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INSTAsmile.

Giving you the confidence to smile again.

Instasmile Privacy Policy

Updated: 24 May 2018

INSTAsmile respects your privacy and is committed to protecting your personal data. Below is our Privacy Policy.

  1. Introduction

This privacy policy lets you know how INSTAsmile, and its corresponding companies, use your personal data when you interact with us, visit the website and buy our products or services.

It also tells you about your privacy rights and how the law protects you.

It is important that you read this privacy policy and our terms and conditions so that you understand how we use your data.

If you have any queries, or would would like to exercise your privacy rights then please follow the instructions in this privacy policy.

  1. Our website and our corresponding companies

Our website instasmile.com sells clip-on veneers, a temporary cosmetic oral solution which is aimed at adults. The website is not intended for children and we do not knowingly collect data relating to children.

Instasmile Ltd is a subsidiary of SEBL Group Ltd.

SEBL Group Limited located at Trafford House, Platt Fold Street, Leigh WN7 1JH, United Kingdom and is  made up of three different legal entities:

  • Instasmile Limited located at Trafford House, Platt Fold Street, Leigh, WN7 1JH, United Kingdom

  • DenLab Direct Limited located at Trafford House Platt Fold Street, Leigh, WN7 1JH, United Kingdom

  • SEBL Group Inc located at 55 E Monroe St 3800, Chicago, IL 60603, United States of America

SEBL Group Limited is the data controller responsible for this website and any handling of personal data carried out by or on behalf of Instasmile Limited, DenLab Direct Limited and SEBL Group Inc.

When we mention “Instasmile”, “we”, “us” or “our” in this privacy policy, we are referring to SEBL Group Limited.

  1. Personal data which we collect about you

Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect a variety of information about each of our customers and visitors to the Instasmile website. This personal data fits within these categories:

Identity Data includes, title, first name, last name, username, or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media username.

Contact Data includes billing address, delivery address, email and telephone numbers.

Financial Data includes payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

User Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses as well as any profile data which we have added (for example, using analytics and profiling).

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operation 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, products and services.

Tracking Data includes information we or other collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.

Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may ask you to answer some basic dental health related questions in order to determine your suitability for our products or services however this data is never collected or stored within any of our systems. Therefore, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you use any of these types of personal data within any type of communication with us, such as (but not exclusively) email, chat or phone calls, then we will not be able to tell. We will treat all the personal data included in communication as ordinary personal data.

If you choose to not share personal data with us, or refuse to certain contact permissions, we might not be able to provide the products and services you’ve asked for.

  1. How is your personal data collected?

We use various different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by completing forms or by corresponding with us by post, phone, email, online chat or social media.

This includes personal data you provide when you:

  • Order our products or services

  • Make enquiries or request information to be sent to you

  • Sign up to receive our newsletter

  • Create an account on our website

  • Ask for marketing to be sent to you

  • Engage with us on social media

  • Leave comments or reviews on our products or services either on our own website or via third parties, such as (but not exclusively) Trustpilot, Google and Yelp; or

  • Contact customer services, or any other member of staff at Instasmile

Automated technologies or interactions.

As you interact with us, including via the instasmile.com website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website, or when you click on one of our adverts (including those shown on third party websites).

Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:

  • Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;

  • Contact, Financial and Transaction Data from providers of payment and fraud prevention services;

  • Identity and Contact Data from data partners; and

  • Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites 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:

  1. How we use your personal data

We use your data in the following ways:

  • Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products or services, that’s a contract.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, when we carry out fraud screening as part of the check-out process.

  • Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.
See 'Explaining the legal bases we rely on to process personal data' below to find out more about the types of lawful basis that we will rely on to process your personal data.

  1. Explaining the legal bases we rely on to process personal data

In this table linked here, it shows you all of the ways we plan to use personal data, and which of the legal bases we rely on to do so. We have also identified some data examples to make it easier to understand however it may not be exclusive to these examples. We have also described what our legitimate interests are when appropriate.

If you have any queries about this, please contact us using the details below within the ‘How to contact Instasmile about privacy’ about privacy below.

  1. Advertising, marketing and your communications preferences

We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you and to tell you about them. This is what we call direct marketing.

We may carry out direct marketing by email, phone, text or post. For example you may receive a phone call letting you know that we can offer a discount on a product or service which we believe you may be interested in.

On our website, we do our best to make it clear what we are doing and which communications you will be sent in relation to direct marketing. You have the right at any time to opt-out of these communications either by clicking the ‘unsubscribe’ links or by contacting us using the details in the ‘How to contact Instasmile about privacy’ below.

You may see advertisements for Instasmile or those of our corresponding companies online or in the real world, however these advertisements may not be specifically directed at you as we purchase advertising space in many different forms; both digitally and physically. To make it clear, here are some forms of advertising that we may carry out which may be specifically directed at you:

  • Phone calls, to let you know about products, offers or services which may be relevant to you. Such as adding additional warranty to a product which you recently purchased.

  • Emails, to let you know about products, offers or services which may be relevant to you. Such as an email letting you know that we are running a sale on some selected products or services.

  • Promotions by post, to let you know about products, offers or services which may be relevant to you. Such as sending you a sample pack of a new product along with a voucher code.

  • Text Messages, to let you know about products, offers or services which may be relevant to you. Such as letting you know about a limited time sale or voucher code.

We work with partners to try and promote the reach of our adverts and use analytics and retargeting for this reason. We also use Tracking Data to deliver relevant online advertising, including via websites, search and social media.

