Dentist Gold Card Privacy Notice

This Privacy Notice explains how personal information is collected, used, stored and shared when you:

• register for Dentist Gold Card;
• use the Dentist Gold Card website, dashboard, application, referral links or QR codes;
• enquire about dental treatment or related services;
• participate in a referral, cashback, reward, competition or member-benefit programme;
• communicate with us by WhatsApp, SMS, email, telephone, social media, website chat, push notification or another communication channel;
• interact with a participating dental practice, business, employer, brand or programme partner through Dentist Gold Card.

This Privacy Notice applies across the Dentist Gold Card programme, including services and campaigns associated with SPACE Dental, Straights, SHINE Veneers and other participating or affiliated dental brands, providers and practices.

Clinical treatment information may also be governed by the separate privacy notice of the dental practice or clinician responsible for your care.

Dentist Gold Card is operated by:

For the purposes of applicable data protection law, Space Dental Limited is the controller of personal information processed to operate Dentist Gold Card.

A participating dental practice, clinician, brand, finance provider, employer or business partner may separately act as an independent controller for information it receives and uses for its own purposes. Where appropriate, that organisation will provide its own privacy information.

We process personal information in accordance with applicable laws, including:

• the UK General Data Protection Regulation;
• the Data Protection Act 2018;
• the Privacy and Electronic Communications Regulations 2003;
• other applicable healthcare, consumer, financial, tax, fraud-prevention and regulatory requirements.

The personal information collected depends on how you interact with Dentist Gold Card.

4.1 Identity and contact information

• name;
• title;
• date of birth or age;
• postal address;
• email address;
• mobile and telephone numbers;
• account or member number;
• username;
• identity-verification information;
• signature;
• profile photograph.

4.2 Account and membership information

• registration date;
• membership type;
• account status;
• selected brand, practice or programme;
• account preferences;
• communication preferences;
• consent records;
• app or dashboard activity;
• membership benefits and eligibility;
• competition, promotion and giveaway entries.

4.3 Referral and reward information

• unique referral links and QR codes;
• the identity or account reference of a referrer;
• the source, date and status of a referral;
• consultation or appointment status;
• treatment acceptance or commencement status;
• reward, discount, commission and cashback eligibility;
• reward balances and payment history;
• information required to investigate duplicate, false, disputed or fraudulent referrals.

We do not intend to disclose a referred person’s confidential clinical records to their referrer. A referrer may receive limited programme information, such as whether a referral has reached a reward-qualifying stage, where this is necessary to operate the programme.

4.4 Business and employment information

Where you join as a business, corporate partner, employee, practice or representative, this may include business or employer name, work contact details, job title or role, practice details, business address, partner category, referral activity, employee-benefit eligibility, payment and account information, and communications and relationship-management records.

4.5 Enquiry, appointment and treatment-related information

When you request information about treatment or ask us to arrange a consultation, we may collect the treatment or service you are interested in, preferred practice or location, availability, booking and appointment information, your stated concerns, objectives and preferences, photographs, videos or smile-simulation submissions, relevant information you voluntarily provide about your dental or health circumstances, and whether a consultation was booked, attended, cancelled or rearranged, or whether you chose to begin treatment.

Detailed clinical records are normally collected and controlled by the dental practice or clinician providing your assessment or treatment.

4.6 Communication information

This may include WhatsApp conversations, SMS messages, emails, call notes and, where notified, call recordings, social-media messages, website-chat conversations, customer-service requests, complaint, feedback and survey information, and opt-in, opt-out and unsubscribe requests.

4.7 Financial and transaction information

This may include payments made or due, deposits, refunds, reward or cashback payments, bank details required to pay rewards, payment references, transaction history, and information received from payment or finance providers. We do not generally retain complete payment-card details where payments are processed by an authorised payment provider.

4.8 Technical and usage information

This may include IP address, device and browser type, operating system, app identifiers, login information, pages or screens viewed, referral-link and QR-code interactions, date, time and duration of use, approximate location derived from an IP address, cookie and analytics identifiers, advertising and campaign attribution, and communication delivery, read, response and engagement information.

