This is the privacy notice of Smileright. In this document, “we”, “our”, or “us” refer to Smileright.
- This is a notice to inform you of our policy about all information that we record about you through our website. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
- We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
- We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
- Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
- The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
- Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
1. Information we process because we have a contractual obligation with you
If you join us as a patient or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
- verify your identity for security purposes
- sell products to you
- provide you with our services
- provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our Practice, you provide your consent to us to process information that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at Cheltenham – email@example.com; Barbican – firstname.lastname@example.org; Cardiff – email@example.com; Basingstoke – firstname.lastname@example.org; Waterloo – email@example.com. However, if you do so, you may not be able to use our website or our services further.
3. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
4. Specific uses of information you provide to us
Information you give to us. We may use this information to:
- Send you general and marketing communications;
- Send you e-mail notifications;
- Notify you about changes to our service;
- Ensure that content from our site is presented in the most effective manner for your and for your computer
- Provide third parties with statistical information about our users – but this information will not be used to identify any individual user; and/or
- Deal with enquiries and complaints made by or about you relating to the website.
Information we collect about you. We will use this information:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and review purposes;
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- As part of our efforts to keep our site safe and secure;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and/or
- To make suggestions and recommendations to you and other users of our site about services that may interest you or them.
Information we receive from other sources.
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.
5. Complaints regarding content on our website
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
How you can complain
- You can find further information about our complaint handling procedure at https://smileright.co/about-us/complaints-procedure/
- If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
- If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/.
7. Contacting us via our website
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us securely in order to reply with the information you need.
We record your request and our reply as well as the personally identifiable information associated with your message, such as your name and email address and other contact details so as to be able to track our communications with you to provide a high quality service. This data will be held securely online for a period of 3 months, we may also record this information within our practice management software.
Use of information we collect through automated systems when you visit our website
This website uses Google Analytics to help analyse how users use the site. The tool uses “cookies,” which are text files placed on your computer, to collect standard Internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the website and to compile statistical reports on website activity.
We will never (and will not allow any third party to) use the statistical analytics tool to track or to collect any Personally Identifiable Information (PII) of visitors to our site. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a computer user. We will not associate any data gathered from this site with any Personally Identifiable Information from any source, unless you explicitly submit that information via a fill-in form on our website.
9. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution. This information is recorded by Google Analytics as well as via certain 3rd party plugins installed on our website.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
10. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
11. Our use of Call Tracking
We may have call tracking installed on our website. This tracking will automatically record certain information about the visitor by using various types of technology including cookies, clear gifs or web beacons. This automatically collected information may include the phone number, IP address or other device address or ID, geographic location of the Visitor, web browser and/or device type, the web pages or sites visited just before or just after visiting the site, the pages or other content the visitor views or interacts with, and the dates and times of the visit. Calls may also be recorded.
Access to your own information
12. Access to your personal information
- At any time you may review or update personally identifiable information that we hold about you by contacting us.
- To obtain a copy of any information that is not provided on our website you may send us a request at Cheltenham – firstname.lastname@example.org; Barbican – email@example.com; Cardiff – firstname.lastname@example.org; Basingstoke – email@example.com; Waterloo – firstname.lastname@example.org.
- After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
13. Removal of your information
If you wish us to remove personally identifiable information from our systems, you may contact us at Cheltenham – email@example.com; Barbican – firstname.lastname@example.org; Cardiff – email@example.com; Basingstoke – firstname.lastname@example.org; Waterloo – email@example.com.
This may limit the service we can provide to you.
14. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
15. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
16. Retention period for personal data
As mentioned in this privacy notice, we keep your personal information securely online for a period of 3 months. We will also keep the data on our practice management software for as long as required by us:
- To provide you with the services you have requested;
- To comply with other law
- To support a claim or defence in court.
17. Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.