Updated: 15 October 2026
This notice explains how we process your personal data when you contact SmileGeorgia or use our coordination service for dental care and travel arrangements.
Seppo Henrik Metsälä / SmileGeorgia.pro
Registered company name and registration number: Individual Entrepreneur (Private Enterprise) Seppo Henrik Metsala. Identification / Tax No. 300472584/B26370935
Postal address: Erso Matchuglabis Street nr 75 a, Tbilisi, Georgia
Email: seppo@smilegeorgia.pro
Phone: +358 40 312 3221 and +995 591 273 271
We process data that is necessary for your enquiry and the service you request, such as:
• Name, email address and phone number.
• Messages you send and your wishes regarding the service.
• Travel, booking and invoicing details needed to arrange the service.
• By separate agreement, health data needed to coordinate treatment, the processing of which requires a separate legal basis.
We receive data primarily from you through the contact form, email, phone or WhatsApp. If we receive data about you, for example from the treating clinic, we will tell you the source and the processing in accordance with applicable data protection rules.
Use of the website. The website’s server records standard technical log data (for example IP address, time, requested page and browser details) to keep the website working and secure. The website uses one necessary cookie, pll_language, which remembers the language you have chosen (valid for one year). Your acknowledgement of the cookie notice is saved in your browser’s local storage (sg-cookie-ok). We do not use analytics, tracking or marketing cookies, and we do not load third-party services on the website: fonts are served from our own server. If you open a link to, for example, YouTube or WhatsApp, you move to that service’s website, and its own privacy rules apply.
We use personal data to reply to your enquiry, to prepare the quote you request and to arrange the agreed coordination and travel services. The basis for processing is steps taken at your request before entering into a contract, or performance of a contract with you.
In addition to the usual legal basis, processing health data requires a specific condition permitting the processing of health data.
Seppo Henrik Metsälä, operating as SmileGeorgia.pro, processes health information only as necessary to coordinate the dental care you request and facilitate communication with your chosen clinic. This may include information about your dental condition, treatment needs, dental images and treatment plans.
The legal basis for this processing is your consent under Article 6(1)(a) GDPR. The additional condition permitting the processing of health data is your explicit consent under Article 9(2)(a) GDPR.
Before collecting or sharing health information, we request your explicit consent through a separate written or electronic consent statement. The request identifies the information concerned, the specific purposes and any clinic or other recipient involved. We record when and how consent was given. Simply contacting us, sending health information or acknowledging this Privacy Notice does not constitute explicit consent.
You may refuse or withdraw your consent at any time, without charge. Withdrawal is available through the same interface used to give consent, where applicable. You may also withdraw consent by emailing seppo@smilegeorgia.pro.
Withdrawal does not affect the lawfulness of processing carried out before withdrawal. We will stop the processing covered by your withdrawn consent and delete the relevant information unless continued retention has a separate lawful basis and an applicable condition permitting the retention of health data.
Refusing or withdrawing consent may prevent us from providing the parts of your requested coordination service that require health information. You can still contact us with general enquiries.
To carry out the service, necessary data may be given to the dental clinic you choose and to service providers involved in arranging the trip. Recipients receive only the data needed for the task in question.
Depending on the services you request and the communication channels you use, recipients may include:
• Dental clinics and healthcare professionals: your selected clinic and the professionals involved in arranging your consultation or treatment. Sharing health information is subject to the consent arrangements described in this Privacy Notice.
• Travel and accommodation providers: airlines, hotels, transport operators and booking providers that need information to arrange the services you request.
• Website hosting and contact-form providers: technical providers that host the website, maintain its operation and deliver enquiries submitted through the contact form.
• Email and communications providers: providers used to send, receive and store communications, including WhatsApp when you choose that channel.
• AI chatbot and underlying AI service providers: providers that process messages submitted to the AI assistant to generate responses and operate the chatbot.
Each recipient receives only the information necessary for its task.
Providers processing personal data solely on our instructions act as data processors. Providers determining their own processing purposes act as independent data controllers for that processing. Your chosen clinic is responsible for its own clinical assessments, treatment and patient records.
SmileGeorgia operates in Georgia, which is outside the EU/EEA.
Personal data is processed in Georgia, where SmileGeorgia.pro operates and where the dental clinics involved in the arrangements you request are located.
The provider of our website, contact form and email is Hostinger International Ltd. The website, data submitted through the form and emails are stored on Hostinger’s servers located in the Netherlands. If you contact us via WhatsApp, the communication service provider is Meta, which may process data in the EU and the United States.
Georgia is located outside the European Economic Area (EEA), and the European Commission has not adopted an adequacy decision for Georgia.
Where the GDPR requirements for international transfers apply to the disclosure of data, the following transfer mechanisms are used:
We protect data as follows: the website and form use an encrypted HTTPS connection, access to the data is limited to the people who serve our clients, email and administrator accounts are protected with two-factor authentication, and we delete data when it is no longer needed for the arrangements.
You can request more information about processing locations, recipients and international transfers, or a copy of the applicable safeguards, by emailing seppo@smilegeorgia.pro.
We retain personal data only for as long as necessary for its purpose, using the following retention periods:
• Enquiries that do not lead to a customer relationship: up to 6 months after the last substantive contact, after which the enquiry and associated personal data are deleted.
• Customer and service-coordination records: during the requested service and for up to 3 years after its completion, where needed to document the arrangements and address questions or claims. This period excludes health documents and financial records, which follow the separate rules below.
• Health information held for coordination: only while necessary for the requested coordination and agreed follow-up. It is deleted as soon as it is no longer needed, and no later than 90 days after that work ends, unless a separate lawful retention requirement applies. If you withdraw consent, processing based on that consent stops, and the information is deleted unless continued retention is otherwise lawfully permitted.
• Invoices and tax-supporting documents: at least 3 years after the end of the calendar year to which the tax records relate. Where the applicable Georgian accounting rules require a longer period, relevant accounting records are retained for 6 years after the end of the relevant accounting period.
• Website and security logs: normally 30 days from creation. Relevant extracts may be retained longer where necessary to investigate a specific security incident.
Relevant records may be retained longer where required by applicable law or necessary for an ongoing complaint, tax review or legal claim. Access is restricted, and records are deleted when that need ends. Continued retention of health information also requires an applicable legal condition permitting its retention.
When retention is no longer justified, personal data is deleted or irreversibly anonymised.
These periods apply to records held by SmileGeorgia.pro. Dental clinics retain their own patient records under their separate legal obligations and privacy notices.
Under data protection rules you have the right to access your data, to request correction of inaccurate data, and to request deletion or restriction of processing. In certain situations you may also object to processing or have your data transferred to another provider.
If processing is based on your consent, you can withdraw it at any time by contacting us. Withdrawal does not affect the lawfulness of processing carried out before it.
Send data protection requests to seppo@smilegeorgia.pro. We will generally reply within one month. If necessary, we will ask for additional information to verify your identity.
You may lodge a complaint with the competent data protection authority. In Finland this is the Office of the Data Protection Ombudsman (https://tietosuoja.fi), in the UK the Information Commissioner (https://ico.org.uk) and in Ireland the Data Protection Commission (https://www.dataprotection.ie)
Mandatory fields are marked on the contact form. We need sufficient contact details to reply to you. If you do not provide information necessary to arrange a requested service, we may be unable to provide that service.
We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you.
Our AI assistant generates conversational responses and general information. It does not independently determine your eligibility for treatment, approve treatment plans or set personalised prices. Clinical assessments and treatment decisions are made by qualified healthcare professionals.
You can request assistance from a person by contacting seppo@smilegeorgia.pro or calling +358 40 312 3221.