4.9 Marketing preference information

This may include channels you have selected, subjects or brands you are interested in, when and how consent was obtained, the wording presented when consent was given, withdrawal, objection and suppression records, and engagement with communications and offers.

4.10 Special-category information

Information about health is special-category personal data. We may receive limited health or dental information when you voluntarily include it in an enquiry, treatment request, photograph, recording or conversation. Where detailed health or clinical information is required for treatment, it will normally be collected by the relevant dental provider under its own clinical privacy notice.

We will only process special-category information where an additional legal condition applies, such as provision or management of healthcare by an appropriate professional, explicit consent where appropriate, establishment, exercise or defence of legal claims, or another condition permitted by data protection law.

We may receive personal information:

• directly from you;
• through a Dentist Gold Card registration form;
• through an affiliated brand or campaign;
• through a participating dental practice;
• through a business, employer or corporate-partner registration;
• when you use a referral link or QR code;
• from a member who refers you;
• when you contact us through WhatsApp, SMS, email, telephone, social media or website chat;
• from our websites, apps, dashboards, cookies and analytics tools;
• from appointment, customer-management and payment systems;
• from a parent, guardian, representative, carer or authorised person;
• from professional advisers, regulators, public authorities or fraud-prevention services where lawful.

Where another person provides your details as a referral, we may use those details to identify the referral and, where legally permitted, contact you about the specific enquiry or benefit. We will not treat a third party’s submission as your consent to receive unrelated marketing. Your own opt-in will be obtained where consent is required.

6.1 Creating and managing your account

We use information to register and authenticate your account, administer your membership, provide dashboard or app access, maintain account preferences, and provide programme benefits. Our lawful bases may be performance of a contract and our legitimate interests in operating the programme.

6.2 Administering referrals, discounts, cashback and rewards

We use information to attribute referrals, update referral statuses, determine eligibility, calculate rewards, discounts or cashback, make payments, resolve disputes, and prevent manipulation or fraud. Our lawful bases may be performance of a contract, legitimate interests, legal obligations and the establishment or defence of legal claims.

6.3 Responding to enquiries and arranging consultations

We use information to understand what you are seeking, answer questions, connect you with an appropriate brand, practice or provider, book, confirm, rearrange or follow up consultations, and provide requested smile simulations or service information.

6.4 Service and account communications

We may send non-marketing communications that are reasonably necessary to provide or administer a service you requested, including account verification, registration confirmation, password or security messages, consultation or appointment confirmations, responses to your enquiries, referral-status information, reward or cashback administration, significant changes to your account or the programme, and fraud, safety or legal notices.

6.5 Direct marketing

Where required, we rely on your consent to send marketing by WhatsApp, SMS, email, push notification or other electronic messaging channels. Marketing may include member offers and benefits, dental treatment information, appointment opportunities, promotions and price-related campaigns, competitions and giveaways, reward and cashback opportunities, referral campaigns, product or service launches, events, news and updates, surveys and feedback requests, and communications concerning SPACE Dental, Straights, SHINE Veneers and other clearly identified participating dental brands or practices.

Marketing consent is optional. Refusing or withdrawing marketing consent will not prevent you from creating or retaining a Dentist Gold Card account, although you may not receive optional offers or promotional updates. See also our Electronic Messaging and Marketing Consent Notice.

6.6 Personalising and measuring communications

We may use information about your programme, selected brand, location, referral activity, previous enquiries and message engagement to send relevant communications, avoid sending irrelevant campaigns, measure delivery and campaign performance, improve content and timing, manage message frequency, and maintain suppression lists.

6.7 Customer service, complaints and quality assurance

We use information to respond to requests, investigate complaints, monitor service quality, train authorised team members, protect our legal position, and resolve disputes.

6.8 Analytics, platform development and security

We use information to maintain our websites, apps and dashboards, understand service usage, improve registration and referral journeys, diagnose technical issues, prevent unauthorised access, detect fraud or abuse, and maintain backups and business continuity.

6.9 Legal, regulatory and financial administration

We may process information to keep accounting and tax records, respond to legal claims, comply with lawful requests, meet regulatory responsibilities, and cooperate with professional advisers, insurers, regulators and public authorities.

Where you expressly select a communication channel, we may use that channel to send the categories of communications described at the point of consent. For WhatsApp, you must provide a mobile number connected to WhatsApp; Dentist Gold Card or the named participating brand will identify itself; messages may be delivered using the WhatsApp Business Platform and an authorised communications provider; automated workflows and approved message templates may be used; and you may opt out at any time by replying STOP, using another opt-out instruction, updating your preferences or contacting us.

We may retain an appropriate suppression record after an opt-out so that your preferences continue to be respected.

We may use automated workflows to send welcome and verification messages, route enquiries, categorise contacts, send appointment, referral and reward updates, pause or stop communications following an opt-out, assign conversations to team members, and identify potentially duplicate or suspicious referral activity. We do not intend to make decisions producing legal or similarly significant effects solely by automated means without appropriate safeguards.

The Dentist Gold Card programme may connect members with SPACE Dental, Straights, SHINE Veneers, participating dental practices and clinicians, affiliated dental or cosmetic-treatment brands, corporate and employee-benefit partners, and technology, payment and communications providers. We will not interpret your consent to Dentist Gold Card marketing as unlimited consent for unrelated organisations to market their own products to you.

Where necessary and lawful, information may be shared with participating dental practices and clinicians, relevant Dentist Gold Card brands and operational teams, appointment-booking and CRM providers, Respond.io or another authorised messaging and workflow provider, WhatsApp and Meta platform services, SMS, email, telephone and push-notification providers, website, app, dashboard, hosting and cloud-service providers, payment processors, banks and reward-payment providers, finance providers where you request a finance introduction, analytics and advertising providers (subject to cookie and consent requirements), IT and cybersecurity providers, professional advisers, regulators, courts and law-enforcement agencies where required, and potential purchasers or investors in a lawful corporate transaction.

Some technology and communications providers may process personal information outside the United Kingdom. Where personal information is transferred internationally, we will use a legally recognised safeguard where required, such as UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another lawful transfer mechanism.

We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Notice, including legal, accounting, fraud-prevention and dispute-resolution requirements. Information that is no longer required will be deleted, anonymised or securely isolated.

We use appropriate technical and organisational measures designed to protect personal information. No transmission or storage system can be guaranteed to be completely secure.

Dentist Gold Card is not intended to collect marketing consent directly from children who are not legally able to provide it. Where a person is under 16, we may require involvement or authorisation from a parent or legal guardian, depending on the service and applicable law.

Depending on the circumstances, you may have the right to:

• request access to your personal information;
• request correction of inaccurate or incomplete information;
• request deletion;
• request restriction of processing;
• object to processing based on legitimate interests;
• object to direct marketing at any time;
• withdraw consent at any time;
• request data portability;
• complain about how your information has been used.

Requests may be sent to hello@dentistgoldcard.co.uk.

You can stop marketing by:

• replying STOP to an eligible WhatsApp or SMS message;
• selecting an unsubscribe link in an email;
• changing your account preferences;
• asking a team member;
• emailing hello@dentistgoldcard.co.uk;
• telephoning 01924 565955.

We may continue sending essential administrative or service messages where lawful and necessary.

Our websites, applications and dashboards may use essential and non-essential cookies, pixels, software development kits and similar technologies. Non-essential technologies will be used only where permitted and, where required, after consent has been obtained.

We may update this Privacy Notice where our services, providers, brands, technologies or legal obligations change. The current version will be published on our website with its effective date. Where changes materially affect how information is used, we will provide an appropriate notice and obtain new consent where required.

Please contact us first if you have concerns:

You may also complain to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113. Website: ico.org.uk.