Privacy Policy

Martin Docking Limited T/A Revitalise, a company registered in England under company number 04058267 whose registered office is at 1 Abacus House, Newlands Road Corsham, Wiltshire SN13 0BH (hereinafter referred to as ‘Revitalise’ or ‘We’ or ‘Us’ or ‘Our’) have created this privacy statement (‘Statement’) in order to demonstrate Our firm commitment to the privacy of the details that You provide to Us when using the Site to access Our Services.

We are committed to protecting and respecting Your privacy and Your Personal Data. For the purpose of the Data Protection Legislation, We are the Data Controller (ICO registration number: ZA479990)

For all matters relating to privacy and data protection, please contact, Alison Middleton, Our Data Protection Manager (DPM) by email to dpm@revitalise.co.uk or by telephone to 01872 555911.

We are regulated by the General Dental Council (GDC) and the Care Quality Commission (CQC)

In this Privacy Statement, references to ‘You’, ‘Your’ and ‘Patient’ are references to Patients who use the Site.

We aim to be as clear as possible in this Privacy Statement in respect of Your Personal Data. This Privacy Statement applies to Your Personal Data that We collect about You when You use the Site, how and when it is used, how We protect it and who has access to it (the ‘Terms’).

This Privacy Statement incorporates Our Website Terms of Use and Cookie Policy by this reference.

• Your Acceptance of this Privacy Statement
• What Personal Data is collected & how?
• How is Your Personal Data used?
• Who has access to Your Personal Data?
• How do We protect Your Personal Data and for how long?
• Do We use cookies?
• Complaints or queries
• Your rights under Data Protection Legislation?
• Definitions & Interpretations
• Changes to this Privacy Statement

1. YOUR ACCEPTANCE OF THIS PRIVACY STATEMENT

   This Privacy Statement governs Your use of Our Services, including any dispute concerning privacy. By using Our Services, You accept this Privacy Statement in full. You should read the Statement carefully and ensure that You understand its effect before proceeding to use the Site to access Our Services.

   We reserve the right to make reasonable changes to any of the Terms at any time. Any changes We do make will be posted on this page and, where appropriate, notified to You by email, or, when You next log in, the new Terms may be displayed on-screen and You may be required to read and accept them to continue.

   Personal Data and Special Category Personal Data are defined in accordance with the Data Protection Legislation. In this Privacy Statement, Personal Data shall include the meaning of Special Category Personal Data.

2. WHAT PERSONAL DATA IS COLLECTED & HOW?

   PERSONAL DATA SUBMITTED VOLUNTARILY BY YOU TO US:

   1. In order for Us to provide You with Our Services, We collect various types of Personal Data. We are committed to ensuring that the information We collect and use is appropriate, relevant and proportionate for the stated purpose. Some types of Personal Data may be voluntarily provided by You which is to be shared with Us (and Our Service Providers as applicable) in respect of Yourself (or in respect of one or more other individuals where lawful authority is granted to You by those other individuals) which shall include as follows:

      What Personal Data is processed?	Source: Where is it collected from/ via?	What is the ‘purpose’ of processing? & What is the lawful basis (Article 6) for processing?	Retention: For how long is it held?
      Name, address, phone number (home and mobile) email address, date or birth, occupation.	Patient or referral from Changing Faces	To provide Our services to You. Processing is necessary for the performance of a contract Article 6(1)(b) GDPR which are defined at Clause 9.	We will retain Your personal data for up to 8 years according to Private Dentistry Regulations 2017 (HIW). If You have given us Your personal data at a show where We are exhibiting, We will keep this for up to 12 months, unless You go on to become a patient of Ours.
      Photograph	Patient	To identify You when You visit Our premises. Processing is necessary as it is in Yours and Our legitimate interest as set out in Article 6(1)(f) GDPR which are defined at Clause 9.	We will retain Your personal data for up to 8 years according to Private Dentistry Regulations 2017 (HIW).
      Medical history and Dental records (consent to treatment, X-rays, scans, Medical photographs)	Patient	To provide Our services to You for the benefit of Your patients. Processing is necessary for the performance of a contract Article 6(1)(b) GDPR which is defined at Clause 9. If You attend a show which We are exhibiting at, We may offer You the opportunity to see how Our teeth whitening products may work. We process this category of personal date with Your consent as set out in Article 6(1)(a) GDPR which is defined at Clause 9 We process this special category data under the lawful grounds “provision of health and social care” set out in Article 9(2)(h) GDPR which is defined at Clause 9	We will retain Your personal data for up to 8 years according to Private Dentistry Regulations 2017 (HIW). If You have had a photograph taken at a show where We are exhibiting this is taken on the local mobile device (such as an iPad), and not uploaded to the cloud. It is deleted straight away. We will keep Your consent statement for up to 12 months.
      Next of Kin details	Patient	For use in the case of an emergency. Processing is necessary as it is in Yours and Our legitimate interest as set out in Article 6(1)(f) GDPR which are defined at Clause 9.	We will retain this Personal Data while You are registered with Us.

