1. Purpose of this document
This document briefly explains how SmileCrop approaches patient photographs and which responsibilities remain with the orthodontic practice or other healthcare facility.
2. Local processing
SmileCrop is designed as a desktop application. Photographs inserted into the Application are normally processed locally on the User's device. Normal use of the Application does not require uploading patient photographs to the Provider's servers. Internet connection is used only for licence activation, occasional subscription validation, updates, and payment-related processes.
3. Role of the Provider
If the Provider does not have access to patient photographs, the Provider generally does not act as a processor of those patient data. However, the Provider may be a controller or processor of other data, such as customer, licence, payment, or technical support data; see the Privacy Policy.
If the Customer voluntarily sends real patient photographs to the Provider for support purposes, personal data processing may occur. Such transfer should be limited to the necessary scope, ideally anonymized or replaced with sample data, and should have an appropriate legal basis.
4. Role of the Customer
The Customer, typically an orthodontic practice or healthcare facility, is responsible for the lawfulness of processing patient photographs, their security, maintaining documentation, informing patients, and setting internal processes according to the GDPR and regulations relating to medical documentation.
5. Recommended practice
- Store original photographs and outputs securely and back them up regularly.
- Restrict access to the device and folders only to authorized persons.
- Do not send patient photographs by email without a proper reason and security measures.
- Use anonymized, own, or sample photographs for technical support.
- Verify automatically created outputs before storing them in documentation or sharing them with other persons.
- Ensure that the use of QR codes or patient names complies with the clinic's internal rules and personal data protection.
6. No diagnostic function
SmileCrop does not perform diagnosis, medical analysis, treatment evaluation, or clinical decision-making. The Application only technically processes photographs for the purposes of organization and documentation. The Application is not a medical device within the meaning of applicable legal regulations.