Privacy policy

This page explains what personal information Smile Passage collects, why, who sees it, and your rights. We keep it short and try to collect as little as possible.

Who we are

Smile Passage is operated by Arthur Rozitas, a sole trader trading as Smile Passage, [address] (“we”). We are the data controller for the information described here. Contact: hello@smilepassage.com. [ICO registration number, if required]

What we collect

From patients (enquiry): your name, email, country, preferred language, the treatment you are interested in (in your own words or from a list), your rough travel window, how you heard about us (optional), and anything you choose to write. We ask you not to include medical details or send photos or X-rays at this stage.

Later, if you proceed: travel details needed for transfers and hotel (for example arrival time and hotel name), and a record of your consent. Your photos, X-rays and records go to the clinic through the clinic’s own route. We do not ask for passport, payment-card or bank details through this site.

From clinics: contact name, role, business email and phone, and how enquiries reach you.

On this website: we do not use analytics, advertising trackers or non-essential cookies. The enquiry forms open an email in your own mail app, so nothing is sent to us until you press send. Your email provider will process that message under its own terms.

Why we use it, and our legal basis

• To reply to your enquiry and take steps you ask for (contract or steps before a contract).
• To share your enquiry with a partner clinic: with your explicit consent. Information about the treatment you are considering can be health-related, so we ask for explicit consent before sharing, and you can withdraw it at any time.
• To keep simple records (what we received, what we shared and when, and your consent): our legitimate interest in running the service properly and handling disputes.
• To arrange transfers, hotels and interpretation if you ask: to deliver those services.

We do not use your information for marketing unless you separately ask us to.

Who we share it with

• The clinic you choose, only after you consent.
• Providers you ask us to arrange (interpreter, hotel, transfer), who receive only the logistics they need and never health information.
• Service providers that help us run the business, such as our email provider and website host, under their data-protection terms.
• Authorities, where the law requires.

We do not sell your information. We do not upload patient photos, X-rays or health information to AI tools. AI tools may be used to help draft routine messages and translations that contain only the administrative details of your enquiry.

Sending information to Georgia

Clinics are in Georgia, outside the UK. When we share your enquiry with a clinic, your information goes to that clinic, which then handles it under its own obligations. We tell you which clinic before you agree. [Lawyer to confirm transfer wording for UK/EU patients]

How long we keep it

• Enquiries that do not go ahead: deleted within 90 days of your last message.
• If you proceed: we keep a minimal record (consent, which clinic, dates) as long as needed for the service and any dispute period, then delete it.
• If a health file reaches us by mistake, we do not use it, tell you the right route, and delete it.

Your rights

You can ask to see, correct or delete your information, object to or restrict how we use it, withdraw consent, and ask for a copy in a portable form. Email hello@smilepassage.com. If you are in the UK you can complain to the Information Commissioner’s Office at ico.org.uk. If you are in the EU you can contact your local data-protection authority.

Changes

We will update this page when we change how we handle information, and show the date at the top.