Privacy Policy

Smile High Dental Tourism

Privacy Policy
Effective Date: 15th March 2026

Smile High operates exclusively as a dental tourism agency and patient facilitation service. We act solely as an intermediary between patients (primarily residents of the United Kingdom and Ireland) and independently licensed dental clinics in Albania. We do not provide medical advice, medical diagnosis, clinical treatment, or healthcare services. All clinical decisions, examinations, diagnoses, treatment plans, procedures, and aftercare are the sole responsibility of the treating dental clinic and its licensed dental professionals.

This Privacy Policy explains in full detail how we collect, process, store, transfer, and protect your personal data in accordance with applicable data protection laws, including but not limited to:

  • The UK General Data Protection Regulation (UK GDPR)

  • The EU General Data Protection Regulation (EU GDPR), where applicable

  • The UK Data Protection Act 2018

By using our website or services, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

We collect personal data that is necessary, proportionate, and relevant to the purpose of facilitating dental tourism services. We apply the principle of data minimisation and only request information that is required to connect you with appropriate dental clinics and assist with travel coordination.

1.1 Personal Identification Information

When you contact us, submit an enquiry, or engage our services, we may collect:

  • Full legal name

  • Date of birth (if required for booking or clinic identification purposes)

  • Email address

  • Telephone number (mobile and/or landline)

  • Country of residence

  • City of residence

  • Nationality (where relevant for travel purposes)

  • Preferred method of communication

  • Travel availability and preferred travel dates

  • Accommodation preferences

  • Emergency contact information (if voluntarily provided)

  • Any information included in your direct communications with us

This information allows us to respond to your enquiry and coordinate consultations efficiently.

1.2 Health and Medical-Related Information (Special Category Data)

Because we operate within the dental tourism sector, you may voluntarily provide health-related information in order to receive preliminary treatment assessments from partner clinics. This may include:

  • Dental history

  • Existing dental conditions

  • Description of symptoms

  • Previous dental treatments

  • X-rays

  • Photographs of teeth

  • CT scans (if voluntarily shared)

  • Treatment goals or preferences

  • Relevant medical conditions (if disclosed by you)

This data is classified as special category data under UK GDPR and EU GDPR.

We:

  • Collect such information only with your explicit consent

  • Do not interpret or medically evaluate your data

  • Do not provide clinical recommendations

  • Transmit your information securely to partner clinics solely for consultation and quotation purposes

Smile High does not act as a healthcare provider and does not determine medical suitability for treatment.

1.3 Technical and Website Usage Information

When you access our website, certain information may be collected automatically through cookies or analytics tools, including:

  • IP address

  • Device type

  • Browser type and version

  • Operating system

  • Time zone setting

  • Website pages visited

  • Date and time of access

  • Referring website

  • Clickstream data

  • Session duration

This information is used for:

  • Website performance monitoring

  • Security protection

  • Fraud prevention

  • Service improvement

  • Statistical analysis

 

2. Lawful Basis for Processing Personal Data

Smile High Dental Tourism Agency processes personal data strictly in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR) where applicable, and the UK Data Protection Act 2018.

We do not process personal data arbitrarily. Every category of data collected and every processing activity undertaken by Smile High is supported by at least one recognised lawful basis under Article 6 of the UK/EU GDPR. Where health-related information is involved, we additionally rely on conditions under Article 9 for special category data.

Below is a detailed explanation of the lawful bases upon which we rely.

2.1 Contractual Necessity (Article 6(1)(b) UK/EU GDPR)

We process personal data where such processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract.

When you contact Smile High to request information, obtain a quotation, or arrange dental tourism services, you are asking us to take steps on your behalf. In order to do so, we must process certain personal information.

Processing under this lawful basis may include:

  • Responding to your initial enquiry

  • Collecting contact details

  • Forwarding your case to partner clinics

  • Coordinating appointment scheduling

  • Communicating travel dates

  • Assisting with accommodation arrangements

  • Managing administrative follow-up

Without processing this information, we would be unable to provide the facilitation services you have requested.

This lawful basis applies strictly to services we provide as a dental tourism facilitator. It does not extend to medical treatment itself, which is governed by the independent clinic’s contractual relationship with you.

2.2 Explicit Consent (Article 6(1)(a) and Article 9(2)(a))

Where we process health-related information (special category data), we rely on your explicit consent.

Health data includes:

  • Dental history

  • X-rays

  • Photographs

  • Medical disclosures relevant to treatment

  • Treatment objectives

Because this data is sensitive in nature, we require a clear and affirmative indication that you consent to us transmitting this information to partner clinics for consultation and quotation purposes.

Your consent must be:

  • Freely given

  • Specific

  • Informed

  • Unambiguous

  • Provided through a clear affirmative action

You have the right to withdraw your consent at any time by contacting us in writing. If consent is withdrawn:

  • We will cease processing your health-related data

  • We will stop transmitting your information to clinics

  • We may not be able to continue facilitating your case

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Smile High does not rely on implied consent for medical data. Explicit consent is always required.

2.3 Legitimate Interests (Article 6(1)(f))

We may process personal data where it is necessary for our legitimate business interests, provided that such interests are not overridden by your fundamental rights and freedoms.

Legitimate interests may include:

  • Improving our website functionality

  • Enhancing customer service

  • Maintaining internal records

  • Ensuring IT security and system integrity

  • Preventing fraud or misuse of services

  • Managing business operations

  • Responding to complaints or disputes

  • Conducting internal audits

Before relying on legitimate interests, we carry out an internal balancing test to ensure:

  • The processing is necessary

  • The impact on your privacy is minimal

  • Your rights are not unfairly compromised

Where appropriate, we implement safeguards such as data minimisation, access restrictions, and encryption.

You have the right to object to processing based on legitimate interests at any time.

