UK Smiles Privacy Policy
The Key Points
- UK Smiles Marketing Ltd is responsible for the personal information we collect about you (we are the “controller”).
- We collect your contact details, your enquiry, and, if you choose to send them, photos of your teeth and information about your dental and medical health, so that a dental clinic can prepare your treatment estimate.
- We share your information with the dental clinic in Türkiye that will treat you. The Clinic is responsible for the medical records it creates about you.
- We never sell your information.
- We only send you marketing if the law allows it, and you can opt out at any time.
- You have rights over your information, including to see it, correct it or ask us to delete it. Contact hello@uksmiles.co.uk.
1. Who we are
1.1 This Privacy Policy explains how UK Smiles Marketing Ltd (“UK Smiles”, “we”, “us”, “our”) collects and uses personal information about you when you visit our website, contact us, or use our services.
1.2 UK Smiles Marketing Ltd is a company registered in England and Wales with company number 12595335. Our registered office is 86–90 Paul Street, London EC2A 4NE, United Kingdom. We are registered with the Information Commissioner’s Office (ICO) under registration number ZC259424.
1.3 We are the controller of the personal information described in this Privacy Policy. If you have any questions, or want to exercise your rights, email hello@uksmiles.co.uk, call +44 7496 169630, or write to us at the address above.
1.4 We are a UK marketing and patient coordination company. We are not a dental or medical provider. Your treatment is provided by an independent dental clinic in Türkiye (the “Clinic”). Please read this Privacy Policy together with our Terms and Conditions.
2. The information we collect
2.1 Depending on how you deal with us, we may collect:
(a) Contact and identity details: your name, phone number, email address, the town or area you live in, and your date of birth or age.
(b) Enquiry and booking details: the treatment you are interested in, your quote, your preferred travel dates, flight details, and, where needed to arrange your booking, your passport details.
(c) Health information: photos of your teeth, X-rays, and information about your dental and medical history, medication, allergies and health conditions that you choose to share with us. This is “special category” data and we give it extra protection (see section 4).
(d) Payment details: records of payments you make to us, such as our Service Fee. Card payments are processed by our payment provider; we do not see or store your full card details.
(e) Communications: messages, emails, WhatsApp chats, call notes and other communications between you and us.
(f) Feedback and testimonials: reviews, feedback, and, only with your separate consent, photos, videos and testimonials for use in our marketing.
(g) Marketing preferences: whether you have agreed to receive marketing from us.
(h) Website and device information: your IP address, browser and device type, pages visited, and how you arrived at our website, collected through cookies and similar technologies (see section 9).
2.2 We collect this information from you directly, and from:
(a) advertising platforms, such as Facebook, Instagram, TikTok and Google, when you complete an enquiry form on their platforms;
(b) the Clinic, for example updates about your appointments, your treatment plan and aftercare; and
(c) a friend or family member who refers you to us or travels with you, where they have told you they are sharing your details.
3. How we use your information and our lawful basis
3.1 We use your information for the purposes below. For each, we rely on a “lawful basis” under UK data protection law.
(a) To respond to your enquiry and prepare your quote. Lawful basis: taking steps at your request before entering into a contract, and our legitimate interests in responding to enquiries.
(b) To arrange your booking, coordinate with the Clinic, and provide our services under our Terms and Conditions. Lawful basis: performance of our contract with you.
(c) To take and record payments. Lawful basis: performance of our contract with you.
(d) To help you after your treatment, pass on concerns to the Clinic and handle complaints. Lawful basis: performance of our contract with you, and our legitimate interests in looking after our customers.
(e) To send you marketing about our services. Lawful basis: your consent, or, where you have enquired about or bought our services, our legitimate interests in marketing similar services to you (you can opt out at any time).
(f) To show you relevant advertising and measure how well our advertising works. Lawful basis: your consent to non-essential cookies, and our legitimate interests in promoting our business.
(g) To use your photos, videos or testimonial in our marketing. Lawful basis: your consent, which you can withdraw at any time.
(h) To keep business and accounting records and comply with the law. Lawful basis: legal obligation.
(i) To establish, exercise or defend legal claims, and to protect our business. Lawful basis: our legitimate interests.
(j) To improve our website and services. Lawful basis: our legitimate interests, and your consent to analytics cookies.
4. Your health information
4.1 We only collect health information that you choose to give us. We use it only to obtain your treatment estimate and arrange your treatment with the Clinic, and to help you with aftercare and complaints.
4.2 We rely on your explicit consent to use your health information, which you give when you send it to us. We may also use it where necessary to establish, exercise or defend legal claims.
4.3 Our staff are not dentists. We pass your health information to the Clinic so that its dentists can assess it; we do not make clinical decisions.
4.4 You can withdraw your consent at any time by contacting us. This will not affect anything we have already done, but it may mean we cannot continue to help you with your treatment.
