Privacy Policy

Sites and Services Covered by this Policy

This Privacy Policy applies to services provided and data collected through the following platforms:

-www.cuspdentalapp.com

-CUSP Dental Mobile Application

Any term that has not been defined in this Privacy Policy has the meaning given in the Terms of Use or any other agreement between you and I.

Information Collection and Use

While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. You may provide this information when you register, when you subscribe to any particular functions or services, when you sign up for the newsletter, when you place an order for product or services, when you provide feedback, and when you submit content, messages, documents, or other information through the Site.

Personally identifiable information includes the following information (“Personal Information”):

-your name

-email address

-phone number

-resume or biographical data

-social media information

-your physical address

-data and details related to any services or purchases you have made through the site

-technical data including Device IDs, login information, access dates/times, browser type and version, time zone setting, browser type, and location

Non-personal data derived from the types of data listed above may be aggregated for any purpose but will not disclose your identity. We do not collect any Special Categories of sensitive or personal data, such as your social security number, license numbers, etc. Please do not transmit this information through the Site, as we cannot guarantee the privacy of that information.

On occasion, we may ask for additional information to enable us to provide specific functions or services to you. This information will be used only to improve user experience on the Site, send out a periodic newsletter, or to respond to any communications we receive from you via the Site. We partner with third parties to provide services on the Site, specifically shipping and payment services. When the User engages with these services, the information necessary to provide those services will be given to the third party. These parties are not allowed to use the information except for the purpose of providing the engaged service and we are not responsible for the collection of this data. Additionally, where permitted or required by law, we will provide personally identifying information to third parties, without your consent, to comply with court orders, subpoenas, or other legal or regulatory requirements. We may also disclosure this information to third parties in connection with a corporate transaction such as a merger, acquisition, sale, or other transfer of all or a portion of our business or assets. In the event this policy changes you will be notified via updates posted on the Terms and Conditions/ Privacy Policy section of the website.

Where permitted by applicable law, we may use your Non-Personal Data for any purpose not prohibited by applicable law or inconsistent with this Privacy Policy or any written representation we have made to you at the point and time of the data collection.

We will only use your Personal Data to provide services directly to you (in our capacity as a data controller) and/or to provide services to you on behalf of our clients (in our capacity as a service provider/data processor), except as otherwise described in this Privacy Policy or with your consent. We may use your personal data for the following purposes:

-Improving or analyzing user experience

-Performing a contract to which you are a party, or following your requests to enter into a contract

-Complying with legal or regulatory obligations, as provided above

-Any purpose for which you have directly consented to use of such data

Log Data

Like many site operators, we collect information that your browser sends whenever you visit our Site (”Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, and other similar statistics. We use this information to analyze aggregate usage trends, administer the Site, track movement, and gather aggregate demographic information. In addition, we may use third party services such as Jetpack or Google Analytics that collect, monitor, and analyze the Log Data.

Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. For more information on how to make this election, refer to the help page on your browser site. However, if you do not accept cookies, you may not be able to use some portions of our Site.

Do Not Track

Our Site does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, Safari allows you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.

Methods of Data Collection

We collect the data discussed in this Privacy Policy through various methods, including:

-Information provided by you to use when you fill out a form, apply for a position, post a job, or sign up through our Sites

-Information provided by you when you communicate with us through the Sites

-Information automatically collected, including technical and usage data, while you interact with our Sites

– Information automatically collected, including technical and usage data, provided by Third Parties

-Information provided by a client that has hired us to provide services on their behalf

Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security against viruses, hackers, etc. Additionally, all payment information is currently processed through a third party payment service. We do not maintain any financial or payment information on our servers and are not responsible for the use, disclosure, or misuse of any such information.

We allow users to share information in certain functions or sections of the Site. Any personally identifiable information you post or submit through these functions can be read, collected, and used by other users. We are not responsible for any information, or use of the information, that you voluntarily submit in these functions or sections, and these uses are not covered by the terms of this Privacy Policy.

Opt Out and Changes to Information

If you wish for your information to be removed from our records, you may opt out by contacting us at Info@cuspdentalapp.com. Please note that removal may take time to process, and will be reflected in our records as soon as possible. You may also request to review or make changes to the personally identifiable information as collected directly from our Site, please contact us as Info@cuspdentalapp.com to do so.

