We put our customer privacy at the heart of everything we do and we hope that our Privacy Policy described below is easy to understand and clear to you. We reserve the right to modify and update this Policy at any time without notice.

When and if we do update the Policy we will publish it on our website (www.franksmile.co.uk) so you should check the Policy whenever you intend to send us information about yourself. Our Privacy Policy applies to all our customers, including visitors to our website. 

YOUR DATA

We will process information that you provide when you fill in any forms on our website or when you contact us, plus we will process details of any transactions that you carry out through our system, details of your visit to our website and the details of resources that you access using website. All data (personal information) submitted to Franksmile – Kurfürst 1578 GmbH on our website by you is taken to be accurate and correct.

In the course of providing you with our goods and services or you visiting our website, 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, maiden name, last name, title, date of birth and gender.

  • Contact Data

     

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

  • Financial Data

     

    includes bank account, payment card details and other required payment data (depending on the selected payment method).

  • Transaction Data

     

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

  • 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.

  • Profile Data

     

    includes purchases or orders made by you, your preferences, feedback and survey responses.

  • Usage Data

     

    includes information about how you use our website, products and services.

  • Marketing and Communications Data

     

    includes your preferences in receiving marketing from us and our third parties and your communication preferences.

  • Treatment-related Data

     

    includes information you provide as part of the ordering and treatment process, including information on your dental history and other related medical conditions.

By agreeing to our terms and conditions and privacy policy you are also agreeing to only disclose personal information that relates to you. If we suspect a possible fraud or false identity, we may pass information to fraud prevention or law enforcement agencies who may carry out further checks on you which may affect your personal records, such as your credit history

PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA

We use your personal information for the purpose of carrying out our business activities, including providing the products and services you have requested. We may use your information to help make business decisions that enable us to offer a better service. We may also use your information for marketing purposes but only where we have either obtained your express consent to do so or you are an existing customer and were given the opportunity to opt out when your data was initially collected. We may, if legally compelled to do so, supply your information to authorities should they require it to conduct investigations.

Our aim is to process data efficiently and only use it where absolutely needed to give you a better experience and service. We may also use your data to help us improve the customer experience you have, carry out statistical analysis or assess credit risks or suitability for third party products.

In addition to personal and financial information, we may collect information about your computer including your IP address, operating system and browser type. We may use 'cookies' which involve information being stored on your computer browser. Most websites use cookies to improve the overall customer experience and how the website works as well as to provide relevant information to customers at the right time.

We will only use your personal data as set out in this privacy policy and when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • 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.

  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, 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.

Note that we may process your personal data upon 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 ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Some information may be required by the local law, legal enforcement procedures or other bodies with relevant powers or jurisdiction. If you do not provide all of the information requested, we may not be able to provide you with our products or services effectively or at all.

‍ Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You may receive marketing communications from us if you have requested information from us or purchased from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.    

You have a right to opt out of us contacting you for marketing purposes or sharing information about you with other companies for marketing purposes at any time by contacting us at: support@franksmile.com or by sending us a written letter to: Charlottenstraße 4, 10969 Berlin, Germany and letting us know your decision.

DATA SECURITY AND RETENTION

We do our best to protect your personal data that you have shared with us. We protect that information in transit using secure socket layer (SSL) encryption technology. Franksmile – Kurfürst 1578 GmbH uses firewalls and the latest encryption technology to ensure our website is secure and that all customer data is protected and encrypted.

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.

IP ADDRESSES AND COOKIES

Through our website we may collect information about your computer, including your IP address, browser type and version and operating system information for system administration and to report aggregate information to our advertisers. All this information is purely statistical and does not identify any individual.

Note: that third-party affiliates and advertisers who advertise on our site may use cookies, but we do not have access to them or control over them. If you do not want to allow access to the cookies on your system then you can set your browser to refuse cookies. However, doing so you will not be able to enjoy full use of this site.

YOUR 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 any information we have about you in accordance with the data protection laws. If you would like to access this information please contact us by writing to us at Charlottenstraße 4, 10969 Berlin, Germany or emailing us at support@franksmile.com.  

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.

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.

You also have the right to:

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 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.

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. ‍

SHARING YOUR DATA

We may share your personal data with the parties set out below for the purposes set out in the section “Purposes for which we will use your personal data” above. As part of this process, we may transfer your personal data outside the UK.

  • Our affiliates, including our parent company, Kurfürst 1578.

  • Third-party service providers, including our orthodontist based in Ireland and our dental service partner in the USA.

  • Third-party IT and software service providers.

  • Specialist third-party marketing agencies.

  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

  • Fraud prevention agencies.

