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PEARLY WHITES Global
Data Protection

Privacy Policy

Last Updated: April 3, 2026

Welcome to Pearly Whites Global Ltd. We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our applications (including 123Smile™, PEARL™ Sims, Pharmoni Suite, and Pearly Whites Saga®) and tell you about your privacy rights and how the law protects you.

1. Important Information and Who We Are

Purpose of this Privacy Policy: This privacy policy aims to give you information on how Pearly Whites Global collects and processes your personal data, including any data you may provide through this website or our software ecosystems.

Controller: Pearly Whites Global Ltd is the controller and responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this privacy policy).

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data: includes first name, last name, username or similar identifier, and title.
  • Contact Data: includes billing address, email address, and telephone numbers.
  • Health & Clinical Data (Pharmoni Suite & 123Smile™): strictly regulated biometric, symptom, and systemic health indicators voluntarily provided by users or healthcare professionals with explicit patient consent.
  • Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, and operating system.
  • Usage Data: includes information about how you use our website, products, and services.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

  • Direct interactions: You may give us your Identity, Contact, and Health Data by filling in forms, using our clinical interfaces, or corresponding with us by post, phone, email, or otherwise.
  • Automated technologies: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns using cookies and similar technologies.
  • Third parties or publicly available sources: We may receive personal data about you from clinical partners, general practitioners, or care agencies specifically integrated with our Pharmoni Care network, subject to strict data-sharing agreements and patient consent.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • To provide and maintain our suite of dental and healthcare technology solutions.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • To improve our AI algorithms (such as 123Smile™) using completely anonymized and aggregated datasets, strictly adhering to global medical data privacy standards.
  • Where we need to comply with a legal or regulatory obligation.

5. Data Security

We have put in place appropriate, state-of-the-art security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. All Health & Clinical data processed through the Pharmoni Suite utilizes end-to-end encryption. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a clinical or business need to know.

6. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or clinical reporting requirements.

7. Your Legal Rights

Under certain circumstances, you have rights under data protection laws (such as the UK GDPR) in relation to your personal data. These include the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

8. Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways: