Privacy Policy

1. Who We Are

This Privacy Policy describes how Implanr (“we”, “us”) collects, uses, stores, shares, and protects your information when you use the Implanr mobile application, web application, or any related services (the “Service”).

We are the Data Fiduciary under India’s Digital Personal Data Protection Act, 2023 (“DPDP Act”) for personal data we determine the purpose and means of processing. Where we process Protected Health Information (“PHI”) on behalf of a dental college or clinic, that organisation is the controller and we act as a data processor.

Grievance Officer: admin@implanr.com
General Contact: info@implanr.com
Security Incidents: admin@implanr.com

2. Scope

This policy applies to the Implanr iOS, Android, and web applications, all Implanr APIs, dashboards, websites, and email communications.

It covers two workspace types:

Dental College
Dental Clinic

It does not apply to third-party services that integrate with Implanr (Google, Microsoft, Apple SSO, Stripe, App Store, Play Store), each of which has its own privacy policy.

3. Roles & Responsibilities

Dental College / Clinic

Data Controller / Fiduciary for staff, student, and patient records they create. Responsible for obtaining valid patient consent.

Implanr

Data Processor when handling PHI; Data Fiduciary for the account profile we create for you.

End User (You)

Data Principal whose rights this policy describes.

4. What We Collect

4.1 Information You Give Us Directly

Account & Identity

Name
Prefix
Email address
Mobile number (E.164)
Hashed password
Profile photo
Role
Qualifications

Workspace Information

College/clinic name
Registration number
State
Seats
Billing address

Clinical Content

Diagnostic notes
Intra-oral photos
Radiographs
Treatment plans
Implant brand/system/size
Surgical reports
Prosthesis details
Audit overrides
PDF case reports

May include patient-identified PHI.

Uploaded Attachments

PDFs
Images
Documents

Text may be automatically extracted from PDFs to power AI search.

Communications

Chat messages
Forum posts
Support tickets
Feedback

Payment Data

Billing contact
GSTIN
Payment method tokens

Card numbers and UPI IDs are processed by Stripe and are never stored on our servers.

4.2 Information We Collect Automatically

Device and usage data
Crash logs
Screen-view events
Click events

Authentication Telemetry

Login attempts
Sessions
Auto logout events
IP addresses
Device fingerprint

Audit Logs (HIPAA-Aligned)

Records of every:

PHI view
Edit
Export
PDF download
Role change
Safety override

Retention: Minimum 6 years

Cookies & Local Storage

Used for:

Session management
CSRF protection
Theme preferences
Last-active timestamp

See our Cookie Notice for details.

4.3 Information From Third Parties

SSO Providers (Google/Microsoft/Apple)

Name
Email
Profile photo

Only according to permissions you approve.

OTP Providers

Delivery status

Email & Push Providers

Delivery telemetry
Device tokens

Information We Do NOT Collect

Biometrics (Aadhaar, fingerprint, face) for authentication
Background GPS location
Contacts, SMS, or call logs

We never sell your data to anyone.

5. How We Use Your Information

We use your information to:

Provide and maintain the Service (accounts, cases, PDFs)
Deliver clinical decision support (bridge/cantilever detection, biological safety, AI explanations)
Authentication and security (password hashing, OTP, 15-minute auto-logout, brute-force protection, audit logs)
Customer support and bug investigation
Improve services through aggregated, de-identified analytics
Meet legal and regulatory obligations (subpoenas, tax filing, medical record retention)
Billing, payments, and GST invoicing
Marketing communications (only with your consent; you may opt out at any time)

AI Usage Notice

We do not use Clinical Content (PHI) to train any general-purpose AI model.

AI features are stateless calls to OpenAI, Anthropic, or Google with no training opt-in.

6. Sharing & Sub-Processors

Within your workspace, access to data is governed by role-based permissions.

Workspace data is fully tenant-scoped, meaning:

A clinic cannot access a college’s data.
A college cannot access a clinic’s data.