   2. Some of the information collected in the table above is essential for Us to provide You with Our Services but it is Your choice whether You provide all the information We request. Not providing information may affect Our ability to provide all of Our Services to You.
   3. We will retain Your Personal Data only for as long as is necessary to provide Our Services which You request and in accordance with the retention periods set out in this Privacy Statement. We shall then delete it unless You ask Us not to, or We have a legitimate reason to retain it. We need to retain sufficient information about You in compliance with certain legal or statutory requirements, for example, in the event of a legal or insurance claim in the future so that We can identify You.
   4. Where We state that We rely on consent under Article 6(1)(a) to process Your Personal Data for a particular purpose as per column 3 of the table at Clause 2.1, You have the right to withdraw Your consent at any time. This will not affect the lawfulness of processing carried out by Us which was based on consent before its withdrawal.

   PERSONAL DATA AUTOMATICALLY COLLECTED BY US:

   1. As part of the process of using Our Services, We may also collect the following types of Personal Data automatically about You via Your use of cookies and other technologies:
      • Your visits to the Site and the Content that You download;
      • Your IP address;
      • Your geographical location;
      • Your browser type and version;
      • Your operating system;
      • Your referral source;
      • Your length of visit;
      • Your page views and Site navigation and exit;

      To learn more, please see our Cookie Policy.

   2. We agree to adhere to all Data Protection Legislation and will take appropriate technical and organisational security measures against the unauthorised or unlawful processing of Your Personal Data and against accidental loss or destruction of, or damage to, Your Personal Data.
   3. We shall process Personal Data listed in the table at Clause 2.1 only to the extent, and in such a manner, as is necessary for the sole purpose of fulfilling Our Services (including making improvements to Our Services). For the avoidance of doubt, We are the exclusive owner (or lawful licensee) of the Site as well as the Content.

   FINANCIAL PERSONAL DATA

   1. We will process Your financial data solely for the purposes of paying for Our Services rendered. We use Lloyds (Streamline) and Apple Pay. We regularly update Our PCI DSS according to current banking guidelines.

3. HOW IS YOUR DATA USED?

   1. We will process the Personal Data You provide in a manner that is compatible with the Data Protection Legislation.
   2. We will try Our best to keep Your Personal Data accurate and up-to-date and We shall not keep it for longer than is necessary. Our aim is not to be intrusive and We undertake not to ask You irrelevant or unnecessary questions. Moreover, the information You provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
   3. NON-MARKETING COMMUNICATIONS: You acknowledge that, Your Personal Data may be used by Us to contact You when necessary in connection with Your use of the Site to access Our Services or when you are a patient of Ours as follows:

      What Type of Non-Marketing Communication?	Method of presentation/ sending?	Legal Basis for processing?
      We will remind You of Your appointment time on the day before.	Electronic Mail and Live Calls according to Your preference.	We do not need Your explicit consent for this as it is in Our legitimate interest to be able to contact You regarding appointments as set out in Article 6(1)(f) GDPR.
      Treatment plans	Postal Notification	We do not need Your explicit consent for this as the “processing is necessary for the performance of a contract” under Article 6(1)(b) GDPR.

   4. MARKETING:

      PROFILING: We may from time to time use publicly available demographic information to determine who We target for specific events or marketing campaigns so as to avoid contacting individuals unnecessarily. You have the right not to be subject to a decision based solely on automatic processing (Article 22). We undertake profiling when We use retargeting adverts when You have visited Our website or Facebook Page. In order to manage Your cookie preferences via Our Cookie Preference Management Tool, please see Our Cookie Policy.

