Privacy Policy

1. WHO WE ARE AND WHAT THIS POLICY COVERS

1.1 VBS Ventures Private Limited (the Company, we or us) runs multi-specialty dental clinics in Mumbai. This is our privacy policy, published on our website and given free to anyone who asks for it at our premises. It explains what we collect, why, whom we share it with, how we protect it, how long we keep it and what you can ask us to do. It is written to meet the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

1.2 It covers information in every form, and everyone who works for or with us must follow it. The people whose information we hold are our patients and, where a patient is a child or cannot act for themselves, the parent or guardian acting for them; our employees and applicants for employment; the dentists we retain and the dentists and anaesthetists who visit our clinics; the individuals we deal with at our vendors and service providers; and visitors to our website and clinics.

2. WHAT WE COLLECT

2.1 Identity and contact information. Name, date of birth, gender, photograph, address, telephone number, email address, emergency contact, KYC information (such as PAN and Aadhaar) and the reference number we give you in our records.

2.2 Health and dental information, which the law treats as sensitive. Enquiry details, medical and dental history, allergies and medication, examination findings, diagnosis, treatment plans and history, clinical notes, prescriptions and referrals, clinical photographs, radiographs and intra-oral scan data and files derived from it, and impressions, models and appliances made from them.

2.3 Financial information, which the law treats as sensitive. Bank details, payment and card details handled through our payment providers, billing records, and insurance or payor details where someone else meets a bill.

2.4 Employment and engagement information. Proof of identity and address, qualifications and professional registration, references, terms of engagement, bank and payroll details, tax and social security identifiers, attendance and performance records, and health information given for statutory or occupational reasons. We hold contact, tax and bank details for the individuals at our vendors, and login credentials, also sensitive, for our people and providers.

2.5 Website and premises information. What you send us through the forms on dazzle.dental; technical information such as your internet protocol address, browser and device type and the pages you view, recorded through cookies by us and our hosting and analytics providers and refusable in your browser settings; and closed circuit television images and visitor register entries at our clinics. We collect all of this from you directly, and also from the dentist or doctor who refers you, from a parent or guardian acting for a patient, from the laboratory making an appliance for you, from your insurer or the person paying your bill, and, for people we employ or engage, from recruitment agencies and referees.

3. WHY WE COLLECT IT, ON WHAT BASIS, AND YOUR CONSENT

3.1 We collect personal information only for a lawful purpose connected with what we do, only where collection is necessary for that purpose, and never for an unrelated purpose. Our purposes are:

• (a) to examine, diagnose, plan, deliver and record dental treatment and to care for you afterwards, which is why we hold your health and dental information;
• (b) to have crowns, aligners, prostheses and other appliances made for you, which is why your prescription, intra-oral scans and impressions go to the laboratory;
• (c) to raise and collect bills and deal with insurers and payors, which is why we hold financial information;
• (d) to recruit, employ, engage and pay our employees, our retained dentists and our visiting dentists and anaesthetists, and meet our obligations to them and to the authorities;
• (e) to buy goods and services, manage our vendors, and run, secure and improve our clinics, systems and website; and to comply with the law and with the professional requirements applying to dental practice, and to establish or defend a legal claim.

3.2 Our basis is your consent, taken before collection, except where we must act to perform a contract with you, to meet a legal, tax, employment or professional obligation, or to establish or defend a claim. Where a law requires disclosure to a court, a regulator or a Government agency, including for identity verification or the investigation of an offence, we may act without consent, on a written request stating its purpose.

3.3 Before we collect sensitive information we take your consent in writing, by a signed or electronically signed form, letter or email, telling you then what we are collecting, why, who will receive it and the name and address of the company collecting and holding it. Our patient registration and treatment consent forms, employment and engagement forms and vendor onboarding forms carry that notice.

3.4 You may decline to give us information, and may withdraw a consent at any time by writing to our Grievance Officer; withdrawal takes effect for the future and does not undo anything lawfully done before it. If you decline to give us information we need, or withdraw your consent, we may be unable to examine or treat you, to continue a course of treatment begun, to have an appliance made for you, or to continue to employ or engage you, and we will tell you which of these follows before you decide. Where a patient is a child or cannot decide for themselves, the parent or guardian consents and we record who gave it.

