Privacy Policy

Passport involves two distinct roles, and it is important to know them. The data of professionals and clinics (account, profile, billing) is processed by DentGrow as controller. The data of patients (name, NIF, implant records) is entered and controlled by the clinic — which is the controller — with DentGrow acting as processor, under Article 28 of the GDPR and the data processing agreement included in the terms and conditions.

In a group of clinics (Enterprise plan), the controller is the company that owns the group, and whoever administers it accesses the patients of all units. A clinic of another entity that joins a group does so under an agreement with that company, and may leave at any time.

Clinics and professionals: name, email, NIF (Portuguese tax number), professional licence number and telephone number — to create and manage the account, bill the subscription and meet tax obligations.

If you sign in with your Google® account: we receive from Google your name, your email, an indication that the email is verified and the address of your Google profile photo (which we do not display) — solely to create and identify the account. We do not receive your Google password or access to your mail, contacts or files.

Patients (on behalf of the clinic): name, NIF (encrypted), date and record of consent, the clinical data of the implant (tooth position, brand, reference, batch, expiry date, protocol, notes) and the clinical photographs the clinic uploads, stored without metadata (including location) and visible only to that clinic — to build the patient's digital implant passport, for the purpose of ensuring traceability and continuity of care. Health data is a special category (Art. 9 GDPR) and is processed with the measures described on the Security page.

Recording the passport is based on the patient's explicit consent, collected by the clinic and declared on the platform at the time of recording (the date is stored). Processing of account data is based on the performance of the subscription contract; billing, on compliance with legal obligations.

Clinical records are kept for as long as the clinic keeps its account and the patient does not exercise the right to erasure — an implant passport is, by its nature, meant to last a long time. Billing data is kept for the applicable statutory periods.

Access, rectification, erasure, restriction, portability and objection — patients exercise these rights with their clinic, which has tools on the platform to carry them out immediately (including permanent deletion with proof in the audit trail). Professionals exercise them directly with DentGrow. You also have the right to lodge a complaint with the CNPD, the Portuguese data protection authority (www.cnpd.pt).

We do not sell data or use it for advertising. We use infrastructure providers in the European Union (hosting of the database and the application), a payment processor for subscriptions and an error-monitoring service hosted in the European Union, all bound by data processing agreements, as well as the artificial intelligence providers described in section 7. When an entity is deleted, its subscription is cancelled and the cards stored with the payment processor are removed; invoices already issued are kept for the period required by tax law. The monitoring service receives technical failure reports — it is configured not to collect request bodies, cookies, database query data or the content of patient records. The up-to-date list of processors can be requested from privacidade@dentgrow.pt.

On the sign-in, sign-up, password recovery and invitation forms we use Cloudflare Turnstile® (Cloudflare, Inc.) to tell people apart from automated programs. Turnstile processes the IP address, technical browser signals (such as the User-Agent) and the page address, but not what you type in the fields, and it is not used for advertising. Cloudflare processes these signals on our behalf and, as a controller, to improve bot detection; it may transfer them outside the European Economic Area, with the safeguards provided for in the GDPR. The legal basis is our legitimate interest in protecting accounts and the service (Article 6(1)(f) GDPR). It does not run on pages with patient data.

The public website (dentgrow.ai) also uses two measurement tools, and only with your consent — section 8 explains which ones, what they store and how to change your mind. They do not run inside the application.

Implant identification from X-rays, the Academy and question dictation use artificial intelligence services from external providers, acting as processors. They receive only the image, question or recording needed for each function — never the patient's name or NIF — and do not use them to train their models. They may process them outside the European Economic Area, under the European Commission's standard contractual clauses.

We recommend using X-rays on which the patient's name is not visible. The answers support the professional, who decides: they do not replace clinical assessment.

Those needed for the service to work. The session of whoever signs in (set by the authentication provider), two display preferences — theme and text size — and, on the sign-in, sign-up, recovery and invitation forms, what Cloudflare's anti-bot check needs to work. They identify no one beyond what is necessary, are not shared and do not depend on consent: without them the service does not work.

Measurement cookies, which only exist if you say yes. On the public website we use Google Analytics® (Google Ireland Limited) and Microsoft Clarity® (Microsoft Ireland Operations Limited) to understand which pages help and where people get lost. Clarity® also records mouse movement and page scrolling, in aggregate form and with field contents masked. They write cookies in your browser — _ga and _ga_* (up to 2 years), _clck (1 year) and _clsk (1 day). The legal basis is your consent (Article 6(1)(a) GDPR and Article 5 of Portuguese Law 41/2004), and nothing is loaded before you give it. We do not use this data for advertising or build profiles with it.

Where there is no measurement at all. These tools run only on the public website. They do not run in the application (app.dentgrow.ai), where patient records are, or on the verification page the patient opens with the QR code (v.dentgrow.ai) — a screen recording in those places would be a recording of health data, and that is a line we do not cross. The separation is enforced by the server, not by a setting.

Changing your mind. Your answer is kept for six months and can be changed at any time, without giving a reason and with the same number of clicks it took to give it: review my cookie choice. If you decline, measurement cookies already written are deleted. You can also block them in your browser settings.

Both providers may transfer data outside the European Economic Area, under the EU-U.S. Data Privacy Framework and the European Commission's standard contractual clauses.

On the public website (dentgrow.ai) you can request a free PDF guide by giving your email address. We use that email to send you the guide and, only if you tick the corresponding box, to send you the DentGrow newsletter. These are two separate permissions, and neither is pre-ticked. The newsletter only starts after you confirm the subscription via the link in the email we send you. The legal basis is your consent (Article 6(1)(a) GDPR).

The request is recorded in DentGrow's contact system, hosted on a server in the European Union, with the email, the date, the permissions given and the page of origin. We keep the contact while you remain subscribed to the newsletter or, if you did not ask for it, for up to 24 months after requesting the guide. You can withdraw consent at any time — via the unsubscribe link in each email or at privacidade@dentgrow.pt — without affecting what was done before.

So as not to show the offer again to someone who has already seen it, the website stores in your browser (localStorage, key dg_saida_v1) the date the offer appeared and whether the guide was requested. This information does not leave your browser, is not sent to any server and can be deleted in your browser settings.

Privacy questions and exercising your rights: privacidade@dentgrow.pt. Data breaches are notified to the CNPD and, where applicable, to data subjects, within the GDPR deadlines (72 hours).