2.4 Legal Obligations (Article 6(1)(c))

We may process personal data where necessary to comply with legal obligations to which Smile High is subject.

This may include compliance with:

  • Tax and accounting regulations

  • Anti-fraud requirements

  • Court orders

  • Regulatory investigations

  • Law enforcement requests

  • Consumer protection laws

In such cases, processing is limited strictly to what is required by law.

2.5 Establishment, Exercise, or Defence of Legal Claims (Article 9(2)(f))

Where necessary, we may process personal or health-related data for the establishment, exercise, or defence of legal claims.

This may arise in situations involving:

  • Contractual disputes

  • Complaints

  • Regulatory investigations

  • Claims relating to services facilitated

Such processing will be proportionate and limited to what is necessary to protect legal rights.

2.6 International Transfers and Safeguards

Given that Smile High facilitates treatment in Albania for patients primarily located in the United Kingdom and Ireland, personal data may be transferred internationally.

Where personal data is transferred outside the UK or EU, we ensure that at least one of the following safeguards applies:

  • Contractual data protection clauses

  • Confidentiality agreements

  • Secure encrypted transmission methods

  • Data minimisation practices

  • Controlled access limitations

International transfers are conducted only for the purpose of fulfilling your request for dental tourism facilitation.

2.7 No Automated Decision-Making

Smile High does not engage in:

  • Automated decision-making producing legal effects

  • Algorithmic medical assessments

  • Profiling for clinical conclusions

All treatment decisions are made solely by licensed dental professionals at independent clinics.

2.8 Data Minimisation and Purpose Limitation

Regardless of the lawful basis relied upon, Smile High adheres to the core GDPR principles of:

  • Lawfulness

  • Fairness

  • Transparency

  • Purpose limitation

  • Data minimisation

  • Accuracy

  • Storage limitation

  • Integrity and confidentiality

We process only the personal data that is necessary for clearly defined purposes and do not retain data longer than required.

4. Sharing of Information

Smile High Dental Tourism Agency treats all personal data with strict confidentiality. We do not sell, rent, lease, trade, or commercially distribute your personal information under any circumstances.

We share personal data only where it is necessary, proportionate, and directly related to the facilitation of dental tourism services, or where we are legally required to do so.

Because we operate as an intermediary between patients in the United Kingdom and Ireland and licensed dental clinics in Albania, certain information must be shared to fulfil our coordination role. However, we limit all disclosures to the minimum data necessary for the intended purpose.

Below is a detailed explanation of when, why, and how information may be shared.

4.1 Sharing with Partner Dental Clinics

In order to obtain treatment assessments, quotations, and appointment availability, we may share relevant personal and medical information with selected partner dental clinics in Albania.

This may include:

  • Full name

  • Date of birth (where required by the clinic)

  • Contact details

  • Dental history

  • X-rays

  • Photographs

  • Treatment objectives

  • Relevant medical disclosures voluntarily provided by you

The purpose of this sharing is strictly to:

  • Enable clinics to review your case

  • Prepare preliminary treatment plans

  • Provide cost estimates

  • Assess scheduling availability

  • Communicate directly with you where appropriate

 

Important Clarification of Responsibility

Each partner clinic operates as:

  • An independent healthcare provider

  • An independent data controller

  • A licensed medical entity under its own regulatory framework

Once your data is lawfully transferred for consultation purposes:

  • The clinic becomes independently responsible for how it processes medical data

  • The dentist assumes clinical responsibility

  • A direct medical relationship is formed between you and the clinic

Smile High does not:

  • Control the clinical decision-making process

  • Interfere with treatment planning

  • Supervise medical procedures

  • Guarantee treatment outcomes

Our role remains administrative and facilitative only.

4.2 Sharing with Travel and Accommodation Providers

If you request assistance with travel coordination, we may share limited personal information with third-party service providers, such as:

  • Hotels

  • Airport transfer services

  • Transportation providers

  • Accommodation partners

The information shared may include:

  • Full name

  • Contact number

  • Travel dates

  • Arrival/departure times

We share only the information strictly required to secure reservations or coordinate logistics.

Smile High is not responsible for the independent privacy practices of travel or accommodation providers. We encourage clients to review the privacy policies of those providers separately.

4.3 Sharing with Professional Advisers

We may disclose limited personal data to trusted professional advisers where necessary, including:

  • Legal advisers

  • Accountants

  • Insurers

  • Compliance consultants

Such disclosures may occur for:

  • Legal compliance

  • Contractual disputes

  • Insurance claims

  • Regulatory matters

  • Risk management

All professional advisers are subject to confidentiality obligations.

4.4 Sharing for Legal and Regulatory Reasons

We may disclose personal information where required by law or where we believe disclosure is necessary to:

  • Comply with a legal obligation

  • Respond to court orders or lawful requests

  • Cooperate with law enforcement authorities

  • Protect our legal rights

  • Prevent fraud or unlawful activity

  • Defend against legal claims

Any such disclosure will be limited strictly to what is legally required.

4.5 International Data Transfers

Due to the cross-border nature of dental tourism, personal data may be transferred internationally, including from:

  • The United Kingdom to Albania

  • EU Member States to Albania

Where international transfers occur, we implement appropriate safeguards, which may include:

  • Contractual data protection clauses

  • Confidentiality agreements

  • Secure encrypted communication channels

  • Access controls

  • Data minimisation measures

Such transfers are conducted solely for the purpose of fulfilling your request for facilitation services.

 

4.6 Data Processors Acting on Our Behalf

In certain circumstances, we may use trusted third-party service providers who process data on our behalf, such as:

  • Website hosting providers

  • Email service providers

  • IT support services

  • Cloud storage providers

  • CRM systems

These providers are contractually obligated to:

  • Process data only on our instructions

  • Maintain confidentiality

  • Implement appropriate security measures

  • Comply with applicable data protection laws

They are not permitted to use your data for their own independent purposes.

