PRIVACY POLICY

Oral Tech AI Pty Ltd (ACN 638 265 648) seeks to provide users (“You”) of its Technology with information about oral health and a platform to facilitate services that may be required from a Dentist or other Registered Health Professional (“the Services”). The Services are constantly evolving, and new features may be offered from time to time.

This Privacy Policy sets out how we collect, store, use, and disclose your Personal Information, and how to contact us if you have any questions about our data practices or if you would like to access the information we hold about you.

We comply with the Privacy Act 1988 (Cth) (“Privacy Act”) and the applicable Australian Privacy Principles (APPs) in Australia. We take the protection of your Personal Information seriously and maintain robust measures to ensure the security, integrity, and transparency of your data.

Consent

By accessing and using our Technology and accessing the Services, you agree to the collection, storage, use, and disclosure of your Personal Information in accordance with this Privacy Policy.

Minors

To access the Services, you must be at least 18 years of age, or the legal age required to enter into binding contracts in your jurisdiction of use.

If you are a parent or guardian providing consent on behalf of a child, references to “You” in this Privacy Policy apply to both yourself and the child for whom you are responsible.

What is Personal Information?

Personal Information has the meaning given to that term in the Privacy Act. Generally, it means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether it is recorded in a material form or not.

Health Information is defined as a sensitive subset of Personal Information. It includes information or opinions about a person’s health, illnesses, disabilities, injuries, expressed wishes regarding future health care, or health services that have been or will be provided to them. It also includes predictive genetic information.

Sensitive Information is another subset of Personal Information. It includes information or opinions about an individual’s racial or ethnic origin, political opinions, memberships in professional associations or trade unions, religious beliefs, philosophical beliefs, sexual orientation or practices, criminal records, health information, and biometric verification data.

What Types of Personal Information Do We Collect?

The categories of Personal Information we may collect include:

• Identifying details such as names, dates of birth, age, gender, cultural background, and occupation.
• Contact details including telephone numbers, email addresses, and physical or postal addresses.
• User status details, health aids, required services, body height, weight, and languages spoken.
• Financial and payment details for user fees (where applicable).
• Private health insurance details, including your provider name and membership number.
• Government-related details such as your Medicare number, health care card, seniors card, or DVA card details (if provided).
• User feedback, customer support records, and conversational history.
• Photographic, videographic, radiographic, and other images of your oral and perioral structures (your teeth, gums, lips, tongue, and other areas inside your mouth).
• Survey information, including details about your general health, oral health history, symptoms, recent treatments, and planned future treatments.

How Do We Collect Personal Information?

We collect Personal Information through various interactions with our Technology. These collection methods are categorized below:

1. General User Data

If you interact with our Technology, our analytics and hosting services may record certain technical details about your visit, including:

• Your IP address.
• Login details and sessions.
• Geographic location and domain name.
• Your Internet Service Provider (ISP).
• The exact date and time of your visit.
• Any documents, files, or information downloaded from our platform.
• The total length of your session and pages accessed.
• Your viewing and interaction activity, such as bounces, clicks, views, and links.
• The referring website or source of inquiry that directed you to our platform.
• Your purchase history and transactional details.
• The type and version of your web browser.
• Your device operating system and platform.
• Other general diagnostic data related to the device used to access our systems.

2. Demographic and Image Data

To fully utilize the Technology, we will request that you provide specific Health and Sensitive Information:

• Contact Forms: Details entered into contact templates to help us understand your specific oral health concerns.
• Image Uploads: Photographic, videographic, or radiographic images manually uploaded by you, or accessed via your device’s camera roll (with your permission). While we do not request image metadata, standard geotags associated with your images may be processed by default. We only collect the specific images you select for upload.
• Connected Accounts: Visual and profile data from linked social media accounts if you choose to connect your social media profiles to your Smilo.ai Account.

3. Third-Party Platform Access

If you sign up or log in using third-party networks (such as Facebook, Google, Apple App Store, or Google Play), we may collect authorized information from that platform, such as your social media alias or name, in accordance with the third party’s privacy terms.

4. Public Forum Data

The Technology includes an Oral Health Forum where users can post general oral health queries. Any information, posts, or images you upload to public forums will be visible to other users, along with your profile name and picture (if provided).

5. Dental Health Practitioner Data

We collect structural business and professional data from registered dental health practitioners, including:

• Full name, gender, academic qualifications, and specialization summaries.
• Practice name, physical address, email address, and professional phone numbers.
• Health professions, specific specialty certifications, services offered, and fee schedules.
• Preferred languages spoken.

How Do We Use Personal Information?

We process your Personal, Health, and Sensitive Information for the following primary purposes:

• To provide customized, tailored oral and dental health assessments and reports.
• To facilitate direct referrals to registered dental health practitioners as requested by you.
• To train, optimize, and improve our machine learning models to identify oral health conditions more effectively (“Oral Health Data”).