  • 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.  Please contact us if you would like any further information in connection with any third parties that we share your data with.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the relevant data protection authority.

  • Where we use certain service providers, we may use specific contracts approved by the relevant data protection authority which give personal data the same protection it has in the UK.

  • 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 UK and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

FANPAGE

Usage of our Franksmile – Kurfürst 1578 GmbH - Facebook - company appearance

1. Scope of data processing We use the corporate identity of Franksmile – Kurfürst 1578 GmbH of Facebook Menlo Park, Kalifornien, Vereinigte Staaten. We provide information and offer Facebook users a medium to communicate.

Our Facebook corporate appearance serves to inform Facebook users about our information about products, information about services, advertising. Every user is free to publish personal data through activities.

We do not possess or gather information on the processing of your personal data by the Facebook companies jointly responsible for the corporate identity of FrankSmile – Kurfürst 1578 GmbH. More information can be found in the privacy policy of Facebook.

When you use any given function on the corporate website of Facebook (exp. comments, contributions, likes etc.), you may be making your personal data (exp. name, profile picture etc.) public.

2. Purpose of data processing

Our Facebook corporate identity serves to establish contact with and to inform Facebook users about our products and services. Each user is free to publish their personal data through various, relevant online activities.

We put our customer privacy at the heart of everything we do and we hope that our Privacy Policy described below is easy to understand and clear to you. We reserve the right to modify and update this Policy at any time without notice.

When and if we do update the Policy we will publish it on our website (www.franksmile.co.uk) so you should check the Policy whenever you intend to send us information about yourself. Our Privacy Policy applies to all our customers, including visitors to our website. 

3. Legal basis

The legal basis for the processing of your data in connection with the use of our Facebook corporate identity is art.6 par.1 S.1 lit.f DSGVO.

4. Duration of data storage

We will store data on your activities and personal information published via Facebook on our corporate website for a period of up to 6 months. The data will be stored within the legally established timeframe.

5. Objections and the possibility of removal

You may, at any time, object to the processing of your personal information that we collect as part of your use of our Facebook corporate identity and make your personal data protection rights listed in section IV of this privacy policy effective. In the said event, please send us an informal email to customer@franksmile.com.

For information on the processing of your personal data by Facebook, please refer to: https://www.facebook.com

Usage of our Franksmile – Kurfürst 1578 GmbH - Instagram - company appearance

1. Scope of data processing

We use the corporate identity of Franksmile – Kurfürst 1578 GmbH of Instagram Menlo Park, California, USA. We provide information and offer Instagram users a medium to communicate.

Our Facebook corporate appearance serves to inform Facebook users about our information about products, information about services, advertising. Every user is free to publish personal data through activities.

We do not possess or gather information on the processing of your personal data by the Instagram companies jointly responsible for the corporate identity of Franksmile – Kurfürst 1578 GmbH. More information can be found in the privacy policy of Instagram.

When you use any given function on the corporate website of Instagram (exp. comments, contributions, likes etc.), you may be making your personal data (exp. name, profile picture etc.) public.

2. Purpose of data processing

Our Instagram corporate identity serves to establish contact with and to inform Instagram users about our products and services. Each user is free to publish their personal data through various, relevant online activities.

3. Legal basis

The legal basis for the processing of your data in connection with the use of our Instagram corporate identity is art.6 par.1 S.1 lit.f DSGVO.

4. Duration of data storage

We will store data on your activities and personal information published via Instagram on our corporate website for a period of up to 6 months. The data will be stored within the legally established timeframe.

5. Objections and the possibility of removal

You may, at any time, object to the processing of your personal information that we collect as part of your use of our Instagram corporate identity and make your personal data protection rights listed in section IV of this privacy policy effective. In the said event, please send us an informal email to customer@franksmile.com.

For information on the processing of your personal data by Instagram, please refer to: https://www.instagram.com/

USED PLUGINS

Use of Facebook Pixel

1. Scope of personal data processing

With your consent, we use the ‘visitor activity pixel’ of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). With the pixel, we can track users’ activities after they have seen or clicked on a Facebook advertisement. This allows us to measure the effectiveness of Facebook advertising for statistical and market research purposes. The data collected from using the pixel remain anonymous to us; hence, we do not see the personal data of individual users. However, the data is stored and processed by Facebook, of which we will inform you to the best of our knowledge. Facebook can connect this data to their Facebook account and use it for their own advertising purposes according to Facebook’s data usage policy. You can enable Facebook and its affiliates to display ads on and off Facebook. A cookie may also be stored on your computer for the aforementioned purpose(s).

Consent may only be given by users older than 13 years of age. If you are younger than the stipulated age, it is necessary that you obtain advice from your guardians.