 

4.7 No Sale or Commercial Exploitation of Data

Smile High Dental Tourism Agency explicitly confirms:

  • We do not sell personal data.

  • We do not monetise personal data.

  • We do not share data with advertising networks.

  • We do not allow third parties to use your data for marketing unrelated services.

Your information is used exclusively for the facilitation of dental tourism services and lawful operational purposes.

 

4.8 Limitation of Liability After Lawful Transfer

Once personal data has been lawfully transferred to an independent dental clinic or service provider at your request:

  • The receiving entity assumes responsibility for its own data protection compliance.

  • Smile High is not responsible for independent actions taken by third-party data controllers.

  • Any medical data subsequently created during treatment is governed by the clinic’s own privacy policy and regulatory obligations.

We strongly encourage all patients to review the privacy policies of partner clinics before proceeding with treatment.

 

5. International Data Transfers

Due to the nature of our services as a dental tourism facilitation agency connecting patients primarily located in the United Kingdom and Ireland with licensed dental clinics in Albania, the transfer of personal data across international borders is an essential component of our operations.

Smile High Dental Tourism Agency recognises that international transfers of personal data carry additional legal and security considerations. We are committed to ensuring that any such transfers are conducted lawfully, securely, and in compliance with applicable data protection legislation, including the UK GDPR and EU GDPR where relevant.

 

5.1 Nature of International Transfers

When you engage our services, your personal data may be transferred:

  • From the United Kingdom to Albania

  • From an EU Member State to Albania

  • Between service providers operating in different jurisdictions

  • Through secure cloud-based systems hosted in approved jurisdictions

These transfers occur strictly for the purpose of:

  • Facilitating communication with partner dental clinics

  • Obtaining treatment quotations

  • Coordinating appointments

  • Assisting with travel arrangements (if requested)

International data transfers are limited to what is necessary to fulfil your request for facilitation services.

 

5.2 Legal Basis for Cross-Border Transfers

International transfers are carried out under one or more of the following lawful mechanisms:

  • Your explicit consent to transmit medical documentation to clinics abroad

  • Contractual necessity for the performance of services requested by you

  • Implementation of appropriate safeguards as required under UK and EU data protection laws

Where required, we ensure that appropriate contractual or organisational measures are in place to safeguard personal data.

 

5.3 Safeguards Implemented

To ensure that your personal data remains protected when transferred internationally, Smile High implements reasonable and proportionate safeguards, which may include:

  • Secure encrypted email transmission

  • Password-protected documentation

  • Secure file-sharing platforms

  • Access restrictions within our organisation

  • Confidentiality agreements with partner clinics

  • Contractual data protection clauses where appropriate

  • Limitation of data to what is strictly necessary

We apply data minimisation principles to ensure that only relevant information required for consultation or booking purposes is transferred.

 

5.4 Role of Independent Clinics

It is important to clarify that once personal data has been transmitted to a licensed dental clinic in Albania at your request:

  • The clinic acts as an independent data controller.

  • The clinic assumes responsibility for processing medical data in accordance with its own legal and regulatory framework.

  • The dentist establishes a direct clinical relationship with you.

Smile High does not control the internal data handling policies of independent clinics once the transfer has occurred lawfully and at your request.

We strongly encourage patients to review the privacy policies of the treating clinic before proceeding with treatment.

 

5.5 Transfers Through Third-Party Service Providers

Certain service providers used by Smile High (such as email platforms, cloud storage providers, CRM systems, and website hosting providers) may process data in jurisdictions outside the UK and Ireland.

Where this occurs:

  • We use reputable providers that implement appropriate security standards.

  • We ensure contractual safeguards are in place where required.

  • We take reasonable steps to confirm that adequate technical and organisational measures are implemented.

Such transfers are limited to administrative and operational data required to deliver our services.

 

5.6 Data Security During Transmission

To reduce the risks associated with international transfers, we implement technical security measures such as:

  • Secure communication channels

  • Password-protected attachments

  • Limited access controls

  • Internal data handling procedures

  • Staff confidentiality obligations

However, no method of electronic transmission over the internet can be guaranteed to be completely secure. While we take reasonable precautions, you acknowledge that cross-border electronic communication carries inherent risks.

 

5.7 Consent to International Transfers

By voluntarily submitting your personal and medical information to Smile High for the purpose of obtaining treatment assessments abroad, you acknowledge and consent to the international transfer of your data to selected partner clinics and service providers as necessary to fulfil your request.

If you do not wish for your data to be transferred internationally, we may be unable to facilitate your dental tourism enquiry.

 

5.8 Limitation of Responsibility Post-Transfer

Once personal data has been lawfully transferred to an independent clinic or service provider at your request:

  • Smile High is not responsible for the independent data handling practices of that third party.

  • Any further processing of medical data is governed by the clinic’s own privacy policy.

  • Clinical records created during treatment fall under the responsibility of the treating clinic.

Our responsibility remains limited to the secure and lawful facilitation of the initial transfer.

 

6. Data Security

Smile High Dental Tourism Agency takes the security of personal data extremely seriously and implements a combination of technical, organisational, and administrative measures designed to protect personal information against unauthorised access, accidental loss, alteration, disclosure, or destruction.

We recognise that the data we handle includes not only basic personal information but also sensitive health-related documentation such as dental records, X-rays, and medical histories. For this reason, we apply enhanced safeguards appropriate to the nature and sensitivity of the data processed.

However, while we implement robust security measures, no system, method of transmission, or electronic storage environment can be guaranteed to be completely secure. By using our services, you acknowledge this inherent limitation.

 

6.1 Organisational Security Measures

We maintain strict internal policies and procedures to ensure that personal data is handled responsibly and securely by all staff members and contractors.

