Colosseum Dental Group
Privacy Notice – Colosseum Dental Group Academy, website
Version 1.0/October 2020
In the context of our activities, we collect, hold, use and/or otherwise process personal data.
Based on applicable data protection and privacy law, we qualify as the “controller” with respect to the personal data that we process in that context.
Colosseumklinikken AS, hereinafter “Colosseum” or “us” and “we”, understands that your privacy is important and that you care about how your personal data is used. We respect and value your privacy and will only collect and use personal data in the manner and for the purposes as described in this document and in a way that is consistent with our obligations and your rights under the applicable legislation and regulations. By using our website (www.academy.colosseumdental.com, “CDG website” or “website”), applying for our Colosseum Academy, entering into a business relationship with Colosseum Dental Group Academy and by sharing your personal data with us, you acknowledge that your personal data will be processed in the manner described in this Privacy Notice.
2. Information about us
Colosseumklinikken AS is registered with the commercial register of Norway under company number 977.102.278
Registered address: Sørkedalsveien 10D, 0369 Oslo, Norway
For privacy protection matters please contact us by email: firstname.lastname@example.org or at our postal Address: Colosseum AG, Group Privacy Officer, Gutenbergstrasse 10, 8002 Zurich, Switzerland
This Privacy Notice covers our activities on Colosseum Dental Group Academy level. This Privacy Notice does not cover our activities with respect to (i) job applicants, (ii) the activities of our country organizations with respect to business development, or (iii) our clinics in connection with our patients. The relevant privacy notices on these topics can either be found at the “Governance” the section on our CDG website (www.colosseumdental.com) or on the local website of the respective Colosseum country organization.
3. What does this Privacy Notice cover and whose personal data do we process?
This Privacy Notice is intended to ensure compliance with European and Swiss privacy regulations and is relevant for anyone whose personal data we may process in the context of our (business) activities, including but not limited to:
- participants of our Colosseum Academy, who register on our CDG website (www.academy.colosseumdental.com).
- users of our CDG website.
- directors, authorized representatives, employees and/or (other) contact persons of our current and former contracting parties and/or business partners;
- directors, authorized representatives, employees and/or (other) contact persons of our current and former education providers, professional advisers, consultants and service providers for the Colosseum Dental Group Academy;
This Privacy Notice explains on what legal basis we may process your personal data and:
- what personal data we collect;
- for what purposes and how we may use/process such personal data;
- how we collect personal data;
- how we store the personal data;
- for what period we store the personal data; and
- what your rights are under the applicable data protection and privacy legislation.
In view hereof, we encourage you to carefully read this Privacy Notice. From time to time, we may need to update this Privacy Notice. This may be necessary, for example, if the law changes or if we change our business in a way that affects the way we process personal data. The most recent version of this Privacy Notice will always be available on our website www.academy.colosseumdental.com in the “Governance” section.
4. What personal data do we collect and how do we collect this personal data?
The personal data can be collected and imported through the data systems of Colosseum and/or its affiliates (Active Directory, HR systems, general user/employee directories and user/employee data storage systems). The data can also be collected from the users of the application during the registration process.
If we collect your personal data, we may collect information about you in various ways:
- when you provide us with your personal information by registering as a participant to the courses arranged by the Colosseum Dental Group Academy or entering your contact information to download educational content, webinars, course materials or other content provided on the CDG website (www.academy.colosseumdental.com) by means of a contact form or
- when a contact person provides his/her personal data by email or by means of a
- business card;• when you log in to the CDG website and participate by uploading any content or media (including pictures and videos), liking or commenting content available on the website
- when you acknowledge reading or viewing a post, article, or video by clicking the acknowledge button, where the editor of the article and administrators of the platform have access to this acknowledgement
- when you visit our website www.academy.colosseumdental.com and use the contact information provided on this website to get in touch with us; on our CDG website we only use session cookies to enhance the experience when you browse the website;
- when we enter into a business relationship and you provide us contact details;
- from other companies of the Colosseum group;
- from public sources such as the trade register or your website.
We may collect or process some or all of the following personal data:
- Contact details, including but not limited to addresses, telephone numbers and email addresses
- Business/company information
- Excerpts of registers (public or not, for example, excerpts from the commercial register)
- Payment information/bank account details
- Position/job title, workplace within Colosseum and its affiliates (department and location)
Log in data for the CDG website: email and password
Profile picture, voluntary
Educational Data as university titles and other educational certificates
Grades that are achieved or test results during the education courses
- The content you publish on the CDG website: news, posts, articles, static content, forms, surveys etc. – if comments are enabled for articles, these comments will be saved with a link to the concerning set of user data.
5. Purposes for processing
We will use the personal data described above for the following purposes:
- to identify you and to provide access to the CDG website,
- to supply services and educational material to you to personalize the content you see on the CDG website based on the organizational correlation and the educational level
- to request contribution of opinions and acknowledgement of completing educational steps
- to depict usernames as the author of content and comments
- to enter a contract with you and for the performance of these contracts
- to contact you/to communicate with you, for example via email correspondence and/
or telephone calls for the purposes of the CDG website and marketing purposes
- to send you our invoices and to collect debts
- to deal with possible disputes, to establish, defend and exercise our (legal) position
- for business continuity and to evaluate the use of the CDG website for example to determine the frequency of visits to certain parts or contents of the website, to report crashes and errors, to find out what information and services the users are interested in and to develop the content based on the interests
If you contact one of our local representatives listed on our website, please also check the website of our local affiliate for more information on how your personal data is processed.
If any kind of processing is based on your consent, we hereby inform you that you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
6. How long will we keep your personal data?
We will not store or keep your personal data for a longer period than is necessary for light of the purposes for which we process them (please refer to the purposes listed above in paragraph 5).
