Smile Fast Limited respects your privacy and is committed to protecting your personal data.
website (regardless of where you visit it from) and tell you about your privacy rights and how the
law protects you.
areas set out below. Please also use the Glossary to understand the meaning of some of the terms
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
1. Important information and who we are
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
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
Smile Fast Limited is the controller and responsible for your personal data (collectively referred
legal rights, please contact us using the details set out below.
the following ways:
Full name of legal entity: Smile Fast Limited
Email address: firstname.lastname@example.org.
Postal address: Unit 6 Hackthorpe Hall, Hackthorpe, Penrith, Cumbria, CA10 2HX
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
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.
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
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
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,
information about your teeth as set out on our ‘Can You Treat Me’ page, title, date of birth and
• 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
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
• 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
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
• 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.
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
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.
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.
We will get your express opt-in consent before we share your personal data with any third party for
You can ask us or third parties to stop sending you marketing messages at any by contacting us at
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.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or
become inaccessible or not function properly. For more information about the cookies we use,
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
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
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.
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
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.
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
• 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
YOUR LEGAL RIGHTS
You have the right to:
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.
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.
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
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.