Your personal information is of paramount importance to Smartee Group and its affiliated entities (hereinafter referred to as “Smartee,” “we,” “us,” or “our”). This Privacy Policy applies to the customized orthodontic aligners and other related products and/or services (hereinafter “Products and/or Services”) provided by Smartee through various platforms, including, but not limited to, the Intraoral Scanner, Smartee ERP, Case Management System of Smartee, Smartee Doctor App, Smartee Assistant App, Smartee Wolfpack App, and Thinkific. This Privacy Policy describes how we collect, protect, use, disclose, transfer, and process your personal information (data).
You may access many of our websites, applications, or other information systems without identifying yourself or providing any personal information. However, we may request that you provide information about yourself or others, such as your name, email address, and physical address. Prior to collecting such personal information via the Internet, we will notify you and, where necessary, obtain your consent for its processing. The provisions of this Privacy Policy apply to such instances.
By clicking “Accept” or “Consent”, or by otherwise using any Products and/or Services provided by Smartee, you (on behalf of yourself and any entity you represent) consent to be bound by the following terms:
You may click here to review the definitions relevant to this Privacy Policy. These definitions apply to the Privacy Policy, the Jurisdiction-Specific Addendums, and all related annexes.
When you use our Products and/or Services by any means, we may collect the following types of personal information (including sensitive personal information) relating to customers, patients (past, present, and prospective), patients’ parents/guardians, dentists, website visitors, app users, information system users, or other relevant individuals:
Contact Information: Such as your name, mobile number, mailing address, and email address.
Treatment-Related Information: For instance, your gender and age, which enable us to provide you with orthodontic treatment-related Products and/or Services.
Financial Information: Such as your bank account details and tax identification number, to facilitate payment processing and invoicing.
Academic Training Information: Including details such as your professional role, country of residence, and affiliated organization when you participate in our training programs.
For a complete list of the specific types of personal information we collect, please click here.
When we request your personal information (including sensitive personal information), we will clearly inform you of the types of data collected and the purposes for which the data will be processed. We will only collect personal information that is strictly necessary for the intended purpose.
If we collect your medical information or other types of sensitive personal information by any means, we will obtain your explicit and separate consent.
Occasionally, you may choose to provide us with personal information about other individuals to facilitate communication with them regarding our Products and/or Services. Such information should only be provided if you have obtained their explicit consent.
Automatically Collected Information. We use cookies and similar tracking technologies to operate and provide the Platform. A cookie is a small text file that a website stores on your computer or mobile device when you visit the site. For further details, please refer to our Cookies Policy.
Information From Other Sources
Partners. We collaborate with various global partners to provide you with our Products and/or Services. Consequently, we may collect and process your personal information from these partners. For additional details, please click here.
Sellers, Payment and Transaction Fulfillment Providers. We receive information about you from sellers as well as payment and transaction fulfillment providers, such as payment confirmation details, and information about the delivery of products you have purchased through our shopping features.
The personal information collected from your use of our official website, app, information systems, Thinkific and/or other platforms, or that you provide to us by any means, may be used for the following purposes:
To establish and manage your account;
To enable you to use, purchase, book, and/or download our Products and/or Services, such as providing you with custom-made orthodontic aligners;
To send you information regarding our Products and/or Services;
To provide you with contact details for hospitals, clinics, or dentists;
To furnish authorized hospitals, clinics, or dentists with information regarding existing or potential patients;
To analyze the usage of our Products and/or Services, develop new products and services, and personalize your experience;
To provide you with academic training services.
For a detailed description of our personal information processing methods and purposes, please click here.
The legal basis for the collection and processing of your personal information depends on the type of data involved and the context in which it is collected. If we have entered into a contract and/or agreement with you, such as to provide our Products and/or Services, we process your personal information for the purpose of fulfilling that contract and/or agreement. In other cases, we may process your personal information based on Smartee’s legitimate interests (e.g., to improve our Products and/or Services), provided that we have obtained your consent and that such legitimate interests do not override your rights.
If we require your personal information to comply with legal, regulatory, or supervisory requirements, or to fulfill a contract and/or agreement with you, we will inform you and obtain your explicit consent prior to collection.
We may share your personal information under the following circumstances:
Categories of Shared Information: The information described in the “What Information We Collect” section.
Scope of Sharing: Smartee Group.
Purpose of Sharing: The purposes outlined in the “How We Use Your Information” section.
Entity Responsible for Managing Shared Information: The Smartee Group affiliate established in your jurisdiction.
