Privacy – Dentily

Privacy

Data Protection Notice
July 2019
Privacy Policy:
Dentily Technology Ltd is a data controller which means we have a responsibility to decide how and when your data is used and to ensure it is used correctly in all situations. Dentily Technology Ltd is located at 124 Finchley Road, London, NW3 5JS. Company number: 11621629
We put our customer privacy at the heart of everything we do and we hope that our Privacy Policy described below is easy to understand and clear to you. We reserve the right to modify and update this Policy at any time without notice.
When and if we do update the Policy we will publish it on our website (https://www.dentily.co.uk).
Our Privacy Policy applies to all our customers. For further details of our processing of your information, please ensure that you read and understand your aligner treatment conditions that form part of the registration and assessment process.
Your Data
We may store any information that you provide when you fill in assessment forms on our website or when you contact us, plus we may keep details of any transactions that you carry out through our system, details of your visit to our website and the details of resources that you access using our website. All data (personal information) submitted to Dentily Technology Ltd on our website by you is taken to be accurate and correct.
By agreeing to our terms and conditions and privacy policy you are also agreeing not to use other people’s data. If we suspect a possible fraud or false identity, we may pass information to fraud prevention agencies or the police.
We may check details with fraud prevention agencies and if you provide false or inaccurate information or we suspect fraud, this information may be recorded.
Fraud prevention agency records will be shared with other organisations to help make decisions on your credit, motor, household, life and other insurance proposals or claims.
Your Consent
On submitting your personal information to Dentily Technology Ltd you are consenting to us checking the following:
– Our internal databases and records
– Fraud prevention agencies
We will provide you with access to any information we have about you in accordance with the Privacy Act. If you would like to access this information please contact us by writing to us at 124 Finchley Road, London, NW3 5JS.or emailing us at info@dentily.co.uk.
Some information may be required by the local law, legal enforcement procedures or other bodies with relevant powers or jurisdiction. If you do not provide all of the information requested, we may not be able to provide you with our products or services effectively or at all.
Data Security 
We do our best to protect your personal data that you have shared with us. We protect that information in transit using secure socket layer (SSL) encryption technology. Dentily Technology Ltd uses firewalls and the latest encryption technology to ensure our web site is secure and that all customer data is protected and encrypted.
IP Addresses & Cookies
Through our website we may collect information about your computer, including your IP address, browser type and version and operating system information for system administration and to report aggregate information to our advertisers. All this information is purely statistical and does not identify any individual.   Note: that affiliates and advertisers who advertise on our site may use cookies, but we do not have access to them or control over them. If you do not want to allow access to the cookies on your system then you can set your browser to refuse cookies. However, doing so you will not be able to enjoy full use of this site. Your Rights We may contact you by phone, post, email and SMS to tell you about our products, services and promotions. We will only do this if you have agreed to it in terms and conditions. You have a right to opt out of us contacting you for marketing purposes or sharing information about you with other companies for marketing purposes by contacting us at: info@dentily.co.uk or by sending us a written letter to: 124 Finchley Road, London, NW3 5JS and letting us know your decision.
Data Processing
Our aim is to process data efficiently, only use it where absolutely needed to give you a better experience and service. This could include but is not limited to fraud prevention, money laundering and other criminal activities. We may also use data to help us improve the customer experience you have, statistical analysis or assess credit risks or suitability for third party products.

 

In addition to personal and financial information, we may collect information about your computer including your IP address, operating system and browser type. We may use 'cookies' which involve information being stored on your computer browser. Most websites use cookies to improve the overall customer experience and how the website works as well as to provide relevant information to customers at the right time. You can choose to block cookies in your web browser by changing your browser settings. If you choose not to accept cookies this may affect the quality of your visit to Dentily's website.
Sharing your data
We use personal information for the purpose of carrying out our business activities -providing the products and services you have requested. We may use your information to help make business decisions that enable us to offer a better service. We may also use your information for marketing purposes but only if you have not made a request for us not to do so. We may, if legally compelled to do so, supply your information to authorities should they require it to conduct investigations.

 

By using this website you consent to us collecting and using your personal information as described in this privacy policy. We reserve the right to change this privacy policy at any time and without notice. We may also pass your information to third party financial services companies for the purpose of them telling you about their services or products.
Third Party Websites
Our website may contain links to third party websites. Please note that if you follow a link to any such website, we do not accept any liability or responsibility, because these websites have their own Terms & Conditions and Privacy Policies.

