GALENZON Privacy Policy

1. Who we are

GALENZON is a dental marketplace platform operated by Le Marins Ltd, a company registered in England and Wales under company number 16659566, with its registered office at 128 City Road, London, EC1V 2NX, United Kingdom. References in this policy to "GALENZON", "we", "us" and "our" mean Le Marins Ltd operating the GALENZON platform.

GALENZON connects people seeking dental treatment with independent dental clinics and professionals. GALENZON does not itself diagnose patients, prescribe treatment or provide dental care.

Privacy and data protection enquiries: compliance@galenzon.com. General support: support@galenzon.com.

2. Scope of this Privacy Policy

This policy applies to personal data processed through the GALENZON website and applications at https://galenzon.com, including patient accounts, guest treatment requests, clinic and professional accounts, identity and credential verification flows, payment flows and platform communications.

It does not apply to the separate processing carried out by dental clinics and dental professionals in the course of providing treatment, or to third-party websites that we link to. Those organisations publish their own privacy information.

3. Data controller and processor roles

Le Marins Ltd acts as controller where it determines the purposes and means of processing for the GALENZON platform — including account data, treatment requests submitted to the platform, verification records, platform communications, security and fraud-prevention data, and billing records.

Independent dental clinics and professionals may act as separate controllers for clinical care and treatment-related processing where applicable, including when assessing a case, producing a treatment plan and delivering treatment. Where a clinic and Le Marins Ltd determine purposes together for a specific activity, the respective responsibilities are set out in the applicable clinic agreement.

Our infrastructure, verification and payment providers process personal data on the instructions set out in our agreements with them, except where they act as controllers in their own right (for example, a payment provider meeting its own regulatory obligations).

4. Information we collect

We collect information you provide directly, information generated by your use of the platform, and information received from clinics and from our verification and payment providers. The categories most relevant to each type of user are described in the following sections.

5. Patient information

• Account details such as name, email address, password credentials held in hashed form by our authentication service, preferred language and country.
• Treatment request details, including the treatment categories you are interested in, your described symptoms or goals, budget expectations and travel preferences.
• Guest intake details where you request an estimate before creating an account, and the information needed to later claim that request.
• Offers you receive, comparisons you make, offers you accept and related booking information.
• Messages and notifications exchanged through the platform.
• Support correspondence.

6. Clinic information

• Clinic and company details, including legal name, registration or company number, trading address, contact details and country of operation.
• Company registration documents, operating licences and other supporting documentation uploaded during application.
• Clinic team accounts and the roles assigned to them.
• Treatment catalogue, pricing rules, availability and offers issued to patients.
• Banking and payout details required to receive marketplace settlements.
• Verification records, review decisions and related audit history.

7. Doctor and professional information

• Full name, role or title, specialties and treatment categories.
• Country of registration, issuing authority, licence or registration number, issue date and expiry date.
• Professional credential documents such as a diploma, licence or registration certificate and additional professional certificates.
• Identity verification records, which are kept separate from professional credential records.
• Review decisions, review notes and audit history relating to verification.

8. Identity verification information

Where identity verification is required — for clinic owners, authorised clinic representatives and dental professionals — we and our identity verification provider may process identity documents and related data. This is described in detail in sections 18 and 21 and in our Verification & KYC/KYB Policy.

Within the GALENZON platform we store verification status, the type and country of the document presented, document expiry where available, the outcome of provider checks, review decisions, timestamps and audit events. Document images, selfies and provider result payloads are held in private storage and are never shown to patients or to other clinics.

9. Health-related information

To operate a dental marketplace we may process health-related information, including where applicable: treatment requests, dental conditions you describe, panoramic X-rays, dental photographs, treatment plans, offers issued by clinics, uploaded medical or dental documentation, and treatment-related communications.

Health information generally constitutes special category personal data under applicable data protection law and is subject to additional protection. GALENZON is not a healthcare provider and does not carry out clinical assessment of this information.

We process health-related information to operate the marketplace, enable treatment requests, allow clinics to prepare and issue offers, facilitate comparison of those offers, support bookings and related platform functions, and to handle disputes and safety or fraud concerns. Where required by applicable data protection law, GALENZON will rely on an appropriate Article 6 lawful basis and, for special category data, an applicable Article 9 condition.

10. Uploaded dental images and treatment records

Images captured or uploaded through the platform — including dental photographs taken via the guided capture flow, panoramic X-rays and treatment documents — are stored in private storage. They are not publicly accessible and are not indexed by search engines.

Access is granted through short-lived signed links to the account that owns the record, to clinics you have chosen to share a case with, and to authorised GALENZON personnel where necessary for support, safety, dispute handling or legal compliance. Access is subject to database-level access rules and is recorded.

