Privacy Policy

Last updated: October 20, 2026

BioLign is made by BioLign Ltd., based in Calgary, Alberta, Canada. This Privacy Policy is a single policy that covers all of our products. Sections that apply only to a specific product are marked with a tag such as BioLign Track. You can jump to any section using the menu.

This Privacy Policy describes how BioLign ("we", "us", or "our") collects, uses, stores, and shares your personal information when you use our products and services, including:

• BioLign Track: mobile companion app for orthodontic aligner treatment tracking (iOS and Android)
• BioLign Cloud: web-based practice management system and lab coordination platform
• BioLign3D: AI-assisted 3D treatment planning software
• biolign.ca: our website

Please read this policy alongside our Terms of Service. Where we rely on your consent, we ask for it separately and you can withdraw it at any time, as described below. Where we process health information on behalf of your orthodontic provider, we do so under that provider's direction and our Terms of Service.

1. Information We Collect

Account Information

• Full name and email address
• Phone number, where one is provided. BioLign Track does not ask patients for a phone number; your practice may record one in your clinic record, parents and guardians may add one, and independent doctors provide a practice phone number. If you agree to receive texts from your practice, your practice records that consent, and we keep a record of each text sent to or received from your number (the number, the time, and the message). We do not keep the text of replies other than keywords such as STOP, START, and HELP.
• Date of birth, used to verify minimum age, to require parental or guardian permission where needed, and to confirm a teen's identity when they take over a profile from a parent or guardian. If your clinic record has no date of birth, the one you enter in the app is added to it.
• For practice patients, additional contact and demographic details entered by the practice: gender, mailing address and postal/ZIP code, phone number type, and, for a minor, the name of the responsible parent or guardian
• Consent records: when you accepted the current Terms of Service and Privacy Policy and, for independent patients, parents and guardians, and independent doctors, when they gave their consent or confirmation at sign-up
• Authentication credentials, managed by Auth0 (an Okta company). BioLign does not see or store your password.

Patient Treatment Data BioLign Track BioLign Cloud

• Current tray number, total trays per arch (upper / lower), days per tray, and daily wear target
• Treatment start date, estimated end date, and treatment status (active, pending, complete)
• Bout history (multiple treatment phases over time)
• Daily wear time logs (time worn per day, with timestamps)
• Wear sessions (start and stop times when actively tracking)
• Tray change history (dates, which arch changed, fit status, clinical notes)
• Computed treatment compliance metrics (total compliance, 7-day rolling average, streaks). Streaks and milestone badges shown to patients are calculated from your wear logs.
• Daily journal notes and photos you add in the app. For a child, notes and photos may also be added by a parent or guardian, and the provider sees which parent added them.
• Your device time zone, stored to anchor wear-time calculations correctly

Clinical and Health Data BioLign Cloud BioLign3D

• Medical alerts and clinical notes recorded by your provider
• Treatment photos uploaded by your provider (extraoral, intraoral, and X-ray) or by you in the app (for example, smile and with-aligner photos)
• 3D dental models and scans (such as STL meshes), tooth segmentation data, and treatment-plan state used for treatment planning in BioLign3D and BioLign Cloud
• CBCT (3D X-ray) imaging studies uploaded by your provider
• Prescriptions, treatment plans, case records, staged aligner models, and fabrication orders
• Documents, form responses, and treatment contracts and payment plans that your practice records
• Insurance and billing information, when applicable (BioLign Cloud only; not collected by BioLign Track). This can include the insurance subscriber's name, date of birth, and relationship to the patient, and policy, certificate, and group numbers.

Communication Data

• Doctor-patient messages (text content, attached photos, timestamps), including messages a practice sends to many patients at once
• Consultation requests you send to doctors from the Discover directory, including your message. When a doctor accepts, we create a connection between you and that doctor so you can message each other, which copies your name and email into that connection.
• Appointment bookings, requests, reschedules, and notes
• Emails your practice sends you through BioLign Cloud, such as reminders to wear your aligners and practice newsletters
• Support requests you send us

Community / Discover Content BioLign Track

If you choose to use the in-app Discover feed:

• Posts, comments, and likes you create. Posts and comments are visible to other signed-in users under the name on your account. For likes, only the total count is shown.
• If you turn on treatment context for a post, it shows your aligner progress (for example, "Aligner 5 of 12" and how long you have been in treatment) and the name of your practice.
• If you post anonymously, your name is hidden on that post. It still shows whether you are a patient or a doctor and any treatment context you chose to share. Comments are never anonymous, including comments you write on your own anonymous post. BioLign keeps the link between the post and your account.
• Photos you attach to posts (up to 10 per post)
• Before/after case studies published by doctors. A doctor must confirm they have the patient's consent before uploading each one.
• Reports you file against other users' content, including the reason category and any free-text explanation
• When someone comments on your post, you are notified with their name and a short excerpt of the comment.

