Recruitment
We have separate notice for our recruitment which can be found here
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Third-party marketing – we will not share your information with any third parties for the purposes of direct marketing.
Opting out – you can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Cookies – 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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see here
Change of purpose – we will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5. WHO WE SHARE YOUR INFORMATION WITH
There are certain circumstances where we transfer your personal information to other parties. For example, we will:
- Affiliates: To provide consistent services across regions
- Service Providers: Logistics companies, payment processors, and IT service providers.
- Regulatory Authorities: As required by law or court orders.
- Marketing Partners: With your consent, for promotional purposes.
- Mergers and Acquisitions: In case of business transfers, with adequate safeguards.
We share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use a marketing agency. Other service providers include advertising agencies, IT suppliers, database providers, backup and disaster recovery specialists, and email providers.
Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function. They will not be permitted to use your information for any purposes other than those outlined in this privacy notice.
Your personal information may be transferred to other third-party organisations in certain scenarios:
- if we discuss selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality
- if we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you
- if we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example, the Policy
- if we are defending a legal claim your information may be transferred as required in connection with defending such claim
- if there is an emergency which requires us to share your data to protect the health and safety of our website’s or app’s users or the general public
Your personal data may also be shared with third parties if it is made anonymous and aggregated. In such circumstances the information will cease to be personal data.
6. INTERNATIONAL TRANSFERS
We share your personal data to our affiliates on the basis of providing our services for you or through your licensed orthodontic professional. This will involve transferring your data outside of your country.
Whenever we transfer your information outside of your country, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Standard Contractual Clauses (SCCs) – These are pre-approved legal contracts that ensure data protection standards are maintained when transferring data to countries without an adequacy decision
- Adequacy Decisions – Certain countries are recognized as having adequate data protection laws, allowing for seamless data transfers without additional safeguards
- Regional Agreements – Some regions have their own agreements, such as the Asia- Pacific Economic Cooperation (APEC) Cross-Border Privacy Rules (CBPR) system, which facilitates data transfers among member economies
- In the absence of an adequacy decision or appropriate contractual safeguards we may rely on derogations for specific situations. For further details, see GDPR Article 49: Derogations for specific situations.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of your country.
7. HOW WE PROTECT YOUR INFORMATION
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.
8. DATA RETENTION
How long will you use my personal information for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.
In some circumstances, you can ask us to delete your data.
Sometimes we will anonymize 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.
9. YOUR RIGHTS
Under certain circumstances, you have following rights under data protection laws in relation to your personal data:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal dat
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us privacyservices@angelaligner.com
Fees are typically not required
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 could refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally, it could 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.
10. HOW TO CONTACT US OR MAKE A COMPLAINT
If you have any questions about this privacy notice or our privacy practices, please contact our data privacy manager at privacyservices@angelaligner.com
You have the right to make a complaint at any time. You can contact your countries data protection authority at
United States
Federal Trade Commission (FTC)
Website: www.ftc.gov
California Attorney General
Website: www.oag.ca.gov/privacy
Australia
Office of the Australian Information Commissioner (OAIC)
Website: www.oaic.gov.au
United Kingdom
Information Commissioner’s Office (ICO)
Website: www.ico.org.uk
European Union
European Data Protection Board (EDPB)
Website: www.edpb.europa.eu
Switzerland
Federal Data Protection and Information Commissioner (FDPIC)
Website: www.edoeb.admin.ch
China
Cyberspace Administration of China (CAC)
Website: www.cac.gov.cn
Russia
Roskomnadzor
Website: www.rkn.gov.ru
Singapore
Personal Data Protection Commission (PDPC)
Website: www.pdpc.gov.sg
11. GLOSSARY
Lawful Basis
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 a 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Consent means processing your data where you have freely given, specific, informed and unambiguous indication of your wishes.
Your Rights in Detail
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
We are committed to providing the information you request as part of your Data Subject Access Request and have procedures in place to ensure this occurs in a timely fashion.
We do not have agreements in place with any third-party platforms that offer “Data Subject Access Requests as a Service”. As a responsible data controller of your personal information this represents significant risks when sharing data. The right of access afforded to you, does not obligate us to share data with third-parties. It is our policy to provide the information directly to data subjects ensuring the safety and security of the information throughout the process.
We will monitor future guidance from the Information Commissioner’s Office but will follow our reasonable measures to verify the identity of data subjects. We would like to assure you that the protection of your data is our main concern and we are committed to providing information as part of any valid request.
This policy will also apply to the rights set out below.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we haveoverriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