Our Sub-Processors

MongoDB (managed database)
S3-compatible object storage (attachments and images)
Google Workspace SMTP (transactional email)
Twilio Verify / MSG91 (mobile OTP)
Stripe (payments and subscriptions)
OpenAI / Anthropic / Google via Emergent Universal LLM integration (AI prompts, anonymised where possible)
Apple APNs and Google FCM (push notifications)
Sentry (crash and error monitoring)
Expo Application Services (mobile builds and OTA delivery)

We may also disclose information:

When required by law
During mergers or acquisitions (with notice)
As fully anonymised, aggregated statistics

We never share:

Plaintext passwords
Card numbers
Patient PHI with advertisers or data brokers

7. International Transfers

Implanr operates from India.

If you access the Service from outside India, your data may be transferred to and processed on servers in India or our operating region.

Where required, we use Standard Contractual Clauses or equivalent safeguards under DPDP Section 16 and GDPR.

8. AI Processing of Your Data

Implanr uses third-party LLM providers through the Emergent Universal LLM integration to power:

Ask Implanr
Implant recommendations
Explainable suggestions

Safeguards

Only the minimum necessary context is sent
LLM providers contractually agree not to train on our prompts
Prompts are deleted within 30 days
AI suggestions are clinical decision support only and not a substitute for professional judgment

You may disable AI features through:

Settings → AI Features → Off

9. Data Retention

Data Type	Retention
Active account & profile	While active
Clinical content & case PDFs	Customer medical record policy; default 10 years (India) and minimum 6 years where HIPAA applies
Audit logs	Minimum 6 years
Authentication telemetry	18 months
Crash logs/device telemetry	90 days
Backups	35-day rolling encrypted backups
Deleted account residual data	Anonymised within 90 days; backup copies expire within 35 days thereafter

10. Security Measures

We implement industry-standard safeguards including:

TLS 1.2+ in transit
AES-256 encryption at rest
Role-based access controls
Least-privilege permissions
MFA for engineering staff
15-minute inactivity auto-logout
Audit logging of PHI access/export/override events
Android screen-capture blocking
iOS app-switcher blur protection
Quarterly third-party penetration tests
Annual internal security reviews (target SOC 2 Type II)
Encrypted region-redundant backups
CERT-In incident reporting compliance

No system is completely secure.

Report vulnerabilities to: admin@implanr.com

11. Your Rights as a Data Principal

Under the DPDP Act 2023 (and GDPR/HIPAA where applicable), you may:

Access Your Data

Settings → Account → Download My Data

Correct Information

Settings → Profile → Edit

or contact your workspace administrator.

Erase Your Data

Settings → Account → Delete Account

(90-day soft delete; immediate hard delete available on request)

Withdraw Consent

Settings → Privacy → Manage Consents

or email: admin@implanr.com

Data Portability

Settings → Account → Export Data (JSON)

Nominate a Representative

Settings → Account → Nominee

Grievance Redressal

Email: admin@implanr.com

We respond within 15 working days.

Patients should first contact the college or clinic that maintains their records.

You may also lodge a complaint with the Data Protection Board of India.

12. Children’s Privacy

Implanr is intended for:

Licensed dental professionals
Students enrolled in accredited PG/UG programmes
Clinic staff

We do not knowingly collect personal data from individuals under 18.

Patient records may include information about minor patients where parental or lawful guardian consent has been obtained by the treating dentist.

Obtaining such consent is the responsibility of the customer under DPDP Section 9.

13. Cookies

The web application uses:

Session cookies (HttpOnly, Secure, SameSite=Strict)
CSRF token cookies
Local storage for theme preferences and inactivity tracking

We do not use:

Third-party advertising cookies
Retargeting pixels
Social media tracking cookies

See our Cookie Notice for more details.

14. Changes to This Policy

We may update this Privacy Policy periodically.

Material changes will be communicated at least 30 days in advance through:

In-app notifications
Email communications
Updated effective dates

Continued use of the Service after the effective date constitutes acceptance of the updated policy.

15. Contact

We respond to verified requests within 15 working days, in accordance with DPDP requirements.