Doctor Public Profile Data BioLign Track

If you are a doctor who opts into the public directory:

• Display name, practice name, specialties, bio, and a verified badge where BioLign has verified the profile
• Profile and cover photos (uploaded by you)
• Gallery and case study images you choose to publish
• Practice location: the city, province/state, and country you choose, and the coordinates of that city's center. These coordinates power patient "Near Me" searches; your practice's street address is not used.

Location Data BioLign Track

• When you use "Near Me" in the doctor directory and allow location access, the app reads your device's current location and sends the coordinates to BioLign with that search, and with later directory searches while "Near Me" stays on. We use them to sort doctors by distance and do not save them to your account, but they are recorded in our server request logs along with other request details (see "Device and Technical Data").
• To show the name of the city near you, the app also passes your coordinates to your device's built-in map service (Apple on iOS, Google on Android).
• Alternatively, you may search by city; in that case, only what you type and the city you select are sent.
• Location access is foreground-only and opt-in. The app does not track your location in the background. If you deny the permission, the app falls back to manual city search.

App Lock

• BioLign Track locks itself after 15 minutes of inactivity, or after 15 minutes in the background, and requires Face ID, Touch ID, or your device passcode to resume. If your device has no passcode set, you are signed out instead. The biometric check is performed by your operating system on your device; its result only unlocks the app and is never sent to BioLign or Auth0. Your biometric data (face or fingerprint templates) never leaves your device.

Practice Information BioLign Cloud

• Practice name, phone number, email, address, contact person, and time zone
• Office hours, holidays, chairs and rooms, and scheduling preferences
• Staff profiles, roles, and permissions
• Staff attendance and timesheet records, including edits and the reason given, where the practice uses those features
• Which staff member delivered a patient's aligners, shown to the practice's doctors
• Fabrication orders and lab coordination data
• For practices that collect patient payments through BioLign Cloud, the practice's connected Stripe account

Device and Technical Data

• Device push notification token and your device platform (iOS or Android), used to deliver notifications
• On iOS, if you use Live Activities: a Live Activity token, your time zone, and your current wear timer state, used to keep the lock-screen timer up to date
• Notification preferences (per-category enable / disable settings)
• Home-screen widget and Live Activities: if you use them, your wear timer, today's wear total, goal progress, streak, and aligner numbers are stored on your device and shown on your home or lock screen, where anyone who can see your screen can see them, even while the app is locked. The widget's start and stop button works without opening the app.
• Calendar: when you choose to add tray changes or appointments to your calendar, the app creates those events and later updates or removes the appointment events it created if the appointment changes. It does not read your other calendar events.
• Camera and photo library access, used only when you take or pick a photo (treatment and journal photos, chat attachments, Discover posts, and doctor profile photos)
• Wear changes made while offline are kept on your device until they sync.
• Server request logs and performance monitoring (Microsoft Application Insights) record request details, including your IP address, your app or browser's user agent, and the address of each request. Request addresses can include record identifiers and text typed into search boxes (for example, a patient name searched by clinic staff, or "Near Me" coordinates). Our logs are set to hide passwords, sign-in tokens, emails, phone numbers, and dates of birth inside log messages.
• For our website, our hosting providers keep server logs that may include your IP address and basic request information (see "Cookies and Website Analytics" below)

2. How We Use Your Information

We use the information we collect to:

• Provide treatment tracking and compliance monitoring for aligner patients
• Enable communication between patients and their orthodontic providers
• Facilitate appointment scheduling and reminders
• Send wear time reminders, tray change notifications, and other in-app or push notifications you have enabled
• Keep your wear timer in sync across your devices, using silent background notifications that update the app, widget, and Live Activity
• Let your practice email and message its patients
• Visualize treatment progress for patients and their providers
• Generate and manage 3D treatment plans, scans, staged models, and clinical workflows
• Power the in-app Discover feed and the doctor directory, including "Near Me" search when you have granted location permission
• Allow patient-initiated consultation requests to doctors who have published a public profile (the app gives doctors no way to start contact with patients through the directory)
• Review user reports of community content and take moderation action on posts and comments that violate our policies
• Manage practice operations, patient records, lab coordination, staff scheduling, and attendance
• Process payments and manage billing (BioLign Cloud only), including case fees and, for practices that use it, payments patients make to their practice
• Verify age requirements and require parental or guardian permission where needed
• Authenticate sign-in attempts and maintain session security, including the in-app inactivity lock
• Maintain, secure, troubleshoot, and improve our products, including diagnosing errors and monitoring performance
• Improve the accuracy of our clinical tools, including AI features, using the records of patients who agreed, as described in "Automated Processing and AI" below
• Detect and prevent fraud, abuse, and security incidents
• Provide customer support
• Comply with legal obligations and respond to lawful requests from regulators

BioLign does not use your personal information for advertising, behavioral targeting, or to build advertising profiles. We do not sell your personal information, and we do not share it with third parties for their own marketing.

3. Legal Bases for Processing

Where the European Union or United Kingdom General Data Protection Regulation (GDPR) applies to you, we rely on the following legal bases. This framework also helps explain, for all users, why we process each type of information.