In the event you opt out, we reserve the right to contact you as necessary in order to facilitate or close out any product, service, or function that you have purchased from us. Additionally, you are responsible for providing correct information. If you need to update, or otherwise correct, information provided you can do so by contacting the email address provided above.

Changes to this Privacy Policy

This Privacy Policy is effective as of July 10^th, 2020 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Site after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

California and Nevada Residents

If you are a Nevada resident you may request that we not sell your Personal Information to any third party that may license or sell it to another third party as defined under Nevada Law. You may make such a request by contacting the email address provided below. If you are a California resident please see the additional policy entitled California Privacy Policy for more information.

Contact Us

If you have any questions regarding our Privacy Policy, or would like to contact us for any reason regarding this Privacy Policy or our privacy practices, please email us at Info@cuspdentalapp.com.

California Privacy Notice

Effective Date: July 10, 2020
Last Updated: July201, 2020

Your privacy is important to us and maintaining your trust is our priority. The Cusp Group, LLC (“us”, “we”, “our”) operates https://www.cuspdentalapp.com, and CUSP Dental App mobile application (referred to as the “Site” and the “Sites”). We respect your privacy and are committed to protecting it through our compliance with this California Privacy Notice (“Privacy Notice“).

This Privacy Notice supplements the information contained in our standard Privacy Policy and Terms of Use and applies solely to visitors, users, and others who reside in the State of California (”consumers” or “you”) and use our Services. We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice. Capitalized terms used but not otherwise defined herein or in the CCPA shall have the meanings given to such terms in the Global Privacy Policy.

Information We Collect

A. Personal Information

Our Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, CUSP Dental’s Services have collected the following categories of personal information from its consumers within the last twelve (12) months:

-your name

-email address

-phone number

-resume or biographical data

-social media information

-your physical address

-data and details related to any services or purchases you have made through the site

-technical data including Device IDs, login information, access dates/times, browser type and version, time zone setting, browser type, and location

CUSP Dental has not collected any of the following categories of personal information from consumers within the last twelve (12) months:

-Biometric information (such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data)

-Sensory data (such as audio, electronic, visual, thermal, olfactory, or similar information)

-Non-public education information, per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) (such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

B. Non-Personal Information

CUSP Dental collects, uses and shares de-identified and/or aggregated consumer information, which is not considered personal information. Our policies on the collection of this data can be found in our Privacy Policy. Deidentified or aggregated data may be derived from your personal information, but is not considered personal information under CCPA, since it does not directly or indirectly reveal your identity.

C. Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

-Information provided by you to use when you fill out a form, apply for a position, post a job, or sign up through our Sites

-Information provided by you when you communicate with us through the Sites

-Information automatically collected, including technical and usage data, while you interact with our Sites

– Information automatically collected, including technical and usage data, provided by Third Parties

-Information provided by a client that has hired us to provide services on their behalf

2. USE OF PERSONAL INFORMATION

We describe in detail in our standard Privacy Policy the context in which your personal information may be collected, along with how and why we use your personal information. Pursuant to the CCPA, we may use the personal information we collect for one or more of the following business or commercial purposes:

-To fulfill or meet the reason for which the personal information is provided.

-To create, maintain, manage, customize, and/or secure your account with us.

-To communicate with you about your account or our Services, and to manage our relationship with you.

-To provide you with support and to respond to your inquiries, including investigating and address your concerns and monitor and improve our responses.

-To send you email job alerts, if you registered to receive job alerts.

-To send you marketing communications.

-To send you newsletters where you have indicated an interest or shown an interest based on your preferences as shown by your activity on the Website and/or your profile.

-To maintain certain of your information on a suppression list, if you’ve indicated to us that you don’t want to be communicated in a particular way.

-To manage any surveys, promotions or competitions you entered.

-To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email (with your consent, where required by law).

-To enable our Website to function properly (ensure proper display of content), create and remember your account login details, and for interface personalization, such as language, or any user-interface customization.

-To provide, support, personalize, and develop our Services.

-To process your requests, purchases, transactions, and payments, and prevent transactional fraud.