These measures include:

  • Confidentiality obligations for all staff and collaborators

  • Access control policies restricting data access to authorised personnel only

  • Role-based access permissions (staff only access data necessary for their role)

  • Internal training on data protection and GDPR compliance

  • Procedures for handling sensitive medical documentation securely

  • Clear internal reporting channels for data security concerns or breaches

Access to personal data is granted strictly on a “need-to-know” basis.

 

6.2 Technical Security Measures

We implement a range of technical safeguards designed to protect personal data in electronic form, including but not limited to:

  • Secure Socket Layer (SSL) encryption on website communications where applicable

  • Encrypted email communication for sensitive documentation where available

  • Password-protected files for medical records such as X-rays and scans

  • Secure cloud storage solutions provided by reputable service providers

  • Multi-factor authentication for internal systems where possible

  • Firewalls and intrusion detection systems to protect against unauthorised access

  • Regular system updates and security patch management

  • Malware and antivirus protection on company devices

These measures are regularly reviewed and updated in line with evolving cybersecurity standards.

 

6.3 Data Minimisation and Access Control

We reduce security risks by limiting the amount of personal data stored and restricting access:

  • Only necessary data is collected for service provision

  • Medical files are shared only with relevant partner clinics

  • Access to sensitive documents is restricted to authorised coordination staff

  • Data is not stored longer than required for operational purposes

  • Unnecessary copies of documents are not retained

This significantly reduces exposure in the event of a security incident.

 

6.4 Secure Transmission of Data

When transmitting personal or medical data, especially across borders, we apply enhanced security measures such as:

  • Encrypted email services where available

  • Secure file-sharing platforms with restricted access links

  • Password-protected attachments sent separately from files

  • Verification of recipient identity before data transfer

  • Controlled distribution of medical documentation to approved clinics only

We take reasonable steps to ensure that data is not intercepted, altered, or accessed by unauthorised parties during transmission.

 

6.5 Storage Security

Personal data is stored using secure systems designed to prevent unauthorised access or data loss. These may include:

  • Secure cloud-based storage providers with industry-standard certifications

  • Access-restricted databases

  • Encrypted storage environments where appropriate

  • Regular backups to prevent accidental data loss

  • Secure deletion protocols for obsolete data

Data storage systems are selected based on their compliance with recognised security standards.

 

6.6 Partner Clinic Security Responsibility

Once personal data has been securely transmitted to a partner dental clinic in Albania:

  • That clinic becomes independently responsible for securing the data

  • The clinic applies its own technical and organisational measures

  • Smile High has no control over the internal systems of the clinic

  • Clinics are expected to comply with applicable healthcare and data protection regulations

We only engage with clinics that are expected to maintain appropriate professional standards.

 

6.7 Incident and Breach Management

In the unlikely event of a personal data breach, Smile High has procedures in place to:

  • Identify and assess the nature of the breach

  • Contain and mitigate the impact

  • Restore system security

  • Notify affected individuals where legally required

  • Report breaches to relevant supervisory authorities where applicable

  • Review and improve security practices to prevent recurrence

All breaches are treated seriously and investigated promptly.

 

6.8 Staff Training and Awareness

All personnel involved in processing personal data receive appropriate training covering:

  • GDPR principles and obligations

  • Secure handling of sensitive medical data

  • Phishing and cybersecurity awareness

  • Data breach prevention and reporting procedures

  • Confidentiality requirements

Training is updated periodically to reflect changes in legislation and best practice.

 

6.9 Limitations of Security

While we take all reasonable steps to protect personal data, you acknowledge and accept that:

  • No internet-based transmission is completely secure

  • Email communication may carry inherent risks

  • External systems and networks may be vulnerable to interception

  • Absolute security cannot be guaranteed

We therefore encourage users to share sensitive information only when necessary and through recommended secure channels.

 

7. Data Retention

Smile High Dental Tourism Agency retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, in accordance with the principles of storage limitation and data minimisation under the UK GDPR and EU GDPR.

We do not retain personal data indefinitely, and we implement structured retention periods based on the nature of the data, the purpose of processing, and any applicable legal or regulatory obligations.

Once data is no longer required for its original purpose, it is securely deleted, anonymised, or permanently de-identified.

 

7.1 General Retention Principle

As a general rule, Smile High retains personal data only for the duration necessary to:

  • Provide dental tourism facilitation services

  • Manage ongoing communication with patients

  • Coordinate consultations and clinic interactions

  • Assist with travel arrangements (if applicable)

  • Maintain internal administrative records

  • Comply with legal and regulatory obligations

  • Resolve disputes or enquiries

Retention periods are determined based on operational necessity and legal compliance requirements.

 

7.2 Retention of Enquiry Data (Non-Client Records)

If you make an enquiry but do not proceed with our services, we may retain your personal data for a limited period in order to:

  • Respond to follow-up questions

  • Maintain business communication records

  • Analyse service demand trends

  • Improve customer service quality

  • Prevent duplicate or fraudulent enquiries

Typically, such data is retained for a reasonable period not exceeding what is necessary for administrative follow-up and service improvement purposes, after which it is securely deleted or anonymised.

 

7.3 Retention of Client Case Files

Where you proceed with Smile High services, we may retain your personal and case-related information for the duration of the facilitation process, including:

  • Initial enquiry stage

  • Clinic matching and referral stage

  • Consultation stage

  • Travel coordination stage (if applicable)

  • Post-consultation communication

Once your case is completed, we retain relevant records for a limited period to:

  • Support customer service enquiries

  • Resolve disputes or complaints

  • Maintain business records

  • Comply with legal obligations

Retention of completed case files is limited to what is necessary and proportionate under applicable law.