To support our research, production, sales, and academic initiatives, we may entrust or provide personal information to our business partners within the scope permitted by law or with your consent. Our business partners are prohibited from using your personal information for purposes beyond their cooperation with us. Examples include:
With your explicit consent, we may share your personal information with third parties such as distributors, suppliers, and cloud service providers. We ensure that these third parties meet adequate personal data protection standards by entering into binding contracts or data processing agreements and conducting Data Protection Impact Assessments (DPIA). Smartee’s distributors and suppliers must process personal data in compliance with this Privacy Policy and our instructions. They are prohibited from using shared personal data for their own purposes and must delete or return such data upon fulfilling their obligations.
We collaborate with Thinkific to provide academic training for doctors. For details on Thinkific’s privacy practices, including its Privacy Policy, Cookies Policy, and Data Processing Addendum (DPA), please refer to Thinkific's Legal Center.
In certain jurisdictions, we collaborate with third-party cloud storage providers to legally, securely, and reliably collect, store, and process your personal information, as detailed in the “Jurisdiction Specific Addendums”.
Additionally, the personal information we collect may be disclosed in the context of an anticipated or actual merger, acquisition, debt financing, sale of company assets, or other similar transactions. In the event of bankruptcy or receivership, personal information may be transferred as a business asset to third parties.
We may also disclose your personal information in the following situations:
When required by applicable laws, court orders, or legal proceedings;
When necessary in litigation procedures;
To enforce our legal rights, policies, agreements, or contracts;
To collect payments owed to Smartee;
When we believe disclosure is necessary or appropriate to prevent actual or financial harm or in connection with the investigation or prosecution of actual or suspected illegal activity;
When there is a risk to the life, safety, property, or other rights of yourself or third parties;
When there is a risk of serious disruption to our business operations;
In any other circumstances where we determine in good faith that disclosure is necessary or advisable.
Smartee does not share personal information with third parties for marketing purposes, nor does it sell your personal information.
We implement measures to properly manage the personal information entrusted to us, preventing leaks, loss, or damage while ensuring data accuracy and currency. To securely manage personal information and protect it from unauthorized access, falsification, leaks, loss, or damage, we implement the following security measures:
Establishing Fundamental Policies
This Privacy Policy outlines our fundamental policies on ensuring the proper handling of personal information and provides contact points for inquiries and complaints.
Developing a Security Management System
We have established a comprehensive information security framework, which defines security objectives, scope, principles, and structure. Our system includes policies and procedures for managing physical, host-based, network, application, and data security. This forms a complete information security management framework consisting of security policies, management regulations, and operational guidelines.
Organizational Security Measures
We have established a Privacy Office and appointed personnel responsible for handling personal information, including a Data Protection Officer (DPO).
We define the scope of employees authorized to process personal information.
We have implemented a reporting and contact mechanism for employees to notify the Privacy Office of any actual or potential violations of personal information protection laws or internal policies.
Personnel Security Measures
Employees receive regular training on privacy and personal information protection.
Confidentiality obligations regarding personal information are incorporated into work policies.
Physical Security Measures
We implement measures to prevent theft or loss of equipment, documents, and other assets involved in processing personal information.
Measures are in place to prevent personal data leaks when transporting equipment that stores personal information, including within workplace premises.
Technical Security Measures
We enforce access controls to restrict personnel authorized to process personal information and limit their access.
We implement security safeguards to protect information systems processing personal data from unauthorized external access and malicious software attacks.
Data Transmission Security
When transferring personal information to Smartee Group affiliates or business partners outside your jurisdiction or storing personal information outside your jurisdiction, we implement security management measures and other appropriate safeguards in compliance with the data protection requirements of the relevant country.
We retain your personal information for as long as we have a continuing legitimate business interest, such as providing you with Smartee Products and/or Services or complying with applicable legal, tax, and accounting obligations.
Smartee collaborates with cloud service providers in various jurisdictions to ensure the legal, secure, and reliable localization of your personal information storage.
If there is no longer a legitimate business interest in processing your personal information,(for example, when all orthodontic-related services, including any subsequent adjustments to aligners, have been completed), your personal information will be deleted or anonymized within two years (or within one year for sensitive personal information). If immediate deletion is not possible, such as when your personal information is required for legal proceedings, by a regulatory authority, or is stored in backup files, it will be securely stored and isolated to prevent further processing until deletion becomes feasible.
A cookie is a small text file that a website stores on your computer or mobile device when you visit the site. When you visit our website, we may automatically collect certain data from your device through cookies. In some jurisdictions, such as the European Economic Area, applicable law may consider this data to be personal information. For additional details, please refer to our Cookies Policy.
Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Smartee does not recognise or respond to browser-initiated DNT signals.
Although we cannot entirely prevent children from accessing our website, app, or other information systems, we do not collect any personal information unless it is explicitly indicated that the provider must be at least 13 years old.
Smartee does not knowingly collect information from children under the age of 13 unless such information is provided by a parent or legal guardian. Where the personal information of a minor is collected with the consent of a parent or legal guardian, Smartee will only process such personal information as permitted by applicable law, with explicit consent from the parent or legal guardian, pursuant to a contract or agreement for the provision of orthodontic services, or when necessary to protect the vital interests of the minor. If Smartee becomes aware that it has inadvertently collected personal information from a minor without obtaining the required parental or legal guardian consent, Smartee will take prompt steps to delete such personal information.
Please note that the applicable age threshold may vary depending on the legal requirements of your country or region; in such cases, we will notify you at the time of data collection. If you have any questions regarding our collection and processing of children’s personal information, please contact us at privacy_dpo@smarteealigners.com.
Smartee is headquartered in China and operates globally. Consequently, we may transfer your personal information to other countries or regions where Smartee, its personnel, or its third-party service partners operate, including jurisdictions outside of your country of residence.
When transferring your personal information internationally, Smartee will implement appropriate measures to protect your data. For example, we may transfer your personal information from the European Economic Area to the United Kingdom, Switzerland, or Japan in accordance with the European Union’s Adequacy Decisions (subject to periodic updates), which recognize these jurisdictions as providing an adequate level of data protection. In other cases, we employ mechanisms approved by relevant regulatory authorities, such as Standard Contractual Clauses (SCCs) or Binding Corporate Rules (BCRs), to facilitate cross-border transfers. Further details regarding international data transfer rules and measures applicable in different jurisdictions are provided in our Jurisdiction Specific Addendums.
All personal information you provide is of paramount importance to us. Smartee is committed to implementing reasonable technical and organizational measures to protect your personal data from destruction, loss, misuse, alteration, disclosure, or unauthorized access. However, no method of data transmission over the Internet or electronic storage can be 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. Therefore, please take this into consideration when providing your personal data to us.
Depending on the applicable laws, you may have the right to withdraw consent, access, rectify, disclose, modify, or delete your personal information.
For example:
European Economic Area (EEA): You can contact us to exercise your rights to access, correct, update, delete, object, or withdraw consent.
California, USA: You may request, once per year, a list of third parties to whom we have disclosed your personal information for direct marketing purposes. (We do not sell or rent personal information to third parties for direct marketing.)
Singapore: You may request access to personal information we have collected within one year before your request and inquire how we have used or disclosed your personal data. A fee may be charged for access requests to cover the cost of providing such records. We will inform you of any applicable fees upon receiving your request.
These are only examples. For specific rights applicable to your jurisdiction, please refer to the “Jurisdiction Specific Addendums”. To exercise your rights, contact us using the details in the “Contact Us” section.
This Privacy Policy is for reference only. Depending on your jurisdiction, you may have additional legal rights that are not explicitly listed here.
Additional Jurisdiction Specific Addendums may apply to your use of our Products and/or Services through our website, app, information systems, or other means, depending on the privacy and personal data protection requirements of different jurisdictions. These addendums are incorporated by reference into this Privacy Policy.
We may update this Privacy Policy at any time as we deem necessary. Updates will be indicated by the “Last Updated” date at the bottom of this document. Notifications of updates will be posted on our website or provided as legally required. We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and share your personal information. Continued use of Smartee’s Products and/or Services after updates are posted or notified constitutes acceptance of the changes. If you do not agree with any updates, please discontinue use immediately.
If you have any questions regarding our Privacy Policy, other privacy-related documents, our official website, information systems, your personal information, your rights concerning personal information, or any aspect of our personal information collection and processing activities, please contact us using the details provided below.
When submitting an inquiry, please include your country or region in the subject line.
Global Headquarters:
Shanghai Smartee Denti-Technology Co., Ltd.
Building E, Jixian Center, Lane 565 Shengxia Road, Pudong New Area, Shanghai, China
Email：privacy_dpo@smarteealigners.com
Smartee Entities: You may also contact your local Smartee Entities responsible for handling your personal information. Details can be found here.
Upon receiving your inquiry, Smartee will respond within 30 days and take appropriate action promptly.
Last Updated: March 30, 2025
