Question 1

BACKGROUND:

Accepted Answer

Tooth Fairy Healthcare Ltd understands that your privacy is important to you and that you care about how your personal data is used. We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.   Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Platform. If you do not accept and agree with this Privacy Policy, you must stop using Our Platform immediately.

Question 2

1. Information About us

Accepted Answer

Our Platform is owned and operated by Tooth Fairy Healthcare, a limited company registered in England under company number 11118805. Registered address: Kemp House, City Road, London, EC1V 2NX Data Protection Officer: Kian Dhinsa Email address: office@toothfairyapp.co.uk Postal Address: Kemp House, City Road, London, EC1V 2NX.

Question 3

2.What Does This Policy Cover?

Accepted Answer

This Privacy Policy refers only to your use of Our Platform. Our Platform contains links to other sites. Please note that We have no control over how your data is collected, stored, or used by other sites and We advise you to check the privacy policies of any such sites before providing any data to them.

Question 4

3.What is Personal Data?

Accepted Answer

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

Question 5

4. What Are My Rights?

Accepted Answer

Under the GDPR, you have the following rights, which We will always work to uphold: The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15. The right to access the personal data We hold about you. Part 13 will tell you how to do this. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that We have. Please contact us using the details in Part 15 to find out more. The right to restrict (i.e. prevent) the processing of your personal data. The right to object to us using your personal data for a particular purpose or purposes. The right to data portability. This means that, if you have provided personal data to us directly, We am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases. Rights relating to automated decision-making and profiling. For more information about our OR my use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

Question 6

5. What Data Do We Collect?

Accepted Answer

Depending upon your use of Our Platform, We may collect some or all of the following personal and non-personal data): Name; Date of birth; Gender; Address; Email address; Telephone number; Dental / medical history Payment information; Information about your preferences and interests; IP address; Web browser type and version; Operating system; A list of URLs starting with a referring Platform, your activity on Our Platform, and the Platform you exit to.

Question 7

6. How Do You Use My Personal Data?

Accepted Answer

Under the GDPR, We must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for [one of] the following purposes: Providing and managing your Account; Providing and managing your access to Our Platform; Personalising and tailoring your experience on Our Platform; Supplying services to you. Your personal details are required in order for us to enter into a contract with you. Personalising and tailoring dental services for you. Communicating with you. This may include responding to emails or calls from you. Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time. Analysing your use of Our Platform and gathering feedback to enable us to continually improve Our Platform and your user experience.   With your permission and/or where permitted by law, We may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Question 8

7. How Long Will You Keep My Personal Data?

Accepted Answer

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data is stored in line with CQC, Department of Health and NHS Regulations. We will retain your records from consultations for a maximum of 30 years. In line with the NHS regulations the minimum time we will keep records will be 11 years (adults) or to the age of 25 years (children). Unless there is a regulatory or legal reason to retain personal data, we will delete personal data for patients who have not been active on our platform for 5 years.

Question 9

8. How and Where Do You Store or Transfer My Personal Data?

Accepted Answer

We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.

Question 10

9. Do You Share My Personal Data?

Accepted Answer

We contract with the following third parties to supply certain products and services. These include dental care, emergency care, payment processing and marketing. In some cases, those third parties require access to some or all of your personal data that We hold. If any of your personal data is required by a third party, as described above, We will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above.

Question 11

10. How Can I Control My Personal Data?

Accepted Answer

In addition to your rights under the GDPR, when you submit personal data via Our Platform, you may be given options to restrict our use of your personal data. In particular, We aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails, at the point of providing your details and by managing your Account). You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

Question 12

11. Can I Withhold Information?

Accepted Answer

You may access certain areas of Our Platform without providing any personal data at all. However, to use all features and functions available on Our Platform you may be required to submit or allow for the collection of certain data. You may restrict our use of Cookies.

Question 13

12. How Can I Access My Personal Data?

Accepted Answer

If you want to know what personal data We have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. If you wish to have access to your records, this is within your legal rights. The right of access to records is available under the Data Protection Act or the Access to Health Records Act. There will be an administration charge to access for records, A discretionary fee of up to £10 can be charged and disclosure will take place as quickly as possible but in any event within 40 days of receipt of the signed patient authority (request). If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within 40 days of receiving it. Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of our progress.

Question 14

13. How Do You Use Cookies?

Accepted Answer

Our Platform may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Platform and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times. All Cookies used by and on Our Platform are used in accordance with current Cookie Law. Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Platform may not function fully or as intended. Certain features of Our Platform depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings, but please be aware that Our Platform may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them. Our Platform uses analytics services. Analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Platform is used. This, in turn, enables us to improve Our Platform and the services offered through it. The analytics service used by Our Platform uses Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Platform, it does enable us to continually improve it, making it a better and more useful experience for you. In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Platform more quickly and efficiently including, but not limited to, login and personalisation settings. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

Question 15

14. How Do I Contact You?

Accepted Answer

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Deepak Aulak): Email address: office@toothfairyapp.co.uk Postal Address: Tooth Fairy, Kemp House, City Road, London, EC1V 2NX.

Question 16

15. Changes to this Privacy Policy

Accepted Answer

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change our business in a way that affects personal data protection. Any changes will be immediately posted on Our Platform and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Platform following the alterations. We recommend that you check this page regularly to keep up-to-date.

Question 17

SUMMARY:

Accepted Answer

Our Platform is owned and operated by Tooth Fairy Healthcare, a limited company registered in England under company number 11118805. Registered address: Kemp House, City Road, London, EC1V 2NX Data Protection Officer: Kian Dhinsa Email address: office@toothfairyapp.co.uk Postal Address: Kemp House, City Road, London, EC1V 2NX.

Question 18

Consultation Recording

Accepted Answer

Some consultations may be recorded and stored in an encrypted database. This recording is never shared with anyone without your prior consent. Only Tooth Fairy team members who have a relation to your care will be able to view your recording. Recordings are never viewable by the public without your prior consent. If you wish to see a copy of your recording you can submit a data request via email to patients@toothfairyapp.co.uk

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