11. Payment information

Payments are processed by our payment provider, Stripe, including Stripe Connect for marketplace payouts. Card details are entered into payment interfaces operated by Stripe. GALENZON does not store full payment card numbers.

Within the platform we hold records of payment obligations, payment status, amounts, currency, references, payout status and related accounting entries. See section 22 and our Payment, Cancellation & Refund Policy.

12. Technical and device information

• IP address, approximate location derived from it, browser and device type, operating system and language settings.
• Log data such as request timestamps, pages or endpoints accessed and error information.
• Security and abuse-prevention signals, including authentication events and rate-limiting data.
• Camera access is used only while you are actively capturing an image and is not used for background monitoring.

13. Cookies and analytics

GALENZON uses cookies and similar browser storage that are strictly necessary to operate the platform, keep you signed in and protect against abuse. Our Cookie Policy explains what is used. Where non-essential cookies or analytics are introduced in future, we will obtain consent where legally required before they are set.

14. Communications

We send service communications relating to your account, treatment requests, offers, verification and payments. These are necessary to provide the service and cannot generally be switched off while your account is active. Any marketing communications would be sent only where permitted by law, and you may withdraw consent or object at any time using the unsubscribe link or by contacting support@galenzon.com.

15. Purposes of processing

• Creating and administering patient, clinic and professional accounts.
• Receiving treatment requests and enabling clinics to prepare and issue offers.
• Enabling comparison of offers, acceptance, bookings and related platform functions.
• Verifying clinics, owners, authorised representatives and dental professionals.
• Processing payments, payouts, refunds and disputes through our payment provider.
• Providing support and responding to enquiries and complaints.
• Securing the platform, preventing and investigating fraud, misuse and abuse.
• Meeting legal, regulatory, accounting and tax obligations, and establishing, exercising or defending legal claims.
• Maintaining audit records of verification and financial activity.
• Improving reliability and usability of the platform.

16. Lawful bases

Where required by applicable data protection law, GALENZON will rely on an appropriate Article 6 lawful basis and, for special category data, an applicable Article 9 condition.

Depending on the activity, the lawful basis we rely on is typically:

• Performance of a contract with you, or steps taken at your request before entering into a contract — for account creation, treatment requests, offers, bookings and payments.
• Compliance with a legal obligation — for accounting, tax, and applicable verification and anti-fraud obligations.
• Our legitimate interests, where these are not overridden by your rights — for platform security, fraud prevention, service improvement and defending legal claims.
• Your consent, where we ask for it — for example, for optional communications or for processing that is only permitted on the basis of consent.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing carried out before withdrawal.

17. Special category health data

Health-related information is special category personal data. We apply additional safeguards to it, including private storage, database-level access restrictions, short-lived signed access links and restricted internal access.

Where the platform asks you to give explicit consent before health information is shared with a clinic, that consent is recorded and is the basis on which the sharing takes place. You may withdraw that consent for future sharing at any time, although this does not affect information already shared with, or independently held by, a clinic. Where required by applicable data protection law, GALENZON will rely on an appropriate Article 6 lawful basis and, for special category data, an applicable Article 9 condition.

18. Identity and biometric verification

GALENZON uses a specialist identity verification provider, currently Sumsub, to perform document, facial comparison and liveness checks where configured. Sumsub processes the identity document and related data on the provider side and returns verification results and status to GALENZON through a secure, signed server-to-server notification. GALENZON receives the verification result, status and authorised review information, and stores an audit record, subject to the provider integration and applicable law.

Depending on the verification flow, the following may be processed by the provider:

• Passport or national identity card, and images of that document.
• Data extracted from the document, including machine-readable zone data where present.
• Document authenticity and tamper indicators, and document expiry and validity information.
• Identity details such as name, date of birth, nationality and document number.
• A selfie or live facial capture and related liveness information.
• Face comparison information between the selfie and the document image.
• Device, network and fraud-prevention signals.
• Verification status and risk results.
• Business or KYB information where a company rather than an individual is being verified.

Document capture, facial comparison and liveness processing are carried out by the verification provider using its own technology. GALENZON does not operate its own biometric matching or liveness algorithms and does not receive raw biometric samples beyond what the provider returns as part of the verification result. Depending on how the check is configured and on applicable law, some of this processing may involve biometric data. Where required by applicable data protection law, GALENZON will rely on an appropriate Article 6 lawful basis and, for special category data, an applicable Article 9 condition.