• To provide the Services (accounts, treatment tracking, messaging, scheduling, and support): performance of our contract with you (GDPR Article 6(1)(b)).
• To process health and clinical data to support your care: for special-category health data, the provision of health care under the responsibility of a health professional (Article 9(2)(h)) and, where your provider relies on it, your explicit consent (Article 9(2)(a)). Your provider directs this processing.
• Discover posts, the public doctor directory, "Near Me" location search, and case-study photos: your consent (Article 6(1)(a)), and your explicit consent for any health information you choose to post (Article 9(2)(a)). You can withdraw this consent at any time.
• Security, fraud prevention, content moderation, service improvement, and product reliability: our legitimate interests in operating a safe and functional platform (Article 6(1)(f)). You can object to this processing as described in "Your Rights and Choices."
• Using patients' records to develop and improve our AI features: the patient's explicit consent (Article 9(2)(a)), which they can withdraw at any time.
• Age verification, breach notification, lawful disclosures, and clinical record retention: compliance with a legal obligation (Article 6(1)(c)).

Providing your account and treatment information is necessary to create an account and use the core Services; without it, we cannot provide treatment tracking. Location, calendar, camera, and Discover participation are optional, and the app works without them.

4. How We Share Your Information

With Your Orthodontic Provider

If you are a patient, your treatment data, wear and compliance, tray history, daily journal notes, photos, and messages are shared with the orthodontic provider (doctor or practice) you are linked to. When you link to a provider, the app asks you to confirm before sharing begins. This sharing is essential for your provider to monitor your treatment and communicate with you. A provider can only see data for patients linked to them, with these exceptions:

• If you move from one independent doctor to another in BioLign Track, your new doctor can also see your earlier treatment with your previous doctor, including that doctor's name, your compliance, wear logs, and aligner changes.
• If you later link to a clinic that uses BioLign Cloud, your earlier history in the app from tracking on your own or with an independent doctor (wear, aligner changes, photos, past treatments, and chats with that doctor) is deleted; your Discover conversations are kept. If you leave a clinic and later link to it again, the wear you tracked on your own in between is added to your clinic record.
• An independent doctor who joins a clinic that uses BioLign Cloud can move their BioLign Track patients and those patients' records into that clinic's account.

Within a Practice BioLign Cloud

Staff at your practice can access your patient record according to their role. Staff assigned to one practice see that practice's patients; staff with organization-wide roles see patients at every practice in the organization. Clinical staff can also use BioLign Track with the same sign-in to view and message their patients. A practice's records are not visible to other organizations unless the practice refers a case to them (for example, for aligner fabrication).

Clinic-to-Lab Coordination BioLign Cloud BioLign3D

When a practice orders aligners through BioLign Cloud, the case goes to the BioLign lab, operated by Smile Elements Orthodontics. The lab receives the patient's 3D scans and treatment models, clinical photos, the prescription and clinical instructions, due dates, the referring doctor's name, and the patient's chart details (such as name, contact details, date of birth, address, and parent or guardian name). Medical alerts and insurance details are not shared with the lab. The lab uses the case to plan and produce the aligners, and, if the patient agreed, the case may also be used to improve our tools as described in "Automated Processing and AI."

Publicly in the Discover Feed and Doctor Directory BioLign Track

If you post in the Discover feed, your posts and comments are visible to all signed-in BioLign Track users, and your likes add to the count shown on a post. Anonymous posting hides your name on the post but not its content (see "Community / Discover Content" above). If you publish a doctor public profile, the information in it (including city-level location, specialties, bio, and gallery) is visible to all users browsing the directory.

You can delete your own posts and comments at any time. A post or comment you delete is hidden from everyone and stays in our database until your account is deleted. Deleting your account permanently deletes your posts, comments, and likes from our database; if your account has a 30-day recovery window, your posts stay visible during that window. Photo files attached to Discover posts and doctor profiles currently remain in our private file storage after the post, profile, or account is deleted.

Service Providers Who Process Data for Us

We use the following service providers to operate our platform. They process data on our behalf under written contracts that require them to protect your information and use it only to provide services to us. We remain accountable for personal information handled by our service providers.

• Auth0 (an Okta company): sign-in, identity management, credential storage, and sign-in logs
• Microsoft Azure (Canada Central region): application hosting, databases (Azure SQL Database), file storage for photos, 3D models, scans, and documents (Azure Blob Storage), CBCT imaging storage (Azure Health Data Services), and performance monitoring and error diagnostics (Application Insights). The BioLign Cloud web app's code is served from Azure Static Web Apps in the United States; no patient data is stored there.
• Azure Communication Services: email delivery (app invitations, sign-in links, staff invitations, case review notices, invoices, support confirmations, and emails practices send their patients)
• Stripe: payment processing (BioLign Cloud only), including case fees and, for practices that use it, patient payments through the practice's own Stripe account. Stripe receives the payer's card details, names and emails, practice names, and internal record numbers attached to payments, and sends its own payment receipts. BioLign does not store full card numbers; Stripe handles card data under PCI DSS.
• Infobip: delivery of text messages (SMS) that practices send through BioLign Cloud, and of replies such as STOP. Infobip receives the patient's phone number and the message text. Texts never include health details.
• Expo Push Service, Apple Push Notification service, and Google Firebase Cloud Messaging: delivery of mobile push notifications. Live Activity updates are sent directly to Apple. Notification text is kept general, though some notifications include aligner numbers or the name of the lab.
• Apple and Google device map services: turning "Near Me" coordinates into a nearby city name, on your device
• jsDelivr: the in-app 3D model viewer loads its display code from jsDelivr's network, which receives your device's IP address