Tracking Data, and in particular cookies and tracking pixels, help us to deliver website and social advertising that we believe is the most relevant to you and to potential new customers of Instasmile. The cookies/pixels used for this purpose are often place on our website by either the platform used for advertising or specialist organisations which we use for advertising purposes. This includes retargeting.

Cookies can also tell us if you have seen a specific advert, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the frequency of which people might see our adverts. Cookies also help us understand if you’ve opened an email and whether you have clicked on the links, this allows us to understand whether the emails are useful to our customers and helps to improve our advertising strategy.

If you want to read more information about Tracking Data, in particular cookies, then please see the ‘Cookies’ section below.

  1. Cookies

From reading the ‘Advertising, marketing and communications preferences’ above, you can see that cookies are a useful tool for advertising which many websites use across the world wide web.

Cookies enable the Instasmile.com website to work and provides a lot of functionality that you would expect from a website such as logging into your account and being able to navigate the site whilst still being logged in. Cookies also allow us to temporarily register your responses to the smile assessment so that you can proceed to purchase our products and services. Cookies can also remember choices which you make on the website, such as the language, text size and interactions with media.

There are other cookies which collect information on how visitors use Instasmile.com, for instance which pages visitors go to most often, which links are clicked and whether the visitor experiences any errors. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregates and used to improve how the website works.

There are cookies that collect information about your browsing habits in order to make advertising delivered to you more relevant to you and your interests (see Advertising, marketing and your communications preferences above). They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

When you use Instasmile.com, your device or browser may be sent cookies from third parties, for example when viewing or interacting with embedded content from social networks or other sites. It’s important for you to know that we have no access or control over these third party cookies. We suggest you to check the third-party website for more information about their cookies and how to manage them.

You can see more information about the cookies that we use on Instasmile.com in the table linked here, including who the vendor is, their ID’s, purpose of use and more information on privacy.

If you choose to, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Instasmile.com website may become inaccessible or not function properly.

  1. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it.
We may share personal data with the following categories third parties:

  • Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);

  • SEBL Group Limited subsidiary companies;

  • Government, regulators and law enforcement; and

  • Auditors and professional advisers such as bankers, lawyers, accountants and insurers.

We share personal data with the following specific third parties:

  • Campaign Monitor: we share your data with Campaign Monitor in order to send transaction email messages about your order of products or services. Read their privacy policy here.

  • Message Bird: we share your data with Message Bird in order to send transaction text messages about your order of products or services. Read their privacy policy here.

  • Zendesk: we use Zendesk in order to respond to customer service emails. Read their privacy policy here.

  • Conectys: Conectys is our external customer service team who we share our customer information with in order to respond effectively to customer enquiries and complaints. They access our customer data in a secure environment and they are GDPR compliant. Read their privacy policy here.

  • Netino by Webhelp: Netino by Webhelp is our external social media team who we share social media information with in order to respond effectively to customer enquiries and complaints. They access our customer data in a secure environment and they are GDPR compliant. Read their privacy policy here.

  • Promoter.io: We share customer information with Promoter in order to send out surveys to gather insight into how each customer rates our products and services so that we can continually improve them. Read their privacy policy here.

  • Trustpilot: We share customer information with Trustpilot in order to invite genuine customers to submit verified reviews about out products and services so that we can gain feedback to improve them. Read their privacy policy here.

We also share data with third parties connected to advertising, retargeting and analytics. Please see Cookies above, including the cookie list, for more information about who those third parties are.

We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. Payment information 

Instasmile uses third party payment processors Stripe, Realex, Global Payments, Divido, Dividebuy, Affirm and PayPal to process payments made for products and services via the Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards and your billing information is encrypted before being communicated to them. Subject to the below exceptions, your credit/debit card details are communicated directly from your browser to these payment processors Instasmile never sees your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page.

For PayPal, we only store the tokens required to identify the transaction with PayPal, issue refunds and identify transactions made using PayPal.

  1. International transfers 

Whenever we transfer your personal data out of the EEA, we will comply with applicable data protection law. Some of the mechanisms we may choose to use when undertaking an international transfer are:

  • The transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission.

  • We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”).

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses.

We share your personal data within the SEBL Group of companies, which will involve transferring your data outside the European Economic Area. We do this using the EU Model Clauses.

  1. Data Security

Many of our external third-party providers are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Third-party links

This website may include links to third-party websites, plug-ins and applications (for example, the ability to sign into Facebook Messenger). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

  1. Data Retention 

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.

We also allow our customers to order another product from the same original impression within 12 months so we keep your data and digital impression scans for a minimum of 12 months to allow you to do this.

In some circumstances you can ask us to delete your data; see Your legal rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. Your legal rights

If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:

  • The right to be informed – that’s an obligation on us to inform you how we use your personal data (and that’s what we’re doing that in this privacy policy);

  • The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;

  • The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;

  • The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);

  • The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;

  • The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);

  • The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and

  • Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.

These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.

If you wish to exercise any of the rights mentioned above, please contact us by using the details in the ‘How to contact Instasmile about privacy’ section.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details in  ‘How to contact Instasmile about privacy’ section.

You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

  1. How to contact Instasmile about privacy

If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at [email protected] or write to us with your letter addressed to Data Controller, SEBL Group, Trafford House, Platt Fold Street, Leigh, WN7 1JH, United Kingdom.

  1. Keeping your data accurate

It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us. You can do this within your account section or by contacting us either by phone or email as shown on the Contact Page.

  1. Changes to this privacy policy

As the General Data Protection Regulation comes into place and as the ICO issues new guidance on how to process personal data we may update this privacy policy at any point. So encourage you to regularly read this privacy policy to keep updated with any changes.

 

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