-To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing or collections, or manage payment disputes or issues with the services.

-To help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business.

-To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.

-For testing, research, analysis, and product development, including to collect statistics and develop and improve our Website or Services.

-For debugging to identify and repair errors that impair existing intended functionality of our Website or Services.

-To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

-As described to you when collecting your personal information or as otherwise set forth in the CCPA.

-In connection with or during negotiations of any proposed or actual financing, merger, purchase, sale, sale or transfer of some or all of our assets or stock, joint venture, or any other type of financing, acquisition or business combination of our company, or all or any portion of our assets, or transfer of all or a portion of our business to another company, including without limitation in the event of a divestiture, restructuring, reorganization, dissolution or other event, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by CUSP Dental is among the assets transferred.

CUSP Dental will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

3. SHARING PERSONAL INFORMATION

A. Disclosures of Personal Information at Your Direction

We disclose your personal information when you intentionally interact with third parties and when you direct us or intentionally use CUSP Dental to share your personal information in connection with the services that we provide to you.

Pursuant to the CCPA, in the preceding twelve (12) months, we may have disclosed the following categories of personal information at your direction, depending on the information that you include in your CUSP Dental profile, resume, and/or job application materials:

Category A: Identifiers
Category B: California Customer Records personal information categories
Category C: Protected classification characteristics under California or federal law
Category F: Geolocation data
Category G: Professional or employment-related information

B. Disclosures of Personal Information for a Business Purpose

We describe in detail in our Privacy Policy the context in which your personal information may be disclosed to or shared with a third party. Pursuant to the CCPA, CUSP Dental has disclosed personal information to the following categories of third parties for a business purpose in the preceding twelve (12) months:

Category E: Internet or other similar network activity

Category F: Geolocation data

Category G: Professional or employment-related information

Category H: Inferences drawn from other personal information to create a profile

In addition, CUSP Dental may disclose any or all of the personal information identified in the categories above to the following categories of third parties for a business purpose, depending on how you interact with our Services and/or where CUSP Dental has an obligation to make such disclosure:

-Third party partners that are integrated into our services, where you interact with such partners directly

-Government entities, where required by law or in order to comply with our legal or regulatory obligations

-Other third parties, where required by law or in order to protect our rights, or the rights of our customers or others

-Third parties, in connection with a merger, sale, or asset transfer.

-Third parties, where you have expressly consented to the disclosure your Personal Information

C. Sale of Personal Information

Your privacy is our priority, and we do not monetize your personal information by selling it to third parties.

After you visit our Website and/or use our Services, you may receive advertisements about CUSP Dental’s services when you visit other websites (i.e., social media sites, search engines or other websites that are unrelated to CUSP Dental). This happens because we use third-party vendors to provide you with information about our services based upon your interactions with our website. These third-party vendors may work with additional providers in their relationship network that help provide the advertising services the third-party vendors provide to us.

Our third-party vendors and, if applicable, providers in their relationship network, may use the information they collect for purposes that are unrelated to showing you ads about our services. When this information is used for a purpose other than showing ads about our services or other services we have requested, it may constitute a “sale” of personal information under the CCPA.

Pursuant to the CCPA, in the preceding twelve (12) months, we have sold the following categories of personal information for the purpose of showing you ads about CUSP Dental services:

Category A: Identifiers
Category E: Internet or other similar network activity
Category F: Geolocation data

4. YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how you can exercise them. These rights are not absolute and certain exceptions apply under the CCPA, such as when you provide personal information in your capacity an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency in the context of CUSP Dental providing a service to that company, partnership, sole proprietorship, non-profit, or government agency.

A. Access to Specific Information and Data Portability Requests

If you are a California resident, and the CCPA does not recognize an exception that applies to you or your personal information, you may request that CUSP Dental disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request we will disclose to you:

-Any categories of personal information we collected about you.

-Any categories of sources for the personal information we collected about you.

-Our business or commercial purpose for collecting or selling that personal information.

-Any categories of third parties with whom we share that personal information.

-Any specific pieces of personal information we collected about you (also called a data portability request).