19. Automated verification and human review

Verification results are returned to GALENZON by the provider server-side. An automated pass does not by itself produce a verified status: it places the person in a "pending GALENZON review" state, and the final approval or rejection is made by an authorised GALENZON administrator. An inconclusive or flagged result is escalated to authorised GALENZON personnel for manual review. A clear failure results in an action-required status, and a further attempt may be permitted where appropriate.

Where a decision produces legal effects or similarly significant effects for you and is based solely on automated processing, you may request human intervention, express your point of view and contest the decision by contacting compliance@galenzon.com.

20. Sharing with service providers

We share personal data with service providers who help us operate the platform, under contracts that restrict their use of the data. The main categories are identity verification, payments, backend infrastructure and hosting, and email delivery.

We may also disclose personal data to professional advisers, to authorities or regulators where legally required, and to a successor entity in the context of a corporate transaction, subject to appropriate protections.

21. Sumsub

Sumsub provides our identity and business verification checks. Where a verification flow is started, the categories listed in section 18 may be submitted to and processed by Sumsub, which returns a verification outcome to GALENZON through a signed server-to-server notification. That outcome assists our decision; it is not GALENZON's final approval of a clinic, an owner or a dental professional, which is made separately by our authorised personnel. Sumsub publishes its own privacy information describing how it processes this data, including as a controller for its own compliance and fraud-prevention purposes.

22. Stripe and Stripe Connect

Payment processing and marketplace payment infrastructure are provided by Stripe, including Stripe Connect. Payment information may be processed directly by Stripe without passing through GALENZON systems.

Stripe may process:

• Payer and payee identity and account information.
• Payment method information.
• Transaction information.
• Fraud and risk information.
• Payout information.
• Verification information where Stripe requires it to meet its own regulatory obligations.

Stripe describes its own processing in its privacy policy at stripe.com/privacy. That policy governs Stripe's own processing only; it does not replace this policy or transfer responsibility for GALENZON's processing to Stripe.

23. Backend platform

Our database, authentication and file storage run on a managed backend platform built on Supabase technology. Account records, marketplace records and uploaded files are stored there under access rules enforced at database level. The provider processes this data on our instructions in order to deliver the hosting, database, authentication and storage services.

24. Hosting and infrastructure providers

The GALENZON application is delivered through managed hosting and content-delivery infrastructure, and transactional email is sent through an email delivery provider. These providers process limited personal data — such as IP addresses, request logs and email addresses and message content — in order to deliver, secure and monitor the service.

25. Dental clinics and professionals

When you submit a treatment request or share a case, the relevant information — which may include health-related information and images — is made available to the clinics you select or to clinics matched to your request in accordance with the platform flow shown to you at the time.

Clinics receive this information as independent controllers for their clinical assessment and treatment purposes, and are responsible for their own compliance with applicable health and data protection law.

26. Case-scoped clinic access to medical information

Medical intake information and documents you complete for a case are used for that case only. A clinic can see them only where you have chosen to share them and the case has reached the stage at which sharing applies — in practice, after you have accepted that clinic's offer and completed the intake yourself. Access is enforced at database level and is limited to the case concerned; another clinic, and any clinic on a different case, cannot see them.

Every access is recorded, and you can withdraw a document share at any time. Access is also revoked automatically where a clinic declines the case or is suspended. These records are stored privately, are never publicly accessible and are reachable only through short-lived signed links.

27. Timed disclosure of identity and travel information

Before the authorised milestones in a case, clinics see the clinical content of your case rather than your identity or contact details. Around 48 hours before your recorded outbound travel, your name and arrival logistics — accommodation details only where you chose to share them — are disclosed to the assigned clinic so that treatment and arrival can be coordinated. Around 4 hours before, your phone number is released to authorised users at that clinic. Each disclosure is recorded in the case history, and travel information you store on the platform remains private to you until those points.

28. Case messaging

Messages and attachments exchanged in a case are stored on the platform and are visible to the participants in that case and to authorised GALENZON personnel where necessary for support, safety, dispute handling or legal compliance. Messages are checked automatically against our marketplace rules — for example attempts to move an introduced treatment off-platform — and a flagged message may be reviewed by authorised personnel.

29. Travel providers

Where you search or save accommodation or other travel through the platform, the search details needed to obtain a result — such as destination, dates and number of guests — are sent to the third-party travel provider, and the availability, price, currency and cancellation terms come back from that provider. Those providers are independent controllers for their own booking services and their own terms and privacy information apply to any booking you make with them.

30. Reviews

Where you publish a GALENZON Verified Treatment Review, the rating and the text you wrote are shown publicly with the clinic. The review is linked internally to your completed case so that its eligibility can be verified, but your case details and medical information are not published with it. Reviews are moderated before publication, and you can withdraw your own review.

