. The rule requires covered entities to have written privacy procedures,
including a description of staff that has access to protected information, how it will be used and when it
may be disclosed. Covered entities generally must take steps to ensure that any business associates who
have access to protected information agree to the same limitations on the use and disclosure of that
information.
 Employee Training and Privacy Officer. Covered entities must train their employees in their privacy
procedures and must designate an individual to be responsible for ensuring the procedures are followed.
If covered entities learn an employee failed to follow these procedures, they must take appropriate
disciplinary action.
 Public Responsibilities. In limited circumstances, the final rule permits -- but does not require --covered
entities to continue certain existing disclosures of health information for specific public responsibilities.
These permitted disclosures include: emergency circumstances; identification of the body of a deceased
person, or the cause of death; public health needs; research that involves limited data or has been
independently approved by an Institutional Review Board or privacy board; oversight of the health caresystem; judicial and administrative proceedings; limited law enforcement activities; and activities
related to national defense and security. The privacy rule generally establishes new safeguards andlimits on these disclosures. Where no other law requires disclosures in these situations, covered entities
may continue to use their professional judgment to decide whether to make such disclosures based on
their own policies and ethical principles.
 Equivalent Requirements For Government. The provisions of the final rule generally apply equally toprivate sector and public sector covered entities. For example, private hospitals and government-run
hospitals covered by the rule have to comply with the full range of requirements.
Outreach and Enforcement
HHS' Office for Civil Rights (OCR) oversees and enforces the new federal privacy regulations. Led by OCR,HHS has issued extensive guidance and technical assistance materials to make it as easy as possible for covered
entities to comply with the new requirements. Key elements of OCR's outreach and enforcement efforts include: Guidance and technical assistance materials. HHS has issued extensive guidance and technical materials
to explain the privacy rule, including an extensive, searchable collection of frequently asked questions
that address major aspects of the rule. HHS will continue to expand and update these materials tofurther assist covered entities in complying.
 Conferences and seminars. HHS has participated in hundreds of conferences, trade association meetingsand conference calls to explain and clarify the provisions of the privacy regulation. These included aseries of regional conferences sponsored by HHS, as well as many held by professional associations andtrade groups. HHS will continue these outreach efforts to encourage compliance with the privacyrequirements.
 Information line. To help covered entities find out information about the privacy regulation and otheradministrative simplification provisions of the Health Insurance Portability and Accountability Act of
1996, OCR and HHS' Centers for Medicare & Medicaid Services have established a toll-free
information line. The number is (866) 627-7748.
 Complaint investigations. Enforcement will be primarily complaint-driven. OCR will investigate
complaints and work to make sure that consumers receive the privacy rights and protections required
under the new regulations. When appropriate, OCR can impose civil monetary penalties for violationsof the privacy rule provisions. Potential criminal violations of the law would be referred to the U.S.
Department of Justice for further investigation and appropriate action.

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Civil and Criminal Penalties. Congress provided civil and criminal penalties for covered entities thatmisuse personal health information. For civil violations of the standards, OCR may impose monetary
penalties up to $100 per violation, up to $25,000 per year, for each requirement or prohibition violated.
Criminal penalties apply for certain actions such as knowingly obtaining protected health information inviolation of the law. Criminal penalties can range up to $50,000 and one year in prison for certainoffenses; up to $100,000 and up to five years in prison if the offenses are committed under "falsepretenses"; and up to $250,000 and up to 10 years in prison if the offenses are committed with the intent
to sell, transfer or use protected health information for commercial advantage, personal gain ormalicious harm.

RIGHT TO OPPOSE – CONTACTInternet users may, free of charge and on request, always oppose the use of his/her personal details for direct
marketing purposes, by sending a notice to DENTSPLY IMPLANTS, in writing, to the address below.
Also if you have any other questions or concerns about your privacy rights, this privacy statement, the Terms ofUse of other aspect of accessing or using DentalPlanit® or its Services, please contact DENTSPLY IMPLANTS
NV, Research Campus 10, 3500 Hasselt, Belgium, info@dentalplanit.com.
© 2014 DENTSPLY IMPLANTS NV