This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to all products and services, and instances where we collect your personal data.
Changes to this privacy notice
We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website.
- What kinds of personal information about you do we process?
Personal information that we’ll process in connection with all of our products and services, if relevant, includes:
- Personal and contact details, such as title, full name, contact details and contact details history
- Your date of birth, gender and/or age
- Family members (if relevant)
- Records of your contact with us
- Treatment you have received from us and the associated payment methods used
- Marketing to you and analysing data
- Information about your health
- What is the source of your personal information?
We’ll collect personal information from the following general sources:
- From you directly, and any information from family members.
- From other professionals we have referred you to
- Information generated about you when you use our services
- What do we use your personal data for?
We use your personal data, including any of the personal data listed in section 1 above for the following purposes.
- Managing treatment and services relating to that the product or service, or application for one
- Updating your records, tracing your whereabouts and recovering debt
- To improve the operation of our business
- To follow guidance and best practice under the change to rules of governmental and regulatory bodies
- For management and auditing of our business operations including accounting
- To monitor and to keep records of our communications with you and our staff (see below)
- For market research and analysis and developing statistics
- For direct marketing communications and related profiling to help us to offer you relevant treatments, products and services, including deciding whether or not to offer you certain treatments products and services. We’ll send marketing to you by SMS, email, phone, post, social media and digital channels.
- To develop new products and services and to review and improve current treatments, products and services
- To comply with legal and regulatory obligations, requirements and guidance.
- What are the legal grounds for our processing of your personal information (including when we share it with others)?
We rely on the following legal bases to use your personal data:
- Where it is needed to provide you with treatment, products or services.
- Where it is in our legitimate interests to do so.
- To comply with our legal obligations.
- With your consent or explicit consent.
- For a public interest.
- How and when can you withdraw your consent?
Where we’re relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the details below.
- Is your personal information transferred outside the UK or the EEA?
We’re based in the UK but sometimes your personal information may be transferred outside the European Economic Area. If we do so we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.
- What should you do if your personal information changes?
You should tell us so that we can update our records using the details in the Contact Us section of our website. We’ll then update your records if we can.
- Do you have to provide your personal information to us?
We’re unable to provide you with treatment, products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.
- For how long is your personal information retained by us?
Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:
- For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
- For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
- Retention periods in line with legal and regulatory requirements or guidance.
- What are your rights under data protection laws?
Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.
- The right to be informed about the processing of your personal information
- The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
- The right to object to processing of your personal information
- The right to restrict processing of your personal information
- The right to have your personal information erased (the “right to be forgotten”)
- The right to request access to your personal information and to obtain information about how we process it
- The right to move, copy or transfer your personal information (“data portability”)
- Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you
You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/. You can contact us using the details below.
- Your right to object
You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us by going to the Contact Us section of our website to exercise these rights.
If you have any questions about this privacy notice, or if you wish to exercise your rights or contact the DPO, you can contact us by going to the Contact Us section of our website. Alternatively, you can write to Smile Architect, 111 Harley Street, London W1G 6AW.