Privacy Policy
16th Jun 2022
What this policy covers
This Privacy Policy explains how Testmyteeth Limited (“Testmyteeth”, “we”, “our” or “us”) manages the Personal Information (i.e. information that could be used to identify, relates to, or could reasonably be linked, directly or indirectly, with a particular individual) we collect when you use our websites, mobile application, and other services (collectively known as our “Services”).
This Privacy Policy may be updated or changed as required. If changes are made to this policy, we will notify you by updating the date at the top of this policy, unless another type of notice is required by the applicable law. By continuing to use our website or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you agree that you will be deemed to have agreed to be bound by the replacement Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
Contents
1. What Personal Information we collect
2. Cookies
2. How we use your Personal Information
3. How we store and move your Personal Information
4. How long we keep your data
5. Your rights
6. Our contact details
What personal information we collect
As a part of our business, Testmyteeth may collect Personal Information about you to deliver our services. We will only collect, store and process Personal Information by fair and legal means as required by the General Data Protection Regulation (GDPR). The types of Personal Information we may collect, and store will vary depending on the services you interact with and may include:
Account Information
Such as:
Your name, email address, telephone number.
How we collect it:
We ask for this information when you register an account with us or sign up to our mailing list.
General Health Data
Such as:
Photographs of your teeth, oral health questionnaire responses, general health and diet questionnaire responses, your preferred dental practice, previous dental check-up history, previous treatments you have received, upcoming dental appointments booked through the Testmyteeth mobile application.
How we collect it:
We collect this information when you use our services such as our plaque tracker or fill out a questionnaire or form.
Oral hygiene insights
Such as:
Plaque scores, brushing insights, hygiene recommendations.
How we collect it:
We derive this information from images of your teeth and other general health data you submit when you use our services (such as our plaque tracker).
Communications with us
Such as:
Your emails, calls or live chat with our support team.
How we collect it:
We keep a record of this information when you communicate with us.
Technical information and analytics
Such as:
Your IP address, browser details, operating system, the make and model of your device, time zone, language, location settings, your mobile network provider and location (from your IP address), resettable device identifiers, information about your use of our website or app (including page interactions and times spent).
How we collect it:
We may collect this information directly, via cookies (see details relating to our cookie policy below) or via the services of other data analytics companies when you use our mobile application or visit our website, where this is allowed by your device or browser settings.
Additional personal information we may collect:
We may also collect personal information about:
• Dental providers
• Third parties providing a service to Testmyteeth
• Employees and contractors of Testmyteeth
Cookies
We may use cookies to operate and improve our Website. Cookies are small files stored on your hard drive or in device memory that help us improve our services by understanding which areas and features of our services are popular, count visits and deliver content targeted to your interests. We do not use cookies on your medical or health information. You can find out more about how we use cookies in our Cookie Policy.
How we use your personal data
Testmyteeth will process your personal information for the following purposes:
To provide you with a service
Our main reason for collecting your Personal Information is to provide and improve the service, products, and experiences that you and our customers expect from us. We require your personal identification and contact details to create an account from which you can access other Testmyteeth services. The lawful basis we rely on for processing this information is ‘performance of a contract’. We primarily use and analyse the ‘General Health’ data you provide to assist in identifying possible areas of plaque accumulation which may be relevant to you and recommending possible improvements. The lawful basis we rely on for processing this information is ‘performance of a contract’ and we rely on ‘explicit consent’ as the condition for processing this special category data.
To improve and Develop Testmyteeth’s services
We use the information we collect to improve Testmyteeth Services and to develop new features and Services. The lawful basis we rely on for processing this information is ‘our legitimate interests’. This includes using the collected information to troubleshoot and protect against errors, perform data analytics and testing, understand user trends, conduct research or otherwise improving our mobile and web applications.