Your personal data is erased after your account is deleted or if you request the data to be removed from the website platform, except for your full name. Your name will only remain to be linked to articles published or comments and likes given by you in order to prevent ghost profiles on the website which counteracts the purpose of your engagement and communication. Possible exceptions to this may be media files published on the website containing personal data.
Data shared by you on a voluntary basis can be removed from the website by yourself. Non-group chats (chats with only two participants) will only be deleted when both participants are deleted. However, the data will be retained for 30 days in the recovery backups of the website.
Only where we are legally obliged to, or where this is necessary for defending our interests in the context of judicial proceedings, we will store the personal data for longer periods.
7. How do we protect your personal data?
We have implemented the necessary administrative, technical and organizational measures for ensuring a level of security appropriate to the specific risks that we have identified. We protect your personal data against destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed. Further, we seek to ensure that we keep your personal data accurate and up to date. However, you are responsible for this and we kindly request that you inform us of any changes to your personal data (such as a change in your contact details).
8. Do we transfer and/or share your personal data?
In the context of the purposes as listed above, we may share your personal data with third parties in the following situations:
- We may share your personal data with other group companies of the Colosseum group for the following purposes: for creating groups for communication or customize the content on the Academy website, for communicating educational goals completed, to distribute Academy materials to you, to add you to Academy distribution lists, for performing a contract that is to the benefit of the whole Colosseum group, for administrative purposes, for quality management. For an overview of the different locations where Colosseum is present, please visit http://www.colosseumdental.com/about-us/.
- In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of insurers or a government authority such as data protection authorities.
- We may engage third parties to process the personal data on our behalf (for example providers of certain IT applications that we use in the context of our activities or for assistance in our procurement activities). We will enter into the required contractual arrangements with those parties to ensure lawful and fair processing of your personal data on our behalf.
- We may also transfer personal data in the event of the sale or transfer of all or any part of Colosseum’s business. Where relevant, we will implement safeguards to ensure the protection of your personal data when disclosing your personal data to a third party. For example, we will enter into data processing agreements with relevant parties (providing for restrictions on the use of your personal data and obligations with respect to the protection and security of your personal data).
As a general rule, we do not share your personal data as set out above with other parties located in countries outside the EU and Switzerland. This may, however, be different in the event that we engage service providers in a country located outside the EU and Switzerland. In such a case, we will ensure that adequate measures are taken to ensure adequate protection of your personal data in accordance with applicable data protection legislation. Generally, we will enter into the Standard Contractual Clauses (as approved by the European Commission) with the recipient of your personal data. With respect to third parties located in the United States, we will enter into these Standard Contractual Clauses. You may contact our Group Privacy Officer (see below) if you wish to obtain a copy of the Standard Contractual Clauses entered into or insight in other adequate measures taken.
9. Can I access my personal data?
If you want to know what personal data we have of you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “data subject access request”. All such requests must be made in writing, contain verification of your identity and be sent to the email or postal addresses shown in paragraph 12 below. In principle, there is no charge for a subject access request. If your request is manifestly unfounded or excessive (for example, if you have already been provided with the requested information in the twelve months prior to the application and have no legitimate interest in the further provision of information), a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within 30 days after receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months after the date on which we received your request. In this case, you will, of course, be kept fully informed of our progress.
10. What are your other rights?
Under certain circumstances, you have the right to:
- receive additional information regarding the processing of your personal data;
- rectify your personal data;
- he erasure of your personal data;
- object to (part of) the processing of your personal data;
- the restriction of (part of) the processing of your personal data.
Finally, you also have the right to lodge a complaint with the competent local data protection authority. In Norway, the competent data protection authority is the Datatilsynet: Tollbugata 30152 Oslo. Tel +47 22 39 69 00
11. Automated decision making and profiling
We do not undertake any automated decision making or profiling.
On our CDG website www.academy.colosseumdental.com, we use certain cookies. Cookies are small pieces of data or text files that are stored on your computer or mobile device via your browser. These cookies can be used to make your website experience more efficient. You decide whether or not you give us your permission by using the cookie button that immediately appears on your screen when you visit our website. Our website uses so-called session cookies, which we use to ensure that you are recognized when you move from page to page within our website and that any information you have entered is remembered. We also use Google Analytics, a web analytics service provided by Google, Inc., which helps us to measure how users interact with the content of our website. All major internet browsers offer the option to manage the cookies that were installed on your computer or mobile device. In case you do not wish that this website places cookies on your computer, you may limit or delete these easily by adjusting your mobile or browser settings. In addition, you can set you mobile or browser settings in such a way that you get a notification every time you receive a cookie on your computer or mobile device, so that you can decide whether you wish to accept this cookie or not. Please note that when you disable certain cookies of which we are making use, the possibility exists that certain parts of our website will no longer function properly, and you will no longer enjoy an optimal user experience.
The content of this site is copyrighted and belongs to Colosseum, where the content is produced or modified by us. We may share links or materials or provide access to content from other sources. We are not responsible for content which we did not produce.
It is not permitted to modify, share, or convey the information or access information from this website outside the website or platform. The specific content, that can be shared outside the website, for example on your own social media channels, is separately marked as sharable. Instructions on the correct use of this website is described in the General Terms and Conditions of the Colosseum Dental Group Academy and the correct way of sharing content in your own social media in the CDG Social Media Policy for CDG employees.
14. Contact details
To contact us about anything related to your personal data and/or data protection, including exercising your data subject rights as discussed above in paragraphs 9 and 10, in particular your right to object, please use the contact details below:
For the attention of: Group Privacy Officer
Email address: email@example.com
Postal address: Colosseum AG, Gutenbergstrasse 10, 8002 Zurich