Privacy Policy

1. Controller

The controller of personal data described in this policy is Dentmall s.r.o., Company ID (IČO): 09041036, VAT ID (DIČ): CZ09041036, registered office Pivovarská 214/4, 370 01 České Budějovice, Czech Republic, registered with the Regional Court in České Budějovice, file no. C 29761. Contact for all personal data matters: dentmall@email.cz.

We process personal data in accordance with Regulation (EU) 2016/679 (the "GDPR"). The Provider is not obliged to appoint a data protection officer pursuant to Article 37 GDPR and has not appointed one.

2. Scope of this policy

This policy covers the DentVIS application (macOS, Windows, iPadOS), the web dashboard at app.dentvis.com, the related online services (including project synchronization and Sync Storage) and the website www.dentvis.com. DentVIS is a Class I medical device pursuant to Regulation (EU) 2017/745 (MDR); regulatory information is available on the regulatory information page.

Our website and the Service may contain links to third-party websites and services. We are not responsible for their content or privacy practices; their own terms and privacy policies apply.

3. Data-minimised by design

DentVIS is built to avoid processing personal data of the persons to whom the dental models belong. Case records are identified by a case label chosen by the user — users are contractually obliged not to enter names or other data identifying those persons into the Service, and not to upload photographs or documents identifying any person (see our Terms of Service). Sync Storage and our other systems are therefore designed to hold only case data that does not contain directly identifying information.

If and to the extent case data synchronized through Sync Storage (Team plan) or shared by a share link contains personal data of third parties, the user (the dental professional or practice) acts as the controller of such data and we act strictly as the user's processor under Article 28 GDPR, processing it solely to provide the Service. A data processing agreement is available on request at dentmall@email.cz.

Data that users process solely locally on their devices is not transmitted to us; with respect to such data we are neither a controller nor a processor. The software is a tool under the exclusive control of the dental professional.

A 3D dental model or other case content may, in the hands of the dental professional, constitute data concerning health within the meaning of Article 4(15) GDPR. Where that is the case, the professional — as the controller — is responsible for satisfying one of the conditions of Article 9(2) GDPR for its processing (typically the provision of health care under Article 9(2)(h)); our role remains limited to that of a processor acting on the professional's instructions.

4. What we process, why and on what legal basis

Account data — e-mail address, name, country, profession type, practice/organisation identification (including company and VAT numbers and billing address where provided), profile picture (avatar) if you set one, and subscription information (plan — Solo or Team —, billing period, status, renewal or end date, number of Additional Editor Devices, free trial status). Purpose: creation and administration of your account, provision of the Service, communication. Legal basis: performance of a contract (Art. 6(1)(b) GDPR); invoicing data also legal obligation (Art. 6(1)(c)).

Editor Device data — for each device on which you sign in: a device identifier generated by the application, the device name (as reported by the device or chosen by you — you can rename it), the platform and operating system, the application version, the dates of registration, replacement and deactivation, and the time of last activity; we also keep a history of these device events. Purpose: to apply the device scope of your plan (number of Editor Devices, replacement once every 30 days), to show and manage your devices in the application and the dashboard, to prevent misuse and to provide support. Legal basis: performance of a contract (Art. 6(1)(b) GDPR) and our legitimate interest in preventing misuse of subscriptions (Art. 6(1)(f) GDPR).

Billing data — payments are processed by our merchant of record, Paddle.com Market Ltd, which acts as an independent controller for payment processing. We do not receive or store your full card details; we receive order and invoicing information (product, amount, country, invoicing details). Legal basis: performance of a contract and legal obligations (accounting and tax law).

Case data — the 3D dental models, case labels, photographs you attach to a case and related content you upload are processed solely to provide the Service: local processing on your device and, where your plan includes it (Team) and you use it, project synchronization between your Editor Devices through Sync Storage, and sharing you invoke. With the Solo plan and during the free trial, case content (3D models, case labels, notes and photographs) stays on your device and is not transmitted to us; we hold only a technical case record (an internal case identifier and timestamps, without the case label) that is needed for editing sessions and for product usage data. Case data is not intended to contain personal data (see the previous Section). Legal basis: performance of a contract.

Records of legal acceptance — when you accept the Terms, this policy or other legal documents, we record the accepted document and version, the timestamp, and technical identifiers of the acceptance (such as device identifier, application version, IP address and browser/user agent). Purpose: evidence of the conclusion of the agreement and of consents required by law. Legal basis: performance of a contract and legitimate interest in the ability to prove acceptance.

Technical and security data — technical logs necessary to operate and secure the Service (e.g. authentication events, subscription and Editor Device checks, error logs). Legal basis: legitimate interest in the security and reliability of the Service.

