NEOSMILE PRIVACY POLICY
Introduction
Neosmile values the confidentiality of your personal information and is committed to protecting it. This Privacy Policy (“Policy”) (along with our Cookies Policy) describes the basis on which we will process any personal data that we collect or that you supply to us, why we collect it and how we process that information. It does not include data where the identity has been removed (i.e. anonymous data).
Neosmile will protect your personal data in accordance with applicable law and our Privacy Policy. In addition, Neosmile maintains appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing and/or against accidental loss, alteration, disclosure, or access. For the purposes of applicable data protection laws (General Data Protection Regulation (EU Regulation) 2016/679) (GDPR) and implementing legislation, in particular the Data Protection Act (2018) and GDC, NHS and other standards, Neosmile is responsible for your personal information.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
You will be asked to provide personal information when joining the practice. The purpose of us processing this data is to provide optimum health care to you by, for example, recommending the most relevant treatment and ensuring your safety by taking your medical history.
Collection of your Personal Information
Neosmile collects information that, alone or in combination with other data, can be used to identify your personal information, such as your email address, name, address, phone number and any employment information. When you visit Neosmile, we collect and store your billing and credit card information. Neosmile may also collect anonymous demographic information that does not uniquely apply to you, such as your Zip Code and your Preferences (Non-Personal Information). Non-personal data is not linked to personal data particularly (such as IP addresses). Categories of personal information we collect includes-
- Contact data (such as name, address, email address, telephone number) for the purposes of corresponding with you, for example, regarding your appointments and treatment.
- Contact data (such as name, address, email address, telephone number) for the purposes of direct mail/email/text/marketing.
- Special category data concerning health (including health records, medical history, medication, your doctor’s name and address, warning cards or bracelets, alcohol and drug use) for the purposes of the delivery of safe health care.
- Treatment data (such as photos, moulds, X-rays, clinical findings) for the purposes of providing you with the best treatment.
- Financial data (such as credit card details, bank account information, credit history, employment status) for the purposes of processing your payment for treatment(s).
- Usage data (such as information about how you use our website, products and services) for the purposes of improving the way we provide our treatment and services.
Neosmile collects your personal information in a variety of ways in operating the website and performing any of our services and treatment(s), including when you contact us through the website, telephone, mail, email, or any of the other means listed below.
Information you give us (including information you give to our Clinical Lead, Specialists, Dentists, Hygienists and Orthodontic Therapists who are contracted to work for us). You may give us information about you by filling in forms on our website www.sensu.co.uk or any website wholly owned by Sensu, or by corresponding with us by phone, email, in person or otherwise.
Personal data is obtained when a patient joins the practice, when a patient is referred to the practice and when a patient subscribes to an email list.
Information you provide while registering for a new account-
When you register for a Neosmile account, you voluntarily provide us certain personally identifiable information, including:
Name, phone number as well as email address.
Billing information at the time of purchase or payment. This is required to complete the commercial transactions on the Site.
Third Party Information
Our Clinical Lead, Specialists, Dentists, Hygienists and Orthodontic Therapists are third parties working for us as contractors, however, they are contractually bound to us with regard to obligations of confidentiality in the same way as our employees and by professional obligations of confidentiality.
Third party information includes information you provide when you visit our websites, for the purpose of booking an appointment with a dentist at Neosmile, participate in discussion boards or other social media functions on our site and when you report a problem with our site. We collect personal information about you from third parties such as social networking sites and use this information to acquire potential customer leads.
We are also working closely with third parties (including, for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
We use third-party analytics services (such as Google Analytics) to evaluate your use of the website, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to our website and internet usage. These third parties use cookies and other technologies to help analyse and provide us with data.
Other Information we collect-
We also collect the following personal data when you use the website:
User Content: This includes any text, documents, content or information you upload, enter or otherwise submit in connection with your use of the Website.
Interaction with Neosmile via social media: You can engage with us through our social media sites or through features of the Neosmile site that are integrated with our social media sites. When you engage with us through social media sites, you may allow us to have access to certain information from your social media profile based upon your privacy preference settings on such platforms.
Automatically collected information: When you visit our website, we automatically collect information about your computer hardware and software such as your IP address, browser type, domain names, access times, operating system, cookie information, referring website addresses, pages visited, links clicked, text entered, and your Internet Service Provider. We analyse and use this information to better understand how our users use the service, to maintain and improve our service, and in some cases, to publicly disclose aggregated statistics regarding our services.
Use of your Personal Information
Neosmile collects and uses your Personal Information as necessary to perform our contract with you and for our legitimate business interests, including to:
Operate the Website and deliver the services.
Communication for example if you have problems accessing your account or wish to contact us about the services you use and respond to requests for assistance, including assistance with verifying your account.
View User Content associated with your account and make sure it is available when you use our Services.
Understand and improve how our users use and interact with our services.
Disclosing aggregate statistics about how our users use our services.
If you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or yourself taking steps to enter a contract. When processing payments made by you, we process your personal data to prevent or detect fraud, including fraudulent payments and website misuse. The legal basis for this processing is compliance with our legal obligations.