City search uses a bundled worldwide city and geography reference dataset on our servers. Independent doctors can add a booking link (such as Calendly) and a review link to their practice settings, which are shown to their own patients; if you follow such a link, you leave BioLign and the third party's own terms and privacy policy apply. BioLign does not use Google Analytics, Firebase Analytics, Facebook SDKs, or any advertising network in our mobile apps; Firebase is used only to deliver push notifications on Android.

Platform Administration

A small number of authorized BioLign personnel have administrator access across organizations. It lets them view and manage organizations, practices, staff accounts, and patient records, set up new practices and upload their records, and manage pricing and support tickets. We use this access to operate the service, provide support, investigate security or billing issues, and onboard new practices, subject to our confidentiality and security obligations.

Legal Disclosure

We may disclose personal information when required to do so by law, court order, or government request, or when we believe in good faith that disclosure is necessary to protect our rights, the safety of our users, or to investigate fraud or security incidents. Where permitted by law, we will notify you before complying with such a request.

What We Do Not Do

• We do not sell your personal information to third parties
• We do not use your data for advertising or marketing profiling
• We do not share your data with third parties for their own marketing purposes
• We do not transmit biometric data (Face ID, Touch ID, fingerprint templates) off your device

5. Automated Processing and Artificial Intelligence

BioLign uses software, including artificial intelligence, to assist clinical work. We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing, without human involvement.

• 3D treatment planning (BioLign3D): AI helps generate proposed tooth segmentation and treatment-planning options. The AI analysis of your 3D scans runs on the clinician's own device, not on an outside AI service. When the practice provides a CBCT (3D x-ray), AI on the clinician's device also uses it to build the tooth roots. Every proposed plan is reviewed, adjusted, and approved by a qualified clinician, who makes all treatment decisions.
• Compliance metrics (BioLign Track): we calculate wear-time summaries, streaks, and milestone badges from the wear data you log. These are standard calculations, not AI.
• Content moderation (Discover): we do not use automated moderation tools. Reported content is reviewed by people.
• Improving our clinical tools: we use a patient's records to develop and improve our AI features only when the patient, or their parent or guardian, has agreed. Today this means the tooth segmentation of their case: the 3D shape of their teeth from their intraoral scans and the tooth labels added in BioLign3D, which are exported from BioLign3D to a separate training dataset. With consent, other records the patient agreed to, such as x-rays and CBCT images, may also be used. The exported files do not contain the patient's name or other details, and each case is stored under a case number. We keep a separate record linking that number to the patient's chart so we can remove the case if consent is withdrawn, so the data is not anonymous. The dataset is stored in Microsoft Azure in Canada. This use stays within BioLign Ltd. and our service providers; we never sell this data or use it to train models for unrelated third parties. You or your provider can withdraw consent or ask us to remove a case at any time by contacting us, and we remove it within 30 days.

You can ask us what information was used in an automated process that you believe affected you, and you can raise concerns with your provider or our Privacy Officer and request human review.

6. Data Storage and Security

We take the security of your data seriously and implement multiple layers of protection:

• Encryption in transit: data between the apps and our servers is sent over TLS (HTTPS), and our file storage accepts only HTTPS connections.
• Encryption at rest: our databases (Transparent Data Encryption) and file storage are encrypted at rest using Microsoft Azure's managed encryption.
• Data residency: our production databases, file storage, and CBCT imaging service are hosted in the Microsoft Azure Canada Central region.
• Secure token storage: on mobile devices, sign-in tokens are stored in the iOS Keychain or the Android Keystore. The BioLign Cloud web app keeps sign-in tokens in browser memory rather than browser storage; Auth0 uses its own sign-in cookie so you stay signed in when you reload the page.
• Biometric data: Face ID, Touch ID, and fingerprint data never leave your device. The check is performed by your operating system, and its result only unlocks the app on your device.
• Private file storage: treatment photos, 3D models, and gallery images are kept in private storage with public access turned off, and are served only through signed links that expire within about an hour.
• Role-based access controls: patients see only their own data; practice staff access is based on their role and practice (see "Within a Practice").
• Organization isolation: each organization's data is logically separated so it cannot be accessed by other organizations unless a case is referred to them.
• In-app session lock: BioLign Track locks after 15 minutes of inactivity and requires Face ID, Touch ID, or your device passcode to resume.
• Session limits: BioLign Track requires you to sign in again 90 days after you last signed in, or after 30 days without opening the app.
• Activity records: we keep records of who completed each fabrication step, aligner-position adjustments made by providers, staff timesheet edits, referral decisions, acceptance of our pricing terms, and payment events. Sign-in events are logged by Auth0.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. We work continually to protect your information and to improve our safeguards.

