Privacy Policy

Last updated January 2025

The London Dental Institute (“LDI”) respects your privacy and is committed to maintaining your trust by protecting your personal data. This Privacy Policy (“Policy”) describes how LDI collects, uses, shares or otherwise processes data that (either in isolation or in combination with other information) enables you to be directly or indirectly identified (“Personal Data”) and explains the rights you may have in relation to your Personal Data.

This Policy is intended to help you understand how LDI processes your Personal Data when you:

• interact with us on our websites that display or link to this Policy;
• apply to enrol in one of our offered programmes;
• use our products and services, including participating in programmes, take assessments, use our technology platform and applications made available for use online or through mobile devices;
• Submit study materials, including clinical data;
• register for, attend or take part in our events, webinars, programmes, or promotions, including when/if we photos or recordings of events;
• receive communications from us or otherwise communicate with us; act as a service provider, supplier or vendor to LDI;
• subscribe to receive our newsletters, updates or other communications; participate in surveys, research or other similar data collection activities facilitated by LDI; or
• are affiliated with an organisation or institution that uses our products and services where your Personal Data has been shared with us (e.g., to authorise your access to your educational institution or another organisation’s account).

1. WHO ARE WE

London Dentistry Training Ltd (operating as “London Dental Institute” or “LDI”) is responsible for the processing of your Personal Data as described in this Policy, and acts as the controller of such Personal Data. That means that LDI determines “why” and “how” your Personal Data is collected and used.

Reference to “LDI”, “we”, “our” or “us” is a reference to London Dentistry Training Ltd that is the controller of your Personal Data.

2. PERSONAL DATA WE COLLECT

London Dentistry Training Ltd (operating as “London Dental Institute” or “LDI”) is responsible for the processing of your Personal Data as described in this Policy, and acts as the controller of such Personal Data. That means that LDI determines “why” and “how” your Personal Data is collected and used.

Reference to “LDI”, “we”, “our” or “us” is a reference to London Dentistry Training Ltd that is the controller of your Personal Data.

SPECIAL CATEGORY PERSONAL DATA

Some of the Personal Data we collect and process is classed as being within 'special categories of personal data' under current data protection laws, and access to, and the sharing of, this information is controlled very carefully. Special Category Data we collect may include:

• Information about your race or ethnicity, gender identity, sexual orientation, religious beliefs. This information is collected for equality and diversity monitoring purposes. This information is voluntary.
• Information about any disabilities or learning needs or other medical information. This information is collected so that any reasonable adjustments can be made to accommodate students with disabilities or learning needs and also to ensure that any learning needs are supported in line with our Equality, Inclusion and DIversity practices and Reasonable Adjustments Policy.. This information is voluntary, but please note that LDI will not be able to provide you with learning support/reasonable adjustments if you do not provide this information. This information could also include, for example, dietary requirements where you are attending a catered LDI event.
• Patient and Clinical Data. If you provide clinical data to us as part of your studies or when we use clinical data in our teaching materials, we will process this data solely for educational purposes, including case studies, webinars, and assessments. We ensure that all processing and sharing of clinical data comply with Applicable Law, and that appropriate safeguards are in place to protect patient confidentiality.

3. HOW WE COLLECT YOUR PERSONAL DATA

3.1. DIRECTLY FROM YOU

We collect most of your Personal Data directly from you. For example, you may provide us Personal Data when you register to receive the Services, contact us or inquire about our Services, use our mobile applications, participate in surveys or our online forums, interact with our websites, attend or take part in events or webinars.

The categories of Personal Data that we collect depends on how you interact with us. You may not always be required to provide Personal Data that we request. If you do not wish to provide your Personal Data to us, you may choose not to do so or opt-out of our processing of your Personal Data when this option is offered to you. However, you should be aware that if you do not provide Personal Data that we request, we may not be able to provide you with our products or services or respond to your requests for which the provision of such Personal Data is necessary.

3.2. BY AUTOMATED MEANS, DEVICE AND OUR NETWORK

We may automatically collect your Personal Data, which we may observe or detect without directly asking you to provide the information to us. As is common practice among businesses that operate online and through technology, this will mainly include information gathered automatically through your activity on and use of our websites, mobile applications, emails and online content. This information includes Device, Internet and Network Activity Information and other information collected through cookies, web beacons and other similar technologies. For more information on how we use cookies, internet advertising and other tracking technologies, please see our Cookie Policy.

We may request access or permission to certain features from your mobile device, including your mobile device’s camera, microphone, contacts, reminders, sensors, sms messages, storage, calendar, and other features. If you wish to change our access or permissions, you may do so in your device’s settings. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID and information about the features of our App you accessed.

3.3. OTHER SOURCES

We may also collect your Personal Data from other sources, including:

• Public databases;
• Organisations: your employer, educational institution, regulatory body (including accreditation providers), and/or professional governing bodies to authorize your use of the services in accordance with our eligibility requirements and/or receive examination or test results; and
• Business Partners: To assist with the provision and promotion of our products and services and performance of business-related functions (e.g., payment partners and merchants, advertising and marketing partners).

