PRIVACY POLICY

This is the Privacy Policy of the QAdental service, jointly provided by Suomen Kotilääkäripalvelu Oy and Edocare Oy, concerning the processing of your personal data.

Suomen Kotilääkäripalvelu Oy is committed to protecting the privacy of patients in accordance with the EU General Data Protection Regulation (EU) 2016/679 (GDPR), the Finnish Data Protection Act (1050/2018), the Finnish Patient Act (1992/785), the Finnish Act on the Electronic Processing of Client Data in Healthcare and Social Welfare (2007/159), and other applicable legislation.

Suomen Kotilääkäripalvelu Oy is committed to protecting the privacy of patients in accordance with the EU General Data Protection Regulation (EU) 2016/679 (GDPR), the Finnish Data Protection Act (1050/2018), the Finnish Act on the Status and Rights of Patients (785/1992), the Finnish Act on the Electronic Processing of Client Data in Healthcare and Social Welfare (159/2007), and other applicable legislation.

Please read this Privacy Policy carefully. By using our website and services, you agree to the processing of your personal data as described herein.

We continuously develop our services and reserve the right to amend this Privacy Policy by notifying users through our services. Changes may also be required due to legislative updates.

1. DATA CONTROLLER

Suomen Kotilääkäripalvelu Oy (Business ID 1911124-5)
Address: Ruoholahdenkatu 8, 00180 Helsinki, Finland
Phone: +358 40 556 3011
Email: info@terveydenhuolto.com

Technical Processor of the Register
Edocare Oy (Business ID 2366074-9)
Address: Ruoholahdenkatu 8, 00180 Helsinki, Finland
Phone: +358 40 556 3011

Contact Person
Jani Korpela
Phone: +358 40 556 3011
Email: support@qadental.com

Data Protection Officer
Jani Korpela
Phone: +358 40 556 3011
Email: support@qadental.com

2. PURPOSE OF PROCESSING PERSONAL DATA

We collect, store, and process your personal data only for predefined and legitimate purposes.

The main purposes for processing personal data are:

Identification of users
Management of access rights
Maintenance, development, and monitoring of the Service
Transmission of messages between users
Allocation of payments for paid services to the correct payer
Storage and processing of dental and X-ray images and videos for the purpose of carrying out consultations and improving their quality

3. LEGAL BASIS FOR COLLECTING AND PROCESSING PERSONAL DATA

The processing of personal data is based on your explicit consent to the processing of your data within the Service.

The processing of patient images is necessary for consultation activities carried out by healthcare professionals. Images are added to the Service only when the patient has provided consent in accordance with Section 13 of the Finnish Patient Act. Such consent must be documented in the patient record. The QAdental Terms of Use require that consent be verifiably obtained (for example, in the presence of other healthcare staff).

The processing of patient information (for example, messages or patient images) through the Service is based on the healthcare professional’s performance of their professional duties. In these cases, the user is responsible for ensuring that the patient’s consent for processing has been obtained in accordance with the Finnish Patient Act.

4. REGULAR SOURCES OF INFORMATION

We primarily collect your personal data directly from you when you register or at a later time. The data are collected and processed based on your given consent.

Information provided at the time of registration may be combined with data obtained, for example, from the Julkiterhikki public register to verify professional credentials. QAdental may require verification via an organizational email address before granting additional rights provided by the organization to a user.

5. PERSONAL DATA WE COLLECT FROM YOU

User identification and contact details:

Name, postal address, phone number, email address, username, password, and nickname/display name (visible to others, for example, in discussions, comments, or consultations), year of birth

Information about the user’s education and work:

Education or professional title, educational institution, year of graduation, country of employment

Other information you may provide:

Other optional personal information (such as interests and profile picture)

Information about the organization paying for the Service:

Postal address, business ID, billing details, reference information
The term organization refers to the employer, clinic, or other entity that pays for consultation or continuing education services on your behalf (for example, access to the training library, examination rights, or other paid services)

Service usage and data generated during use:

Questions and comments submitted in the Service and the answers you provide
Viewing and listening data related to consultations and continuing education content
Certificates of completion from QAdental trainings
Any other training certificates you have uploaded to the Service
Registrations for QAdental training events

Patient images and videos related to Service use:

As a user, you may upload dental or X-ray images or videos of patients (“patient image”) to the Service
Patient images are not linked to other personal data of the patient. Images are taken so that the person in the image cannot reasonably be identified

6. CONSULTATION SERVICE

Free Consultation Service
Consultation responses can be requested free of charge from QAdental members. In this case, any user of the Service may respond to or comment on the consultation request. QAdental does not guarantee that responses will be provided.

Paid Service
Consultation responses can also be purchased from QAdental’s official experts.
The right to access the paid consultation service is added to the user account by QAdental’s administration (admin) if the user has personally purchased the paid service or if the organization has purchased the service on their behalf. A separate agreement is made with the user or organization regarding the paid service.