5. Who we share your information with
5.1 We never sell your personal information. We share it only as follows:
(a) The Clinic in Türkiye that provides your treatment, including its dentists and patient coordinators, so it can assess, plan and provide your treatment, arrange your hotel and transfers, and provide aftercare. The Clinic is responsible, as a separate controller, for the medical records it creates and holds about you.
(b) Service providers who help us run our business and act on our instructions, including providers of: website hosting; email, messaging and WhatsApp business tools; customer relationship management and spreadsheets; workflow automation; payment processing; quote and document tools; and email marketing.
(c) Advertising and analytics platforms, such as Meta (Facebook and Instagram), Google (including YouTube), and TikTok, to show and measure our advertising, subject to your cookie choices and marketing preferences.
(d) Review platforms, such as Trustpilot and Google, if you choose to leave a review or we invite you to.
(e) Our professional advisers, such as lawyers, accountants and insurers.
(f) Courts, regulators, the police or other authorities, where the law requires it or it is necessary to protect our rights or the safety of others.
(g) A buyer or successor of our business, if we sell or restructure it, who will be bound by this Privacy Policy.
6. Sending your information outside the UK
6.1 The Clinic is in Türkiye. Türkiye does not have a UK “adequacy” decision, so when we send your information to the Clinic we use safeguards approved under UK data protection law, such as the UK International Data Transfer Agreement or Addendum. Where that is not possible, we transfer your information only where it is necessary to arrange the treatment you have asked for, or with your explicit consent.
6.2 Some of our service providers (for example, Meta, Google and our payment and automation providers) may process information in the United States or elsewhere. Where they do, we rely on the UK–US data bridge, a UK adequacy decision, or other safeguards approved under UK data protection law.
6.3 You can ask us for more information about these safeguards by contacting us.
7. How long we keep your information
7.1 We keep your information only for as long as we need it:
(a) If you enquire but do not book: up to 2 years from our last contact with you.
(b) If you book with us: up to 6 years from the end of your treatment or our last contact with you, whichever is later (or for as long as a guarantee on your treatment applies, if longer), so that we can help with aftercare, guarantee claims and complaints, and deal with any legal claims.
(c) Financial and accounting records: 6 years from the end of the financial year they relate to, as required by law.
(d) Marketing preferences: until you opt out, after which we keep a record of your opt-out so that we do not contact you again.
(e) Photos, videos and testimonials used in our marketing: until you withdraw your consent.
7.2 After these periods, we securely delete or anonymise your information. We may keep it for longer if we are required to by law or need it for a legal claim.
8. How we protect your information
8.1 We use appropriate technical and organisational measures to protect your information, including access controls, secure systems, and limiting access to people who need it. Our service providers and the Clinic are required to keep your information secure and confidential.
8.2 If a data breach is likely to put your rights at risk, we will tell you and the ICO where the law requires it.
9. Cookies
9.1 Our website uses cookies and similar technologies. Strictly necessary cookies make the website work. We use other cookies, including analytics cookies (such as Google Analytics) and advertising cookies and pixels (such as those of Meta, Google and TikTok), only if you agree to them through our cookie banner.
9.2 You can change your cookie choices at any time through our cookie settings or your browser settings. Blocking some cookies may affect how the website works.
10. Marketing
10.1 We will only send you marketing by email, text or WhatsApp if you have agreed to it, or if you have enquired about or booked our services and have not opted out. Every marketing message will tell you how to opt out.
10.2 You can opt out at any time by using the unsubscribe link, replying STOP, or emailing hello@uksmiles.co.uk. We will still send you messages about your booking and treatment.
11. Your rights
11.1 You have the right to:
(a) ask for a copy of your personal information;
(b) ask us to correct information that is wrong or incomplete;
(c) ask us to delete your information;
(d) ask us to restrict how we use your information;
(e) object to our use of your information, including for direct marketing;
(f) ask us to transfer information you gave us to you or another organisation; and
(g) withdraw your consent at any time, where we rely on consent.
11.2 Some of these rights apply only in certain circumstances. To use any of them, email hello@uksmiles.co.uk. We will respond within one month. There is normally no charge.
11.3 Information held by the Clinic, including your medical records, is the Clinic’s responsibility. We will pass your request to the Clinic if you ask us to.
11.4 If you are unhappy with how we have handled your information, please contact us first. You also have the right to complain to the Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, www.ico.org.uk, telephone 0303 123 1113.
12. Children
12.1 Our services are intended for adults. We do not knowingly collect information from anyone under 18 without the involvement of their parent or guardian.
13. Automated decisions
13.1 We do not make decisions about you based solely on automated processing that have legal or similarly significant effects on you.
14. Changes to this Privacy Policy
14.1 We may update this Privacy Policy from time to time. The latest version will always be on our website, with the date it was last updated. If we make significant changes, we will tell you where appropriate.