4. LDI’s DATA PROTECTION OBLIGATIONS: THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA AND THE LEGAL BASIS ON WHICH WE RELY

We are committed to the lawful processing of your Personal Data in accordance with data protection laws, which in certain jurisdictions require us to have a valid legal basis to do so. In most circumstances, we rely on our legitimate interests or those of third parties (where they are not overridden by your interests or fundamental rights and freedoms), for the performance of a contract with you or to comply with our legal obligations.

In certain circumstances, we may process your Personal Data to protect your vital interests or those of other persons or to further an important public interest or we may rely on your consent, which may be implied (e.g., where you have volunteered information for use by us) or express (in accordance with applicable law). Where we rely on your consent as a legal basis, you may withdraw your consent at any time for any processing activities that we conduct based solely on your consent.

The purposes for which we use your Personal Data and, where required, the legal basis on which we rely, are organised into categories in the sections and tables below.

4.1. PROVISION OF LDI SERVICES

4.2. COMMUNICATIONS & MARKETING

4.3. IMPROVEMENTS & ANALYTICS

4.4. WEBSITES & SOCIAL MEDIA PAGES

4.5. OTHER ACTIVITIES

4.6. SPECIAL CATEGORY DATA

5. HOW WE SHARE YOUR PERSONAL DATA

We consider the protection of your Personal Data to be a vital part of our relationship with you; therefore, we do not sell your Personal Data to third parties. There are, however, certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties (“Third Parties”) as set forth in this Policy and as categorised below.

5.1. Our Service Providers

We use third-party companies, vendors, agents and contractors (“Service Providers”) to perform services or business-related functions on our behalf or to assist us with the provision of our products and services. We may share your Personal Data with such Service Providers as necessary for them to perform or provide services on our behalf. For example, we engage Service Providers to programmes and webinars, payment processing, marketing, online advertising, communications, infrastructure and IT services, research and analytics, customer service, surveys, data enhancement, fraud prevention (including anti-money laundering (AML) checks), website analytics, network and information security and technical support. Service Providers are contractually bound to implement appropriate security measures to protect the Personal Data in their possession and to process the Personal Data consistent with this Policy. Service Providers are not authorized to use or disclose your Personal Data for their own purposes and are contractually bound to process Personal Data only as necessary to perform or provide services on our behalf and in accordance with our documented instructions.

5.2. Our Professional Advisors

We may share your Personal Data with our professional advisors, including our lawyers, bankers, auditors and insurers who provide consultancy, legal, banking, auditing, insurance and accounting services to us. Our professional advisors are subject to appropriate obligations of confidentiality (whether contractual or statutory) with respect to Personal Data.

5.3. Organizers, Hosts and Sponsors

We may share your Personal Data with organizers, hosts and sponsors (“Sponsors”) when you register for, attend or take part in events, webinars, programmes, promotions or contests associated with such Sponsors. For example, if you input your name and email address into a web form for an event, webinar, programme, promotion or contest, the associated Sponsor will receive that information. Sponsors that receive your information may send you communications, which may be subject to their own privacy policy. We are not responsible for the privacy or data security practices of such Sponsors, which may differ from those explained in this Policy. You should refer to the Sponsor’s privacy policy and direct any privacy or data security questions directly to them.

5.4. Our Partners

Where permitted by law, we may share your Personal Data with select partners that offer products and services related to your LDI relationship. For example, we may share your Personal Data with organisations who partner with us to provide or supplement educational materials. Our partners are bound by a contractual obligation to process Personal Data only as necessary to offer products and services related to your LDI relationship.

5.5. Professional Organisations

Where permitted by law, we may share your Personal Data with professional organisations, such as accrediting bodies, that review programme materials, assessments, and provide professional qualifications.. Our partners are bound by a contractual obligation to process Personal Data only as necessary to offer products and services related to your LDI relationship.

5.6. Other Third-Party Disclosures

We may share your Personal Data: (i) at your direction or with your consent, (ii) if required to do so by law in order to, for example, respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements) or (iii) in the good faith belief that such action is necessary to: (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of our employees, agents, customers and other third parties, (c) prevent or investigate possible wrongdoing in connection with our products and services, (d) enforce our terms and conditions, policies and agreements, (e) act in urgent circumstances to protect the personal safety of you, other individuals or the public or (f) protect against legal liability.

6. INTERNATIONAL DATA TRANSFERS

LDI’s products and services are available around the world. To make that possible, your Personal Data may be transferred to, accessed by and stored by us and Third Parties in other countries, which may include jurisdictions outside your own. These jurisdictions may have data protection laws that differ from the laws where you reside, and in some cases, may not be as comprehensive or protective. Although the data protection laws of certain jurisdictions may differ from those where you reside, we take appropriate steps to ensure your Personal Data is handled as described in this Policy and in accordance with applicable data protection law.

7. RETENTION OF PERSONAL DATA

We retain Personal Data for a period of time consistent with the original purpose of collection (see Section 4 above) or as long as required to (i) comply with a legal obligation, (ii) protect or defend our rights, interests or property or that of our employees, agents, students, and other third parties, (iii) prevent or investigate possible wrongdoing in connection with our products and services, (iv) enforce our terms and conditions, policies and agreements, (v) protect against legal liability or (vi) pursue legitimate interests or essential business purposes. We determine the appropriate retention period for Personal Data on the basis of the length of time we have an ongoing relationship with you (e.g., for as long as you have an account with us or keep using our products and services), the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorised use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal obligations (such as applicable statutes of limitation).

