Privacy policy

Who processes your data

The person responsible for the decisions on how we process your data is the Data Controller of Oralsnap. For every privacy matter, write to a single address:

Oralsnap was created by Vladyslav Pereverzyev, who remains its creator; the Service is now owned and operated by Hundredjack OÜ, which is the Data Controller.

We have not designated a DPO: the mandatory conditions provided by Art. 37 GDPR do not apply. For Oralsnap, the privacy contact point coincides with the Controller.

For clinical data, it's different

When a dentist or dental technician uploads data referable to a patient of theirs into the app, we are only Processors (Art. 28 GDPR) - the Controller is the professional. If you are a patient and want to exercise your rights on clinical data, you must contact your professional.

For details on the relationships between us, the professional and the patient, see the T&C Section 12.

Which data we collect, one by one

For each individual data we collect, we explain when we take it, why we need it, where it ends up and how long we keep it. No vague categories, only reality.

What we do NOT collect, clearly

Since too many Privacy Policies list data they never actually collect, here we tell you in black and white what we don't do and which device permissions we don't use.

When a device permission is not listed above among the "yes", it means we don't request it at all. Concrete examples: the app does NOT request access to the address book, messages, microphone, light sensor, Bluetooth, calendar contacts.

Only necessary permissions

The permissions the app requests from the device are limited to:

• Camera - only when you choose to take a clinical photo.
• Photo gallery - only when you choose to import an existing image.
• NFC - only when you write or read a tag.
• Local biometrics - only if you enable app unlock with Face ID/fingerprint (verification happens on your device, never on our servers).
• Push notifications - only if you accept them.

Cookies and similar technologies

On oralsnap.com we use our own cookie banner, in compliance with Italian Garante Provision no. 231/2021. We don't run any analytics, marketing or profiling cookies of our own, and the site sets no cookies of its own: your choice is remembered in your browser's local storage. The only third-party cookies come from the YouTube videos on our home page, and only after your consent.

For the complete list of all cookies with technical details (purpose, duration, provider), see the Cookie Policy. The mobile app does not use cookies: it relies on JWT authentication tokens stored in the secure native storage of your device.

Data collected automatically

When you use the app or site, some technical data is collected without you entering it explicitly. They serve for security, diagnostics and abuse prevention. They are not used to profile you.

From this data we derive an approximate geolocation at city or region level, only to detect anomalous accesses (e.g. login from a country different from the usual one). We don't track your GPS location.

The emails you may receive from us

Emails from Oralsnap are of two types. We explain what to expect and how to manage them.

6.1 - Transactional emails (you cannot unsubscribe)

These are emails necessary for the Service to function. You receive them only as a consequence of your action or a condition of your account:

• Registration confirmation and OTP code
• Password reset
• Access from a new device
• Subscription expiration reminder
• Purchase or plan change confirmations
• Important security notifications
• Updates to T&C or Privacy Policy

You cannot unsubscribe from these emails because they are part of the Service. You receive them only if you have an active account: by deleting the account, you will stop receiving them.

6.2 - Optional emails (you can unsubscribe at any time)

Only if you explicitly accept, we send you emails with:

• Updates on new features
• Tips to better use the app
• Invitations to beta tests (if active)

You find the unsubscribe link at the bottom of every optional email. Unsubscribe is immediate. You can also write to info@oralsnap.com.

Technical email sending is managed by Brevo (based in France), which acts as Data Processor. Brevo receives only the recipient's email address and the content to send. One-time login codes are sent through the Hostinger (EU) mail service, which likewise receives only the address and the message.

What happens when you create an account

To be even more transparent, here is the exact flow of your data at the key moments of your relationship with Oralsnap:

What the App Stores do with your data

In particular, the App Stores autonomously manage:

• Purchase data (credit card, IBAN, billing address) - we don't receive them, we only see if a purchase was successful.
• Advertising identifier (IDFA/AAID) - we don't request it or use it.
• Download statistics and aggregate crash reports - Apple and Google show them to us in anonymous and aggregate form, not at the level of individual user.
• Sign in with Apple data - when you choose Apple login, Apple generates an anonymous email on your behalf if you prefer. We only see that anonymous email.

To learn more:

• Apple Privacy Policy
• Google Privacy Policy

Your rights, in practice

The GDPR guarantees you a series of rights you can exercise at any time, free of charge. For each one we tell you how you can practically do it, not just which article of law it is.

Response times

We will respond to any request within 30 days. In complex cases we can extend by 60 days with written motivation. To verify your identity before processing sensitive requests, we may ask you for additional information - this is to protect yourself from unauthorized access.

Minors under 18

Oralsnap is not intended for minors under 18 as registered users. The app's conditions provide that the professional user must be of legal age and authorized to practice the profession.

If we become aware that a minor has created an account providing personal data, we will delete the account and all associated data without notice. If you are a parent or guardian and suspect that a minor family member has created an account, write to us at info@oralsnap.com.

Minor patients in clinical cases

The case of minor patients whose clinical data is managed by the professional in the app is different. In this scenario:

• The responsibility of consent collection falls on the professional (Controller).
• Consent must be signed by both parents or by the legal guardian.
• Enhanced protections apply for Art. 8 GDPR (minors under 14 in the EU).
• Even for minors, the prohibition on entering direct identifying data applies (Section 02).

For details, see T&C Section 10.

Automated decisions and profiling

The only automation active in the Service is technical and security-related:

• Automatic block after 5 failed login attempts - to prevent attacks.
• Rate limiting on API calls - to guarantee Service stability.
• Automatic filtering of files with disallowed extensions - to prevent malicious uploads.

These automations are aimed at security, not profiling, and do not produce legal effects or significant decisions pursuant to Art. 22 GDPR.

Changes and contacts

12.1 - How we notify you if something changes

We will update this Privacy Policy whenever necessary to adapt to new regulations, Service evolutions or changes to our providers. When changes are substantial (e.g. new categories of data, new subprocessor, new purpose):

• We will notify you via email to your registered address and via in-app notification.
• Notice will be at least 30 days.
• The "last updated" date at the top will be updated.
• Previous versions remain available upon request.

For minor changes (formatting corrections, clarifications) we limit ourselves to updating the document and date, without direct notification.

12.2 - Single contact

The complete legal and fiscal data of the Controller (Hundredjack OÜ) are publicly available at the Estonian Business Register (e-Äriregister).