7. Data Breach Notification

If a security breach affects your personal information and creates a real risk of significant harm, we will act without unreasonable delay to investigate, contain, and remediate it, and we will notify you and the relevant authorities as required by law. In particular:

• Canada: we will report qualifying breaches to the Office of the Privacy Commissioner of Canada and, where applicable, the Office of the Information and Privacy Commissioner of Alberta and your provincial regulator, notify affected individuals, and keep records of breaches as required by PIPEDA and provincial law.
• Health-provider context: where we hold information on behalf of a healthcare provider, we will notify that provider without unreasonable delay so they can meet their own obligations, including, for US providers covered by HIPAA, notification no later than 60 days after discovery.
• Where you use BioLign without a covered healthcare provider, or where other law requires it, we will notify affected individuals and regulators directly within the timeframes those laws require, including under the US Federal Trade Commission's Health Breach Notification Rule and applicable state breach-notification laws.
• EU / UK: where GDPR applies, we will notify the competent supervisory authority within 72 hours where required, and affected individuals without undue delay where the breach is likely to result in a high risk to their rights.

8. Your Rights and Choices

Account Deletion

Patients, parents and guardians, and independent doctors can delete their account at any time in BioLign Track: go to Profile and select "Delete Account."

• Independent accounts (patients tracking on their own or with an independent doctor, parents and guardians, and independent doctors): your account and personal data are hidden from the app right away and kept for a 30-day recovery window, so an accidental deletion can be undone. Signing back in within those 30 days lets you restore your data (treatment tracking, wear logs, messages, your doctor connection, and your Discover posts, comments, and likes) or start fresh and erase it right away. If you take no action, after 30 days your personal data and your sign-in account are permanently deleted and your email becomes available again for re-registration. Your records with an independent doctor are deleted with your account; independent doctors do not keep a separate copy.
• Clinic patients: if your account is linked only to a clinic that uses BioLign Cloud, deletion takes effect right away, with no recovery window. Your sign-in, Discover activity, journal notes, and your message threads with the clinic are deleted immediately. The clinical records your clinic created about your care (which may include your treatment chart, scans, photos, notes, and appointments) remain part of that clinic's own records and are retained by the clinic in accordance with applicable medical record-keeping laws (see "Patient Data Ownership" in our Terms).
• Parents and guardians: deleting a parent or guardian account also deletes, on the same 30-day schedule, the children that account alone manages who have no sign-in of their own, and restores them if the account is recovered. Children who are clinic patients stay with their clinic. A parent or guardian who removes a child directly from the app deletes that child's data right away.
• Teens who took over their profile: if a parent or guardian still manages your profile, deleting your account removes your sign-in and returns the profile to them.
• BioLign Cloud: staff accounts are managed by your practice. Staff with permission to manage users can delete a staff account, which takes effect immediately. To close a practice account, contact us at biolign@smileelements.ca.

Residual copies may persist in database backups and in logs for a limited period after deletion before being overwritten or purged.

Leave Your Provider

In BioLign Track, you can leave your provider at any time from your Profile settings. If you are a clinic patient, "Leave Practice" leaves every clinic you are linked to at once; your tracking history stays on the clinic's side as part of its records, your future logs stop being shared with it, and you can keep using BioLign Track on your own. If you leave an independent doctor, that doctor loses access to your data and your history stays with you.

If Your Provider Removes You

A doctor or practice can remove you from their patient list. This is an unlink, not a deletion of your account: your BioLign Track account and your personal progress (wear history, streak, and milestone badges) are kept, and you can continue tracking on your own, set up your own treatment plan, or connect with a new provider whenever you are ready. If a clinic removes you, it keeps the clinical records it created during your care, in accordance with applicable medical record-keeping laws, and a copy of your plan and wear history from that clinic is kept for you in the app. If an independent doctor removes you, they lose access to your data, including notes they wrote. Only you can permanently delete your account and personal data (see Account Deletion above).

Export Your Data

Patients, parents and guardians, independent doctors, and clinic staff can export their personal data from the Profile screen in BioLign Track. The export is a JSON file you can save, share, or transmit to another organization, supporting your right of access and data portability.

• For patients, the export includes account information, every treatment record, all wear logs, tray changes, wear sessions, bout history, journal notes, clinical notes recorded about you, medical alerts, appointments, documents, all messages, consultation requests you sent, notification preferences, your Terms and Privacy Policy acceptance, and your Discover activity (posts, comments, likes, and reports). Photos and 3D models are listed by file reference; to receive copies of the files themselves, contact us. A guardian's export includes the data of each child they manage.
• For independent doctors, the export includes account information, professional profile, practice details, the list of your patient relationships, invitations you sent, messages you authored, your public doctor profile (if any), consultation requests you received, and your Discover activity.
• For clinic staff, the export includes your account and staff profile details and the messages you wrote.
• Device push notification tokens are intentionally excluded to prevent credential leakage if the file is mishandled.

