Welcome to Practi’s privacy policy

Practi respects your privacy and is committed to protectingyour personal data. This privacy policy explains in detail the way in which anypersonal data you provide to us is used and kept safe. It applies whenever we collect, store and useyour personal data. We know there’s alot of information here, but we want you to be fully informed about yourrights, and how we use your data, so please take the time to read it.

It’slikely that we’ll need to update this privacy policy from time to time. We’llnotify you of any significant changes, but you’re welcome to come back andcheck it whenever you wish.

Who we areand about this privacy policy

Practi is operated and run by a group of companies made up of Simplyhealth Group Limited and the companies it owns and controls. For simplicity throughout this policy, ‘we’ and ‘us’ means Simplyhealth. Different companies within Simplyhealth may process your information.

About this privacy policy

This privacy policy explains what information we may collect about you, how we may use it, and the steps we take to ensure that it is kept secure. We also explain your rights in respect of your personal data.

So you are fully aware of how and why we are using your data, it is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions. These additional documents are intended to complement this privacy policy.

How is your personal data collected?

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

For patients, your dental practice. When setting up your Practi platform or plan your dental practice will provide your name, date of birth, phone number, email address and, for platform customers the dental treatment being provided
For patients, the lender. For platform customers, Information regarding the outcome of any credit application may be shared with Practi
For patients, direct interactions. You may give us your personal information by filling in forms or by corresponding with us by email or phone (we may record or monitor phone calls to make sure we are keeping to legal rules, codes of practice and internal policies, and for quality assurance purposes). Platform customers may provide further personal information when interacting with the platform, plan customers may provide further personal information when accessing the portal
For practice staff, direct interactions. When setting up your Practi administration account, you will provide your name, and email address
For dental practitioners. When requesting information on our services, you will provide your name and contact details
Automated technologies or interactions. As you interact with our website and mobile applications, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

The data 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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, title, date of birth
Health Data for platform customers, includes any information relating to your mental or physical health including details and conditions surrounding treatment received
Contact Data includes email address, telephone number and address
Financial Data for plan customer includes bank account details, details about your payments and for platform customers includes information relating to your application for credit
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 our mobile application
Profile Data includes your username and password, preferences, feedback and survey responses
Usage Data includes information about how you use our mobile application

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data is not considered personal data because it 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 mobile application feature. If we combine Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of an agreement we have with you and you fail to provide that data when requested, we may not be able to provide you with our services. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

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:

For the purposes described in this privacy policy, with your consent
Where it is necessary for our legitimate interests * or those of a third party and your interests and fundamental rights do not override those interest

* 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.

Where we have a legal or regulatory obligation to use your personal information
Where we need to use your personal information to establish, exercise or defend our legal rights, for example when we are faced with any legal claims, or where we want to make any claims ourselves
Where we need to use your personal information, for reasons of substantial public interest, such as carrying out fraud, credit and anti-money laundering checks
Where we need to use your sensitive personal information such as health data because it is necessary for your vital interests, an example would be a life-or-death matter

Purposes for which we will use your personal data

We have set out below, in a table, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note, that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer (note the type of data processed will be determined by the product)

Identity
Health
Contact

Consent (platform customers)
Performance of a contract (dental practitioners, practice staff & plan customers)

To process and deliver our service to you including (note the type of data processed will be determined by the product:

Create educational treatment guides
Facilitate finance applications
Hold patient and practice details
Manage payments, fees and charges

Identity
Health
Contact
Technical
Profile
Financial

Consent (platform customers)
Performance of a contract (dental practitioners, practice staff & plan customers)

To manage our relationship with you which will include:

Notify you about changes to our products and services
Ask for product feedback

Identity
Health
Contact
Technical
Profile

Consent (patients)
Performance of a contract (dental practitioners & practice staff)

To enable you to complete a survey

Identity
Health

Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)

To administer and protect our business and this mobile application (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Identity
Health
Contact
Technical
Profile
Usage

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)

To use data analytics to improve our mobile application, products/services, customer relationships and experiences

Technical
Profile
Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our mobile application updated and relevant and to develop our business)

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are set. If you disable or refuse cookies, please note that some parts of this mobile application may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy for further details.

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.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for those purposes set out in table ‘Purposes for which we will use your personal data’:

Internal Third Parties

Other companies within Simplyhealth acting as controllers or processors and who provide IT and system administration services and undertake leadership reporting.

External Third Parties

Service providers acting as processors or controllers who provide and IT and system administration services, support services and commissioned services
For platform customers, If you choose to apply for credit through the Practi platform, your data will be shared with the lender
For platform customers Information relating to your application for credit received from the lender may be shared with your dental practice
Professional advisers acting as processors or controllers based in the United Kingdom including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
HM Revenue & Customs, regulators and other authorities acting as processors or controllers based in the United Kingdom who require reporting of processing activities in certain circumstances
Fraud detection agencies and other third parties who operate and maintain fraud detection registers
The Financial Ombudsman Service and regulatory authorities such as the Financial Conduct Authority, the Information Commissioner’s Office and the Prudential Regulation Authority
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.

International transfers

Some of our external third parties are based outside the UK or European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the UK or EEA.

Whenever we transfer your personal data out of the UK or EEA, we ensure the same level of protection is afforded to it by ensuring appropriate contractual and technical safeguards are implemented:

Please contact us at thedataprotectionofficer@practihealth.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

Data security

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.

Data retention

How long will you use my personal data for?

We will only retain 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.

If you would like more information about how long we will keep your information for, please contact us at thedataprotectionofficer@practihealth.co.uk.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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
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. 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding 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
Where any automated decision making and profiling has taken place, you have the right to obtain human intervention, express your point of view, and obtain an explanation of the decision and to challenge it.

If you wish to exercise any of the rights set out above, please contact us at thedataprotectionofficer@practihealth.co.uk

No fee usually 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 may 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 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.

Data protection contacts

If you have any questions, comments, complaints or suggestions regarding any aspect of your personal data or this privacy policy, please contact our Data Protection Officer thedataprotectionofficer@practihealth.co.uk

You have a right to make a complaint at any time to your local privacy supervisory authority. Simplyhealth’s main establishment is in the UK, where the local supervisory authority is the Information Commissioner's Office (ICO). You can also contact the Information Commissioner’s Office using their online form: https://ico.org.uk/global/contact-us/email/ (www.ico.org.uk),

However, we would appreciate the chance to address your concerns before you approach the ICO, so please contact us in the first instance.