Compliance and Privacy Links:

Website Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our	LIBERTY Dental Plan Corporation and its subsidiaries
Personal information	Any information relating to an identified or identifiable individual

2. Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers	Name, address, social security, Internet Protocol (IP) address, email, home address, billing address, driver’s license number
Characteristics of protected classifications under California or federal law.	Disability, race, gender, sex
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)	Records of dental insurance plans or other dental coverage
Internet or other electronic network activity information	How you interact with our website
Geolocation data	Geographic data associated with your Internet Protocol Address
Professional or employment-related information	Name and social security to verify employer-sponsored dental coverage (if any)

We do not collect biometric information, non-public education information, or other inferences drawn from other personal information.

This personal information is required to provide and administer dental benefits to you. If you do not provide personal information we ask for, it may delay or prevent us from providing and administering dental benefits to you.

3. Cookies. Depending on how you use our website, we may store cookies on your computer in order to collect certain aggregate data about our users and to customize certain aspects of your specific user experience. A cookie is a small data text file which is stored on your computer that uniquely identifies your browser. Cookies may also include more personalized information, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and your first name to welcome you back to our Site. We may use cookies to perform tasks such as: monitoring aggregate site usage metrics, storing and remembering your passwords (if you allow us to do so), storing account and advertising preferences that you have set, and personalizing the Services we make available to you. However, we do not use cookies to track your browsing behaviors.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some aspects of the website may not function properly if you elect to disable cookies.

4. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and mobile apps. However, we may also collect information:

From publicly accessible sources (e.g., property records);
Directly from a third party (e.g., sanctions screening providers, regulatory authorities, employers, and other health plans);
From a third party with your consent (e.g., your employer or health plan);
From cookies on our website

5. How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:

To comply with our legal and regulatory obligations;
For the performance of our services for you;
For our legitimate interests or those of a third party; or
Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide or administer dental benefits to you	To verify that we are administering benefits to the appropriate individuals, we may need to request personal information
Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies	To comply with our legal, regulatory, and contractual obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests to be as efficient as we can so we can deliver the best service for you efficiently
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests to protect trade secrets and other commercially valuable information and to comply with our legal, regulatory, and contractual obligations
Statistical analysis to help us manage our business	For our legitimate interests to be as efficient as we can so we can deliver the best service to you
Preventing unauthorized access and modifications to systems	For our legitimate interests to prevent and detect criminal activity that could be damaging for us and for you and to comply with our legal, regulatory, and contractual obligations
Updating and enhancing member records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal, regulatory, and contractual obligations

The above table does not apply to protected health information, which we will only process in accordance with the HIPAA Privacy Rule. See our HIPAA Notice of Privacy Practices at https://www.libertydentalplan.com/Legal/Privacy-Statement/Patient-Privacy-1.aspx for more information.

6. Promotional Communications. We do not send promotional communications unless such communications are related to Health Care Operations, as defined under 45 C.F.R. § 164.501. We may use your personal information to send you updates by email, text message, telephone, or post about your benefits and available services, including changes in benefits coverage, explanation of benefits, preventive care incentives, and new services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or disclose it to third parties without your consent.

You have the right to opt out of receiving promotional communications at any time by:

Contacting us at compliance@libertydentalplan.com
Using the “unsubscribe” link in emails or “STOP” number in texts; or
calling us at: 888.704.9833

7. Who We Share Your Personal Information With. We routinely share personal information with:

Our affiliates, including companies within the LIBERTY Dental Plan group;
Health care providers to render dental care;
Other third parties we use for case management and surveys;
Third parties approved by you, including health care providers, communication vendors, and legal representatives.

We only allow our vendors and subcontractors to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on vendors and subcontractors to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., regulatory authorities and their delegates, the National Committee for Quality Assurance (NCQA), and the Utilization Review Accreditation Commission (URAC).

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

8. Personal Information We Sold or Disclosed for a Business Purpose. We do not share or disclosure your Personal Information, including de-identified patient information, to a third party outside of Health Care operations.

9. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing services to you or on your behalf. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law or legal obligation.

10. Your Rights Under CCPA. The following applies to all visitors, users, and other who reside in the State of California to the extent applicable. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale [or disclosure] of your personal information. If you exercise your right to opt-out of the sale [or disclosure] of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale [or disclosure] of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: link
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your personal information.

11. Keeping Your Personal Information Secure. We have appropriate technical and physical security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. However, no security system is impenetrable and we cannot guarantee the security of our website, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet, and we are not liable for the illegal acts of third parties such as criminal hackers.

12. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

Complete a data subject request form available on our website at link
Call us, toll-free, at 888-704-9833; or
Email us at privacy@libertydentalplan.com.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by phone or email, you will need to provide us with:

Enough information to identify you (e.g., your full name, address, and member ID number); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

13. COPPA Notice. We do not intentionally collect personal information from users under the age of 13. Please do not send any personal information to us if you are under the age of 13. If we learn we have collected Personal Information from a User under the age of 13 without parental consent, or if we learn a user under the age of 13 has provided us personal information beyond what we request from him or her, we will delete that information as quickly as possible. If you believe that a user under the age of 13 may have provided us Personal Information in violation of this Website Privacy Policy, please contact us at the ‘Contact Us’ information below.

14. Changes to This Privacy Notice. This privacy notice was published on 11/11/2021 and last updated on 11/11/2021.

We may change this privacy notice from time to time–when we do, we will inform you via [mechanism for informing the data subject of changes to the notice, e.g., our website or other means of contact such as email].

15. Contact Us. Please contact us and/or our Privacy Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details
Contact address	Compliance Officer LIBERTY Dental Plan 1730 Flight Way, Suite 125 Tustin, CA 92782 1730 Flight Way, Suite 125 Tustin, CA 92782
Contact email address	privacy@libertydentalplan.com or use our form- Report Compliance Concerns >
Contact telephone number	888.704.9833

16. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).