Privacy Policy

1. DATA CONTROLLER

The controller of the personal data collected through Dental Expert Panel is:

KEY-STONE S.R.L.
Corso Enrico Tazzoli 215/12A
10137 Turin (TO), Italy
Turin Companies Register, REA TO-850109
Tax code and VAT number: IT07161770016

Contact: info@dentalexpertpanel.com

Data protection contact: dpo@key-stone.it

Dental Expert Panel is an initiative by Key-Stone Research & Consulting aimed at professionals in the dental sector.

2. APPLICABLE LAW

Personal data is processed in accordance with Regulation (EU) 2016/679 (the “GDPR”) and the Italian Personal Data Protection Code (Legislative Decree 196/2003, as amended), as Key-Stone S.r.l. is established in Italy. Where users are located in other European Economic Area countries, any mandatory national provisions applicable to the processing will also apply where relevant.

Electronic communications and the use of cookies and similar technologies are governed by the ePrivacy framework, including Directive 2002/58/EC as implemented in the applicable national legislation.

3. WHAT DATA WE PROCESS

Depending on the information provided by the user, Dental Expert Panel may process the following categories of data:

• identification and contact data: first name, last name, email address and telephone number, if provided;
• country, province or region and, where technically derived from the province, autonomous community (Spain);
• profession, role and professional status;
• name or company name of the practice or business, if provided, and type of facility;
• approximate number of dental chairs;
• areas of professional activity and interests;
• free text entered in “Other (please specify)” fields;
• for dentists and stomatologists: professional association and registration number;
• records of acceptance of the Participation Terms and of consents (type, answer, text version, date, time and channel);
• history of invitations and participation in research and answers given in studies, where relevant;
• information needed to manage incentives or remuneration for certain studies;
• technical data and logs strictly necessary for the operation and security of the platform.

The professional registration number may be checked against public professional registers to verify the applicant's professional qualification.

Dental Expert Panel does not ask its members for clinical information on identified or identifiable patients.

Participants must not provide personal data of patients or third parties through forms, surveys, interviews or participation spaces, unless specifically instructed and with an appropriate legal basis.

4. PURPOSES OF PROCESSING

Personal data may be processed for the following purposes:

Legal basis: membership of the panel and acceptance of the Participation Terms, under Article 6(1)(b) GDPR.

Legal basis: membership of the panel and acceptance of the Participation Terms, under Article 6(1)(b) GDPR.

Legal basis: the data subject's consent, given through a separate and optional checkbox, under Article 6(1)(a) GDPR.

Managing the participation of members who accept an invitation to individual interviews, focus groups, expert panels or other qualitative activities.

Some of these activities may include remuneration or an incentive, the conditions of which will be communicated before participation.

Legal basis: performance of the relationship between the participant and Key-Stone arising from the Participation Terms and the acceptance of the specific activity (Article 6(1)(b) GDPR).

Any audio or video recordings, the presence of observers from the research client or disclosure of the participant's identity will be handled study by study, with the relevant information and, where necessary, specific consent.

Wherever possible, results intended for publication will be presented in aggregate or anonymised form, without allowing individual participants to be identified.

Legal basis: Key-Stone's legitimate interest in preserving the security, reliability and integrity of Dental Expert Panel, under Article 6(1)(f) GDPR.

5. PROFILING AND SELECTION FOR STUDIES

Key-Stone may use the professional information provided by members to identify studies or research activities relevant to their profile.

For example, a study may be aimed exclusively at practice owners, orthodontists, implantologists, purchasing managers or professionals in a specific geographical area.

This segmentation serves to select suitable participants for each study.

This information will not be used to take decisions based solely on automated processing that produce legal effects concerning the data subject or similarly significantly affect them within the meaning of Article 22 GDPR, unless expressly disclosed and supported by an appropriate legal basis.

6. VOLUNTARY NATURE

Registration with Dental Expert Panel is voluntary.

Participation in each survey, interview, focus group or research activity is also voluntary.

Members may decline an invitation to a study without losing their membership of Dental Expert Panel.

The optional consent for newsletters and content is not a condition for joining the panel.

7. REMUNERATION AND INCENTIVES

Certain studies may include credits, incentives, vouchers, fees or other forms of remuneration, depending on the length and nature of the study.

The conditions applicable to each study will be communicated to the participant before they agree to take part.

Where necessary to manage the incentive or remuneration, only the data strictly required for that purpose and for compliance with applicable administrative, tax or accounting obligations will be processed.

8. HOW LONG WE KEEP DATA

Data relating to the Dental Expert Panel profile will be kept for as long as the data subject keeps their membership active.

Data processed on the basis of consent will be used until consent is withdrawn or erasure is requested, without prejudice to the retention periods needed to demonstrate compliance with Key-Stone's legal obligations.

Data relating to specific research activities may be kept for as long as necessary to complete the project, validate its results, manage research quality and meet related legal or contractual obligations.

Irreversibly anonymised data, which no longer allows a natural person to be identified, may be kept for statistical, historical or research purposes.

9. WHO DATA MAY BE DISCLOSED TO

Key-Stone will not sell the personal data of Dental Expert Panel members.

Data may be accessible to providers delivering services necessary for the operation of the project, including:

• hosting and technology infrastructure;
• databases;
• email;
• survey platforms;
• analysis tools;
• support and maintenance services;
• providers responsible for managing incentives or remuneration.

Where these providers act on behalf of Key-Stone, they act as data processors under Article 28 GDPR and are bound by the corresponding contractual data protection obligations.

Data may also be disclosed where required by law.

A participant's individual identity will not be disclosed to research clients unless there is an appropriate legal basis and the participant has been informed in advance, where required.

10. INTERNATIONAL TRANSFERS

Some technology providers used to operate Dental Expert Panel may operate or provide services from countries outside the European Economic Area.

Where personal data is transferred internationally, Key-Stone will apply the mechanisms set out in Chapter V GDPR, such as European Commission adequacy decisions or standard contractual clauses, together with any additional safeguards required.

11. DATA SUBJECT RIGHTS

Data subjects may exercise the rights granted by the GDPR and applicable law, including:

• access;
• rectification;
• erasure;
• objection;
• restriction of processing;
• portability, where applicable;
• withdrawal of consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise these rights, please contact:

dpo@key-stone.it

The request must allow the requester and the right they wish to exercise to be adequately identified.

Data subjects also have the right to lodge a complaint with a competent supervisory authority, in particular in the EU Member State of their habitual residence, place of work or place of the alleged infringement (Article 77 GDPR). As Key-Stone S.r.l. is established in Italy, the Italian supervisory authority is the Garante per la protezione dei dati personali. For cross-border processing, the rules on the lead supervisory authority under Article 56 GDPR apply where relevant.

12. WITHDRAWAL OF CONSENT AND UNSUBSCRIBING

Members may change their preferences or withdraw the optional consent for newsletters and content at any time.

Withdrawing consent must be as easy as giving it.

Electronic communications will include a simple, free mechanism to stop receiving them where required by law.

Users may also leave Dental Expert Panel at any time by writing to info@dentalexpertpanel.com or dpo@key-stone.it.

13. SECURITY

Key-Stone will apply technical and organisational measures appropriate to the risk to protect personal data against unauthorised destruction, loss, alteration, disclosure or access.

Access to data will be limited to the people and providers who need it for the stated purposes.

14. CHANGES TO THIS POLICY

Key-Stone may update this Privacy Policy to reflect regulatory or technical changes or changes in how Dental Expert Panel operates.

The current version and its update date will be available on this page.

Where a change substantially affects processing based on consent, new consent will be requested where necessary.