Colorado Consumer Privacy Policy










CPA Privacy Policy for Colorado Residents Last Updated and Effective On: December 20, 2023


This CPA Privacy Policy for Colorado Residents (“CPA Privacy Policy” or "Policy") supplements the information contained in Pacific Dental Services’ (“PDS,” “we,” “us,” or “our”) online privacy notice and applies solely to consumers who are residents of the State of Colorado (“consumers” or “you”).


We adopt this notice to comply with the Colorado Privacy Act of 2023 (“CPA”). The CPA imposes specific obligations on businesses processing personal data of Colorado residents. Terms used in this CPA Privacy Policy, such as personal data, consumers, third party(ies) and service providers, have the same meaning as they are defined in the CPA. Pursuant to the CPA, Pacific Dental Services is required to provide consumers a notice, used at or before the point of collection of personal data, that identifies the categories of personal data that may be collected, indicates the purpose of such collection, and provides the consumers rights related to such data.


Notice at Collection

At or before the time of collection, you have a right to receive notices of our practices, including the categories of personal and sensitive personal data to be collected, the purposes for which such information is collected or used, whether such information is sold or shared and how long such information is retained. You can find those details below.


What Is Personal Data?

The CPA provides personal data rights to Colorado residents. The CPA defines personal data as information that “is linked or reasonably linkable to an identified or identifiable individual.” Personal data does not include “de-identified data or publicly available information.


Categories of Personal Data We Collect About You

We collect or generate personal information about you in a number of ways depending on the product or service and the relationship we have with you.  For example:

  • Your contact information, such as your email, home address, ZIP code, and phone number. Such items are collected when you sign up for our contests or promotions.
  • Your public information, such as comments or reviews that you post on our site. We also collect requests or questions that you publicly post.
  • Your demographic information, such as your postcode, preferences and interests.
  • Other information, such as your location, your IP address, the browser/device/hardware you are using, your GPS location and what pages you visit on our site. Such items are collected when you visit our digital ads.
  • When you communicate with us through the sites, over the phone, via social media or other platforms, we collect the content of the communications, information about the channel in which you contacted us and we may also collect personal information about you indirectly through monitoring or other means, such as recording telephone calls and collecting phone metadata and digital information.
  • When you interact with the sites or our advertisements, we collect digital information using cookies, web beacons, page tags, pixels or similar tools that we and our service providers and other third parties have set.
  • When you interact with the sites via a social media platform, we collect a copy of the posts and other information, such as account ID or username.

We require this information to understand your needs and provide you with a list of dental offices for relevant referrals. Once you have selected a new dentist, we will share your information with your dentist.


For more information, see below for a list of the categories of personal information, along with some descriptions and examples that we may collect through each of the processes described above:

  • Personal Identifiers: This includes first and last name, previous name, address, telephone number, unique personal identifier, and signature.
  • Device and Online Identifiers and Related Information: This includes online identifiers, Internet Protocol (IP) address, email address, account user name, mobile/ wireless number, social media profile, unique device identifier and serial number, and other device information.
  • Demographic Information: This includes date of birth and household income data.
  • Internet, Application, and Network Activity: This includes text messages or emails sent to us, clickstream/online website tracking information, and data related to user activity (e.g., browser visits and cookies or other similar technologies).
  • Location Data: We may receive information about your location and your mobile device, including a unique identifier for your device; in addition, in some instances, location information can be derived from your IP address or through your wi-fi connection.
  • Sensory Data: This includes audio data, such as a recording of your voice when you call our contact center. Although you don’t have to supply any of the personal information we request, we may not be able to provide products or services to you or you may not be able to interact with our sites if you do not.


The Purposes for Which Your Personal Data is Collected or Used

We use your personal data for the following business purposes:

  • To keep an internal record for our reporting and analysis purposes.
  • To provide you with relevant content, materials, offers, programs and to administer your participation in our contests or sweepstakes.
  • To respond to your requests or questions that you may provide via our social sites.
  • To improve our sites, products, services and other marketing purposes.
  • To protect our company, other patients and our assets and sites and for other security measures.
  • To remain in communication with you with any products or services you requested.
  • From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or mail.
  • We may provide your information to our third-party service providers for marketing or promotional purposes.
  • To target ads to you based on your past online activity.
  • Customer information retention is indefinite and is shared with select third-party service providers and supported dentists.
  • Supporting our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.
  • Complying with contractual obligations, relevant industry standards, and our policies.
  • Notifying you about changes to the sites, products and policies.
  • Performing analytics concerning your use of the products and sites, including your responses to our emails and the pages and advertisements you view.
  • Mitigating fraud and enhancing the security of the sites and our online services.
  • Managing institutional risk.
  • Operating, evaluating and improving our business (including developing new products and services; improving existing products and services; and performing accounting, auditing and other internal functions).
  • Authenticating your identity, including when scheduling appointments and financial application processes through the sites as well as afterwards.
  • Quality control and training purposes.