In the paid service, the following information may be disclosed to the person or organization paying for the service for billing and usage monitoring purposes:

The consultation’s URL address (accessible only to logged-in users)
The name and email address of the user who made the consultation

7. CONTINUING EDUCATION SERVICE

Free Content
After registration, the user gains access to the free portion of the continuing education content (for example, live webinars and certain recordings).

Paid Content
Additional rights may be added to a user account by QAdental administration (admin) in the following cases:

The organization has purchased for the user access to the entire training library, examination rights, or other paid services; or
The user has personally purchased a license, test package, or other paid service.

QAdental concludes a separate agreement with organizations regarding the purchase of continuing education services for their personnel. However, organizations do not at any stage disclose personal data of their personnel to QAdental.

QAdental may require verification via the organization’s email address before activating additional rights.

QAdental may disclose the following data to the organization:

User’s name
User’s email address
Training records (including those purchased personally or provided by other organizations whose certificates are stored in the user’s QAdental profile)

Disclosure is made only for as long as the service provided by the organization remains valid. If the user does not accept such disclosure, the service offered by the organization cannot be activated or continued. If required by the organization, reporting of training records may continue until the next reporting cycle even if the user is no longer employed by that organization.

User consent is requested for data disclosure to the organization. The user may withdraw consent at any time by emailing support@qadental.com.

Training Registration
Users may register while logged in for QAdental webinars, live vodcasts, and in-person training sessions. Depending on the event, the following information may be requested at the time of registration:

Name, email address, phone number, and interests (e.g. targeted services related to the event)
Selections concerning third-party offerings (such as training partners or sponsors), including product sample orders, participation in prize draws, job opportunities, or requests for contact
QAdental may require acceptance of certain terms when registering for training

Allergies and Special Diets
Information regarding dietary restrictions or allergies may be requested during registration. This information is processed solely for the organization of the event and is not combined with other personal data without separate consent.

Errors in the Service
If a user detects an error in the training content or the Service, it may be reported by email to support@qadental.com.

Training Content and Records
All training content (such as videos, vodcasts, exams, and other learning materials) are the property of QAdental or its experts or partners. Saving, downloading, recording, copying, sharing, or public presentation of such content without written permission is prohibited.

User accounts are personal. In trainings that include an examination, the session may nevertheless be viewed collectively using a single account, provided that each participant completes the paid test using their own individual account.

Successful completion of an online test or participation in a training session (online or in person) produces a certificate that is stored in the user’s information and retained as long as the user account exists. The user may view and print their certificates.

Administrators (admin users) have access to this data and may disclose it to the organization if the organization pays for the user’s continuing education service. If the user does not accept this disclosure, the organization’s service cannot be activated.

Technical Monitoring and Analytics
QAdental monitors the use of the continuing education service for service development and analytics purposes. Monitoring occurs at two levels:

General (non-user-specific) monitoring:

Number of logged-in users over time
Total views of videos and podcasts
Page visits and content usage
Website clicks and document downloads

User-specific monitoring:

Viewing and listening data of trainings
Completion and results of tests
Usage rate of test packages (e.g., number of remaining tests)

The information is used for learning analytics, service development, and training recommendations. Data may be shared with customers, partners, and advertisers only in anonymized form, without personal data.

The Service uses third-party providers (e.g., YouTube, Spotify) for content presentation. Cookies are used for usage analytics and to ensure functionality. Cookie data are not linked to personal data.

Disclosure of Data to Third Parties
The user may consent to the disclosure of their data to third parties, for example when:

Ordering a product sample during training or webinar registration
Participating in a prize draw
Expressing interest in a job opportunity posted in the Service
Requesting contact from an advertiser or QAdental partner

Data disclosed may include:

Name, professional title, and contact details
Name and postal address of the clinic or practice
Other information voluntarily provided by the user

Data are generally disclosed to entities that have purchased advertising space in a training event or that advertise jobs, services, or products in the Service. Third parties may use the data only for the specific purpose stated at the time of disclosure — for example, to deliver a product sample and/or to contact the user regarding the advertised service or product. Consent may be withdrawn at any time by emailing support@qadental.com.

8. OTHER SERVICE FEATURES

Job Application Function
Within the QAdental Service, the user may:

Apply for open positions
Submit a general job application through which employers may contact them

If the user applies for a specific job, the following information may be disclosed to the employer:

Name
Professional title
Phone number
Email address
Job position of interest
Other information entered by the user

In general job applications, data are transmitted to employers anonymously, without personal or contact information. Personal and contact details are disclosed only if the employer expresses interest in the user.

An anonymous application may include the following data:

Sector (public/private), location preference, mobility
Type of employment and preferred working hours
Year of graduation, professional title, areas of expertise, work experience
Interests
Continuing education history
Other information provided by the user

QAdental does not disclose personal or contact information without the user’s consent (e.g., via a checkbox).