 

7.4 Retention of Health and Medical-Related Data

Health-related information (including dental records, X-rays, photographs, and scans) is treated as special category data and is subject to stricter retention controls.

We retain such data only:

  • For the duration required to facilitate consultation with partner clinics

  • For as long as necessary to support ongoing treatment coordination (if applicable)

  • For dispute resolution or legal protection purposes where required

Once the facilitation process is completed and no further communication with clinics is required, medical data is securely deleted unless:

  • You request continued storage

  • Legal obligations require retention

  • A dispute or claim is ongoing

Medical data is never retained for longer than necessary without a clear lawful basis.

 

7.5 Retention for Legal and Regulatory Compliance

We may retain personal data for longer periods where required to comply with:

  • Tax regulations

  • Accounting obligations

  • Legal claims or litigation

  • Regulatory investigations

  • Contractual enforcement

In such cases, data will be retained only for the minimum duration required by law.

 

7.6 Retention of Communication Records

We may retain records of communications (emails, messages, calls, and enquiries) for:

  • Customer service purposes

  • Quality assurance

  • Training and internal review

  • Dispute resolution

These records are stored securely and access is restricted to authorised personnel only.

 

7.7 Data Deletion and Anonymisation

When personal data is no longer required, we ensure it is either:

  • Permanently deleted from active systems, or

  • Anonymised so that it can no longer identify an individual

Anonymised data may be retained for statistical, analytical, or service improvement purposes.

Once anonymised, data is no longer considered personal data under GDPR.

 

7.8 Secure Destruction Procedures

We apply secure deletion methods appropriate to the type of data and storage system, including:

  • Permanent digital deletion from secure systems

  • Removal from cloud storage environments

  • Overwriting or secure erasure of stored files

  • Secure disposal of physical records (if any exist)

We take reasonable steps to ensure that deleted data cannot be recovered or reconstructed.

 

7.9 Your Right to Request Deletion

You have the right to request deletion of your personal data at any time, subject to legal and operational limitations.

Upon receiving a valid request, we will:

  • Review whether continued retention is legally required

  • Delete data that is no longer necessary

  • Inform you of any data we are required to retain for legal purposes

Where deletion is not immediately possible, we will securely restrict processing until deletion becomes permissible.

 

7.10 Retention in Partner Clinics

Once your data has been transferred to a partner dental clinic:

  • That clinic is independently responsible for its own retention policies

  • Clinical records created during treatment are subject to the clinic’s legal obligations

  • Smile High does not control retention periods within third-party clinical systems

We recommend that patients review the retention policies of their treating clinic directly.

 

8. Your Rights

Smile High Dental Tourism Agency fully recognises and respects your rights as a data subject under applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and the UK Data Protection Act 2018. These rights are fundamental to ensuring transparency, accountability, and control over your personal data.

We are committed to facilitating the exercise of your rights in a clear, accessible, and lawful manner. Any request made by you in relation to your personal data will be handled carefully, securely, and in accordance with statutory requirements.

You may exercise any of the rights set out below at any time by contacting us using the details provided in Section 13. In order to protect your privacy and the security of your personal data, we may require you to verify your identity before we can respond to your request.

 

8.1 Right of Access (Article 15 UK/EU GDPR)

You have the right to obtain confirmation as to whether or not we are processing your personal data. Where such processing is taking place, you are entitled to access your personal data and receive supplementary information regarding its use.

This includes the right to request:

  • A copy of all personal data we hold about you

  • The purposes of processing your data

  • The categories of personal data concerned

  • The categories of recipients to whom data has been or will be disclosed (including partner clinics)

  • The envisaged retention period or criteria used to determine retention

  • The source of the data, where it has not been collected directly from you

  • Information about your rights under data protection law

  • Whether your data is subject to automated processing (if applicable)

We will provide this information in a structured, commonly used, and machine-readable format where feasible.

This right allows you to understand exactly what information is held about you and how it is being used within the scope of our services.

 

8.2 Right to Rectification (Article 16 UK/EU GDPR)

You have the right to request that we correct any inaccurate personal data or complete any incomplete personal data we hold about you.

This includes corrections to:

  • Personal identification details (name, contact information, etc.)

  • Travel or booking-related information

  • Communication records

  • Any voluntarily provided medical or dental information

We take reasonable steps to ensure that all personal data we process is accurate and up to date. Where appropriate, we may also communicate rectified data to relevant third parties, such as partner dental clinics, where they have received the original data.

 

8.3 Right to Erasure (Right to be Forgotten) (Article 17 UK/EU GDPR)

You have the right to request the deletion of your personal data in certain circumstances.

This right applies where:

  • The personal data is no longer necessary for the purpose for which it was collected

  • You withdraw consent (where consent is the lawful basis)

  • You object to processing and there are no overriding legitimate grounds

  • The data has been unlawfully processed

  • The data must be erased to comply with a legal obligation

However, this right is not absolute. We may retain personal data where:

  • We are required to do so by law

  • Retention is necessary for legal claims, disputes, or defence of legal rights

  • We are obliged to retain records for regulatory or accounting purposes

Where full deletion is not possible, we will ensure that the data is securely restricted and no longer actively processed except where legally required.

 

8.4 Right to Restrict Processing (Article 18 UK/EU GDPR)

You have the right to request that we temporarily suspend the processing of your personal data in specific circumstances.

This may apply where:

  • You contest the accuracy of the personal data

  • Processing is unlawful but you oppose erasure

  • We no longer need the data, but you require it for legal claims

  • You have objected to processing and verification is pending

When processing is restricted:

  • Your data will be stored securely

  • No further processing will take place except with your consent or for legal reasons

  • We will inform you before lifting any restriction

8.5 Right to Object (Article 21 UK/EU GDPR)

You have the right to object to the processing of your personal data where such processing is based on legitimate interests.

