Owner and Data Controller
MiSmile Network Limited,
Staverton Court,
Staverton,
Cheltenham,
Gloucestershire,
England,
GL51 0UX
Owner contact email: hello@mismile.co.uk
Types of Data collected
Among the types of Personal Data that mismile.co.uk collects, by itself or through third parties, there are:
Trackers; Usage Data; device information; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); purchase history; various types of Data; first name; last name; phone number; email address; ZIP/Postal code; city; state; province; country; county; latitude (of city); longitude (of city); metro area; geography/region; IP address; app information; device logs; operating systems; browser information; language; launches; number of sessions; session duration; scroll-to-page interactions; mouse movements; scroll position; keypress events; motion sensor events; touch events; video views; clicks; browsing history; search history; session statistics; page views; interaction events; page events; custom events; Application opens; number of Users.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using mismile.co.uk.
Unless specified otherwise, all Data requested by mismile.co.uk is mandatory and failure to provide this Data may make it impossible for mismile.co.uk to provide its services. In cases where mismile.co.uk specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by mismile.co.uk or by the owners of third-party services used by mismile.co.uk serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through mismile.co.uk.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of mismile.co.uk (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Advertising, Displaying content from external platforms, Traffic optimisation and distribution, Tag Management, Analytics, Commercial affiliation, Remarketing and behavioural targeting, Heat mapping and session recording, Hosting and backend infrastructure, Managing contacts and sending messages, Contacting the User, Spam and bots protection and Registration and authentication provided directly by mismile.co.uk.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on mismile.co.uk, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers for identifying Users, behavioural retargeting i.e. displaying ads tailored to the User’s interests and behaviour, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
TikTok conversion tracking ( TikTok Information Technologies UK Limited )
TikTok conversion tracking is an analytics and behavioural targeting service provided by TikTok Information Technologies UK Limited that connects data from the TikTok advertising network with actions performed on mismile.co.uk. The TikTok pixel tracks conversions that can be attributed to TikTok ads and enables to target groups of Users on the base of their past use of mismile.co.uk.
Personal Data processed: device information; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United Kingdom – Privacy Policy.
Amazon Advertising (Amazon Europe )
Amazon Advertising is an advertising service provided by Amazon Europe .
Personal Data processed: Trackers; Usage Data.
Place of processing: European Union – Privacy Policy – Opt out.
NextRoll (NextRoll, Inc.)
NextRoll is an advertising service provided by NextRoll, Inc. NextRoll, Inc. performs a hash of the User’s email address in order to serve targeted advertising to other devices connected to them (i.e. cross-device tracking).
Personal Data processed: device information; purchase history; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Meta ads conversion tracking (Meta pixel) (Meta Platforms Ireland Limited)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms Ireland Limited that connects data from the Meta Audience Network with actions performed on mismile.co.uk. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt out.
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Analytics
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.
Google Analytics (Universal Analytics) (Google Ireland Limited)
Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilises the Data collected to track and examine the use of mismile.co.uk, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Meta Events Manager (Meta Platforms Ireland Limited)
Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on mismile.co.uk.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Google Analytics 4 (Google Ireland Limited)
Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of mismile.co.uk, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: number of Users; session statistics; Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
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Commercial affiliation
This type of service allows mismile.co.uk to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with mismile.co.uk.
For details of which data are collected, please refer to the privacy policy of each service.
Amazon Affiliation (Amazon Europe )
Amazon Affiliation is a commercial affiliation service provided by Amazon.com Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: Luxembourg – Privacy Policy.
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Contacting the User
Contact form (mismile.co.uk)
By filling in the contact form with their Data, the User authorises mismile.co.uk to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: email address; first name; last name; phone number; ZIP/Postal code.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of mismile.co.uk and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Video Vimeo (Vimeo, LLC)
Vimeo is a video content visualisation service provided by Vimeo, LLC that allows mismile.co.uk to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Google Fonts (Google Ireland Limited)
Google Fonts is a typeface visualisation service provided by Google Ireland Limited that allows mismile.co.uk to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Heat mapping and session recording
Heat mapping services are used to display the areas of mismile.co.uk that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyse web traffic and keep track of User behaviour.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honours generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable mismile.co.uk to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of mismile.co.uk.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United Kingdom – Privacy Policy.
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailgun (Mailgun Technologies, Inc.)
Mailgun is an email address management and message sending service provided by Mailgun Technologies, Inc.
Personal Data processed: Trackers; various types of Data.
Place of processing: Germany – Privacy Policy.
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Registration and authentication provided directly by mismile.co.uk
By registering or authenticating, Users allow mismile.co.uk to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (mismile.co.uk)
The User registers by filling out the registration form and providing the Personal Data directly to mismile.co.uk.
Personal Data processed: email address; first name; last name; phone number; ZIP/Postal code.
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Remarketing and behavioural targeting
This type of service allows mismile.co.uk and its partners to inform, optimise and serve advertising based on past use of mismile.co.uk by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
TikTok Remarketing ( TikTok Information Technologies UK Limited )
TikTok Remarketing is a remarketing and behavioural targeting service provided by TikTok Information Technologies UK Limited that connects the activity of mismile.co.uk with the TikTok advertising network.
Personal Data processed: device information; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United Kingdom – Privacy Policy.
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Spam and bots protection
This type of service analyses the traffic of mismile.co.uk, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognised as spam or protecting it from malicious bots activities.
Cloudflare Bot Management (Cloudflare Inc.)
Cloudflare Bot Management is a malicious bot protection and management service provided by Cloudflare Inc.
Personal Data processed: app information; Application opens; browser information; browsing history; city; clicks; country; county; custom events; device information; device logs; geography/region; interaction events; IP address; keypress events; language; latitude (of city); launches; longitude (of city); metro area; motion sensor events; mouse movements; number of sessions; operating systems; page events; page views; province; scroll position; scroll-to-page interactions; search history; session duration; session statistics; state; touch events; Trackers; Usage Data; video views; ZIP/Postal code.
Place of processing: United States – Privacy Policy.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on mismile.co.uk in a centralised fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Traffic optimisation and distribution
This type of service allows mismile.co.uk to distribute their content using servers located across different countries and to optimise their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between mismile.co.uk and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimisation and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through mismile.co.uk, i.e., communication between mismile.co.uk and the User's browser, while also allowing analytical data from mismile.co.uk to be collected.
Personal Data processed: Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie
Policy.
Cookie Policy
Mismile.co.uk uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of mismile.co.uk or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, mismile.co.uk may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, mismile.co.uk and any third-party services may collect files that record interaction with mismile.co.uk (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within mismile.co.uk and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through mismile.co.uk (or third-party services employed in mismile.co.uk), which can include: the IP addresses or domain names of the computers utilised by the Users who use mismile.co.uk, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using mismile.co.uk who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of mismile.co.uk. The Data Controller, unless otherwise specified, is the Owner of mismile.co.uk.
mismile.co.uk (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by mismile.co.uk as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to mismile.co.uk, if not stated otherwise within this document.