any websites owned and operated by us, including www.bemealigners.com and the associated applications and services (the “Website”);
any official social media channels created by us on any social media platforms (including but not limited to Facebook, Instagram, Twitter, WeChat, YouTube, Telegram and WhatsApp) (the “Channels”); and
Children under the age of 18
Information we collect about you
We provide access to orthodontic medical device involving our “BeMe Aligners” and “BeMe Retainers” (which are invisible dental aligners and plastic dental retainers) and related products developed by us, by collaborating with dentists and orthodontists registered to practice dentistry in the countries we operate (collectively, the “BeMe Treatment”).
By using our Services, whether as a
visitor of the Website or Channels;
(prospective, current or former) patient;
parent / guardian of such patient; or
dentist / orthodontist / other dental healthcare professional,
you may be asked to provide us with personal data such as your name, age, contact information, health information about teeth alignment or geographical location. We may collect your personal data either directly from you, your authorised representatives, and/or through our third-party service providers (e.g. partners or third-party applications).
Purposes for collection
We use your personal data to provide you with relevant Services and to operate our business. We may also use the data collected to communicate with you, for instance, to inform you about new features of the Services, security updates, or to inform you about your account. Your personal data may also be used to show you relevant information, content, advertisements, whether through the Services or third-party applications and in combination with information from other sources.
Use of your personal data
Your data will be used to process, record, monitor and fulfil the Services or your requests. Including but not limited to the below uses
facilitating our provision of the Services;
communicating with you for research, marketing, advertising and promotional purposes;
administrative matters on your subscriptions to the Services, managing your accounts, processing your sign-ups/registrations for mailing lists, etc.;
diagnosis and maintenance of the Services;
maintaining the security of the Services;
to protect you and other users of the Services and visitors;
enforcement of our policies and procedures;
to permit you to submit questions, feedback or complaints; and/or
such other purposes notified to you from time to time.
Where you are a visitor, (prospective, current or former) patient, or parent/guardian of such patient (collectively, the “Patients”) some examples of our use of your personal data include:
to allow you to access online facilities, to book an appointment with our partner dentist(s) / orthodontist(s) / other dental healthcare professional(s);
to provide you with details of dentist(s) / orthodontist(s) / other dental healthcare professional(s); and/or
to generate preliminary compatibility assessment reports to assist in determining your suitability for BeMe Treatment.
Where you are a dentist / orthodontist / other dental healthcare professional, some examples of our use of your personal data include:
to provide you with information on prospective or actual Patients;
to allow you to accept appointment bookings or other requests from Patients; and/or
to allow the creation of profiles which can be viewed by Patients (which may include details such as dental professional’s name and contact details, the dental clinic’s name and contact details, and other relevant information such as practice experience and specialisations).
The manner in which your personal data is used will depend on the circumstances at hand, and it will be used in compliance with applicable laws and regulations.
Disclosure of your personal data
We share your personal data with third parties such as our subsidiaries, affiliates, related corporations, service providers, vendors, in necessary circumstances, as an extension of your patient care as part of the BeMe Treatment, or regulatory authorities or other third parties. Such third parties processing your personal data either on our behalf or otherwise may be located in a different country from the point of collection of your personal data, or may have multiple physical locations and backups.
Where your personal data must be shared with third parties in circumstances that are not reasonably contemplated within the normal course of our dealings with you, we would first seek your consent unless the disclosure:
is required or authorised based on the applicable laws and/or regulations;
is clearly in your interests, and if consent cannot be obtained in a timely way;
is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
is necessary for any investigation or proceedings;
is required by a law enforcement agency;
is to a public agency and necessary in the public interest; and/or
where such disclosure without your consent is permitted by law.
Where we disclose your personal data to third parties, we will employ our best efforts to require such third parties to protect your personal data.
By using our Services, you agree that the transfer of your personal data to various countries is reasonably necessary for us to provide you with these Services.
Accessing and updating your personal data
You may request access to or correct the personal data held by us by submitting a written request to firstname.lastname@example.org.
We may require further information from you to verify your identity as well as the nature of your request. Handling and processing fees may be payable before we can proceed with your request.
Once we have sufficient information to deal with your request, we will seek to provide you with the relevant personal data or information within thirty (30) days of your request, unless otherwise stated.
Request to withdraw consent
Should you wish to withdraw your consent to our use of your personal data, please stop using the Services immediately and notify us in writing at email@example.com to inform us that you wish for us to stop collecting, using or sharing your personal data and we will process your request within a reasonable time from such a request. You may also elect to withdraw your consent to the use of your personal data for a specific purpose, so please ensure that your notification contains sufficient and specific information to enable us to comply with your request.
Your withdrawal of consent could result in certain legal consequences, which may mean that we will not be able to continue with your existing relationship with us, including but not limited to, providing you with our Services even if it is being paid for.
Retention, administration and management of personal data
We take reasonable efforts to ensure that your personal data is protected and secured, accurate and complete, based on the information that you have provided us with. Please ensure that all information provided to us is up to date and keep us informed of any relevant changes.
We put in place measures to ensure your personal data in our possession or under our control is destroyed and/or anonymised, unless required by law, regulation or other business or audit requirements, as soon as it is reasonable to assume that:
the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and
retention is no longer necessary for any other legal or business purposes.
Sharing of personal data via Channels
Where you are a user of any of the Channels and/or other social media platforms with public account settings and you use any hashtags which may be related to BeMe, the BeMe Treatment or any of its campaigns and/or products or services, we will be able to retrieve your reviews of our services from the Channels and post them on our Website or Channels, for the purposes of sharing your opinions about our products with the visitors of our Website and Channels. You hereby agree not to use such hashtags if you do not wish for your reviews/feedback/content to be made available on any of our Website or Channels. By posting or otherwise making available any content on the Channels or a social media platform about your experience in relation to the BeMe Treatment, and responding “yes” where we request your permission to share your content on any of our Website or Channels, you represent and warrant that you are 18 years of age or older and that you agree to the terms and conditions listed on the Website and Channels.
We may collect information from you (or others on your behalf) de-identified information to help us in our business and provide you with the relevant Services. Such anonymised and de-identified information may be transferred, disclosed, assigned, leased, licensed, sold and otherwise shared with and by our partners, service providers, advertisers and/or other third parties for purposes permitted under law.
Complaint/ contact process