2. Legal basis for the processing of personal data

The legal basis for personal data processing is Art.6 Para. 1 S.1 lit. f GDPR.

3. Duration of storage

We have no information regarding the duration of the storage.

4. Objections and removal option

For more information, refer to Facebook’s privacy policy.

Use of Facebook Plug-in

1. Extent of personal data processing

We use the Plug-In of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025 United States. They are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. By enabling this plug-in, your browser will connect to the Facebook servers. Facebook acknowledges and learns when you visit our website with your IP address. In addition, Facebook receives information about the date, time, browser type and version, operating system version, and Facebook cookies already stored in your browser. By doing so, Facebook is able to recognize the websites containing Facebook content that you were have previously visited. The plug-in is part of Facebook and will only be displayed on our site. Any interaction with this plug-in is an interaction with "Facebook.com".

If you are logged in to Facebook, activating the plug-in will initiate a transfer of your Facebook application number. The visits you make on our website can then be linked to your Facebook account. Depending on the settings on your Facebook account, clicking on the plug-in may also lead to the publishing of said action on your Facebook profile. You can avoid this by logging out of your Facebook account before you enable the plug-in and, after visiting websites with Facebooks plug-ins, deleting all the Facebook cookies.

Please note that facebook messenger data can also be processed by the third party Spectrm Publishing UG Local Court Potsdam, HRB 28204 P. The company will only transfer the data to franksmile and will not be used for commercial or any other purposes.

2. Purpose of data processing

Facebook processes the data to find errors in its own system, improve its own products and their adaptation to user behaviour, and to control the placement and individualisation of advertisements. In addition, the processing is also used for localization, to record how websites with Facebook content are used, and for the purpose of market research.

3. Legal basis for the processing of personal data

The legal basis for processing personal data is Art.6 Para.1 S.1 lit.a GDPR.

4. Duration of storage

Facebook stores up to 90 days of self-reported data. Thereafter, the data will only continue to be used in its anonymous form.

5. Objections and removal option

Further information on the use and collection of data can be found in Facebook’s privacy policy.

Use of Google AdWords

1.Scope of personal data processing

We use Google AdWords by Google Inc., 1600 Amphiteatre Parkway, Mountain View, CA 94043, United States. This is an online advertising program that uses conversion tracking. When you receive a Google Ad on our website. Google AdWords places a cookie on your computer. Each Google AdWords customer will be assigned a different cookie.

2. Purpose of data processing

We only receive information on the total number of users who respond to our ad(s). No other information will be shared with us that allows us to identify you. The use of Google AdWords is not to enable traceability.

3. Legal basis for the processing of personal data

The legal basis for data processing is Art.6 Para. 1 S.1 lit. f GDPR.

4. Duration of storage

The cookie loses its validity after 30 days.

5. Objections and removal option

You can disable the Google-Conversion-Tracking by turning it off in your browser. For more information, kindly refer to the following link: https://policies.google.com/privacy

Use of Google Analytics

1. Scope of personal data processing

We use Google Analytics, a web analytics service provided by Google Inc., 1600 Amphiteatre Parkway, Mountain View, CA 94043, United States ("Google"). Google Analytics uses so-called "cookies", text files that are stored on your computer that allow an analysis of your use of the website. The information generated by the cookie on your use of this website is transmitted to a Google server in the USA and stored there. However, if IP anonymization is activated on this website, your IP address will be abbreviated by Google beforehand within member states of the European Union or other parties to the Agreement on the European Economic Area. Only in specific cases will the full IP address be sent to a Google server in the US and abbreviated there. IP anonymization is active on this website. On behalf of the operator of this website, Google will use this information to evaluate your use of this website, compile reports on website activity, and provide other services related to website activity and internet usage. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data. You can prevent the storage of cookies by changing the settings on your browser software. However, by preventing the storage of cookies, you may not be able to use all the functions on our website to its full potential.

2. Purpose of data processing

The purpose of processing personal data is to optimize the approach towards a target group which expresses their initial interest by making their first page visit.

3. Legal basis for the processing of personal data

The legal basis for data processing is Art.6 Para. 1 S.1 lit. f GDPR.

4. Duration of storag‍e

Advertising data in server logs are anonymized by deleting parts of the Google IP address and cookie information after 9 and 18 months.