Manage Your Community Content

• You can edit or delete your own posts, and delete your own comments, in the Discover feed at any time, including posts made anonymously.
• You can report another user's post or comment for review: use the report option on a post, or press and hold a comment.
• Doctors can turn off their public profile at any time from the in-app profile setup screen, or delete it from the directory.

Notification, Location, and Calendar Controls

You can control which notifications you receive through the app's notification settings, and you can revoke notification, location, or calendar permission entirely through your device settings at any time without affecting your ability to use the rest of the app.

Access, Correction, and How to Exercise Your Rights

You can view and update some of your personal information directly in your profile; details in a clinic record are managed by your clinic. Depending on where you live, you may also have the right to access, correct, delete, restrict, or object to our processing of your personal information, to withdraw consent, and to data portability. To make a request, email us at biolign@smileelements.ca. We will respond within the time required by the law that applies to you (generally 30 days in Canada and for access requests, and one month under GDPR, each extendable with notice for complex requests), at little or no cost. If we cannot fulfill a request, we will explain why. We may need to verify your identity before acting. You will not be treated differently for exercising your rights.

For records your orthodontic provider created or controls, requests to access or amend that information are fulfilled by your provider; contact your provider directly, or contact us and we will route your request to them as required by our agreements.

Withdraw Consent

You can withdraw consent for the sharing of treatment data with your provider at any time by leaving the practice or deleting your account. Withdrawing consent does not affect the lawfulness of processing that occurred before your withdrawal, and some processing may continue where the law requires it (for example, records kept for legal reasons and clinical records held by your provider).

9. Raising a Concern or Complaint

If you believe we have not handled your personal information properly, please contact our Privacy Officer first at biolign@smileelements.ca. We will acknowledge your concern, investigate it, respond to you, and tell you what we have done to resolve it.

If you are not satisfied, you may escalate to your regulator, including the Office of the Privacy Commissioner of Canada, the Office of the Information and Privacy Commissioner of Alberta, the Commission d'acces a l'information du Quebec, your provincial health-information regulator, the US Department of Health and Human Services Office for Civil Rights, your US state attorney general, or your supervisory authority in the EU or UK.

10. Data Retention

We keep personal information only as long as needed for the purposes described in this policy, or as required by law. In practice:

• Account and treatment data: retained while your account is active, and deleted as described in "Account Deletion" above.
• Backups: our database provider keeps automatic backups for a limited period, after which deleted data is no longer recoverable.
• Discover content: a post or comment you delete is hidden and kept in our database until your account is deleted; on account deletion your posts, comments, and likes are permanently deleted from our database. Photo files from Discover posts and doctor profiles currently remain in our private file storage.
• "Near Me" location coordinates: not saved to your account; they remain in our server request logs for as long as those logs are kept.
• Server logs and diagnostics: kept for a limited period for security and troubleshooting.
• Invoice records: kept indefinitely for accounting and tax purposes. Other billing and security records are kept as long as required for accounting, tax, and legal compliance.
• AI training dataset: kept until consent is withdrawn or you or your provider ask us to remove a case. We remove it within 30 days of the request.
• Clinical records held by your provider: retained by the practice for the minimum period required by the applicable medical-records law. For example, in Alberta this is commonly at least 10 years for adults, and for a minor at least 10 years past the age of majority.

11. Communications and Your Consent

We send service emails and notifications needed to operate the Services, such as app invitations, sign-in links, case and fabrication updates, invoices, support confirmations, and push notifications about your treatment and appointments. These are part of providing the Services. Password-reset emails you request yourself are sent by Auth0.

We do not currently send promotional or newsletter emails of our own. If we start, we will send them only with your consent where the law requires it, and every such message will identify BioLign Ltd., include our contact information, and provide an easy way to unsubscribe, consistent with Canada's Anti-Spam Legislation (CASL).

Practices that use BioLign Cloud can email their patients through BioLign, including reminders to wear aligners and practice newsletters, and can send in-app messages to many patients at once. These messages come from your practice and say so; your practice decides what it sends. To stop receiving them, contact your practice.

Practices that use BioLign Cloud can also send text messages from the practice's own number to patients who agreed to receive them, about their appointments and their account, such as appointment reminders, invitations to BioLign Track, and alerts that the practice sent them a message in the app. Text messages are separate from messaging in BioLign Track. Your practice texts you only if you agreed, and records that on your file. Texts never include health details or advertising. Message frequency varies. Message and data rates may apply. Reply STOP to any text to stop texts from that practice, START to turn them back on, or HELP for the practice's contact information. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging opt-in data and consent are not shared with any third parties, except the providers that deliver the texts.

You can control in-app and push notifications by category in the app or through your device settings.

