Privacy Policy

Active Aligners UK Limited
Registered in England and Wales, company number 13132738
Registered office: Third Floor, 207 Regent Street, London, W1B 3HH
Data protection contact: info@activealigners.co.uk  |  +44 20 7307 5959
ICO registration number: ZB057453

Last updated: 10 August 2026. This policy replaces all previous versions.

This policy explains what we do with personal data. It is written to meet the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR).

1. The two roles we act in

This matters, because it decides who is responsible for what.

We are the controller for personal data about dental professionals, practice staff, prospective providers, website visitors and people who contact us. We decide why and how that data is used, and this policy governs it.

We are a processor for patient clinical data. When a dentist sends us a scan, photographs, a prescription or clinical notes so we can design and manufacture an appliance, the prescribing dentist or practice remains the controller of that patient’s records. We act only on their written instructions. Patients should ask their own dentist for that practice’s privacy notice, and should direct requests about their records to the practice in the first instance. We will always support the practice in answering them.

2. What we collect

2.1 Dental professionals and practices (we are controller)

• Name, job title, GDC number where relevant, practice name and address
• Work and personal contact details you give us, including email address and telephone number
• Account, ordering, delivery and payment records
• Training, accreditation and CPD records where you take one of our courses
• Your marketing preferences and your history of opening or clicking our emails
• Correspondence with us, including enquiry form submissions and support messages

2.2 Website visitors (we are controller)

• IP address, approximate location, device and browser information
• Pages viewed and how you reached the site
• Cookie identifiers, but only in the categories you have accepted. See our Cookie Policy.

2.3 Patient clinical data (we are processor for the prescribing dentist)

• Intra-oral scans, STL files, photographs and radiographs supplied by the practice
• Clinical prescription, treatment plan and related notes
• A case reference. We ask practices to supply patient identifiers only where genuinely needed for the case.

This is health data, which is special category data under Article 9. We handle it under the practice’s instructions and under Article 9(2)(h), the provision of health or social care, with the confidentiality duties that go with it.

3. Why we use it, and our lawful basis

What we do	Lawful basis
Set up and run your provider account, take and fulfil orders, take payment, handle returns and remakes	Contract
Design and manufacture appliances from a practice prescription	Processing on the practice’s instructions as processor. Article 9(2)(h) for the clinical data.
Answer an enquiry you send us	Legitimate interests, namely responding to someone who has contacted us
Deliver training, accreditation and CPD certificates	Contract
Send you marketing emails about our products, courses and offers	Consent, or the PECR soft opt-in where you are already a customer. See section 4.
Analytics and improving the website	Consent, given through the cookie banner
Keep accounting, tax and clinical device records	Legal obligation
Protect against fraud, misuse and legal claims	Legitimate interests, namely protecting the business

4. Marketing

We only send marketing emails to people who have asked for them, or who are existing customers.

If you tick the marketing box on one of our forms, you are consenting to receive emails from Active Aligners about clear aligners, our courses and accreditation, clinical tips, case studies and offers. That box is optional. You can ask us a question, request information or use this website without ticking it.

If you are already an Active Aligners customer, we may email you about our own similar products and services under the soft opt-in in regulation 22 of PECR. You can stop this at any time, and every message we send carries an unsubscribe link.

To stop receiving marketing, click unsubscribe in any email or write to info@activealigners.co.uk. We act on it immediately. We keep a record of your email address on a suppression list afterwards, purely so that our system knows never to contact you again. That record is not used for anything else.

4.1 We do not sell or share your details with other companies for their marketing

This is a change from our previous policy, and we want to be explicit about it.

We do not pass your name, email address or telephone number to any other organisation so that they can market to you. We do not do this with partners, with sponsors, with associated businesses, or with anyone else. If you hear from another company, it is not because we gave them your details.

From time to time we may mention a partner, supplier or event in our own emails, sent by us, from our own address, to our own list. Your data stays with us.

5. Who we share data with

We share personal data only where it is necessary, and only with the following:

5.1 To design and make an appliance

• Our own clinical and technical team
• Licensed dental technicians and manufacturing partners working on the case
• Our digital treatment planning platform, currently 3Shape, used to prepare and design cases
• Couriers, for delivery to the practice

5.2 Service providers who process data on our behalf

• Intuit Mailchimp, email marketing
• Google, website analytics, only where you have accepted analytics cookies
• Our website host, and the plugins that run this site, including our forms and consent tools
• Our accounting, payment and IT support providers

Each of these is bound by a written contract under Article 28. They may only act on our instructions and may not use your data for their own purposes.

5.3 Where the law requires it

Regulators, including the MHRA and the ICO, law enforcement, our insurers and our professional advisers, where we are legally required or legally entitled to disclose.

If our business is sold or merged, personal data may transfer to the buyer. We will tell you if that happens and what it means for you.

6. Sending data outside the UK

Some of our providers, including Mailchimp and Google, are based in the United States or store data there. Where personal data leaves the UK we rely on one of the following safeguards:

• UK adequacy regulations, including the UK Extension to the EU-US Data Privacy Framework where the provider is certified under it
• The UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses, together with a transfer risk assessment

You can ask us for a copy of the safeguard that applies to a specific transfer.

7. How long we keep things

Data	Retention
Provider account and order records	The life of the relationship, then 6 years for tax, accounting and limitation purposes
Patient clinical case data held as processor	The duration of treatment plus 2 years, to cover remakes and warranty, then deleted, unless the prescribing practice instructs otherwise. The practice keeps the clinical record itself under its own professional retention obligations.
Training and accreditation records	7 years, so we can reissue certificates
Enquiry form submissions	24 months from last contact
Marketing list membership	Until you unsubscribe, or after 3 years with no engagement at all, whichever is sooner
Unsubscribe suppression record	Kept indefinitely, because we need it to keep honouring your opt-out
Website analytics	14 months

8. Your rights

You have the right to:

• Be told how your data is used, which is what this policy does
• Get a copy of the data we hold about you
• Have inaccurate data corrected
• Have data erased, in the circumstances where that right applies
• Restrict how we use it
• Receive it in a portable format
• Object to processing based on legitimate interests
• Object to direct marketing at any time. This one is absolute and we will always action it.
• Withdraw consent at any time, which does not affect anything we did before you withdrew it

Write to info@activealigners.co.uk. We respond within one month. There is no charge. We will only ask you to prove who you are where we have a genuine doubt, and we will ask for the least we need in order to be sure.

For patient records, please contact the treating practice first, as they are the controller. We will help them respond.

9. Cookies

We set only strictly necessary cookies until you tell us otherwise. Analytics and any other non-essential cookies are set only after you accept them in our cookie banner, and you can change or withdraw that at any time using the consent button on any page. Full detail is in our Cookie Policy.

10. Complaints

If you are unhappy with how we have handled your data, please tell us first at info@activealigners.co.uk and we will try to put it right.

You also have the right to complain to the Information Commissioner’s Office at any time:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline 0303 123 1113  |  ico.org.uk/make-a-complaint

11. Changes

If we change this policy we will update the date at the top. Where a change materially affects how we use your data, we will tell you directly.

This policy and any dispute arising from it are governed by the law of England and Wales.