Patient Communication
Through QAdental, the user may send digital brochures and scheduled message chains (for example, email or text message) to patients. Such messages may include:

A pre-produced patient brochure and/or video
A personal covering message written by the user

To send a message, the patient’s phone number and email address are required, and the patient’s verbal or written consent must be obtained. The user must record this consent and the sending of the message in the patient record. QAdental provides a ready-made copyable phrase to be added to the patient record as proof of the message being sent.

Messages are stored in the Service temporarily and are deleted regularly so that no permanent register is created.

9. TARGETED MARKETING AND COMMUNICATION

Content Processing
QAdental may process service content (not personal data) technically, for example, to:

Improve search functionality
Transcribe content
Translate content into other languages

Such processing may utilize artificial intelligence. Processing is conducted solely for QAdental’s internal purposes, and the content remains protected and free of user personal data.

Targeted Marketing and Communication
QAdental may use user data, such as training history and interests, for internal content targeting. The goal is to enhance user experience by offering individually tailored content, such as:

Training recommendations
Notifications of new content or consultations
Information on events, services, or advertiser offers related to the user’s professional profile or interests

QAdental may send such information via email and/or text message (notifications, newsletters). The user can manage these settings in their account preferences or opt out of receiving messages altogether.

10. RECIPIENTS OF PERSONAL DATA

Data stored in the register will not be disclosed to third parties without the user’s explicit consent.

Dental or X-ray images or videos of patients are visible to all users of the Service unless a patient image has been specifically set as private. However, patient images are not disclosed to outsiders.

The user’s name, questions, comments, and answers — as well as any attached photos — are visible to all other users of the Service worldwide.

The user may post messages anonymously, in which case the user’s name will not be visible to other users.

The register may be transferred to a third party in connection with a business acquisition or other corporate arrangement.

11. TRANSFER OF DATA TO THIRD COUNTRIES

All data are stored and processed on servers controlled by QAdental within the EU/EEA area.

12. RETENTION PERIOD OF PERSONAL DATA

Your personal data are retained as long as your user account exists. You may delete your account yourself, but certain data may be retained for organizational reporting or billing purposes for up to 12 months if a valid legal basis so requires.

User accounts that have never been accessed will be deleted, along with all their content, at 12-month intervals.

User accounts that have been inactive for 5 years will be deleted.

Any content you have created within the Service (for example, consultations, consultation responses, comments, or educational materials) will remain in the Service anonymously, in principle, permanently. Patient images are retained in the Service permanently once added for consultation or educational use, provided that you have given explicit consent for such use. The images are not linked to identifiable information. You are responsible for ensuring that consent is documented in the patient record in accordance with QAdental’s Terms of Use.

Backups are retained for 12 months.

13. RIGHTS OF THE DATA SUBJECT

We are committed to receiving and acting on requests concerning your personal data whenever they are justified. You may exercise the following rights regarding the user register data:

Withdrawal of Consent
If we process your data based on your consent, you may withdraw that consent at any time by notifying us.

Right of Access
You have the right to obtain confirmation from us as to whether we are processing your personal data and to know what personal data concerning you are being processed. You also have the right to receive additional information regarding the basis for processing your personal data.

Right to Rectification
You have the right to request that we correct any inaccurate, outdated, or otherwise incomplete personal data concerning you.

Right to Erasure (“Right to be Forgotten”)
You have the right to withdraw your consent to data processing and thereafter submit a written request for the deletion of your personal data from the register, to the extent that the data are not processed to comply with a legal obligation.

Right to Restrict Processing
You have the right to request that we restrict the processing of your personal data, for example, while awaiting our response to a request for rectification or deletion.

Right to Object to Processing
You have the right to object to the processing of your personal data for profiling-related purposes, such as training recommendations or targeted communication. You may exercise this right by contacting the Data Controller. We will assess the impact of such objection on the provision of the Service and take the necessary actions.

Right to Data Portability
You have the right to receive your personal data in a machine-readable format and to transmit those data to another controller. This applies only to data you have personally provided to us.

How to Exercise Your Rights
You can exercise the above rights by contacting the Data Controller in writing or electronically — the contact details are provided at the beginning of this Policy.

You have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data violates data protection legislation. In Finland, the supervisory authority is the Office of the Data Protection Ombudsman, whose contact details are provided below.

14. COMPETENT DATA PROTECTION AUTHORITY

Office of the Data Protection Ombudsman
Visiting address: Lintulahdenkuja 4, 00530 Helsinki, Finland
Postal address: P.O. Box 800, 00531 Helsinki, Finland
Switchboard: +358 29 566 6700
Registry: +358 29 566 6768
Email (registry): tietosuoja(at)om.fi