   5. SOCIAL MEDIA
      Social media plugins: On Our Site, We have included social media plugins that You can use to share certain content over social networks. To protect Your privacy, We offer You these social plugins as so-called “2-click buttons.” The “2-click solution” prevents data (e.g. Your IP address) from being transmitted to social networks such as Facebook or Twitter as soon as You open Our website. For this purpose, the buttons are deactivated by default and are only activated by clicking the social plugins for the first time. After activation, the plugins also collect Personal Data such as Your IP address and send it to the servers of the respective provider where it is stored. In addition, activated social plugins set a cookie with a unique identifier when loading the relevant website. This also allows providers to create profiles of Your usage behaviour. The data will be used to show You personalized advertising, as well as for market and opinion research purposes.
      Data transfer is independent of whether You have an account with the plugin provider and are logged in there. If You are logged in with the plugin provider, Your data collected with Us will be assigned to Your existing account with the plugin provider.
      We have no exact information about the concrete use of the data nor about the storage period. Please read the privacy policy of the respective providers. We have integrated the plugins of the following providers on Our website:
      • Facebook (Facebook Inc., USA, Data protection declaration: http://www.facebook.com/policy.php)
      • Twitter (Twitter Inc., USA; Data protection declaration: http://twitter.com/privacy/)
      • LinkedIn (LinkedIn Ireland Unlimited Company; https://www.linkedin.com/legal/privacy-policy)

4. WHO HAS ACCESS TO YOUR DATA?

   1. We have a legitimate interest in sharing Your Personal Data with Service Providers who We engage to provide some of Our business and daily operational functions on Our behalf. Consequently, We need to disclose Your Personal Data to them for the sole purpose of fulfilling Our Services only (including making improvements to Our Services). We limit the Personal Data that We share to the minimum required to provide the Services and the Service Provider will only be able to use the Personal Data for the specific purposes for which it was shared with them by Us. We do not need Your express consent for this as We rely on legitimate interests under Article 6(1)(f) GDPR in addition to the fact that the “processing is necessary for the performance of a contract” under Article 6(1)(b) GDPR.
   2. Disclosure of Your Personal Data in Compliance with Laws or by way of a Legal/Statutory Obligation
      You should be aware that We may release Your Personal Data when We believe it is necessary to comply with laws or regulations, to assist law enforcement, to enforce the terms under which You transact or communicate with Us, or to protect Our rights, property or safety of or those of a Patient or other third parties. We may need to process Personal Data about You to comply with a legal or statutory obligation including but not limited to:
      (a) accounting, auditing, compliance and administration practices; and,
      (b) the maintenance of amendments to consents and to create suppression lists to ensure a Patient who objects to processing are excluded from the relevant processing activity in the future.
   3. Transfer of Your Personal Data (to third party Data Processors)
      From time to time, We may transfer Your Personal Data to a related company, agent or contractor (also known as Service Providers and third party Data Processors) in order to perform certain business services for Us, improve Our Services or to assist Our security, credit risk or fraud protection activities and as permitted by Data Protection Legislation.

      Name or category of Service Provider	Processing Activity?	Where is the data transferred to? & what level of protection is given to it?
      Marketing Agency	Marketing, creating Our email newsletters, SEO, Google Ad Words	Your Personal Data will only be stored within the United Kingdom. You are deemed to consent to this by using the Services. Should We need to transfer Your Personal Data outside of the UK or EEA in the future, it will be in compliance with the GDPR requirements for external transfer and all details will be added to Our Privacy Statement.
      Dental Prosthetic Manufacturers	So that We can arrange to have Dental Prosthetics made for You.	Your Personal Data will only be stored within the United Kingdom. You are deemed to consent to this by using the Services. Should We need to transfer Your Personal Data outside of the UK or EEA in the future, it will be in compliance with the GDPR requirements for external transfer and all details will be added to Our Privacy Statement.
      Digital Dental Design Partners	So that We can diagnose and provide You with the correct treatment or devices.	Your Personal Data is transferred and stored outside of the European Economic Area (the “EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, Liechtenstein.). It is stored by Our US Data Processors and is safeguarded by Standard Contractual Clauses.
      IT Consultants	Ad Hoc help with Our IT systems	Your Personal Data will only be stored within the United Kingdom. You are deemed to consent to this by using the Services. Should We need to transfer Your Personal Data outside of the UK or EEA in the future, it will be in compliance with the GDPR requirements for external transfer and all details will be added to Our Privacy Statement.