Sending marketing emails directly from a third-party partner with your consent.
Change of purpos
We will only use your personal information for the purposes for which it was collected, unless it must be passed down for another reason and that reason is consistent with the original purpose. Please note that we may process your personal data without your knowledge or consent when required or permitted by law.
Your decision to provide us with personal data is voluntary, except for certain information required by law or Neosmile guidelines. Therefore, even if you do not wish to provide personal data, you will not be subjected to adverse consequences. However, if you do not provide us with certain information, we may not be able to achieve some or all the purposes described in this Privacy Policy and may not be able to use certain tools or systems that require such use of personal data.
Personal Information access and disclosure
We will only disclose Personal Information to third parties:
When we use our Clinical Lead, Specialists, Dentists, Hygienists and Orthodontic Therapists, Private health insurance companies (at your request if you are using private health insurance), contractors, vendors, lawyers and service providers to assist us in meeting business or operating needs, such as providing legal services, hosting our website, communicating with users, delivering and improving our services, e-mail communication, invoicing and payments, customer support services and analytics. These service providers may only access, process or store personal information pursuant to our instructions and to perform their duties to us, and in accordance with applicable laws and regulations; or
When we have your explicit consent to share your Personal Information; or
When we determine that disclosure is required to protect the rights, property, or personal safety of Neosmile and users of the Website, or to respond to lawful subpoenas, warrants, or requests by public or regulatory authorities, including requests by law enforcement authorities; or
If we sell some or all of our business or assets, we may disclose your Personal Information to the prospective seller or buyer of such business or assets, and if the transaction closes, then your Personal Information may be transferred to the buyer.
We never pass your personal details to a third party unless we have a contract for them to process data on our behalf and will otherwise keep it confidential.
If we intend to refer a patient to another practitioner or to secondary care such as a hospital we will gain your consent before the referral is made and the personal data is shared.
The website may include links to third party websites, plugins 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 notice of every website you visit.
Lawful basis for processing personal data
The lawful bases for processing personal data (including providing your personal data to third parties) are:
Consent of the data subject for data relating to treatment, care, our services, processing payment, credit checks, marketing and reviews, improving our services and improving our website (including using data analytics). This will also apply to the storage of personal data for these purposes.
Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract such as the provision of the services by us.
Processing is necessary to comply with a legal obligation such as financial, tax and contractual laws.
The reason for processing special category data such as patients’ health data is:
The processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of Union or Member State law or a contract with a health professional; and
Data is processed by or under the responsibility of a professional subject to the obligation of professional secrecy under Union or Member State law or rules established by national competent bodies or by another person also subject to an obligation of secrecy under Union or Member State law or rules established by national competent bodies.
Purposes for processing personal data
We (and the third parties listed above) process your personal data for the following purposes:
To provide you with our services
To discuss relevant treatments.
To provide a safe working environment for staff, contractors and patients.
To check your employment and financial status for payment plans.
To process payments
To keep you informed of our latest offers, other services we provide and general marketing activities.
To obtain reviews and feedback on your experience of our services.
To store our data.
If you would like more information about how your data is processed, please contact us by using the details set out above.
Data Transfer
Neosmile may transfer certain personal data across geographical borders to Neosmile and its service providers in other countries, subject to applicable laws. Neosmile may transfer your personal data to other entities or persons in countries that guarantee the same level of data protection laws and regulations.
If you provide us with your information or use our website, we may collect, transfer, store and process your information. These transfers are subject to the European Union (EU) Standard Contractual Clauses or equivalent data transfer agreements designed to protect the security and confidentiality of personal data.
How we protect your data
We use appropriate data collection, storage, and processing practices to protect against unauthorised access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our website. We employ strict practices and security measures through appropriately executed contracts, where Neosmile ensures that its service providers commit to the “same level of data protection” as applicable data protection laws and regulations.
Neosmile has implemented appropriate physical, technical and administrative security measures to protect personal data from loss, misuse, alteration or destruction. Our service providers and agents must maintain the confidentiality of personal information and must not use the information for unauthorised purposes
Data retention
The retention period for special category data in patient records is a minimum of 10 years and may be longer for complex records in order to meet our legal requirements. The retention periods for other personal data is two years after it was last processed.
You will receive marketing emails until you unsubscribe, either by contacting us or by clicking on the unsubscribe link at the bottom of the email. For details of other retention periods please contact us using the details set out above.
Terms of Service
We understand that your satisfaction with our software tools / service is of utmost importance, and we strive to provide a seamless experience for our customers. However, we also recognise that situations may arise where a return or refund is necessary. Neosmile provides a variety of mechanisms that allows businesses to create & streamline communication, operations, and helps to track compliance and performance of employees, services, independent contractors as well as of the organisation. These Terms of Service govern the access and use of the Platform and any App. All terms of service shall be mutually agreed between both the parties and signed before any commencement of work.
