SmilePass Ltd take your privacy very seriously and abide fully with the provisions of the European Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and seeks therefore to fully comply with this Directive however it has been implemented into the individual laws of member states. We comply fully with the Principles of the UK Data Protection Act 1998 in that data processed and held by SmilePass is:
- Processed fairly and lawfully
- Processed only for one or more specified and lawful purpose
- Adequate, relevant and not excessive for those purposes
- Accurate and kept up to date – data subjects have the right to have inaccurate personal data corrected or destroyed if the personal information is inaccurate to any matter of fact
- Kept for no longer than is necessary for the purposes it is being processed
- Processed in line with the rights of individuals – this includes the right to be informed of all the information held about them, to prevent processing of their personal information for marketing purposes, and to compensation if they can prove they have been damaged by a data controller’s non-compliance with the Act
- Secured against accidental loss, destruction or damage and against unauthorised or unlawful processing – this applies to you even if your business uses a third party to process personal information on your behalf
- Not transferred to countries outside the European Economic Area – the EU plus Norway, Iceland and Liechtenstein – that do not have adequate protection for individuals’ personal information, unless a condition from Schedule four of the Act can be met
We also seek to comply with the legal requirements appertaining to data processing in countries that are not subject to European law by taking the approach of:
- Ensuring that personal data is only obtained for the purposes of using the services agreed to between SmilePass Ltd and the customer
- Only requesting, processing and storing data that is required to provide the service to the customer as agreed to in the Terms and Conditions, as accepted by the customer
- Only keeping such data for a period that is required for the continuation of the service provided to the customer
- Deleting, or otherwise making inaccessible, any data that is no longer required to ensure the provision of the service provided to the customer
- Only processing data that is in line with the rights of data subjects and having in place a policy of informing, on request, details of the data so held to the data subject
- Ensuring that all data obtained, processed and stored by SmilePass Ltd is secured against accidental loss, destruction or damage and against unauthorised or unlawful processing and rigorously testing and revising data processing policies and procedures on a regular basis
- Not sharing personal data for marketing purposes, or transferring that data otherwise than as agreed by the customer in acceptance of the General Terms and Conditions
What information do we collect?
We collect information on our website users in several ways, including through cookies, registration and emails sent to us via our website. Our information collection includes the following:
- To use the full range of services offered by SmilePass Ltd we require users to register on our website and to provide us with a name, telephone number, email address (if they have one) and postal address. We may also ask for additional information to assist us with our development of new products.
- If you purchase a product through our website we will require you to provide us with the above information plus your payment and delivery details. Any credit, debit, or bank details supplied will not be stored by SmilePass Ltd, but processed and held as appropriate by our payment gateway provider.
- If you send us email messages, you will automatically provide us with your electronic mail address, as well as any other personally identifiable information you include in the text of your message.
- We collect and store from all visitors to our website, whether they actively provide us with information or merely browse our website, the internet protocol (IP) address of the computer they are using, the browser software they use and their operating system, the date and time they access our website, the internet address of the website from which they linked directly to our website. We use this type of information to track website usage, to measure the number of visitors to the different sections of our website and to help us make our website more useful.
What do we do with the information we collect?
We use personal information to provide you with the services and goods you have requested. Unless you have informed us that you do not wish to receive such information, we or our agents may periodically contact you about our products and services.
We may perform statistical analyses of user behaviour (for example, by analysing the website usage data gathered passively from all users) in order to measure relative consumer interest in the various areas of our website. These analyses assist us in our product development efforts.
With whom do we share the information we collect?
We will only also share personally identifiable information if you have given us permission to do so and we will share your personally identifiable information if required by law to do so, including in response to legal processes, such as a court order or subpoena, or to comply with other federal, state or local laws.
We may disclose statistical information to third parties in aggregate form without revealing any personal details about our users (for example, 50% of our customers buy product parts online). SmilePass Ltd will not reveal your personal identity in connection with the disclosure of such information.
What opt out rights and rights to obtain details of the information we hold on you do you have?
Where you to opt in to marketing communications, we may contact you using the address and email address that you have provided.
If you wish to opt out of being contacted by SmilePass Ltd or its agents about our products and services, you may either do so at the time you provide us with your contact details, or at any time by:
- Using the unsubscribe option included in all our email correspondence, or
- Sending an email to email@example.com, or
- Writing to us at SmilePass Ltd, 1 Knightsbridge, Knightsbridge, London, SW1X 1HQ.
We will provide users of our website with details of the contact information that we hold on them upon request within 30 days. To make such a request, send an email to firstname.lastname@example.org, or write to us at SmilePass Ltd, 1 Knightsbridge, Knightsbridge, London, SW1X 1HQ.
If any of the information that you have provided to SmilePass Ltd changes, for example if you change your e-mail address, name or postal address, please let us know the correct details by an e-mail to email@example.com.
Links to third party websites
As a service to you, we may provide links to websites operated and controlled by third parties. Those third parties have their own information collection practices. We are not responsible for their information collection practices or for the content of their sites. We encourage you to review carefully the privacy policies of all websites, including those websites which can be accessed from this site.
What kind of security is used to protect your information?
All information about you that we store on our web server is in secure databases protected through a variety of technical access controls.
For more information on the data privacy principles of SmilePass Ltd, please email us at firstname.lastname@example.org.
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