Dieses Dokument wird als englische Übersetzung zur Information angezeigt. Rechtsverbindlich ist die türkische Fassung.
PRIVACY NOTICE ON THE PROCESSING OF HEALTH DATA
1. Data Controller
UNG Sağlık Teknolojileri Ürünleri ve Hizmetleri Ltd. Şti. (the "Company") is the data controller, under the Personal Data Protection Law No. 6698, of the health data processed through the Oralenta mobile application. This notice has been prepared to inform you about the processing of your health data, which qualifies as special category personal data under Article 6 of the Law.
Email: info@ungmedical.com
2. Health Data Processed
The following health data is processed through the Application:
— Intraoral photos: Images taken with the device camera from five angles (front, upper jaw, lower jaw, left side, right side).
— AI assessment summaries: General assessment results produced by the AI system analysing your photos (such as suspected decay, plaque build-up, possible missing teeth, gum condition). These assessments are for information only and do not constitute a medical diagnosis or treatment.
— Dental chart data: The current condition of each tooth and its classification as a primary or permanent tooth.
— Oral health behaviour data: Daily brushing count, brushing streak, total brushing statistics, toothbrush start date and replacement period.
— Appointment and treatment data: Clinic name, reason for treatment, date and status of dentist appointments.
The health data listed above belonging to family members (including spouse and children) is also processed within the profiles created by the parent who owns the account.
3. Purposes of Processing
Your health data is processed solely for the following purposes:
a) Performing the AI-assisted preliminary oral and dental health assessment.
b) Creating and updating the dental chart.
c) Tracking a personalised oral care routine and providing brushing guidance.
d) Managing the oral health profiles of family members.
e) Appointment management.
f) Developing and improving the AI model (only where you have separately given explicit consent, and using anonymised data).
4. Legal Ground
Your health data is processed on the basis of your explicit consent under Article 6, paragraph 2 of the Law. Explicit consent is obtained separately for each family member, per profile. If you do not give explicit consent, the features of the Application that require health data (dental assessment and AI assessment, dental chart, brushing and toothbrush tracking, appointment records) will not be available, while your access to the other functions that do not require consent will continue. You may withdraw your explicit consent at any time; withdrawal does not affect the lawfulness of processing carried out before the date of withdrawal.
5. Method of Collection
Your health data is collected, by fully or partly automated means, through intraoral photos taken with the device camera via the Application, data generated automatically while you use the Application (brushing statistics, assessment history), and information you enter directly (appointment details, dental chart notes).
6. Transfer of Data
The hosting of your health data and the transfers within the technical infrastructure of the Application are described below:
— Company servers (Türkiye): Photos and database records are kept in encrypted storage on the Company's own servers located in Türkiye; this data is not transferred abroad for hosting purposes.
— AI models: The AI models used for photo assessment and the language model of the AI assistant run on the Company's own servers located in Türkiye; data is not transferred to an external AI service or abroad. No identity information is sent to the models; for photo assessment, only the assessment identifier and the images are processed.
Transfers abroad are carried out on the basis of your explicit consent under Article 9 of the Law. All data transmission takes place over encrypted connections (TLS).
7. Storage and Security of Data
Your intraoral photos are kept in encrypted, private storage and cannot be accessed through public links. Access to images is provided through time-limited (at most one hour) signed links, and every access is logged. During the AI assessment, your identity information is not processed together with the images. Raw AI output is not shown to you; only an edited summary text is presented. Other users cannot access your personal health data; within the Company, only authorised personnel can access it within the scope of their duties.
Dental assessment records (including intraoral photos, AI findings and the result summary) are retained for at most 2 years from their creation; expired records are deleted automatically and permanently. Dental chart, brushing and appointment records, whose purpose of current use continues, are retained for as long as your account is active unless you delete them.
If your account is deleted, all of your health data (photos, assessment results, dental chart, appointments) is permanently deleted in a cascading manner.
8. Your Rights
Under Article 11 of the Law, with respect to your health data you have the right to learn whether it is processed, to request information, to learn the purpose of processing, to know the third parties to whom it is transferred, to request correction, to request deletion or destruction, to request that these actions be notified to third parties, to object to a result produced by automated analysis, and to claim compensation for damages.
You can submit your requests from within the Application (Settings > Download My Data, Delete My Account, My Consents) or by email to info@ungmedical.com.