   4. Transfer of Your Personal Data to independent Data Controllers
      From time to time, We may transfer Your Personal Data to a related company, agent or contractor (also known as an independent Data Controller) e.g. where We refer You to a fellow Health Care Professional

      Name of Independent Data Controller?	What Personal Data is transferred/ shared?	Purpose of Sharing?	What is the lawful basis for processing i.e. sharing the Personal Data (as applicable from Article 6 and/ or Article 9)?
      Health Care Professionals	Name, contact details, medical or dental information as appropriate	To facilitate further treatment as necessary.	Processing is necessary under the lawful basis of ‘legitimate interest’ Article 6(1)(f) GDPR which are defined at Clause 9. We process this special category data under the lawful grounds “provision of health and social care” set out in Article 9(2)(h) GDPR which are defined at Clause 9
      Dental Health Plan Providers	Name, contact details, medical and dental details as necessary, bank details	To facilitate payment plans or insurance for dental treatment.	We are relying on the lawful basis of consent as set out at Article 6(1)(a) GDPR which are defined at Clause 9. You will be subject to the terms of these Data Controllers as set out in their Terms of Service and Privacy Statements. Special category data will be processed on the lawful basis of explicit consent set out in Article 9(2)(a) GDPR which are defined at Clause 9
      Accountants, Solicitors.	Company name, contact details, bank details	To assist with the efficient and lawful running of Our business.	We are relying on the lawful basis of Our contract with You as set out at Article 6(1)(b) GDPR which are defined at Clause 9

   5. Transfer of Your Personal Data to Joint Data Controllers
      We do not transfer Your Personal Data to any Joint Data Controllers. However, we maintain a Facebook Page. In this instance, Facebook is considered to be a Joint Data Controller with Us.

      Name of Joint Data Controller?	What Personal Data is transferred/ shared?	Purpose of Sharing?	What is the lawful basis for processing i.e. sharing the Personal Data (as applicable from Article 6 and/ or Article 9)?
      Facebook (through the use of Our page)	Name, contact details and any other personal identifiable details as is placed on Facebook by the Data Subject and made accessible to the Data Controller.	So that the Data Subject can be a part of the Facebook Page community. More information can be found on Facebook here.	We are relying on Your consent set out in Article 6(1)(a) GDPR Where Our customers share their own special category data, we will be relying on Article 9(2)(e) GDPR where the data is manifestly made public (We are defining ‘public’ as in the Facebook Audience and this is in accordance with Facebook’s terms and conditions)

   6. Transfer of Personal Data in the Event of the Sale of Revitalise or its Assets
      In the event that Revitalise is sold or transfers some of its assets to another party, Your Personal Data could be one of the transferred assets. If Your Personal Data is transferred, its use will remain subject to this Privacy Statement. Your Personal Data will be passed on to a successor in the event of a liquidation or administration.
   7. Other Websites and their Privacy Policies and Cookie Policies
      The Site may contain links to other websites or applications. We are not responsible for the privacy practices or the content of such websites or applications or for the privacy policies, cookie policies and practices of other third parties, so You should be careful to read and understand those policies independently.

5. HOW DO WE PROTECT YOUR PERSONAL DATA & FOR HOW LONG?

   1. We aim to ensure Our Services are fully inclusive and accessible to everyone. To make this possible, We need to collect (and may provide to prospective Service Providers) information on Your usage of Our Services which will help us review the accessibility of, and Your usage of, Our Services. This information is very important to Us as it also enhances Our understanding of the Patient needs and helps Us to help the technical administration of the Site, to better understand how the Site is functioning and to draw conclusions upon demographic information. Such information is provided in anonymised and aggregate form and do not include any individually identifiable data.
   2. RETENTION: How long We keep Your Personal Data depends on the context in which You provide it and the purpose for which We use it. We will only retain it for as long as is necessary for such purposes. Our retention periods are set out in this Privacy Statement in the tables at Clauses 2.1

6. DO WE USE COOKIES?

   For information about cookies and how they are used on the Site, please visit Our Cookie Policy.