Use of cookies
This website uses cookies to personalise your online experience. A cookie is a text file that we or our marketing partners place on your hard drive from a website server. Our cookies do not run programs or transmit viruses to your computer. A cookie is uniquely assigned to your computer and can only be read by a web server within the domain that issued the cookie to your computer. One of the main purposes of cookies is to provide a convenient feature that saves your time. Cookies explain the server that you returned to an appropriate page. For example, if you personalise a website page or register with a website, cookies help the website to remember certain information on subsequent visits. This simplifies the process of recording personal information such as that of billing address or website preferences. When you visit the same website again, you can retrieve previously provided information so that you can easily use the customised website features. We may place the following cookies:
Required cookies: These are cookies that are necessary for the operation of the website. These include, for example, cookies that allow you to log into secure areas of our website or use billing services.
Analytics/Performance Cookies: This allows Neosmile to recognise and count the number of visitors and see how they move around the website as they use it. This also allows us to improve the functionality of our website, such as making it easier for users to find what they are looking for.
Functionality cookies: These are used to recognise you when you return to the website. It allows you to personalise your content, greet you by your name, and remember your saved preferences.
Targeting cookies: These cookies record your visits to the website, the pages you visit and the links you follow. We use this information to make our website more relevant to your interests and for marketing as described below. If you want to see or change the types of cookies you accept, you can usually do it by visiting your browser settings. Third parties (including advertising networks and providers of external services such as website traffic analysis companies) may also use these cookies, over which we have no control.
How to refuse cookies
If you do not wish to receive cookies, you can opt out by changing your browser settings to decline cookies. If you refuse cookies, you may not be able to access all or some parts of Neosmile services or websites you visit, or you may not be able to fully use the interactive features of Neosmile services or websites. For general information about cookies, including how to disable them, visit https://www.aboutcookies.org . This website also contains details on how to remove cookies from your computer. For more information about our cookies, please check our Cookie Policy.
Data security and integrity
Neosmile is committed to taking reasonable and legitimate steps to protect the personal information we hold against misuse, loss or unauthorised access. We achieve this by various technical and organisational measures, including steps to address any suspected data breach. If you suspect any misuse, loss, or unauthorised access to your personal information, please notify us immediately. This website is designed to protect the personal information you provide to our computer servers in a controlled, secure environment that is protected from any unauthorised access, use or disclosure. When personally identifiable information (such as credit card numbers) is transmitted to other websites, it is protected using encryption, like the Secure Socket Layer (SSL) protocol.
Although we do our best to protect your personal information, we cannot guarantee the security of all information transmitted to the website or other websites over the Internet. If you have provided (or have chosen) a password to access certain areas of the site, please keep that password safe.
Your rights
We respect your rights to information, access, rectification, erasure or restriction, portability, objections and rights regarding automated decision-making and profiling when using your personal data in accordance with applicable laws. We also ensure that the personal information we collect is accurate and up-to-date and take steps to delete the information when it is no longer needed.
Your rights are subjected to the defined conditions, the possibility of exercising those rights and to the applicability of your geographical location.
You have the right to know what personal data we control about you, as long as it is applicable.
Upon request, we shall provide a copy of your personal data in a structured, commonly used and machine-readable format.
If your personal information is inaccurate or incomplete, you have the right to ask us to update it.
You have the right to object to our processing of your personal information only if the data is processed.
You may also request that we delete your personal information or restrict how we use your personal information, but this right is subject to applicable law and may affect your access to some of our services.
You have the right to access your personal information which may vary from visitor to visitor.
You have a right to object to processing your personal information where it is so conducted by automated means and involves any kind of decision-making subject to discovery that your data was used for automated means.
You also have the right to lodge a complaint with the competent authority if you believe that the processing of your personal data violates applicable law. We will respond to requests in accordance with applicable data protection laws. We may decline requests that are unreasonably repetitive, require excessive technical effort, violate the privacy of others, jeopardise ongoing investigations, or are unrealistic. We will never discriminate against you for exercising any of these rights. To exercise your rights, please contact our Data Protection Officer in writing. Details are provided in the Contact Information section of this notice.
Revision of Privacy Notice
This Privacy Policy may be updated annually or from time to time in accordance with applicable laws, regulatory changes, court precedents, or notices from supervisory or regulatory authorities. If changes to our privacy policy materially affect your rights, we will notify you. Such Privacy Policy changes will apply from the effective date specified in the notice posted on the Website. We encourage you to periodically review the notice for the latest information on our privacy practices.
Acceptance of these terms
By using this website, you agree to this policy. Your continued use of the site following the posting of any changes to this policy constitutes your acceptance of those changes
Complaint resolution
If you believe that we have not complied with this Policy or your data protection rights, you have the right to lodge a complaint with the UK Information Commissioners Office. However, we would appreciate it if you could try to resolve the complaint with us first. Please contact us for more information.
Third party advertising
We use remarketing services to advertise our products on a third party website after you visit our website.
Links to third party sites
Our website contains links to other websites whose privacy practices are not controlled by Neosmile. If you submit personal information to one of these websites, that information will be governed by that website privacy policy. We encourage you to carefully read the privacy policy of each website you visit.
Contact Information
If you have any questions or complaints about this statement, our privacy and information handling practices, you may contact our Data Protection Officer using the details below: -
Email ID: admin@neosmile.co.uk