12. Cookies and Website Analytics

Our website (biolign.ca) is hosted on Elementor Cloud and served through Cloudflare. It does not use analytics or advertising cookies. Cloudflare sets a short-lived security cookie to filter automated bot traffic. Pages load fonts from Google Fonts, which receives your IP address. If you use our contact form, what you enter (such as your name, email, company, role, and message) is sent to Web3Forms, which delivers it to us by email. We do not use the website to build advertising profiles or to sell or share your information for cross-context behavioral advertising. You can control cookies through your browser settings. If we add website analytics in the future, we will update this section and obtain consent where the law requires it.

The BioLign Cloud web app uses Auth0's sign-in cookie and Microsoft Application Insights cookies to measure performance and diagnose errors. These are not used for advertising.

Our mobile apps do not use cookies, advertising trackers, or third-party analytics SDKs.

13. Children's Privacy

BioLign Track uses the date of birth provided at sign-up to enforce minimum age requirements:

• We do not allow children under 13 to create their own account; every self-sign-up path checks the date of birth. If we learn that we have collected personal information directly from a child under 13 without the required consent, we delete it promptly.
• A child under 13 can participate only through a parent or guardian account, where the parent or guardian holds the account and provides consent. Children managed this way do not sign in themselves until they take over their own profile, as described below.
• A parent or guardian can invite another adult to help manage a child's profile using a family code that is valid for 72 hours. Each adult who joins has full access to the child's profile.
• Users aged 13 to 17 must give a parent or guardian's email and confirm that they have their parent or guardian's permission to create the account and share their health information. Parents and guardians must be at least 18.
• Taking over a guardian-managed profile: once a child managed under a guardian account turns 13, their parent or guardian may generate a one-time transfer code that lets the child create their own sign-in and take over their profile. Generating the code is how the parent or guardian consents to the takeover. All existing treatment history stays on the profile. The parents or guardians who managed the profile keep their access after the takeover until that access is removed, either by themselves or by the profile's new owner from their Profile screen. The child reviews and accepts the Terms of Service and this Privacy Policy for themselves when taking over, and the date of birth they provide is checked against the profile to verify the takeover.
• We do not serve targeted advertising to, or sell or share the personal data of, any user we know to be a minor. If a minor uses "Near Me", their location is handled as described in "Location Data."
• Aligner treatment is a clinical decision; minors should always use BioLign Track in coordination with their orthodontic provider and a parent or guardian.

BioLign Cloud and BioLign3D are intended for orthodontic professionals and are not intended for use by children. If you are a parent or guardian and believe your child has provided us with personal information without your consent, contact us at biolign@smileelements.ca and we will delete the account and associated data promptly.

14. Healthcare Privacy by Region

Because BioLign products handle health-related information, additional protections apply depending on where you live and where your provider practices. This Privacy Policy is not a substitute for, and is not, your provider's own Notice of Privacy Practices; your orthodontic provider is responsible for providing you with its own notice describing how it uses and discloses your health information.

• Canada: we are committed to complying with the Personal Information Protection and Electronic Documents Act (PIPEDA), Alberta's Personal Information Protection Act (PIPA), Quebec's Law 25, and applicable provincial health-information statutes such as Alberta's Health Information Act (HIA) and Ontario's Personal Health Information Protection Act (PHIPA). Where your provider is a health information custodian, BioLign acts as that custodian's service provider, agent, or information manager and processes patient health information only on the custodian's instructions and under our Terms of Service. Under Quebec's Law 25, our Privacy Officer is the person in charge of the protection of personal information, including keeping a register of confidentiality incidents and assessing privacy risks before personal information is transferred outside Quebec.
• United States (HIPAA): when BioLign processes Protected Health Information on behalf of an orthodontic provider that is a HIPAA-covered entity, we act as a Business Associate under HIPAA and the HITECH Act, subject to a Business Associate Agreement with the provider. Our safeguards include encryption in transit and at rest, role-based access controls, records of key clinical and fabrication actions, and an automatic lock in the mobile app. Practices and covered providers can request our Business Associate Agreement before transmitting Protected Health Information.
• When HIPAA does not apply: if you use BioLign Track on your own, or with a provider who is not a HIPAA-covered entity, HIPAA may not govern that information. In those cases we protect your health information under the US Federal Trade Commission's Health Breach Notification Rule and applicable state consumer-health-privacy laws, and we honor the consumer-health rights described below regardless of whether HIPAA applies.
• European Economic Area / United Kingdom: where GDPR or UK GDPR applies, BioLign acts as a processor on behalf of your provider (the controller) for provider-managed health data, and as a controller for the Discover feed, the doctor directory, "Near Me" search, independent accounts, the website, and account, billing, and product-improvement data. Health data is treated as special-category personal data under Article 9 and is processed only with explicit consent or where another lawful basis applies. Practices and providers can request a data processing agreement under Article 28.

Under these laws you may have the right to know what personal information we hold, to access and obtain a copy of it, to request correction or deletion (subject to legal or clinical retention requirements), to withdraw consent, to restrict or object to certain processing, to data portability, and to file a complaint with your regulator (see "Raising a Concern or Complaint").

