BACKGROUND

We at Need That Smile understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.needthatsmile.co.uk (“Our Site”) and 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.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below;

“Cookie Law” means the relevant parts of the Privacy and Electronic (EC Directive) Regulations 2003; and
“We/Us/Our means R M Clinic Limited, trading as Need That Smile, whose full details appear at Section 2 below.

2. Information About Us

https://needthatsmile.co.uk is a site owned and operated by R M Clinic Limited trading as Need That Smile, a company registered in England and Wales. Our company registration number is 10054487.Our trading address is PO BOX 329, CHEADLE SK8 9FS.

You can contact us by:

  • telephoning our customer service team at 01625 464 416 Monday to Friday 9am to 7.30pm, Saturday 10am to 6pm, Sunday Closed;
  • by writing to us at PO BOX 329, CHEADLE SK8 9FS;
  • by completing our online contact request athttps://needthatsmile.co.uk/contact

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites, apps or plug-ins.. Please note that We have no control over how your data is collected, stored, or used by other parties and We advise you to check the privacy policies of any such website or app before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) 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.

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which We will always work to uphold:

a) 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 2.

b) The right to access the personal data We hold about you. Part 13 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by Us is inaccurate or incomplete.Please contact Us using the details in Part 2 to find out more.

d) 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 hold. Please contact Us using the details in Part 2 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to Us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if We are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) The right to data portability. This means that, if you have provided personal data to Us directly, We are 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.

For more information about Our use of your personal data or exercising your rights as outlined above, please contact Us using the details provided in Part 2.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data We hold about you changes, please keep Us informed as long as We have that data.

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. We would welcome the opportunity to resolve your concerns ourselves however, so please contact Us first, using the details in Part 2.

6. What Data Do You Collect and How?

Depending upon your use of Our Site, We may collect and hold some or all of the personal and non-personal data set out below, using the methods also set out below. Please also see Part 14 for more information about Our use of Cookies and similar technologies. We do not collect any special category or sensitive personal data or personal data relating to children.

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
  • Contact Data includes contact address, email address and telephone numbers.
  • Financial Data includes bank or credit/card details and may include information received from Klarna or Laybuy if you apply for their financial assistance.
  • Transaction Data includes details about the products you purchase from Us and payments received from you.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from Us and Our third parties and your communication preferences.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To process an order and to take payments. Identity
Contact
Financial
Transaction
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests to take and make payments
To submit your application for finance to purchase our products via our retail finance platform. Identity
Contact
Financial
To assist you with the obtaining of finance.We are not the lender nor are involved in the actual loan process, application, granting of, or refusal of the finance.
To manage our relationship with you which will include:
Notifying you about changes to our terms or privacy policy
Asking you to leave a review or take a survey
Identity
Contact
Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how users use our Site)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Identity
Contact
Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how users use our Site)
To use data analytics to improve our website, services, marketing, customer relationships and experiences Identity
Contact
Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
To make suggestions and recommendations to you about products or offers that may be of interest to you Contract
Technical
Usage
Necessary for our legitimate interests (to define types of customers, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)

Legitimate Interest means the interest of Our business in conducting and managing Our business to enable Us to give you the best service/product and the best and most secure experience. We make sure We consider and balance any potential impact on you (both positive and negative) and your rights before We process your personal data for Our legitimate interests. We do not use your personal data for activities where Our interests are overridden by the impact on you (unless We have your consent or are otherwise required or permitted to by law). You can obtain further information about how We assess our legitimate interests against any potential impact on you in respect of specific activities by contacting Us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that We are subject to.

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, telephone, text message or post with information, news, and offers on Our products and on Our website.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 Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We will only use your personal data for the purpose(s) for which it was originally collected unless We reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If We do use your personal data in this way and you wish Us to explain how the new purpose is compatible with the original, please contact Us using the details in Part 2.

If We need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, We will inform you and explain the legal basis which allows Us to do so.

In some circumstances, where permitted or required by law, We may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will You Keep My Personal Data?

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.

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

We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.

10. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

  • If We sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that We have used it, as specified in this Privacy Policy.
  • In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if We are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
  • We may need to discuss your purchase/finance application with Klarna (Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden) where you request their finance services and you will be required to agree their privacy policy which can also be found here Klarna privacy statement.
  • We may share your details with Laybuy if you choose to pay by finance using their facility on our website. You can view their privacy policy here.

11. How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, 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.

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.

12. Can I Withhold Information?

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

You may restrict Our use of Cookies. For more information, see Part 14.

13. How Can I Access My Personal Data?

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 2.

There is not normally any charge for a subject access 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 28 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.

14. How Do You Use Cookies?

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives Us access to your computer or any information about you, other than the data you choose to share with Us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our website.

We use the following cookies:

    • Strictly necessary cookies. These are cookies that are required for the operation of Our Site. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
    • Analytical/performance cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around Our Site when they are using it. This helps Us to improve the way Our Site works, for example, by ensuring that users are finding what they are looking for easily.
    • Functionality cookies. These are used to recognise you when you return to Our Site. This enables Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
    • Targeting cookies. These cookies record your visit to Our Site, the pages you have visited and the links you have followed. We will use this information to make Our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
    • You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of Our Site.

Social Network Sharing

We encourage users to share Our content and/or like our on profile on the popular Social Media websites Facebook, Twitter, YouTube, Instagram and LinkedIn. In order to make ‘Social Sharing’ accessible, Our Site utilises widgets either provided directly from the Social Networks and/or via amalgamative widgets from third parties such as AddThis. Cookies and privacy implications from the social networks vary and will be dependent on your nominated privacy settings with each Social Network. Social Sharing buttons will only deploy cookies if you are signed to that respective Social Network at the time of being on Our Site.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which We have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

15. Changes to this Policy

We may change this Policy from time to time. This may be necessary, for example, if the law changes, or if We or Our business changes in a way that affects personal data protection.Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Policy was last updated on 18th March 2021.