Privacy Policy
Introduction
Welcome to the SmileFast Implants Limited's website privacy policy.
SmileFast Implants Limited respects your privacy and is committed to protecting your personal data. This
privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of
where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- GLOSSARY
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how SmileFast Implants Limited collects and processes your
personal data through your use of this website, including any data you may provide through this website when you
sign up to receive information about our services.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing
policy we may provide on specific occasions when we are collecting or processing personal data about you so that
you are fully aware of how and why we are using your data. This privacy policy supplements other notices and
privacy policies and is not intended to override them.
Controller
SmileFast Implants Limited is the controller and responsible for your personal data (collectively referred to as
"Smile Fast", "we", "us" or "our" in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights,
please contact us using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following
ways:
Full name of legal entity: SmileFast Implants Limited
Email address:
info@smilefastimplants.com.
Postal address: 12c Alanbrooke Road, Carlisle, CA1 2UT.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK
regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with
your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if
your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When you leave our website, we
encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be
identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped
together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier as set out on
our contact forms.
- Contact Data includes email address and phone number.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time
zone setting and location, browser plug-in types and versions, operating system and platform, and other
technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third
parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data could be derived from your personal data but is not considered personal data in law as this data
will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate
the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data
with your personal data so that it can directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or
ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health, and genetic and biometric data). Nor do we collect any information
about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail
to provide that data when requested, we may not be able to perform the contract we have or are trying to enter
into with you (for example, to provide you with goods or services). In this case, we may have to cancel a
product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes personal data you provide when
you:
- apply for our products or services;
- request marketing to be sent to you; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect
Technical Data about your equipment, browsing actions and patterns. We collect this personal data by
using cookies, server logs and other similar technologies. Please see our cookie
policy for further
details.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in
the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests.
- Where we need to comply with a legal obligation. Click
here to find out more about the types of lawful
basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will
get your consent before sending third party direct marketing communications to you via email or text message.
You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and
which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where
appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose
for which we are using your data. Please contact us if you need details about the specific legal ground we are
relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
|
(a) Identity
(b) Contact
(c) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how
customers use our products/services)
|
To enable you to complete a survey |
(a) Identity
(b) Contact
(c) Usage
(d) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our
products/services, to develop them and grow our business)
|
To administer and protect our business and this website (including troubleshooting, data
analysis, testing, system maintenance, support, reporting and hosting of data)
|
(a) Identity
(b) Contact
(c) Technical
|
(a) Necessary for our legitimate interests (for running our business, provision of
administration and IT services, network security, to prevent fraud and in the context of a
business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|
To use data analytics to improve our website, products/services, marketing, customer
relationships and experiences
|
(a) Technical
(b) Usage
|
Necessary for our legitimate interests (to define types of customers for our products and
services, to keep our website updated and relevant, to develop our business and to inform our
marketing strategy)
|
To make suggestions and recommendations to you about goods or services that may be of interest
to you
|
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Marketing and Communications
|
Necessary for our legitimate interests (to develop our products/services and grow our
business)
|
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and
advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may
want or need, or what may be of interest to you. This is how we decide which products, services and offers may
be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods
or services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing
purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as
a result of a product/service purchase.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access
cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible
or not function properly. For more information about the cookies we use,
please see
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider
that we need to use it for another reason and that reason is compatible with the original purpose. If you wish
to get an explanation as to how the processing for the new purpose is compatible with the original purpose,
please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal
basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the
above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes
for which we will use your personal data above.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our
business, then the new owners may use your personal data in the same way as set out in this privacy
policy. We require all third parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your personal data for
their own purposes and only permit them to process your personal data for specified purposes and in
accordance with our instructions.
6. International transfers
Some of our external third party suppliers are based outside the UK so their processing of your personal data
will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to
it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level
of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which
give personal data the same protection it has in the UK. Please contact us if you want further
information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost,
used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal
data to those employees, agents, contractors and other third parties who have a business need to know. They will
only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any
applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting
requirements. We may retain your personal data for a longer period in the event of a complaint or if we
reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity
of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the
purposes for which we process your personal data and whether we can achieve those purposes through other means,
and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy
which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for
research or statistical purposes, in which case we may use this information indefinitely without further notice
to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However,
we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we
could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to
access your personal data (or to exercise any of your other rights). This is a security measure to ensure that
personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you
for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month
if your request is particularly complex or you have made a number of requests. In this case, we will notify you
and keep you updated.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to
give you the best service/product and the best and most secure experience. We make sure we consider and balance
any potential impact on you (both positive and negative) and your rights before we process your personal data
for our legitimate interests. We do not use your personal data for activities where our interests are overridden
by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can
obtain further information about how we assess our legitimate interests against any potential impact on you in
respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to
which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a
legal obligation that we are subject to.
THIRD PARTIES
External Third Parties
- Dental practices in the United Kingdom acting as controllers, for the purposes of dentists contacting
you to discuss treatment options, following your specific request for them to do so via our website.
- Service providers acting as processors such as Cloudways Limited in Malta who provide website hosting,
IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and
insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting
services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based
in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to
receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or
inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you
provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there
is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your
personal data where you have successfully exercised your right to object to processing (see below), where we may
have processed your information unlawfully or where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply with your request of erasure for specific
legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third
party) and there is something about your particular situation which makes you want to object to processing on
this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object
where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that
we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of
your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise
or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate
grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party
you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this
right only applies to automated information which you initially provided consent for us to use or where we used
the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will
not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your
consent, we may not be able to provide certain products or services to you. We will advise you if this is the
case at the time you withdraw your consent.