31. International data transfers

GALENZON is an international marketplace. Personal data may be processed in more than one jurisdiction, including outside the United Kingdom and the European Economic Area — for example where a clinic you contact is established in another country, or where a service provider operates infrastructure or support functions abroad. We do not claim that all data remains exclusively in the United Kingdom.

Where a transfer requires it, we use an appropriate transfer mechanism, such as the UK International Data Transfer Agreement or Addendum, the European Commission's Standard Contractual Clauses, or reliance on an adequacy decision, together with any additional safeguards required in the circumstances. You may request further information about the safeguards applied by contacting compliance@galenzon.com.

32. Data retention

We keep personal data only for as long as reasonably necessary for the purposes for which it was collected. Where a formal retention period has not yet been set for a category of data, we apply the following criteria rather than an arbitrary fixed duration:

• How long the data is needed to deliver the service and maintain your account.
• Contractual obligations between you, GALENZON and any clinic involved.
• Fraud prevention and platform-security needs.
• The existence or reasonable prospect of a dispute, complaint or legal claim.
• Accounting and tax record-keeping requirements.
• Other compliance obligations applicable to the activity.

Identity verification data is also subject to retention requirements applying to our verification provider and to any applicable anti-fraud or regulatory obligations, which may require records to be retained for a defined period after a check is completed. Audit and financial ledger records are retained as records of what occurred and are not edited retrospectively.

You can ask us to delete your data by contacting compliance@galenzon.com. We will delete or anonymise what we are not required to keep, and explain what must be retained and why — for example transaction, tax, verification, audit and dispute records. Requests are handled within the timescales set by applicable data protection law.

33. Security

We apply technical and organisational measures appropriate to the risk. No online service can be guaranteed to be completely secure, and we do not make absolute security claims.

Measures currently implemented include

• Authentication of accounts and role-based access control across patient, clinic and administrator roles.
• Row Level Security enforced at database level, so records are readable only by the accounts entitled to them.
• Private file storage for identity documents, professional documents, dental images and vault records, with no public URLs.
• Short-lived signed links for document and image access.
• Server-side execution and validation of sensitive operations, including verification and financial routines.
• Signature verification and idempotent handling of provider webhooks.
• Immutable audit and event logs for verification and financial activity.
• Least-privilege access for internal administrative functions.
• Encryption of data in transit.

If you believe your account or data has been compromised, contact compliance@galenzon.com as soon as possible.

34. Your rights

Depending on where you are located and the law that applies, you have rights in relation to your personal data. We will respond to a request within the period required by applicable law, and we may need to verify your identity before acting on it. Some rights are subject to conditions and exemptions — for example, we may need to retain certain records for legal, accounting or fraud-prevention reasons.

35. Access, correction, deletion, restriction, objection and portability

• Access — obtain confirmation of whether we process your personal data and a copy of it.
• Correction — have inaccurate personal data corrected and incomplete data completed.
• Deletion — request erasure of personal data where the conditions for that right are met.
• Restriction — request that we limit processing in defined circumstances.
• Objection — object to processing based on our legitimate interests, and to direct marketing at any time.
• Portability — receive certain data you provided to us in a structured, commonly used, machine-readable format, and have it transmitted to another controller where technically feasible.

36. Withdrawal of consent

Where we rely on your consent — including any explicit consent for health-related data or for optional communications — you may withdraw that consent at any time by using the relevant control in the platform or by contacting compliance@galenzon.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal, and does not affect processing we carry out on another lawful basis.

37. Complaints and supervisory authorities

If you have a concern about how we handle your personal data, please contact compliance@galenzon.com so we can try to resolve it. You also have the right to lodge a complaint with a supervisory authority. In the United Kingdom this is the Information Commissioner's Office (ico.org.uk). If you are in the European Economic Area, you may complain to the supervisory authority in your country of residence, place of work or the place of the alleged infringement.

38. Children and minors

GALENZON accounts are intended for adults. Where a treatment request concerns a minor, it is expected to be submitted and managed by a parent, guardian or other person with legal authority to act for them, and that person is responsible for the information they provide. If you believe a minor has created an account directly, contact compliance@galenzon.com and we will review the account.

39. Changes to this policy

We may update this policy as the platform, our providers or legal requirements change. The effective date and last updated date at the top of this page show the current version. Where a change is material, we will take reasonable steps to notify affected users, for example by email or by a notice in the platform.

40. Contact details

Privacy, data protection and verification enquiries: compliance@galenzon.com

General support: support@galenzon.com

Postal address: Le Marins Ltd, 128 City Road, London, EC1V 2NX, United Kingdom. Please mark privacy correspondence for the attention of the GALENZON compliance team.