Communication — if you contact us (e-mail, support requests, incident reports), we process the communication and the data you provide in it for the purpose of handling your request. Legal basis: performance of a contract or legitimate interest. Service e-mails (e.g. account confirmation, subscription, Editor Device and Sync Storage notifications) are sent as part of the provision of the Service.

Product usage data — starting with application version 3.0.3, the application and our servers record technical events about how the Service is used. Each event may contain: your account identifier; the identifier of the Editor Device; an internal case identifier (a random technical ID, not the case label); the event type (for example application started or closed, case created, opened or saved, scan imported, segmentation run, export started, completed or failed, project synchronization upload, download or clean-up, Editor Device registered or replaced, subscription changed); the feature used; timestamps and the duration of use; the application version; the platform; and your plan. Product usage data never contains names or other data identifying the persons to whom the dental models belong, case labels, notes, photographs, scans, 3D model geometry or the content of exported files.

Purpose of product usage data: to operate and improve the product, to understand how its functions and plans are used (including at the level of individual accounts, for example for support and for managing subscriptions), and to plan capacity, in particular of Sync Storage. We do not use product usage data for advertising, do not sell it and do not pass it to third-party analytics providers; it is not used for automated decision-making and plays no part in verifying your subscription. Legal basis: our legitimate interest in operating, securing and developing the product (Art. 6(1)(f) GDPR). Product usage data is kept separate from case data: it is stored apart from case content, with its own access rules and its own retention period. Right to object (opt-out): you may object to this processing at any time, without giving reasons, by writing to dentmall@email.cz; once the corresponding setting is available in your account in the dashboard, you can also switch product usage data off there. After your objection the application stops sending product usage events for your account. Records that are necessary to provide and secure the Service (authentication, subscription and Editor Device records, error logs — see “Technical and security data”) continue to be created. Opting out does not limit any function of the Service.

Aggregated statistics — we may create and use aggregated, statistical information about the use of the Service (for example, numbers of active subscriptions or feature usage counts derived from technical logs and product usage data) to operate, secure and improve the Service. Such statistics do not contain Customer Data content and do not identify any account, device or person. Event-level product usage data is not covered by this paragraph; it is described above.

There is no automated individual decision-making within the meaning of Article 22 GDPR.

5. Processors and recipients

We use a limited number of service providers. Those acting as our processors are bound by data processing agreements under Article 28 GDPR; providers marked as independent controllers process personal data under their own responsibility and their own privacy terms:

• Supabase — hosting of the database (including Editor Device data and product usage data), authentication and file storage (Sync Storage), on infrastructure located in the European Union (Frankfurt, Germany);
• Paddle.com Market Ltd — merchant of record for purchases (independent controller for payment processing);
• Resend (United States) — delivery of transactional e-mails (e.g. account confirmation and service notifications);
• Netlify — hosting of the website and dashboard (static content);
• Apple — distribution of the iPadOS application through the App Store (independent controller under your relationship with Apple).

A current list of processors is available on request. Beyond that, personal data may be disclosed to competent public authorities upon a lawful request, and to our professional advisers where necessary to protect our rights. Recipients may not process the data for any other purpose.

We do not sell or rent personal data, and we do not share it with third parties for their marketing purposes. If the Provider or its assets are involved in a merger, acquisition, financing, reorganisation or sale, personal data may be transferred to the legal successor or acquirer as part of that transaction, subject to this policy and applicable law; we will inform you of such a change.

6. International transfers

Service data (account, Editor Device, case and product usage data) is stored in the European Union. Some supporting providers may process limited personal data (such as e-mail address and message content of transactional e-mails) outside the EU/EEA; in such cases the transfer is safeguarded in accordance with Chapter V GDPR, in particular by the European Commission's Standard Contractual Clauses or an adequacy decision. This applies in particular to the delivery of transactional e-mails through Resend (United States). A copy of the relevant safeguards, or information on where they are available, can be obtained at dentmall@email.cz.

7. Retention

Account and contract data — for the duration of the contractual relationship and thereafter for the time necessary to protect legal claims arising from it: as a rule up to 10 years from termination, corresponding to the objective limitation periods under the Civil Code; records directly evidencing the conclusion and content of the agreement (including records of legal acceptance) may be retained for up to 15 years where necessary with regard to the limitation period applicable to intentionally caused damage.

Billing records — for the periods required by tax and accounting law.