We may also process and hold this information for secondary operational purposes:

• To communicate with you regarding your account, usage status, or upcoming appointment reminders.
• To send promotional material, publications, newsletters, and targeted advertisements. You may opt out of marketing communications at any time by clicking “Unsubscribe” or contacting us at info@smilo.ai.
• To send system push notifications to your device (which you can manage via your device settings).
• To provide aggregate functional reports to dental professionals regarding platform utility.
• To run diagnostic evaluations, perform internal business planning, and conduct analytics to improve platform performance.
• To secure our infrastructure, manage access controls, prevent fraud, and enforce our terms.
• To process payments, manage subscriptions, and manage debt collection activities.

Disclosure of Personal Information

Your Health and Sensitive Information is handled with strict confidentiality. To facilitate the Services, we may share your information with trusted partners under confidentiality agreements:

• Dental Practitioners: Registered health professionals when you explicitly request a professional clinical referral.
• Internal Associates: Our related business entities and associates.
• Technical Partners: Service providers who support our core IT infrastructure, cloud databases, payment gateways, and security systems.
• Professional Advisors: Our accountants, legal counsels, auditors, and insurers.
• Statutory Bodies: Law enforcement agencies, courts, or regulatory authorities where required or authorized by law.

We utilize targeted advertising (retargeting) services. These networks use tracking technologies to display relevant ads about Smilo.ai across external websites based on your browsing patterns. You may opt out of behavioral advertising via our system preferences.

If we sell, license, or restructure our Technology, your demographic data may be disclosed in an aggregated, fully de-identified manner (e.g., general user base statistics). In addition, your anonymized Oral Health Data (such as dental images) may be integrated into our systems to train our clinical analysis models. We make reasonable efforts to crop, blur, or de-identify facial features or personal signifiers in images used for these purposes.

Disclosure Overseas

We host our primary databases on secure servers located within Australia. If we disclose data to overseas partners or subscribers, they are bound by confidentiality agreements that comply with this Privacy Policy and the Australian Privacy Principles.

Dental Health Practitioner Information Sharing

If you choose to share your records with your registered dental practitioner through the Technology, they will be granted access. You acknowledge that once your practitioner downloads or stores your information on their local systems, that data becomes subject to the practitioner’s own independent privacy policies and clinical security structures.

Direct Marketing

We may use your contact details to provide updates about our services or direct marketing offers from our trusted associates. You can opt out of direct marketing lists at any time by contacting our Privacy Officer or clicking the unsubscribe link in our emails.

Cookies and Other Technologies

Our platform uses cookies (both session-based and persistent text files) to track performance, manage login states, and optimize navigation speeds. You may disable cookies via your browser settings, though doing so may limit your access to some features of the Technology.

Government Related Identifiers

We do not use government identifiers (such as Medicare numbers or driver’s licenses) as our internal user account identifiers. We will only collect and use these details to verify eligibility for health care claims or as required by law.

Storage of Personal Information

We take all reasonable steps to secure the Personal Information we hold from:

• Misuse, interference, and loss.
• Unauthorized access, modification, or disclosure.

Your data is stored on secure cloud databases located in your country of residence (as declared during registration). While we employ industry-standard encryption, no data transmission over the internet is completely risk-free, and you transmit information at your own risk.

Data Rights and Retention

We rely on you to provide accurate and complete information. If your details change, please contact us to update your records. When your Personal Information is no longer legally required or operationally necessary, we will take reasonable steps to securely destroy or permanently de-identify the data.

Access and Correction

You may request access to, or seek corrections to, the Personal Information we hold about you. Please send your request in writing to our Privacy Officer. To maintain data security, we will require you to confirm your identity before processing your request.

In certain instances, we may refuse access or correction requests if permitted or required under the Privacy Act (e.g., due to legal retention requirements). If we refuse, we will provide you with a written statement outlining our reasons.

Links to Third-Party Sites

Our Technology contains links to external web resources. We do not control and are not responsible for the privacy practices or contents of these third-party platforms.

Complaints

If you have a privacy-related complaint, please submit it in writing to our Privacy Officer. We do not charge fees for investigating complaints and will acknowledge your inquiry promptly.

We aim to complete investigations and provide a response within 30 days. If you are not satisfied with our resolution, you may contact the Office of the Australian Information Commissioner (OAIC):

Contact Us

To request access to your information, update your account details, or raise a privacy query, please contact our Privacy Officer:

Changes to This Policy

We may amend this Privacy Policy in our sole discretion at any time. Any updates will be published on our platform.

This Privacy Policy was last updated in June 2022 and is accurate at the time of publication.