Upon receiving an objection, we will:

  • Assess whether our legitimate grounds for processing override your rights and freedoms

  • Stop processing your data unless we can demonstrate compelling legitimate grounds

  • Always respect your right to object to direct marketing (where applicable)

You also have the absolute right to object to the use of your personal data for marketing purposes at any time.

8.6 Right to Data Portability (Article 20 UK/EU GDPR)

Where processing is based on consent or contractual necessity and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.

You also have the right to request that we transmit your personal data directly to another data controller where technically feasible.

This right applies only to data you have provided directly to us.

8.7 Right to Withdraw Consent (Article 7 UK/EU GDPR)

Where we rely on consent—particularly for the processing of special category (health-related) data—you have the right to withdraw your consent at any time.

If consent is withdrawn:

  • We will immediately stop processing the relevant data where no other lawful basis applies

  • We will cease transmitting medical documentation to partner clinics

  • We may be unable to continue facilitating your dental tourism enquiry

Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

8.8 Right Not to Be Subject to Automated Decision-Making (Article 22 UK/EU GDPR)

You have the right not to be subject to decisions based solely on automated processing, including profiling, where such decisions produce legal or similarly significant effects.

Smile High Dental Tourism Agency confirms that:

  • We do not use automated decision-making systems to evaluate your eligibility

  • We do not use algorithms to determine treatment suitability

  • We do not make clinical or financial decisions based on automated profiling

All assessments and case handling are carried out by human personnel and/or independent dental professionals at partner clinics.

8.9 Right to Lodge a Complaint

If you are dissatisfied with how your personal data has been handled, you have the right to lodge a complaint with a supervisory authority.

If you are based in the United Kingdom, you may contact:

  • Information Commissioner’s Office (ICO)

If you are based within the European Union, you may contact your local Data Protection Authority.

We strongly encourage you to contact us first so that we may attempt to resolve any concerns directly and efficiently.

8.10 Response Times and Handling of Requests

We are committed to responding to all valid data subject requests without undue delay and in any event within one calendar month from receipt.

This period may be extended by up to two additional months where:

  • The request is particularly complex

  • Multiple requests have been submitted

  • Additional identity verification is required

Where an extension is necessary, we will inform you within the initial one-month period, together with the reasons for the delay.

8.11 Identity Verification Requirement

To protect your personal data and prevent unauthorised access, we may request reasonable verification of identity before fulfilling any rights request.

Verification may include:

  • Confirmation of registered email address

  • Matching personal identifiers

  • Verification of previous communication history

We will only request the minimum information necessary for verification purposes.

8.12 Excessive or Unfounded Requests

Where requests are manifestly unfounded, excessive, or repetitive, we reserve the right to:

  • Charge a reasonable administrative fee, or

  • Refuse to act on the request

In such cases, we will clearly inform you of the reasons for our decision in accordance with applicable law.

9. Cookies Policy

Smile High Dental Tourism Agency uses cookies and similar tracking technologies on our website to ensure proper functionality, enhance user experience, analyse website performance, and support the secure operation of our digital services.

This Cookies Policy explains what cookies are, how we use them, what types of cookies we use, and how you can manage your cookie preferences.

By continuing to use our website, you agree to the use of cookies in accordance with this policy, unless you disable them through your browser settings.

9.1 What Are Cookies

Cookies are small text files that are stored on your device (computer, tablet, or mobile phone) when you visit a website. These files allow the website to recognise your device and store certain information about your preferences or past actions.

Cookies are widely used to ensure websites function efficiently and to provide a better browsing experience.

Cookies do not typically contain personally identifiable information, but they may be linked to personal data that we process in accordance with this Privacy Policy.

9.2 How We Use Cookies

We use cookies for several purposes, including:

  • Ensuring the website functions correctly

  • Improving website performance and speed

  • Remembering your preferences and settings

  • Analysing how users interact with our website

  • Monitoring website traffic and usage patterns

  • Enhancing security and preventing fraudulent activity

  • Supporting basic functionality of enquiry forms

Cookies help us understand how visitors use our website so we can improve the quality of our services and user experience.

9.3 Types of Cookies We Use

We may use the following categories of cookies:

9.3.1 Strictly Necessary Cookies

These cookies are essential for the operation of our website. Without them, certain services cannot be provided.

They are typically used for:

  • Website navigation

  • Secure access to forms

  • Basic functionality of pages

  • Protection against security threats

These cookies do not require user consent as they are strictly necessary for website operation.

9.3.2 Performance and Analytics Cookies

These cookies help us understand how visitors use our website by collecting information such as:

  • Pages visited

  • Time spent on pages

  • Navigation patterns

  • Error messages encountered

  • Website performance metrics

This information is aggregated and used to improve website functionality and user experience. It does not directly identify individual users.

9.3.3 Functionality Cookies

Functionality cookies allow the website to remember choices you make and provide enhanced features, such as:

  • Language preferences

  • Contact form inputs

  • User settings and preferences

These cookies improve usability but are not essential for basic website operation.

9.3.4 Security Cookies

Security cookies are used to:

  • Detect and prevent fraudulent activity

  • Protect forms from spam submissions

  • Maintain website integrity

  • Monitor suspicious behaviour

These cookies contribute to safeguarding both user data and website systems.

9.4 Third-Party Cookies

In some cases, we may use third-party services that place cookies on your device when you visit our website. These may include:

  • Website analytics providers

  • Hosting and security providers

  • Embedded content services (if applicable)

Third-party cookies are governed by the respective third party’s privacy and cookie policies. We do not control how third parties use their cookies.

We encourage users to review the privacy policies of these providers for more information.

9.5 Cookie Duration

Cookies may be:

  • Session cookies: These are temporary and are deleted when you close your browser

  • Persistent cookies: These remain on your device for a set period or until manually deleted

The duration of each cookie depends on its purpose and configuration.