8. SECURITY RELATING TO PERSONAL DATA

We use appropriate technical and organisational measures to protect your Personal Data against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. Such measures take into account the nature of the Personal Data and the processing and the threats posed. While we endeavor to implement generally accepted security measures, no method of storage or transmission is 100% secure. In the event of a security incident, we will notify regulators and/or you as required by applicable laws and regulations. Such notice may come in the form of an email, postal mail, in-app notification or an electronic notice posted online or through our products and services.

9. AUTOMATED DECISION-MAKING

Currently, we do not make any decisions based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”). In the event our position changes, we will update this Policy and inform you as required by applicable data protection laws.

10. YOUR RIGHTS RELATING TO YOUR PERSONAL DATA

We consider the protection of your Personal Data to be a vital part of our relationship with you; therefore, we do not sell your Personal Data to third parties. There are, however, certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties (“Third Parties”) as set forth in this Policy and as categorised below.

10.1. Your Rights

Depending on where you live, you may be able to exercise certain rights in relation to your Personal Data. These rights may include the right to:

• Obtain confirmation as to whether or not your Personal Data is being processed by us, and where that is the case, access to such Personal Data (and related details);
• Obtain rectification of inaccurate Personal Data and to have incomplete Personal Data completed;
• Obtain erasure or deletion of your Personal Data;
• Obtain restriction of our processing of your Personal Data or object to processing of your Personal Data;
• Know about the existence of Automated Decision-Making and to not be subject to Automated Decision-Making;
• Withdraw your consent at any time, to the extent we rely on your consent as the legal basis for processing your Personal Data (without affecting the lawfulness of the processing based on such consent prior to your withdrawal or processing based on reliance on a legal basis other than consent);
• Lodge a complaint with the applicable supervisory authority; and

You will not be discriminated against for exercising any of your rights described in this Policy. Please note that these rights may be subject to further conditions, limitations and/or exemptions under applicable data protection laws. If any of the rights listed above are not provided under law for your jurisdiction, we have absolute discretion in providing you with these rights.

10.2. How to Exercise Your Rights

To exercise your applicable rights, please complete contact us by using the information in Section 13 below.

To protect your privacy and maintain security, we may ask you to provide certain information to verify your identity and residence before granting you access to your Personal Data or complying with your request. We will contact you if we need additional information in order to process your request. If we are unable to verify your identity or rights to the data, we may not be able to provide you with data rights until you are able to provide us with proper documents. Where permitted by law, we reserve the right to charge an appropriate fee to cover administrative costs incurred in responding to your request, for instance, if your request is manifestly unfounded or excessive.

Under certain data protection laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

10.3. Your Marketing Preferences

We want to make you aware of the fantastic products and services we offer! To do so, we may send you communications via email, text message, push notifications and in-app alerts. If we process your Personal Data for the purpose of sending you marketing communications, you can manage your preferences in a number of ways. To opt out of email marketing communications, you can use the unsubscribe function in any email you receive from us. Opt-out requests can take up to ten (10) business days to be effective. To opt out of text messages, you can reply “STOP” to any SMS messages you receive from us. To control push notifications sent by our apps, you can change your notification settings on your device. Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as transactional communications about programmes, webinars, event registrations, service messages, security alerts, invoices and updated terms and conditions.

10.4. Cookies, Target Online Advertising

For more information on how to manage the use of cookies, targeted online advertising and other tracking technologies, please see our Cookie Policy.

11. CHILDREN AND PERSONAL DATA

Our products and services are not directed at children. We do not knowingly collect Personal Data from children under the age of 16, or such other applicable age of consent for privacy purposes in relevant individual jurisdictions, unless (a) we have obtained consent from a parent or guardian, (b) such collection is subject to a separate agreement with us or (c) the visit by a child is unsolicited or incidental.

12. CHANGES TO THIS POLICY

From time to time, we will update or modify this Policy, in our sole discretion, to reflect changes in legal and regulatory requirements and our business practices. The updated Policy will be posted to this website with a change to the “Last Updated” date (located at the top of this Policy). We encourage you to review this page periodically to stay informed, especially before you provide Personal Data. In circumstances where we make updates or modifications to this Policy that materially alter your privacy rights, we will provide additional notice, such as via email or with in-service notifications, as required by law. The updated Policy will take effect immediately after being posted or as otherwise notified by us. Your continued relationship with us or your continued use of our website, products or services after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of the updated Policy.

13. CONTACTING US

If you have questions or concerns relating to this Policy or privacy-related issues, please email us at [email protected]. When you contact us, please indicate which country you reside. If within the United States of America please also inform us of which state you reside.

14. SUPPLEMENTAL PRIVACY NOTICES

Certain U.S. state privacy laws (e.g., California and Virginia) may require specific disclosures for state residents. Please contact us for additional state-specific privacy disclosures and notices.