This policy (together with our terms and conditions) applies to
· your visits to our website at www.plusdent.co.uk (our “Website”);
· your use of PlusDent mobile application software (our “App”), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (“Device”); and
· any of the services accessible through the App and/or our Website (“Services”).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
PlusDent Services and the App are not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. Data controller
We are committed to protecting your personal data and respecting your privacy.
3. Contact details
Our contact details are:
· Email address: firstname.lastname@example.org
· Postal address: SSS UK Services Ltd, 130 Wood Street, London, England, EC2V 6DL
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
It is important that the personal data we hold about you is accurate and current. Please keep us informed by emailing email@example.com if your personal data changes during our relationship with you.
5. Third party links
Our App and/or our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates, for example, our payment services providers. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
We may also be required to pass on some personal data to social media organisations via social media plug-ins (Facebook, Twitter, Pinterest, Instagram). These organisations will only receive your data if you click on the relevant plug-in on our Website or App. Please see the plug-ins providers privacy policies for more details about what data they collect and how they store it. They will be independent data controllers of any such data
6. The data we collect about you
Depending on the level of your engagement with our Website, our App and our Services, we may collect, use, store and transfer different kinds of personal data about you as follows:
· Identity Data:
Includes first name, last name, username or similar identifier, title, date of birth, gender.
This is information you provide to us when you create an account on our App and/or Website. Creating and maintaining an account with PlusDent is necessary to receive our Services, so if you cannot provide us with this information, we will not be able to provide our Services to you.
· Contact Data:
Includes billing address, delivery address, email address and telephone numbers. It also includes the content of your communications with us.
We require this information from you in order to communicate with you in relation to our Services. Without this data, we will be unable to respond to your queries, contact you to inform you about important matters and/or deliver the PlusDent Programme kit that you may purchase. This data is also necessary to manage your appointments with our Network Partners (as defined in paragraph 7).
· Financial Data:
Bank account and payment card details.
If you purchase PlusDent Programme, we will collect this information from you and transmit it to one of our payment services providers, depending on the method of payment selected by you.
· Transaction Data:
Includes details about payments to and from you and details of purchases.
We will record and keep this information to maintain a record of your purchases.
· Technical Data:
In relation to the use of our App, this includes: the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
In relation to the use of our Website, this 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.
· Profile Data:
Includes your username and password, purchase history, preferences, feedback and survey responses.
This is all data that relates to your interactions with us. It is necessary to provide you with your registered account service.
· Usage Data:
Includes details of your use of our App and/or our Website, including but not limited to, traffic data and other communication data, and the resources that you access.
We collect this data to monitor and measure the performance of our App and Website.
· Marketing and Communications Data:
Includes your preferences in receiving marketing from us and your communication preferences.
· Location Data:
Includes your current location disclosed by GPS technology.
If you enable Location Data within our App or in your browser, we will use this data to allow you to search our Network Professionals appointments by your current location]
· Health Data:
Includes information about your dental health (e.g. gum problems), the extent of your malocclusions, bite size, any pre-existing conditions, diagnoses, tooth positions, medication, information on allergies, intolerances, images of teeth and any other health or medical information that may be necessary in connection with aligners programme provided by PlusDent (“PlusDent Programme”), including any treatment plans prepared for you by our Network Partners (as defined in paragraph 7 below).
Most of the personal data that we process about you will be provided by you, for example during registration on our Website or App, when you complete an enquiry form or an application to subscribe to PlusDent Programme, when you book an appointment with one of our Network Partners, when you purchase PlusDent programme and/or when you otherwise interact with us, whether via our Website, App or by telephone. The provision of such information is voluntary, but if you cannot provide it to us, we may not be able to provide our Services to you. For example, if you cannot provide us with your name or age, we will not be able to register your account with PlusDent.
We also use GPS technology to determine your current location. The “find your local Network Partner” feature on our App and Website requires your Location Data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings[LH8] [a9] .]
We will also receive personal data about you from various third parties:
· Some of your Health Data will be provided to us by the dentist or orthodontist who has assessed your eligibility for PlusDent Programme (“Network Partner”). If you attend an appointment booked via our App or Website, our Network Partner will provide us with the results of the assessment, including images of your teeth and treatment plan and other relevant Health Data;
· Contact, Financial and Transaction Data from providers of technical, payment and delivery services. As of May 2020 the companies we work with includes Stripe, PayPal and Tabeo LTD, Tabeo Broker Limited,
7. How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
· Where you have consented before the processing. Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by [emailing firstname.lastname@example.org from your registered email address] [LH10] ].
· Where we need to perform a contract, we are about to enter or have entered with you. 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.
· 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. For example, 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.
· Where we need to comply with a legal or regulatory obligation. 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.
In relation to your Health Data, we will ask for your explicit consent when you submit your account registration application. You can always withdraw your consent to our processing of your Health Data by contacting us. However, if you withdraw your consent, we will be unable to provide PlusDent Programme to you. This is because the use of Health Data is necessary for the design of the aligners and the monitoring of your progress.
The table below explains what we use (process) your personal information for (other than the special category of data) and our reasons for doing so.
8. Disclosures of your personal data
The above purposes and activities may require us to pass on some of our personal data to the following third parties:
· Sunshine Smile GmbH based in Germany – this is our holding company, which provides us with all back-office support and infrastructure;
· Network Partners, who will act as data controllers in relation to your data;
· Our service providers acting as independent controllers; Our service providers acting as our processors;;
· Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
· HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances; and
We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you and for no other reasons.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
9. International transfers
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.
Some of the third parties that receive personal data from us are based outside the UK or EEA so their processing of your personal data will involve a transfer of data outside the UK or EEA.
Whenever we transfer your personal data out of the UK or EEA, 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 by the European Commission and/or the UK Government.
· Where we use certain service providers, we may use specific contracts approved by the European Commission and/or the UK Government which give personal data the same protection it has in Europe or the UK.
· Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the UK, and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
10. Data security
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website or our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
11. Data retention
We keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes, and in case there is a complaint or legal claim.
In some circumstances you can ask us to delete your data: see your legal rights section below for further information. Where we are processing your data on the basis of your consent, and you withdraw that consent, we will stop processing your data, and delete it.
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.
In the event that you do not use your account with PlusDent for a period of 12 months then we will treat the account as expired and your personal data may be deleted.
12. Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data
· 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. If we are satisfied that you have a right to see this personal data, and we are able to confirm your identity, we will, except where an exemption applies, provide you with this personal data.
· 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:
o if you want us to establish the data’s accuracy;
o where our use of the data is unlawful, but you do not want us to erase it;
o 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; or
o 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.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
If you would like to exercise any of the above rights please contact us via the contact details in section 3. If we have reason to doubt your identity (for example, you make the request from a different email than the one associated with your account), then we may ask you for proof of identity. 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.
13. How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation, which can be found at https://ico.org.uk/make-a-complaint/.