Any information collected is disclosed to you here and is used as permitted or required by law. We also abide by the set of rules prescribed to use by Google AdWords:


We may also use your personal data for any other purpose that we disclose at the time you provide, or when we collect, your information and other purposes permitted by applicable law. We may also use data that we collect on an aggregate or anonymous basis for various business purposes, where permissible under applicable laws and regulations.


We are required to identify the categories of personal data we share with third parties for operational purposes. We disclose the following categories of personal data for operational purposes: personal identifiers; device and online identifiers and related information; demographic information; internet, application, and network activity; location data; sensory (audio data)


The Sources of The Personal Data We Collect About You

  • When you sign up for things automatically like a contest or a promotion or when you register to any of our sites.
  • Through tracking tools, such as cookies, tags and other technologies.
  • Our partners, such as Smile Generation Financial, My Smile Dental Plan™, and our trusted dental offices will provide us with information that you voluntarily give them. We may also use information associated with your social media account, e.g., your name, username, email address, gender, profile picture, etc. We may also collect information about your friends or family if you share any of our social content using web tools.
  • Any information that you provide to a third party with whom we have a contractual relationship, e.g., social media, digital display media (banner ads), and any other advertising partners.

Sharing of Your Personal Data

We share personal data as set forth below:

  • Our third-party service providers, including Google, show our ads on sites across the internet.
  • Please be aware that third-parties may use cookies, web beacons, and similar technologies to collect or receive information from our website and use that information to provide measurement services and target ads.
  • Additionally, please be aware that Facebook may also use cookies, web beacons, and similar technologies to collect or receive information from our website and use that information to provide measurement services and target ads.

Selling of Your Personal Data

Colorado law requires that we describe certain disclosures of personal data where we receive valuable consideration. Colorado law treats such disclosures as “sales” even if no money is exchanged.

To the extent that PDS “sells” your personal data (as the term “sell” is defined by the CPA), you have the right to opt-out of that “sale” going forward. See the section titled “Do Not Sell or Share My Personal Information” below for more information.


Amount of Time Your Personal Data is Retained

We retain personal data for various periods depending on the nature of the personal information, the purposes for its collection and use, and based on our legal and ethical obligations. Generally, we retain personal data only for so long as necessary to fulfill the purposes for which we collected it. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of your personal data; the purposes for which we process your personal data and whether we can achieve those purposes through other means; and the applicable legal requirements.


Rights to Your Personal Data

You have a number of legal rights when it comes to your Personal Data under the CPA. Without being discriminated against for exercising these rights, you have the right to request that we disclose what personal data we collect from you, the purposes for which we disclose your personal data, the right to request that we delete that information, the right to correct inaccurate personal information and to opt-out of the sale or sharing of your personal data, subject to certain restrictions.


Right to Know

You have the right to request that we disclose what categories of personal data we collect, use, or sell and the purposes for which the personal data is disclosed. You may request access to the specific pieces of personal data that we have collected from you. (“Right to Know”)


Right to Delete

You have the right to request that we delete your personal data, subject to certain limited exceptions. For example, we may retain an archived copy of your records consistent with applicable law. (“Right to Delete”)


Right to Correct

You have the right to request that we correct inaccurate personal data that we collect about you, considering the nature of the personal data and the purposes of the processing of the personal data. (“Right to Correct”)

To exercise any of the privacy rights detailed above submit a CPA request form or call 888-508-2033.


Right to Opt-Out of the Selling or Sharing of Your Personal Data

You have the right to opt-out of the “sale” or “sharing” of your personal data with third parties who are not our service providers (as those terms are defined under the CPA). To exercise this right, click the “Do Not Sell/Share My Information” link on the bottom of the webpage where your information is being collected.


Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to request that we limit our use and disclosure of your “sensitive data,” (as that term is defined under the CPA) to certain permissible purposes. However, we process sensitive data only as permitted by the CPA, and we don’t use sensitive data to infer characteristics about you. Accordingly, we do not offer an option to limit further processing of Sensitive Data.


How Will You Verify My Identity If I Make a CPA Request?

In order to verify your identity, we will collect your:

  • Name
  • Date of Birth
  • Email
  • Telephone Number
  • Address

We will use this information to verify your identity using reasonable methods in order to process your rights request. These methods may include matching information you provided to us with information already maintained by us or through the use of a third party identity verification service.

We cannot respond to your request or provide you with personal data if we are not able to verify your identity or authority to make the request or confirm the personal data relates to you.

You are not required to have an account with us to make a verifiable request.


Contact, Questions or Complaints

We take your privacy seriously and invite you to contact us at the email address below also with any further questions or concerns you may have regarding your privacy or our collection, storage and use of your personal data: