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Privacy policy

Draft under legal review. This text is a draft prepared for our counsel's review and is not yet in force. Text in square brackets will be completed in the final version.

Last updated: [EFFECTIVE DATE]

This policy explains how Dente AI processes personal data: what data, for what purposes, on which legal basis, who we share it with, how long we keep it and how you can exercise your rights. It follows Brazil's General Data Protection Law (Law 13,709/2018, LGPD), the EU General Data Protection Regulation (GDPR) where it applies, and US state privacy laws where they apply.

Who we are

Dente AI is operated by [LEGAL NAME], registered under [REGISTRATION NUMBER (CNPJ)], with its registered office at [ADDRESS] ("Dente AI", "we", "us").

Data protection officer (encarregado): [DPO NAME], [DPO EMAIL].

General contact: [CONTACT EMAIL].

[EU representative (GDPR art. 27), if required: NAME AND ADDRESS.]

What Dente AI does

Dente AI is an AI employee for clinics, starting with dental clinics. On the clinic's behalf, the AI answers patients on WhatsApp, in the chat on the clinic's website and, where purchased, on the phone; books and reminds appointments; and helps the clinic's team through an internal chat (the "assistant"). The AI learns about the clinic from its public website, files uploaded to it and the owner's answers. We also offer a public demo on our website.

Two different roles

Patient data: the clinic is the controller and Dente AI is the processor. We process messages, appointments, contacts and other patient data only to provide the service to the clinic and on its instructions. The clinic decides the purpose, the legal basis and the privacy notice given to its patients. If you are a clinic's patient, read the clinic's privacy notice and send your requests to the clinic; if a request reaches us, we forward it to the clinic (see "Your rights"). The rules for this processing are in the Data Processing Addendum attached to the Terms of service.

Data of clinic users, billing data and data of visitors to our website and the demo: Dente AI is the controller. This policy deals mainly with that data and, for transparency, also describes what we process as a processor.

Data we process as controller

Account and use of the app

  • Name, email, language, role in the clinic (owner, admin, staff or viewer) and, if you use it, Google sign-in.
  • Credentials: password (stored only as a hash by our authentication provider), sign-in codes sent by email and two-step authentication factors.
  • Audit records of significant actions (who did what and when), and technical and security logs.
  • What you write or say to the assistant. For voice conversations we keep the text transcript; we do not keep the audio.
  • Preferences (language, theme, call sounds) and notifications.

Billing

  • The clinic's billing details: name, billing email and address, tax ID (CNPJ, VAT number and similar), plan, subscription status, invoices and usage.
  • Card and other payment method details are collected and stored by Stripe, our payment processor; we do not receive them.
  • Promotion codes and, when the clinic arrives through a partner, the partner's (affiliate's) code and where the visit came from (UTM parameters).

Affiliates

  • Name, contact email, code, commission percentage and the monthly commission report (with invoice identifiers, no patient data).

Public demo

  • The website address entered, the language, where the visit came from (partner, promotion code, UTM), a one-way hash (HMAC) of the IP address, the browser (user agent, up to 200 characters), when you accepted the demo terms and, if you give it, your email.
  • The public content read from the website, a screenshot of its home page and a brand preview (title, logo, image and color).
  • The demo conversation, by text and by voice (voice is transcribed to text; we do not keep the audio), and a contact card the AI builds from what is said in the conversation (name, phone, interest, preference), only to show the feature.
  • Details in the Demo terms.

Visitors to our website

  • Cookies and local storage described in the Cookie notice.
  • The anti-bot check (Cloudflare Turnstile) on the demo and sign-in forms.
  • Product usage events sent by our servers, without IP address, email or message text.

Contact and support

  • What you send us by email or another support channel.

Data we process as processor, for clinics

  • Patients and contacts: name, phone, email, language, channel identifiers (for example the WhatsApp number), WhatsApp profile photo, tags, staff notes and conversation history.
  • Messages and media exchanged with the clinic, including photos and PDFs the patient sends (for example an insurance card), which the AI may read to answer.
  • Appointments, reminders, confirmations, no-shows and waitlists.
  • Calls answered by the AI: the caller's number and the text transcript. We do not keep the audio.
  • Website chat: a random visitor identifier and a hash (HMAC) of the IP address, used for abuse limits.
  • Health data may appear in conversations (for example symptoms, treatments, insurance). It is sensitive personal data (LGPD art. 11; GDPR art. 9). The AI does not diagnose, and the legal basis for processing it is set by the clinic.
  • The clinic's knowledge: website pages, files, the owner's answers and the version history.

Purposes and legal bases

As controller:

  • To create and maintain your account, provide the service purchased and give support: performance of a contract (LGPD art. 7, V; GDPR art. 6(1)(b)).
  • To charge, issue invoices and meet tax and accounting obligations: performance of a contract and compliance with a legal obligation (art. 7, II and V; art. 6(1)(b) and (c)).
  • Security and prevention of fraud and abuse (per-IP limits, anti-bot check, audit records): legitimate interests and compliance with a legal obligation (art. 7, II and IX; art. 6(1)(c) and (f)).
  • To run the demo you asked for: steps taken at your request before entering into a contract, and legitimate interests (art. 7, V and IX; art. 6(1)(b) and (f)).
  • To keep the email you give in the demo and contact you about it: consent (art. 7, I; art. 6(1)(a)), which you may withdraw at any time.
  • To attribute an account to a campaign or partner and pay commissions: legitimate interests and performance of the contract with the partner (art. 7, V and IX; art. 6(1)(b) and (f)). [Review whether the attribution cookie requires consent in the EU.]
  • To measure and improve the product with usage events, without message content: legitimate interests (art. 7, IX; art. 6(1)(f)).
  • Service emails (sign-in codes, alerts, billing notices, reports you ask for): performance of a contract.
  • To establish, exercise or defend legal claims: art. 7, VI; art. 6(1)(f).

Where we rely on legitimate interests, we have assessed that the processing is expected, limited to what is necessary and does not override your rights and freedoms. You may object (see "Your rights").

As processor, we process patient data only to provide the service to the clinic. The clinic chooses the legal basis; for example, for health data, the protection of health in a procedure carried out by health professionals (LGPD art. 11, II, "f").

Artificial intelligence

  • Replies are generated by third-party language models: today, Anthropic's Claude models, accessed through the Vercel AI Gateway, and OpenAI models for voice and audio transcription.
  • The AI says it is an AI, answers from the knowledge the clinic approved and gives no diagnosis or clinical advice. In an emergency it tells the patient to contact emergency services and hands the conversation to the team.
  • The clinic's team can take over any conversation at any time.
  • Website, file and message content is treated as untrusted data: it does not change the AI's rules.
  • We contract with and configure our AI providers so that they do not use our customers' data to train their models, under the terms they offer for commercial API use. [Confirm the no-training and retention terms of Anthropic, the Vercel AI Gateway and OpenAI before publication.]
  • We do not use patient data to train models. [Confirm whether Dente AI will use de-identified conversations to evaluate and improve the AI; if so, describe it here.]
  • Automated decisions: the AI replies and may book, reschedule or cancel appointments within the rules the clinic sets. You may ask for a review of a decision based solely on automated processing (LGPD art. 20; GDPR art. 22); patients should ask the clinic.

Who we share data with

We do not sell personal data and do not use it for advertising.

We share data only with:

  • The clinic, for the data of its patients and its team.
  • The subprocessors below, which provide services to us under contract, with the minimum necessary.
  • Authorities, when the law or a court order requires it.
  • A successor, in a merger, acquisition or sale of assets, with prior notice.

Subprocessors

  • Supabase: database, authentication and file storage. United States (AWS, Virginia, us-east-1).
  • Vercel: hosting of the app and the website, firewall, and the AI Gateway that routes calls to the AI models. United States (region iad1) and global network.
  • Railway: background processes, the voice gateway and the WhatsApp QR connector (OpenWA, run by us). [Region to confirm.]
  • Anthropic: Claude models, which generate replies and read knowledge and files. United States.
  • OpenAI: real-time voice (assistant voice, demo voice, voice in the website chat, phone AI) and audio transcription. United States.
  • Firecrawl: reading the public pages of the clinic's website and the demo screenshot. [Region to confirm.]
  • Stripe: payments, invoices, tax and the billing portal. United States and other countries.
  • Resend: service emails (sign-in codes, alerts, reports). United States.
  • PostHog: feature flags and usage events, sent by our servers without IP address, email or message text. United States.
  • Sentry: error monitoring, configured without user data, cookies, headers or request bodies. [Region to confirm.]
  • Langfuse: records of AI calls, for quality and troubleshooting. European Union.
  • Telnyx: phone numbers and call routing for the phone AI. United States.
  • Cloudflare: anti-bot check (Turnstile) and DNS. Global network.
  • Google: Google sign-in, Google Calendar sync when the clinic connects it, and address suggestions (Google Maps). Global.
  • Bright Data: IP addresses in the clinic's country for the WhatsApp QR connection; it carries the connection's encrypted traffic. [Confirm the technical description.]
  • Expo: push notifications to the mobile app, when used. United States.

WhatsApp (Meta) is not our subprocessor: it is the channel the clinic chooses to use, with its own account and under WhatsApp's terms. The same applies to the clinic's Google Calendar.

International transfers

Several subprocessors are outside Brazil, mainly in the United States, and one is in the European Union. We make these transfers under the standard contractual clauses approved by Brazil's data protection authority, ANPD (Resolution CD/ANPD 19/2024), the European Commission's standard contractual clauses for data of people in the European Union, or another mechanism under LGPD art. 33 and GDPR chapter V. [Confirm the mechanism in place with each subprocessor.]

How long we keep data

  • Account and clinic data: while the account exists. A canceled account keeps its data until the clinic asks for deletion. [Set an automatic deletion period after cancellation.]
  • Billing data and invoices: for the period required by tax and accounting law. [Period to confirm, for example 5 years.]
  • A demo request that does not become an account: deleted after 90 days.
  • An unclaimed demo: deleted after 7 days (or 24 hours if reading the website failed), with its conversation, screenshot and contact card. If you left your email, the request is kept until it is 90 days old.
  • An account created from a demo and never paid for: deleted after 30 days.
  • App notifications: 90 days. Files given to the assistant only to read: 24 hours.
  • Website chat visitor identifier: deleted after 30 days without use (the conversation stays with the clinic).
  • Records of AI calls (Langfuse): [period to confirm].
  • Backups: up to 7 days after deletion.
  • Audit and usage records: while the account exists; when a patient is erased, they lose their reference to that patient.

Security

We isolate each clinic's data in the database (row level security) and on the server; use encryption in transit (TLS) and our providers' encryption at rest; offer two-step authentication; keep secrets in a vault; keep personal data out of technical logs; and keep audit records and backups with point-in-time recovery of up to 7 days. Our team's access to an account for support is view-only, limited to 30 minutes and recorded with its reason. No system is fully secure: if an incident may cause significant risk or harm, we will notify you and the competent authority as the law requires.

Your rights

Under the LGPD (art. 18) you may ask for: confirmation that we process your data; access; correction of incomplete, inaccurate or outdated data; anonymization, blocking or deletion of unnecessary or excessive data or data processed unlawfully; portability; deletion of data processed with your consent; information about who we share it with; information about the possibility of not consenting and its consequences; and withdrawal of consent. You may also object to processing based on another legal basis if it breaches the law, ask for a review of automated decisions (art. 20) and file a complaint with Brazil's National Data Protection Authority (ANPD).

If the GDPR applies to you, you have the rights of access, rectification, erasure, restriction, portability, objection and not to be subject to decisions based solely on automated processing (arts. 15 to 22), and you may lodge a complaint with the data protection authority of your country.

How to exercise them: write to [DPO EMAIL]. We may ask you to confirm your identity. We reply within 15 days (LGPD) or one month (GDPR).

Patients: the clinic is the controller of your data. Send your request to the clinic. If it reaches us, we forward it to the clinic and help the clinic answer it within 5 business days.

Notice for US residents

If a US state privacy law applies to you (for example California's), you may ask to know what personal data we collect and to access, correct and delete it, without discrimination for exercising these rights. We do not sell personal data or share it for cross-context behavioral advertising, and we do not use sensitive data to infer characteristics. The categories, sources, purposes and recipients are in this policy. Send your request to [DPO EMAIL]; you may use an authorized agent. For patient data, the clinic is responsible. [Review how HIPAA applies to US clinics.]

Children

The app and the demo are meant for adults who represent clinics. Patients may be minors; in that case the clinic is responsible for obtaining the consent of a parent or legal guardian where required (LGPD art. 14).

Changes

We may update this policy. We will announce significant changes in the app or by email before they take effect. The date at the top shows the current version.

Contact

Data protection officer: [DPO NAME], [DPO EMAIL]. General: [CONTACT EMAIL]. [LEGAL NAME], [ADDRESS].

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