Shanghai Smartee Denti-Technology Co.,Ltd. and Smartee's affiliates (hereinafter referred to as "Smartee") design and distribute custom orthodontic products for patients in the European Economic Area(EEA), the United Kingdom(UK), and Switzerland in collaborations with medical institutions and healthcare providers.
This privacy statement (hereinafter referred to as “Statement”) explains how Smartee processes your personal data when using Smartee's products under care of your orthodontist, dentist, or other healthcare professionals (collectively referred to as “healthcare providers”). The aim of Statement is to provide clarify on how Smartee collects, uses, and processes your personal data in connection with these products, ensuring transparency about your data’s management, usage, and your rights. Smartee processes your personal data in compliance with EU and UK privacy and data protection laws, including but not limited to the General Data Protection Regulation (GDPR) and its implementation in the UK.
1. Categories of personal data processed by Smartee
Smartee processes the following types of personal data related to the use of its products by your healthcare providers as following:
(a)Identification Information: Name, gender, date of birth, personal photograph.
(b)Contact Information: Mobile phone number.
(c)Health Data: Diagnoses and treatment plans provided by your healthcare providers, photographs of your teeth, face, and full body, including CBCT scans, X-rays, and digital scan data.
These categories of personal data are essential for the purposes outlined in Section 2, and without them, Smartee’s products may not be used effectively.
2. How and why Smartee uses your personal data
Smartee processes your personal data as a data processor on behalf of your healthcare providers for the following purposes:
(a)To facilitate orthodontic and related treatments.
(b)To manufacture Smartee orthodontic products, including product labeling with your identification information.
(c)To provide you with information about Smartee products and services.
(d)To assist your healthcare providers in managing your registration and documents with Smartee and to customizing products and services based on your treatment plan.
(e)To provide technical services and software necessary for the use of Smartee products, including storage-related communication.
(f)To contact you or your healthcare providers regarding the design, manufacturing, or distribution of the Smartee products.
As a data controller, Smartee also processes your personal data for the following purposes:
(a)To updated you on news and events related to Smartee.
(b)To analyze product performance and usage, aiming to improve Smartee’s offerings.
(c)For research, training, and academic purposes related to dental and orthodontic products and techniques.
Smartee processes your personal data based on its lawful interests in statistical analysis, training, and products improvement. Appropriate safeguards are in place to protect your privacy, balancing Smartee’s lawful interests with your rights. In some cases, you have the right to object to Smartee’s use of your personal data (see Section 6 for more details). Data will be anonymized before processing, which means it will no longer be considered personal data.
3. Disclosure of your personal data
Your personal data may be disclosed to the following entities for the purposes outlined in Statement:
(a)Smartee and Smartee's affiliates: Within the Smartee Group of companies.
(b)Third-party Service Providers: Such as IT providers, financial services providers, governmental authorities, or other third parties for legal compliance or the protection of Smartee’s and others' rights, property, and safety.
(c)Auditors and Consultants: To verify compliance with in-house and external requirements.
(d)Successors: of Smartee: In the event of a business transfer, your data may be shared with third parties acquiring Smartee’s assets or business.
4. Transfer of your personal data outside the EU/UK
To fulfill the purposes outlined in Section 2, Smartee may transfer and disclose your personal data to recipients in China, including Smartee's affiliates and cloud hosting providers. Such transfer will comply with EU and UK data protection regulations. As China has not been recognized by the European Commission or UK Parliament as providing an adequate level of data protection, Smartee will implement appropriate safeguards, such as standard contractual clauses, to ensure that your data is transferred securely and in compliance with applicable laws.
5. Data security and retention
Smartee is committed to safeguarding your personal data through appropriate technical, logical, and physical security measures to protect against accidental or unlawful destruction, loss, falsification, unauthorized disclosure, or access. When your personal data is no longer required for the purposes outlined in this Statement, Smartee will delete or anonymize it.
For personal data processed as described in Section 2, where Smartee acts as a data processor for your healthcare provider, your personal data will be retained for the duration of your treatment involving Smartee’s products and services, as determined by your healthcare provider.
For purposes related to statistical analysis, training, and product improvement, Smartee will retain your personal data throughout the research and analysis phases. In relation to the processing of your data for news and events concerning Smartee, your personal data will be retained until you object to its processing or until 3 years have passed since your last interaction with Smartee.
However, Smartee may be required to retain certain personal data to comply with legal and regulatory obligations, or to fulfill requests from regulators or other authorities.
Additionally, Smartee may retain your personal data to establish, exercise, or defend legal claims, or for other legitimate business purposes.
6. Your rights regarding personal data
Smartee has outlined your rights regarding personal data below. If you have any queries about your rights or wish to exercise any of these rights, please refer to the contact details provided in Section 7 of this Statement. Please note that these rights may not apply in all circumstances, and there may be exceptions based on applicable local laws. However, subject to these exceptions, you have the following rights:
(a)The right to receive information about the personal data Smartee holds about you and to obtain a copy.
(b)The right to request the correction of incomplete or inaccurate personal data.
(c) The right to request the deletion of your personal data, except where Smartee is required or entitled to retain it for legal reasons.
Restriction of processing:
In certain circumstances, you may request Smartee to limit the processing of your personal data. In some cases, Smartee may retain the right to continue using your personal data and/or deny your request. You can also request to receive your personal data, stored by Smartee, in a structured, commonly used, and machine-readable format, allowing you to transfer it to a third party or, when technically feasible, have Smartee directly transfer such data to a third party. This right applies if Smartee processes your personal data based on your consent or a contract with you, including cases where automated methods are used.
If Smartee processes your personal data based on its lawful interests, you have the right to object to such processing. However, in certain circumstances, Smartee may retain the right to continue processing your personal data and/or deny your objection.
Please note that you may also contact your healthcare provider or the institution that serves you directly. Smartee can forward any rights-related requests to the relevant healthcare provider or institution with whom you have a contractual relationship.
7. Contact information
If you have any queries or concerns about how Smartee process your personal data, please contact us at [info@smartee.cn].
8. Updates to Statement
Smartee's Statement may be updated periodically. Any significant updates will be communicated with you as necessary.
9. Disclaimer of product information
The information provided by Smartee is for informational purposes only and should not be considered medical advice. Smartee is not a healthcare provider and does not engage in orthodontics, dentistry, or any form of medical consultation or treatment services. To the extent permitted by law, Smartee makes no guarantees or warranties regarding treatment outcomes.
