Consumer Health Data Privacy Policy
Version 1.0 · Effective October 29, 2026
What we collect
This policy explains how Smile Lab USA LLC collects, uses and shares consumer health data. It applies to residents of Washington, Nevada, Connecticut and other states with similar laws, and we apply it to all customers.
Fit-check answers (missing teeth, loose teeth, gum disease, recent extractions, braces, age range); photos of your mouth and teeth; impressions you mail us and the physical and digital models we make; notes of the licensed dentist who reviews your case; the fact that you ordered a dental appliance; what you tell Smiley, our AI assistant, by chat or voice; and inferences such as whether an appliance is likely to fit.
Sources
You; the reviewing dentist; our own processing.
Why we use it
- Necessary to provide what you request: checking suitability, dentist review, designing, making, shipping, adjusting, repairing and remaking your appliance, keeping your model on file for remakes and duplicates, support, and records of your order and our communications.
- With your consent: collecting fit-check answers and photos before you order; using chats and calls to improve Smiley (separate optional consent).
- Also: security, fraud prevention, legal compliance, and establishing or defending legal claims.
We do not use consumer health data for advertising and we do not send it to advertising or analytics companies.
Who receives it
Only processors under written contracts acting on our instructions: the reviewing dentist; our partner dental laboratory; hosting, database and file storage providers; AI service providers for Smiley; email and messaging providers; shipping carriers (name and address only). We share with anyone else only with your separate consent or where the law requires.
No sale
We do not sell consumer health data.
De-identified data
We may de-identify health data so it cannot reasonably be linked to you, publicly commit not to re-identify it, and contractually require recipients not to re-identify it. De-identified data is not consumer health data and may be used for quality, research and developing design tools.
Your rights
You may confirm whether we collect, share or hold your consumer health data; access it with a list of third parties and affiliates we shared it with and their contact details; withdraw consent; and request deletion, including from processors and backups. We respond within 45 days, extendable once by 45 days with notice. Requests are free up to twice a year. If we decline, you may appeal by replying "Appeal" within 30 days; we answer within 45 days, and you may contact your state Attorney General.
Withdrawing consent stops processing that depends on consent. It does not undo an order you already placed; we will tell you if we cannot complete it without the data. We may keep information where the law permits, including to complete a transaction you requested, to meet tax and record-keeping duties, and to defend legal claims.
How to make a request
privacy@smilelabusa.com or the request form in your account. We verify your identity with your order number and email.
Security
Access is limited to people who need it; data is encrypted in transit and at rest; private storage; multi-factor authentication.
Retention
Fit-check answers and photos of non-customers: 12 months. Impressions, models and design files: 2 years from receipt. Smiley chats and recordings: 3 years for records; for improvement only if you opted in.
No geofencing
We do not geofence around health care facilities.
Contact
Smile Lab USA LLC, Smile Lab USA LLC, Hollywood, FL 33020 · legal@smilelabusa.com · privacy@smilelabusa.com · 1 888 886 5530.
Changes
We post updates here with a new date. We ask for consent before using or sharing health data for a new purpose that needs consent.
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