16th Jun 2022
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:
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.
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.
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).
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.
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 also collect personal information about:
• Dental providers
• Third parties providing a service to Testmyteeth
• Employees and contractors of Testmyteeth
Testmyteeth will process your personal information for the following purposes:
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.
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 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.
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.
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.
We will make disclosures as required to comply with reasonable requests by regulatory bodies or for other purposes required by law or regulation.
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.
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.
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.
Data Protection Officer, Testmyteeth Limited, 12 Forge Drive, Claygate, Esher, Surrey, KT10 0HR
Or via email at: firstname.lastname@example.org
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