-If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (i) sales, identifying the personal information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

B. Deletion Requests

If you are a California resident, and the CCPA does not recognize an exception that applies to you or your personal information, you may request that CUSP Dental delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request (in whole or in part) in accordance with any purpose that is permitted by the CCPA.

C. Exercising Access, Data Portability, and Deletion Requests

Making a Verifiable Consumer Request: To exercise an access, data portability, or deletion request as described above, you can submit a verifiable consumer request to us in one of the following ways:

Delete Your Account: If you would like to delete your job seeker account (including the personal information associated with your account), you may log in to your password-protected account on the website and process the deletion through your account.
Download Your Data: If you are a job seeker and would like to access your personal information or obtain a copy of your personal information in a portable manner, you may email us at Info@cuspdentalapp.com
Send Us an Email with your Request: You may send an email to Info@cuspdentalapp.com. To submit a verifiable consumer request via email, you must email us from the email address that is associated with your CUSP Dental job seeker account. If you are requesting access to categories and/or specific pieces of your personal information, you will be asked to provide identifying information that enables us to verify you with information in our system. Once you submit your verifiable consumer request, we will verify your identity by matching the information you provided us with information in our systems.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Using an Authorized Agent: If you use an authorized agent to submit a request to access, delete, or opt-out on your behalf, the authorized agent must: (1) be a person or business entity registered with the California Secretary of State to conduct business in California; (2) provide proof of such registration; and (3) provide documentation or other proof indicating that they are authorized to act on your behalf. For requests to access or delete, we may require you to verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request.

Limitations on CCPA Requests: You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

D. Response Timing and Format

We endeavor to respond to a verifiable consumer request within ninety (90) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, for example, through an Excel or JSON file format.

A fee may be incurred for any such requests.

E. Opting Out from the Sale of Personal Information

For more information, or to submit an opt-out request, you (or your authorized representative) may email your request to Info@cuspdentalapp.com. We will only use personal information provided in an opt-out request to review and comply with the request.

5. NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

-Deny you goods or services.

-Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

-Provide you a different level or quality of goods or services.

-Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

6. CUSP DENTAL AS A SERVICE PROVIDER

In certain instances, our clients hire CUSP Dental to provide services on behalf of the client. In such case, we process personal information under the direction of that client as a service provider, and we have no direct relationship with the individuals (consumers) whose personal information we process.

Where CUSP Dental acts as a service provider, it will collect, retain, use, disclose, and/or otherwise process personal information (i) to fulfill CUSP Dental’s obligations to perform the services pursuant to a written agreement with that client; (ii) pursuant to a valid business purpose, as permitted under the CCPA; and/or (iii) as otherwise directed by the client in writing. Where CUSP Dental processes personal data in the capacity of a service provider, CUSP Dental does not sell that personal information or otherwise retain, use, or disclose personal information for any commercial purpose, except as otherwise directed by the client in writing.

In addition to the purposes set forth above, CUSP Dental may collect, retain, use, disclose, and otherwise process personal information in the context of a service provider:

-To retain and employ another service provider as a subcontractor, where the subcontractor meets the requirements for a service provider under the CCPA;

-For internal only use, to build or improve the quality of our services (as permitted by the CCPA);

-To detect data security incidents, or protect against fraudulent or illegal activity;

-To comply with applicable laws;

-To comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;

-To cooperate with law enforcement agencies concerning conduct or activity that a client, CUSP Dental, or third party reasonably and in good faith believes may violate federal, state, or local law;

-To exercise or defend legal claims; and/or

-To collect, use, retain, share, or disclose information that has been aggregated or de-identified, in accordance with the CCPA.

Where CUSP Dental processes your personal data in the capacity of a service provider, and you seek access, or want to correct, amend, or delete your personal data, or have another request, we will provide you with the client’s contact information, so you can contact them directly.

7. CHANGES TO THIS CALIFORNIA PRIVACY NOTICE

This California Privacy Notice is effective as of July 10^th, 2020 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change this policy at any time and you should check this California Privacy Notice periodically. Your continued use of the Site after we post any modifications to this policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified California Privacy Notice.

8. CONTACT INFORMATION

If you have any questions regarding our Privacy Policy, or would like to contact us for any reason regarding this Privacy Policy or our privacy practices, please email us at Info@cuspdentalapp.com