7. YOUR RIGHTS UNDER DATA PROTECTION LEGISLATION

   1. You have a number of rights that You can exercise free of charge and on request in certain circumstances, however, if Your requests are obviously unfounded or excessive, We reserve the right to charge a reasonable fee or to refuse to act. You have the right:
      • to be informed about the collection and use of Your personal data;
      • to access Your Personal Data and supplementary information;
      • to have inaccurate Personal Data corrected, or completed (if it is incomplete);
      • to have Your Personal Data erased;
      • to restrict Our processing of Your Personal Data
      • to receive a copy of any Personal Data You have provided to Us, in a machine-readable format, or have this information sent to a third party (portability);
      • to object at any time to processing of Your Personal Data for direct marketing purposes;
      • to object in certain other situations to the continued processing of Your Personal Data.

      For more information on these rights and when You can exercise them, see the Information Commissioner’s Guide

   2. If You wish to exercise any of these rights, please complete Our Data Subject Rights Request Form. We will respond to You within one month from when We receive Your request, unless the complexity and number of requests We receive means that we need more time. If We do need more time (up to two further months), We will tell You why within the first month.

8. COMPLAINTS OR QUERIES

   We try to meet the highest standards when collecting and using Personal Data. For this reason, We take any complaints We receive about this very seriously. We encourage You to bring it to Our attention. We are happy to provide any additional information or explanation needed in respect of Our processing activities upon request. If You are still not happy with the way in which Your Personal Data is being processed by Us, You also have the right to lodge a complaint with the Information Commissioner’s Office if You are in the UK, or with the supervisory authority of the European Member State where You work, normally live or where the alleged infringement of data protection laws occurred. The Information Commissioner’s Office can be contacted here.

9. DEFINITIONS & INTERPRETATIONS

   Article 6(1) GDPR: as found here.

   Article 9(2) GDPR: as found here.

   Content: the content including all Intellectual Property Rights therein residing on the Site (which may or may not include Personal Data).
   Data Controller: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data (Article 4(7));

   Data Processor: means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Data Controller (Article 4(8));Data Protection Legislation: means, as applicable to either Party:

   (a) the General Data Protection Regulation 27 April 2016;
   (b) the Data Protection Act 2018;
   (c) the Privacy and Electronic Communications (EC Directive) Regulations 2003;
   (d) any other applicable law relating to the Processing, privacy and/or use of Personal Data, as applicable to either Party;
   (e) any laws which implement any such laws; and,
   (f) any laws that replace, extend, re-enact, consolidate or amend any of the foregoing.

   Data Protection Manager (DPM): Alison Middleton, dpm@revitalise.co.uk

   Data Subject Access Request or ‘DSAR’: refers to right of access as further described in the table at Clause 7.

   Electronic Mail: includes email, text, video, voicemail, picture and answerphone messages (including push notifications).

   General Data Protection Regulation or GDPR: the General Data Protection Regulation ((EU) 2016/679). Personal data is subject to the legal safeguards specified in the Data Protection Legislation including the GDPR.

   Intellectual Property Rights: patents, rights to inventions, copyright and neighbouring and related rights, trademarks and service marks, business names and domain names, rights in get-up and trade dress, goodwill and the right to sue for passing off or unfair competition, rights in designs, database rights, rights to use, and protect the confidentiality of, confidential information (including know-how and trade secrets) and all other intellectual property rights, in each case whether registered or unregistered and including all applications and rights to apply for and be granted, renewals or extensions of, and rights to claim priority from, such rights and all similar or equivalent rights or forms of protection which subsist or will subsist now or in the future in any part of the world.

   Marketing: refers to Marketing done via social media, SEO or PPC. This is subject to our Cookie Policy which you can view for more information about how you can manage your cookie preferences.

   Non-Marketing Communication(s): refers to any communication which is functional/administrative only as distinct from Marketing Communications.

   Personal Data: has the meaning set out in the Data Protection Legislation.

   Service Provider(s): refers to third party Data Processors or Data Controllers with whom We work with from time to time as a necessary part of providing Our Services and with whom We may need to share Your Personal Data with from time to time.

   Services: refers to Our Services We may provide to You.

   Special Category Data: is defined under Article 9 of the GDPR as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

   Patient: refers to the person using the Site.

10. CHANGES TO THIS PRIVACY STATEMENT

    We keep Our Privacy Statement under regular review. This Privacy Statement was last updated on 30 May 2019.

    Contains public sector information from https://ico.org.uk licensed under the Open Government Licence v3.0.