 

By agreeing to our privacy policy, and signing up with Dentily, you agree that on occasions where we cannot help you, that we pass your details on to a carefully vetted partner that we think we can still help you. You may email us at info@dentily.co.uk to prevent this from happening, but you are under no obligation to commit to our partner’s services, and they are designed to help you with your requirements.

 

You can request your information The UK Data Protection Act provides you with the right to access information held about you. Any such request may be charged a fee to meet our costs in providing you with details of the information we hold about you. If you require such information, please do not hesitate to contact us.
Contact Us

We welcome any concerns or questions you may have regarding our privacy policy and any services that we offer to you. Please send an email to info@dentily.co.uk, write to us at Customer Services, 124 Finchley Road, London, NW3 5JS or call 0161-989-0608 if you have any questions or comments about your personal information.

Data Protection Policy
- Context and overview - Key details Introduction Dentily needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact. This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.   Why this policy exists This data protection policy ensures Your Smile Direct:
  • Complies with data protection law and follow good practice
  • Protects the rights of staff, customers and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach
Data protection law The Data Protection Act 1998 describes how organisations — including Dentily— must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. The Data Protection Act is underpinned by eight important principles. These say that personal data must:
  1. Be processed fairly and lawfully
  2. Be obtained only for specific, lawful purposes
  3. Be adequate, relevant and not excessive
  4. Be accurate and kept up to date
  5. Not be held for any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, risks and responsibilities Policy scope This policy applies to:
  • The head office of Dentily
  • All branches of Dentily
  • All staff and volunteers of Dentily
  • All contractors, suppliers and other people working on behalf of Dentily
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • ...plus any other information relating to individuals
Data protection risks This policy helps to protect Dentily from some very real data security risks, including:
  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
  • Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Responsibilities Everyone who works for or with Dentily has some responsibility for ensuring data is collected, stored and handled appropriately. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles. However, these people have key areas of responsibility:
  • The board of directors is ultimately responsible for ensuring that Dentily meets its legal obligations.
  • The Senior Leadership Team is responsible for:
    • Keeping the board updated about data protection responsibilities, risks and issues.
    • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
    • Arranging data protection training and advice for the people covered by this policy.
    • Handling data protection questions from staff and anyone else covered by this policy.
    • Dealing with requests from individuals to see the data Dentily holds about them (also called ‘subject access requests’).
    • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
  • The Senior Leadership Team is responsible for:
    • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
    • Performing regular checks and scans to ensure security hardware and software is functioning properly.
    • Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
  • The marketing team is responsible for:
    • Approving any data protection statements attached to communications such as emails and letters.
    • Addressing any data protection queries from journalists or media outlets like newspapers.
    • Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
General staff guidelines
  • The only people able to access data covered by this policy should be those who need it for their work.
  • Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
  • Dentily will provide training to all employees to help them understand their responsibilities when handling data.
  • Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
  • In particular, strong passwords must be used and they should never be shared.
  • Personal data should not be disclosed to unauthorised people, either within the company or externally.
  • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
  • Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
Data storage These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
  • When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
  • Data printouts should be shredded and disposed of securely when no longer required
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
  • Data should be protected by strong passwords that are changed regularly and never shared between employees.
  • If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
  • Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing data should be protected by approved security software and a firewall.
Data use Personal data is of no value to Dentily unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
  • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
  • Personal data should never be transferred outside of the European Economic Area.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
Data accuracy The law requires Dentily to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort Dentily should put into ensuring its accuracy. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
  • Dentily will make it easy for data subjects to update the information Dentily holds about them. For instance, via the company website.
  • Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
  • It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject access requests All individuals who are the subject of personal data held by Dentily are entitled to:
  • Ask what information the company holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date.
  • Be informed how the company is meeting its data protection obligations.
If an individual contacts the company requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email. The data controller will always verify the identity of anyone making a subject access request before handing over any information. Disclosing data for other reasons In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Dentily will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary. Providing information Dentily aims to ensure that individuals are aware that their data is being processed, and that they understand:
  • How the data is being used
  • How to exercise their rights
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company. Dentily