9.6 Managing and Controlling Cookies

You have full control over cookies and can manage them in several ways:

  • Accept or reject cookies via your browser settings

  • Delete existing cookies stored on your device

  • Set your browser to notify you before cookies are stored

  • Block cookies entirely (though some website features may not function properly)

Please note that disabling certain cookies may affect the functionality and performance of our website.

9.7 Consent to Use Cookies

Where required by law, we will request your consent before placing non-essential cookies on your device.

By continuing to use our website after being presented with our cookie notice, you consent to the use of cookies as described in this policy, unless you adjust your settings to disable them.

9.8 Changes to This Cookies Policy

We may update this Cookies Policy from time to time to reflect changes in technology, legal requirements, or our operational practices.

Any updates will be posted on this page with a revised effective date.

10. Third-Party Links

Smile High Dental Tourism Agency’s website may contain links to external websites operated by third parties. These links are provided solely for your convenience and informational purposes, particularly in relation to:

  • Partner dental clinics in Albania

  • Travel and accommodation providers

  • Transportation services

  • External informational resources relevant to dental tourism

By clicking on these links, you may be redirected to websites that are not operated, controlled, or maintained by Smile High Dental Tourism Agency.

10.1 No Responsibility for External Websites

We do not control, endorse, or assume responsibility for the content, accuracy, security, or privacy practices of any third-party websites.

Once you leave our website:

  • You are subject to the terms and privacy policies of the external website

  • We are not responsible for how third parties collect or use your data

  • We do not guarantee the accuracy or reliability of third-party content

  • We are not liable for any loss or damage arising from your use of external websites

We strongly encourage you to review the privacy policy and terms of any third-party website before providing personal information.

10.2 Independent Data Controllers

Third-party websites, including partner dental clinics, operate as independent data controllers. This means that:

  • They determine how and why your personal data is processed once you engage with them directly

  • They are responsible for their own compliance with applicable data protection laws

  • Their privacy policies govern any information you submit directly to them

Smile High Dental Tourism Agency has no control over the independent processing activities of these organisations once you interact with them outside of our facilitation services.

10.3 Partner Dental Clinics Disclaimer

Although we carefully select partner dental clinics based on professional standards, accreditation, and reputation, we do not:

  • Operate or manage these clinics

  • Provide medical services on their behalf

  • Supervise clinical procedures

  • Control clinical decisions or treatment outcomes

Any interaction between you and a dental clinic is an independent professional and medical relationship.

All treatment decisions, clinical advice, and medical responsibility rest solely with the treating clinic and its licensed dental professionals.

10.4 External Content Accuracy

We do not guarantee that information contained on external websites is:

  • Accurate

  • Up to date

  • Complete

  • Free from errors

Any reliance you place on external content is strictly at your own risk.

10.5 Security of Third-Party Websites

We cannot guarantee the security of any external website linked from our platform. Third-party websites may:

  • Use different security standards

  • Collect additional personal data

  • Use cookies or tracking technologies independently

We are not responsible for any data breaches or security incidents that occur on external platforms.

10.6 Use of External Services

Where third-party services are integrated into our website or used in connection with our services (such as booking systems, payment processors, or communication tools), those services may collect and process personal data independently.

In such cases:

  • Their own privacy policies will apply

  • They may act as independent data controllers or processors

  • We are not responsible for their data handling practices beyond our contractual obligations

10.7 No Endorsement

The inclusion of any third-party link does not imply:

  • Endorsement

  • Recommendation

  • Guarantee of quality

  • Partnership beyond facilitation purposes

Links are provided strictly to support the dental tourism facilitation process.

10.8 User Responsibility

It is your responsibility to:

  • Review third-party privacy policies

  • Understand how your data may be used externally

  • Make informed decisions before submitting any personal information

By choosing to interact with third-party websites, you accept that their policies govern your use of their services.

11. Medical Responsibility & Limitation of Liability

Smile High Dental Tourism Agency operates strictly as a dental tourism facilitation and coordination service. We are not a healthcare provider, do not operate a dental clinic, and do not employ licensed dentists to provide clinical treatment. Accordingly, we do not provide medical services, medical advice, dental diagnosis, or treatment planning.

All clinical services are provided exclusively by independent, licensed dental professionals at partner clinics in Albania. Any decision regarding diagnosis, treatment, procedures, suitability, risks, or outcomes is made solely by the treating dentist or clinic.

This section explains the legal limitation of responsibility between Smile High, partner clinics, and patients.

11.1 No Medical Advice or Clinical Services

Smile High explicitly confirms that:

  • We do not provide dental or medical advice

  • We do not diagnose dental conditions

  • We do not recommend specific clinical treatments

  • We do not perform any dental procedures

  • We do not supervise clinical care

  • We do not guarantee medical outcomes

Any information we provide is strictly for administrative and coordination purposes only.

All medical decisions must be made in consultation with a licensed dental professional at the treating clinic.

11.2 Independent Clinical Relationship

When you proceed with a partner dental clinic:

  • You enter into a direct professional and clinical relationship with that clinic

  • The clinic becomes solely responsible for your treatment

  • The treating dentist assumes full responsibility for medical decisions

  • The clinic determines suitability, risks, procedures, and aftercare

Smile High is not a party to the clinical contract between you and the dental provider.

11.3 No Liability for Clinical Decisions or Outcomes

To the maximum extent permitted by law, Smile High Dental Tourism Agency shall not be held liable for:

  • Medical or dental treatment outcomes

  • Clinical decisions made by partner dentists

  • Complications arising from treatment

  • Misdiagnosis or clinical error by third-party providers

  • Dissatisfaction with treatment results

  • Post-treatment complications or side effects

  • Failure or success of dental procedures

  • Recovery outcomes or healing processes

All liability for medical care rests solely with the treating clinic and its licensed professionals.