4. WHOM WE SHARE IT WITH, AND TRANSFERS

4.1 Our group laboratory. We share a patient's prescription, intra-oral scans and impressions with Smileforge Solutions Private Limited, a company in our group, which fabricates prostheses and other appliances for us to our dentists' prescriptions. We send only what it needs to make the appliance, under a written arrangement requiring it to keep the information confidential, use it only for that work and pass it to no one else.

4.2 Others involved in your care. The dentists, anaesthetists, specialists and hospitals treating or referring you, where that is necessary for your treatment; and, where an appliance cannot be made in our group laboratory, an external laboratory or milling centre engaged on the same written terms.

4.3 Those who help us run the practice. Insurers, third party administrators and payors you ask us to bill; our bankers, auditors and advisers; the providers running our practice management software, information technology, payroll and appointment services, on our instructions and under written confidentiality obligations; and a person proposing to invest in, lend to or acquire our business, under confidentiality and limited to what the transaction requires.

4.4 No sale, no unrelated use, and limits on transfer. We do not sell, rent or trade personal information and do not use it for any purpose outside this Policy. We do not publish sensitive information, and anyone who receives it from us may not pass it on further. We transfer information to another company or person, in India or outside it, only where that is necessary for the purpose for which it was collected or for a lawful contract with you, or where you have consented, and only where the recipient maintains the same standard of protection this Policy requires of us; that standard is written into our contract with it.

5. HOW LONG WE KEEP IT, AND HOW WE PROTECT IT

5.1 We keep personal information only as long as it is needed for the purpose for which it was collected, or as long as the law, the record keeping requirements applying to dental practice, a contract, or the defence of a claim requires, whichever is longer. We then dispose of it securely: paper is shredded, digital records are deleted from live systems and from backups in the ordinary cycle, storage media are wiped or destroyed, and impressions, models and appliances no longer needed are destroyed rather than discarded whole.

5.2 We maintain a documented information security programme, with managerial, technical, operational and physical controls proportionate to the information we hold and the harm its loss or misuse could cause. In practice:

• (a) access to patient records, employment records and payment information is limited to those who need it for their work, through individual named accounts; our systems are protected by firewalls, current protective software, encryption in transit and on the devices holding it, and regular protected backups;
• (b) our premises are secured, and clinical records, imaging equipment, impressions and models are kept in locked or access controlled areas under closed circuit television;
• (c) everyone who works for or with us, and every provider handling information for us, is bound by written confidentiality obligations, may use the information only for the work given to them, and is trained in handling it; and any incident is recorded, escalated, investigated, notified to the authorities and to those affected where the law requires, and used to improve our controls.

6. YOUR RIGHT TO REVIEW AND CORRECT

6.1 You may ask to review the personal information you have given us and to correct anything inaccurate or incomplete. We will make it available, or correct it, so far as feasible and within a reasonable period, and we do not charge for it. Clinical records are not deleted or rewritten, because a complete and auditable record is required of us and protects you as much as it protects us: a correction is recorded alongside the original entry, with its date and the name of the person making it.

6.2 We may first take reasonable steps to satisfy ourselves of your identity. We may decline a request that is plainly unfounded, excessive or repeated, or that the law does not require us to meet, and may keep information a law, a contract or the defence of a claim requires us to keep, telling you if we do.

7. OUR GRIEVANCE OFFICER, AND REVIEW OF THIS POLICY

7.1 We have appointed a Grievance Officer to deal with any discrepancy or grievance about the way we handle personal information. Write to him by email or letter, saying what has happened and how he can reach you.

Grievance Officer: Aashutosh Magdum, Manager. Email: grievance@dazzle.dental. Address: VBS Ventures Private Limited, Unit No. 501/502, Notan Chambers, Turner Road, Bandra (West), Mumbai 400050.

7.2 He will acknowledge your complaint, may ask for what he needs to verify your identity, and will redress the grievance expeditiously and in any event within one month from the date on which he receives it, which is the period the law fixes. These details are on our website and displayed at our premises, and we keep a register of complaints and of what was done about them.

7.3 This Policy takes effect on 8 September 2026 and is approved by the board of directors. We review it at least once every two years, and sooner on a material change in the law or in the way we work; a revised Policy is approved by the board and published on our website with a new effective date. Questions about this Policy or about the information we hold may go to contact@dazzle.dental or to the Grievance Officer named above.