We may use anonymised copies of any uploaded images of your teeth that you provide to improve our services, including our artificial intelligence systems and website. This helps us to improve the accuracy of our Services for you and other Testmyteeth users. We anonymise this data by removing details that could identify you, such as your name, address and contact details ('personal identifiers'). If any Personal Information is used, we will make sure that our interests never come before your rights.
To help health research
To support dental health research, we may use anonymised copies of your uploaded data (i.e., without being able to identify you at all), for research purposes, such as better understanding oral hygiene behaviours, disease risk or health outcomes. This may include sharing your anonymised data with carefully selected third party research institutions, such as universities or other academic institutions. We aim to publish our research results in peer-reviewed journals or by working with academics.
We will ask for your consent to process your data anonymously for research purposes. By uploading your images in our Mobile Application and having confirmed your Informed Consent, you explicitly agree to your uploaded images being processed for the above research purposes and to be used anonymously. As such, your images may be reviewed by our employees or third-party consultants who work for us and who are bound by strict confidentiality.
To provide support
We may also use your Personal Information to provide support in-line with your legitimate interests, including:
• to resolve any issues or complaints.
• to answer your questions and requests.
• to verify and update Personal Information held by Testmyteeth.
• to manage our relationship with you.
To keep you updated
We would love to stay in touch and provide you with updates of our latest product features, offers or upcoming events. We will only use your Personal Information in this way if you opt in (consent to marketing emails).
If you do consent, we may contact you in various ways, including e-mail, post, SMS, in-app and push notifications, via social media platforms and by phone.
To comply with our legal obligations
We will make disclosures as required to comply with reasonable requests by regulatory bodies or for other purposes required by law or regulation.
How we store and move your personal data
Testmyteeth stores all your General Health Data and Oral Hygiene Insights on secure servers. We may also store the data in a secure cache, not accessible from other apps without your explicit consent, on your personal mobile device or the device you choose to log in with.
If you've chosen a password or authentication method to access the app, you are responsible for keeping this password and/or authentication method confidential. Please don't share it with anyone. Testmyteeth does not store or handle your password. Authentication with our services is processed via a third party authentication provider.
Your data may be processed or stored outside of the UK and the European Economic Area (EEA). This is because we sometimes work with other companies who help us deliver Testmyteeth Services to you. These companies might have servers outside of the UK or EEA. This will always be in line with applicable data protection lawful mechanisms (such as appropriate contractual terms) and subject to strict safeguards. If you would like further information please contact us.
How long we keep your data
We will keep your Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer. The actual period for which we store your Personal Information will vary depending on the type of Personal Information and how it is used. For example, we keep your account information, like your name and email address for as long as you have an account with us, because this is a requirement to operate your account. We will destroy or de-identify your personal information once it is no longer required for the purpose or purposes for which it was collected.
To the extent required by the data protection law, Testmyteeth will take reasonable steps to: Ensure that the Personal Information that we collect, hold, use and disclose is accurate, complete and up-to-date; Protect the Personal Information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure. Testmyteeth will take reasonable steps to ensure that Personal Information that is held which is no longer required, including under any contractual or legal requirement, is destroyed or de-identified in a secure manner.
Your rights
Under data protection law, you have the right to:
• Remove or change your consent for how we use certain data. You can do this by selecting your ‘profile settings’ followed by ‘privacy’ through our mobile application, or by following the link at the bottom of any marketing email.
• Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Be aware that you may always access your General Health Data and Oral Hygiene Insights through our Mobile Application.
• Ask us to correct information that is wrong, delete it, or ask that we only use it for certain purposes. There may be instances when we cannot complete your request such as if it goes against our legal and medical obligations.
• Ask us to restrict any automated decisions made with your data.
• Ask for your data to be provided on a portable basis.
Our contact details
If you have any questions about this Privacy Policy or would like to perform any actions in line with your rights, please contact:
Data Protection Officer, Testmyteeth Limited, 12 Forge Drive, Claygate, Esher, Surrey, KT10 0HR
Or via email at: support@testmyteeth.com
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