15. Consumer Health Data (Washington, Nevada, Connecticut)

This section applies to "consumer health data" as defined by the Washington My Health My Data Act, Nevada SB370, and Connecticut's health-data provisions. The categories of consumer health data we may collect include your treatment status and history, aligner wear and compliance data, journal notes, clinical notes and photos, and, only when you choose to search for nearby providers, location data you provide for that search. We collect this data from you, your provider, and your use of the app, and we use and share it only as described in this policy, including with your linked provider, the BioLign lab for fabrication, and the service providers listed above.

• We do not sell consumer health data.
• Where these laws require it, we collect and share consumer health data only with your consent, which you can withdraw at any time, and you can request deletion of your consumer health data.
• No geofencing: we do not establish geofences around any healthcare facility, dental or orthodontic office, or other location to identify or track consumers, to collect their data, or to send them messages or advertising based on their proximity to such a place. Device location is used only for "Near Me" searches you choose to run, to calculate distance to listed doctors, and is not used to detect your presence at any clinic.

To exercise these rights or ask a question about your consumer health data, contact us at biolign@smileelements.ca.

16. California Privacy Rights

This section provides information required by the California Consumer Privacy Act, as amended (CCPA/CPRA). In the past 12 months we have collected the following categories of personal information: identifiers (such as name, email, phone, IP address, and account identifiers); customer records (such as contact and demographic details); characteristics like age; commercial and billing information; internet and app activity; precise geolocation (only for "Near Me" search); audio, visual, or similar information (such as treatment photos); professional information (for doctors and staff); and medical and health information. We collect this information from you, your provider, and your use of the Services, and we use and disclose it for the business purposes described in this policy. Health information and precise geolocation are treated as sensitive personal information.

We do not sell or share (as those terms are defined under the CCPA) your personal information, and we do not use or disclose your sensitive personal information for purposes that would require us to offer a "Limit the Use of My Sensitive Personal Information" option. We do not use your information for cross-context behavioral advertising.

If you are a California resident, you have the right to know and access the personal information we hold about you, to request correction, to request deletion, and to not be discriminated against for exercising your rights. To exercise these rights, email biolign@smileelements.ca or call 1-825-779-5484; we will respond within 45 days (extendable with notice). You may use an authorized agent to submit a request, and we may verify your identity and the agent's authority. Note that health information we hold as a Business Associate under HIPAA, and certain medical information, are handled under those laws rather than the CCPA.

17. Other US State Privacy Rights

If you are a resident of a US state with a comprehensive privacy law (such as Virginia, Colorado, Connecticut, Texas, Utah, Oregon, or Montana), you may have rights to access, correct, delete, and obtain a portable copy of your personal data, and to opt out of targeted advertising, the sale of personal data, and certain profiling. Because we do not sell personal data, do not use it for targeted advertising, and do not engage in that kind of profiling, browser opt-out preference signals such as Global Privacy Control do not change how we process your data, and we honor such signals where they apply. We process sensitive data, including health data, with the consent these laws require.

To exercise these rights, email biolign@smileelements.ca. If we deny your request, you may appeal by replying to our decision; we will respond within the time your state law allows and tell you how to contact your state attorney general if you remain dissatisfied.

18. Cross-Border Data Transfers

BioLign's production databases, file storage, and application servers are hosted in the Microsoft Azure Canada Central region. Some service providers process data outside Canada, mainly in the United States: Auth0 (sign-in), Stripe (payments), Expo, Apple, and Google (push notifications and device map services), Microsoft's email delivery service (a global service) and the host of the BioLign Cloud web app's code (no patient data), and jsDelivr (3D viewer code). Infobip, which delivers text messages, may process phone numbers and message text outside Canada. For our website, Elementor Cloud, Cloudflare, Google Fonts, and Web3Forms may also process your information outside Canada. When personal information is transferred across borders, we rely on these providers' contractual commitments to protect it, including standards comparable to PIPEDA and, where applicable, GDPR Standard Contractual Clauses or a recipient's certification under a recognized transfer framework. Information processed in another country may be accessible to that country's courts, law enforcement, and national security authorities. You can request more information about these safeguards by contacting our Privacy Officer.

19. Changes to This Policy

We may update this Privacy Policy from time to time. When we make significant changes, we will notify you through the app or by email. Where a change materially affects how we handle your health information in a way that relies on your consent, we will seek your renewed consent before that change applies to you. Your continued use of BioLign products after other changes are posted constitutes your acceptance of the updated policy.

20. Contact Us and Privacy Officer

BioLign is made by BioLign Ltd., based in Calgary, Alberta, Canada. We have designated a Privacy Officer who is accountable for our compliance with this policy and with applicable privacy laws. You can contact the Privacy Officer with any question, access request, correction, or complaint, including questions about how your information is handled outside your country:

• Privacy Officer, BioLign Ltd.
• Email: biolign@smileelements.ca
• Phone: 1-825-779-5484
• Mail: #250, 15 Royal Vista Place NW, Calgary, AB T3R 0P3, Canada