Case data in Sync Storage (Team plan) — Sync Storage is temporary: data is kept only for as long as it is needed for project synchronization between your Editor Devices and within the capacity of your plan. DentVIS automatically removes older synchronized project data when Sync Storage is needed for newer projects. Your local projects are not deleted. Incomplete uploads, superseded versions, projects that have not been opened for a longer period (currently 90 days) and — when the capacity is reached — the least recently opened projects are removed automatically. A project is removed only where a copy of it is recorded on one of your registered Editor Devices. After the end of a Team subscription the remaining data is removed by the same automatic removal, not merely because the subscription has ended; after deletion of your account it is deleted without undue delay.

Technical logs — for a period appropriate to their security purpose.

Product usage data — event-level records for 24 months from the event; after that only aggregated statistics that do not identify any account, device or person are kept. If you object (opt out), no further product usage events are collected from the application for your account.

Editor Device data — for the duration of your account; the history of device events for up to 24 months from the event.

After expiry of the retention period, personal data is deleted.

8. Cookies and local storage

The website www.dentvis.com is static and uses no advertising, analytics or tracking cookies; it stores only a local acknowledgement of the cookie notice in your browser. The DentVIS web dashboard (app.dentvis.com) uses only strictly necessary cookies and local storage — for example to keep you signed in. Strictly necessary cookies do not require consent under the ePrivacy rules. We do not use third-party marketing or profiling cookies. Product usage data described in Section 4 is collected by the DentVIS application and our servers, not through cookies on the website or in the dashboard.

Our home page additionally loads payment components from our Merchant of Record: Paddle.js (cdn.paddle.com) and Paddle Retain (public.profitwell.com). They are there so that a customer whose subscription payment has failed can update an expired card in one step. We have verified that loading them sets no cookies and no local or session storage in your browser. Because the files are fetched from Paddle servers, Paddle receives your IP address, browser information and the address of the page you are viewing. Legal basis: our legitimate interest in the operation and security of paid subscriptions (Art. 6(1)(f) GDPR). For this processing Paddle acts as an independent controller — see Paddle privacy notice. These components are not loaded on any other page of the website. The same components are also loaded in the DentVIS web dashboard (app.dentvis.com), but only for accounts that have a subscription with Paddle; in that case Paddle additionally receives your customer identifier, so that a failed payment can be matched to your account. There too, these components set no cookies and no local or session storage.

9. Security

We have adopted appropriate technical and organizational measures to secure personal data, taking into account the state of the art and the nature of the processing. Data is encrypted in transit; access to production data is restricted to authorised persons and protected by authentication; data in Sync Storage and in our database is logically separated per account. Only persons authorised by the Provider have access to personal data. No method of transmission or storage is completely secure; we will notify you and the supervisory authority of personal data breaches where required by Articles 33 and 34 GDPR.

10. Your rights

Under the conditions set out in the GDPR you have the right of access to your personal data (Art. 15), the right to rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), the right to object to processing based on legitimate interest (Art. 21), and — where processing is based on consent — the right to withdraw consent at any time. In particular, you can object to the processing of product usage data at any time in the way described in Section 4.

You can exercise these rights at dentmall@email.cz. We will respond without undue delay, at the latest within one month. In the case of manifestly unfounded or repeated requests we may charge a reasonable fee or refuse to act, as permitted by the GDPR.

You also have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your habitual residence, place of work or of the alleged infringement. In the Czech Republic this is the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Praha 7, uoou.gov.cz. We would, however, appreciate the opportunity to address your concern first — please contact us at dentmall@email.cz.

11. Children

The Service and the website are intended for professionals and business users aged 18 or over. We do not knowingly collect personal data from children. This does not affect the processing of case data concerning persons of any age carried out by dental professionals in their role as controllers (see the following section).

12. Persons whose dental models are processed

If your dental professional or dental laboratory uses DentVIS to prepare a digital model concerning you, the controller of any personal data involved is that professional or laboratory — please direct any requests concerning your data to them. Data processed only locally on the professional's device never reaches us. Where the professional uses project synchronization (Team plan) or share links, we act solely as their processor: we do not decide on the purposes of the processing, and we are contractually prevented from using the data for our own purposes. If you send us a request and identify the professional concerned, we will forward it to them without undue delay; please note that cases are stored under neutral labels, so we are generally unable to locate data from a person's name alone. Product usage data that we collect about the professional's use of the software contains no information about you — no names, photographs, scans or model geometry.

13. Changes to this policy

We may update this policy from time to time, for example due to changes in legislation or in the Service. The current version is always available at www.dentvis.com/privacy; material changes will be announced through the Service or by e-mail, and where required you will be asked to acknowledge the new version.

This policy is effective as of [DRAFT — effective date to be set on publication] and replaces all previous versions.