5. Objections and removal option

In addition, you may prevent the collection of data generated by the cookie, data related to your use of the website (including your IP address), as well as the processing of the respective data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout. For more information, kindly refer to the following link: https://policies.google.com/privacy

Use of Google Analytics Remarketing (also known as Google Dynamic Remarketing)

1. Scope of personal data processing

On our website, we use the “remarketing” feature by Google Inc., 1600 Amphiteatre Parkway, Mountain View, CA 94043, United States. In collaboration with Google, we offer you matching and interest-based advertisements. Google Analytics Remarketing also uses cookies which are stored on your computer. According to Google, no personal information is collected. They also claim to be unrelated to and disconnected from other Google services.

2. Purpose of data processing

The purpose of personal data processing is to effectively identify and address a specific target group. The cookies stored in your browser will recognize you as a user when you visit a website, which enables us to show you interest-based advertisements.

3. Legal basis for personal data processing

The legal basis for personal data processing is in accordance with Art.6 Para. 1 S.1 lit. f GDPR.

4. Duration of storage

Advertising data in server logs are anonymized by deleting parts of the Google IP address and cookie information after 9 and 18 months.

5. Objections and removal possibility

You can disable the “remarketing” feature by adjusting the settings in the following link https://www.google.de/settings/ads. For more information, please refer to the following link: https://policies.google.com/privacy

Use of Instagram Plugin

1.Scope of personal data processing

Plugins by Instagram are incorporated on our pages. These plugins are offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA.

The Instagram buttons are used to the link the user to our Instagram profile. Similarly, a widget is also incorporated to allow us to map selected photos and videos found on our Instagram profile to our website. This will automatically transfer data to Instagram which are then stored in their servers. This data includes connection information (such as your IP address, date and time of visit, as well as the URL visited), the browser used, and the operating system. Your visit on our pages can be tracked by Instagram, even if you do not actively use the plug-in features.

When you visit a page of ours that contains such a plug-in, your browser directly connects to an Instagram server. The contents of the plug-ins are transmitted directly to your browser and are integrated into the website.

If you are logged in to your Instagram account, you can link the content of our pages to your Instagram profile by clicking on the displayed Instagram button. This allows Instagram to associate the relevant visits to our pages with your user account. If you want to prevent this immediate assignment, you must log out of your Instagram account before visiting our website. For more information pertaining this topic, kindly refer to Instagram’s privacy policy.

2. Purpose of data processing

For information pertaining the purpose of personal data processing, kindly refer to Instagram’s privacy policy.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is Art.6 Para. 1 S.1 lit. f GDPR.

4. Duration of storage

We have no information regarding the duration of the storage.

5. Objections and removal option

For more information, kindly refer to the following link: https://help.instagram.com/

Use of HotJar Plugin

1.Extent of processing

On our website, we use "Hotjar", a web analysis service of Hotjar Ltd., Level 2, St Julian's Business Center, 3, Elia Zammit Street, St Julian's STJ 1000, Malta (hereinafter referred to as: "Hotjar") on our website. Among other things, Hotjar uses cookies, which are small text files stored locally in the cache of your web browser on your device, which allow you to analyse the use of our website, as well as a so-called tracking code. The information collected in this way will be transmitted to Hotjar on a server in Ireland and stored there. The Tracking Code collects the following information: Dependent on your device the following data is collected by Hotjar:

1. IP address of your device (collected and stored in an anonymous format)

2. E-mail address including your first and last name, as far as you have made it available through our website

3.Screen size of your terminal

4. Device type and browser information

5. Geographical data (country only)

6. Language used to represent our website

7. User interactions

8. Mouse commands (movement, position and clicks)

9. Keystrokes

Log data automatically used by our server when using Hotjar:

1. Referring domain

2. Visited websites

3. Geographical data (country only)

4. Language for the presentation of our website

5. Date and time of access

2. Legal basis for the processing of personal data

The legal basis for personal data processing is in accordance with Art. 6 Para. S.1 lit. f GDPR.

3. Purpose of data processing

The offerings on this website.

4. Duration of storage

Hotjar stores this information in a pseudonymized user profile. Cookies used by Hotjar are stored for different periods of time, sometimes only during your visit, sometimes 365 days, on your device.

5. Objections and removal option

You may opt out of saving a user profile and information about your visit to our site by Hotjar and setting Hotjar Tracking cookies on other sites by clicking on the following: https://www.hotjar.com/legal/compliance/op-out

THIRD PARTY WEBSITE

Our website may contain links to third party websites. Please note that if you follow a link to any such website your use and disclosure of personal data will be subject to their own Terms & Conditions and Privacy Policies.

CONTACT US

We welcome any concerns or questions you may have regarding our privacy policy and any services that we offer to you. Please send an email to customer@franksmile.com, write to us at Charlottenstraße 4, 10969 Berlin, Germany, or call +44 (0) 20 3966 8614 if you have any questions or comments about your personal information.