Smile Denture & Implant Clinic ("we," "us," "our") is committed to protecting the privacy of your personal information and personal health information. As a denturist practice, we are a health information custodian under Ontario's *Personal Health Information Protection Act, 2004* ("PHIPA"). Where applicable, we also comply with the *Personal Information Protection and Electronic Documents Act* ("PIPEDA") and *Canada's Anti‑Spam Legislation* ("CASL"). This policy describes how we collect, use, disclose, and safeguard information through this website and in our clinics in Ottawa, Perth, Carleton Place, and Kanata.
1. Definitions
- Personal information — information about an identifiable individual (e.g., name, contact details).
- Personal health information (PHI) — information about your health, health care, or payment for health care, as defined in PHIPA.
2. Information we collect
- You provide it through our Contact, Book a Consultation, New Patient Intake, and Referral forms — including your name, contact details, appointment preferences, and, on the intake form, PHI such as dental and medical history and current denture information.
- Coverage & billing — *Canadian Dental Care Plan (CDCP)* / Sun Life and private insurer details you provide so we can confirm coverage and bill.
- Smiley assistant — messages you type into our automated chat assistant.
- Automatically — limited technical data (browser, device, pages viewed) and, where enabled, cookies/analytics:
currently none.
3. Purposes for which we use information
To provide, plan, and coordinate your denturist care; schedule and confirm appointments; respond to enquiries and referrals; verify coverage and process billing with CDCP and insurers; meet our legal, regulatory, and professional record‑keeping obligations; and operate and improve this website. We do not sell your personal information or PHI.
4. Consent
We collect, use, and disclose your PHI with your knowledgeable consent, as permitted or required by PHIPA. Within your circle of care, your consent to share PHI with health‑care providers participating in your treatment may be implied. We rely on express consent for any non‑essential or marketing communication. You may withdraw or withhold consent at any time, subject to legal and record‑keeping limits, by contacting our Information Officer; we will explain any consequence of doing so for your care.
5. How we disclose information
We disclose only as necessary: to members of our clinical team across our four locations; to CDCP/Sun Life and your insurer to confirm coverage and bill, with your consent; to other health‑care providers in your circle of care; to agents and service providers (e.g., our website host and chat‑assistant provider) who act on our behalf under confidentiality and PHIPA‑consistent obligations; and where required or permitted by law.
6. The Smiley chat assistant
Smiley is an automated assistant providing general information and booking help. It is not a denturist and does not give medical advice. Your messages may be processed by a third‑party AI service a third‑party AI service provider, which may process your messages outside Canada to generate replies. Do not enter sensitive PHI, and never use it for emergencies — call 911. Your conversation is kept in your browser for your current visit. We also keep a copy of the conversation — the page you were on, what you typed or selected, and Smiley’s replies — on our server for up to 30 days, so our team can review chats for quality and improve how Smiley answers. This copy is linked only to a random, temporary conversation code generated in your browser, never to your name, email, phone number, or any other identifier — unless you choose to share those details through Smiley’s guided booking questions, which are sent to our front desk the same way a booking‑form submission is, and are handled under this policy like any other booking request. A daily summary, including conversation transcripts, is emailed to our team for the same quality purposes and is handled confidentially under this policy. If you start a request in the chat but don’t finish it, our team may use the contact details you provided to follow up. The 30‑day copy is deleted automatically; you do not need to do anything to have it removed. If you have questions about this, contact our Privacy Officer (see section 16).
7. Electronic communications (CASL)
If you opt in to emails (e.g., updates or a newsletter), we will send commercial electronic messages only with your consent, identify ourselves, and include an unsubscribe mechanism in every message, in accordance with CASL. Transactional messages about your care or appointments are not marketing.
8. Cookies & analytics
This website uses analytics and advertising-measurement cookies: Google Analytics (to understand how visitors use the site), Google Ads conversion tracking (to measure whether an ad visit led to a call or booking request), the Meta (Facebook) Pixel (advertising measurement), and Microsoft Clarity (anonymized usage insights that help us improve the site). These tools set cookies or similar identifiers in your browser. They are never sent your personal health information — details you share in our forms or chat go only to our clinic. You can limit these cookies in your browser settings, and you can opt out of personalized advertising through Google’s Ads Settings and Meta’s Ad Preferences.
9. Safeguards & breach notification
We maintain reasonable administrative, physical, and technical safeguards to protect information against theft, loss, and unauthorized access, in accordance with PHIPA s. 12. If your PHI is stolen, lost, or accessed or disclosed without authority, we will notify you at the first reasonable opportunity and advise you of your right to complain to the Information and Privacy Commissioner of Ontario, as required by PHIPA.
10. Retention
We retain records only as long as necessary for the purposes above and as required by the College of Denturists of Ontario's record‑keeping requirements and applicable law, after which they are securely destroyed.
11. Your rights under PHIPA
Subject to limited exceptions, you may access your records of PHI (PHIPA s. 52) and request a correction (PHIPA s. 55). You may also ask questions or raise concerns about our practices. To exercise these rights, contact our Information Officer (below). If we cannot resolve your concern, you may complain to the Information and Privacy Commissioner of Ontario (IPC) — ipc.on.ca.
12. Where information is stored
Your information is held in Canada. Where a service provider processes data outside Canada (for example, the chat assistant), it may be subject to the laws of that jurisdiction; we use providers bound by appropriate safeguards.
13. Minors
Care for patients under the age of consent is provided with the involvement of a parent or legal guardian.
14. Links to other websites
We are not responsible for the privacy practices or content of third‑party sites we link to (e.g., CDCP, the Canadian Dental Association).
15. Changes
We may update this policy; the "Effective" date will change and material changes will be posted here.
16. Contact — Information / Privacy Officer
Caner Karaceper, Denturist · Smile Denture & Implant Clinic · 1218 Rooney's Lane, Ottawa, ON K1H 7Y7 · (613) 909‑7979 · ottawa@smiledenture.ca IPC (Ontario): Information and Privacy Commissioner of Ontario, ipc.on.ca, 1‑800‑387‑0073.