11.4 No Guarantee of Results

Smile High does not guarantee:

  • Specific treatment outcomes

  • Cosmetic results

  • Treatment success rates

  • Healing times

  • Long-term dental results

  • Patient satisfaction outcomes

All dental treatments carry inherent medical risks, which are explained and managed solely by the treating clinic.

11.5 Patient Responsibility and Informed Consent

It is your responsibility as a patient to:

  • Provide accurate medical and dental history

  • Ask questions directly to the treating dentist

  • Review treatment plans provided by the clinic

  • Understand risks and benefits before consenting

  • Sign informed consent forms issued by the clinic

Informed consent is obtained solely by the treating dental clinic, not by Smile High.

11.6 Limitation of Agency Role

Smile High’s role is strictly limited to:

  • Connecting patients with partner clinics

  • Forwarding information and documentation

  • Assisting with travel coordination (if requested)

  • Facilitating communication between parties

We do not act as:

  • A medical provider

  • A healthcare consultant

  • A regulatory authority

  • A clinical decision-maker

11.7 Third-Party Clinical Responsibility

All partner dental clinics are:

  • Independent legal entities

  • Independent healthcare providers

  • Fully responsible for their clinical services

Any claim relating to medical negligence, treatment error, or clinical dissatisfaction must be directed to the relevant clinic, not to Smile High.

11.8 Travel and External Service Disclaimer

Where Smile High assists with travel or accommodation arrangements:

  • We are not responsible for airline, hotel, or transport service performance

  • We are not liable for delays, cancellations, or service disruptions

  • These services are provided by independent third-party providers

Any claims relating to travel services must be made directly to the provider.

11.9 Limitation of Liability (Legal Scope)

To the fullest extent permitted by law:

  • Smile High shall not be liable for indirect, incidental, or consequential damages

  • We shall not be liable for financial loss arising from treatment outcomes

  • We shall not be liable for loss of enjoyment, travel disruption, or personal dissatisfaction

  • We shall not be liable for actions or omissions of third-party providers

Our total liability, if any, is strictly limited to the facilitation services provided directly by us.

11.10 No Warranty

All services provided by Smile High are offered on an “as is” and “as available” basis.

We do not provide warranties or guarantees regarding:

  • Clinic performance

  • Treatment results

  • Availability of services

  • Accuracy of third-party information

11.11 Legal Independence of Parties

Nothing in this Privacy Policy or service arrangement creates:

  • A medical partnership between Smile High and partner clinics

  • An employment relationship with dentists

  • A joint healthcare responsibility structure

  • A fiduciary clinical obligation

All parties operate independently under their own legal and professional frameworks.

12. Changes to This Privacy Policy

Smile High Dental Tourism Agency reserves the right to update, modify, or amend this Privacy Policy at any time in order to reflect changes in legal requirements, operational practices, technological developments, or service structures.

We are committed to maintaining transparency and ensuring that any changes made to this Privacy Policy continue to comply with applicable data protection laws, including the UK GDPR and EU GDPR.

12.1 Right to Update Policy

We may revise this Privacy Policy from time to time for reasons including, but not limited to:

  • Changes in applicable data protection or privacy legislation

  • Updates to regulatory guidance or enforcement practices

  • Changes in our business model or service structure

  • Introduction of new services or operational processes

  • Changes in data processing activities or technologies used

  • Updates to security measures or technical infrastructure

  • Changes in third-party providers or partner clinic arrangements

All updates are made to ensure continued compliance and operational transparency.

12.2 Notification of Changes

Where material changes are made to this Privacy Policy, we will take reasonable steps to notify users by appropriate means, which may include:

  • Posting an updated version on our website

  • Updating the “Effective Date” at the top of the policy

  • Providing notice through email communication (where applicable)

  • Displaying prominent notices on relevant webpages

Non-material changes, such as clarifications or formatting updates, may be made without direct notification but will always be reflected in the latest published version.

12.3 Continued Use of Services

By continuing to use our website or services after any updates to this Privacy Policy become effective, you acknowledge and accept the revised terms.

If you do not agree with any changes made to this Privacy Policy, you should discontinue use of our services and contact us if you wish to request deletion of your personal data, subject to legal retention obligations.

12.4 Version Control

We maintain internal version control of this Privacy Policy to ensure transparency and accountability. Each updated version will replace the previous version and will include a revised effective date.

Only the most recent version published on our official website shall be considered the active and legally applicable version.

12.5 Ongoing Commitment to Compliance

We remain committed to continuously reviewing and improving our privacy practices to ensure that:

  • Your personal data is handled lawfully and fairly

  • Processing remains transparent and limited to necessary purposes

  • Security measures remain appropriate and up to date

  • Your rights under data protection law are fully respected

13. Contact Details

If you have any questions about this Privacy Policy, or if you wish to exercise any of your rights under data protection law, you may contact Smile High Dental Tourism Agency at any time.

We handle all requests relating to personal data in accordance with applicable data protection laws, including the UK GDPR and EU GDPR. This includes requests for access, correction, deletion, restriction of processing, withdrawal of consent, or any general enquiries regarding how your data is used.

We are committed to responding to all legitimate requests in a timely and lawful manner. In some cases, we may need to verify your identity before processing your request to ensure the security and confidentiality of your personal data.

If you are not satisfied with our response, you also have the right to lodge a complaint with the relevant data protection authority in your country of residence, including the UK Information Commissioner’s Office (ICO) if you are based in the United Kingdom, or your local Data Protection Authority if you are located within the European Union or European Economic Area (EEA)  

Contact Details:
Email: info@smile-high.co.uk
WhatsApp: +44 7735 775344
Website: smile-high.co.uk

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