Your data. Clearly explained.

Controller and contact

1. Scope and responsibilities

This policy covers ImplTrack, ImplTrack Patient, impltrack.at and support. Dr Otis Rezegh is responsible for the website and handling enquiries (contact above). The dental practice or treating organisation is responsible for professional processing of patient information. It determines the purposes, access rights, legal bases and retention periods for its records.

The app provides tools for this documentation. Case files are not sent to a central ImplTrack patient database. The app provider cannot view your locally stored case files. This does not cover information you choose to send to support.

2. Information processed by the apps

ImplTrack processes information you enter or import: patient identifiers and details, implant information (manufacturer, system, dimensions, REF and LOT), surgical protocols, findings, radiographs, measurement points, calibration data, clinical media, voice notes, transcripts and recall details. Practice details, case tags, inventory, preferences and entitlement status are also processed.

Personal statistics are calculated from documented implants and, where entered, historical annual totals. The app does not make automated diagnostic, treatment or other decisions producing legal or similarly significant effects.

3. Local storage and access protection

Case files and related files are stored within the app’s storage area on the device. The current app encrypts persistently stored case information, images and voice notes using AES-256-GCM; keys are managed using Apple Keychain. ImplTrack Patient also encrypts its locally stored passport data.

Optional Face ID protection restricts access to the app. The operating system checks biometric facial data; the apps cannot access it. A device passcode, up-to-date software and appropriate access controls remain necessary. Separately exported files depend on the protection and storage options chosen for that export.

4. iCloud synchronisation and backups

When you use cross-device synchronisation in ImplTrack, case content and supported preferences are synchronised through the private CloudKit database of your Apple Account. The app encrypts transferred content before upload; the required keys are made available through iCloud Keychain. Apple also processes account and technical information needed to provide its service.

Backups are separate from ongoing synchronisation: they restore a saved data state. ImplTrack supports manual and automatic encrypted backups, stored locally or, when configured, through iCloud Drive. Restoration may require the matching Apple Account and iCloud Keychain. Check the displayed backup status; a backup stored only on the same device does not protect against losing that device.

Additional copies may be created by Apple device backups you configure or other storage providers you select. Apple’s privacy information also applies to iCloud and Apple services. The app provider does not operate its own cloud storage for your case files.

5. Sharing, exports and recipients

Information is shared through export and sharing actions you initiate. Depending on your selection, an export may include complete case files, individual implants, findings, radiographs, measurements or related content. PDF and narrative text provide readable records; structured case files and colleague QR codes allow import into ImplTrack. Imported colleague records are marked as external, read-only documentation.

Implant passports can be transferred to ImplTrack Patient by QR code or passport file. Statistics can be exported as Excel, PDF or an image. A QR code can itself contain confidential information. Check the content, recipient and transfer method before sharing. An optionally protected PDF is not the same as an encrypted complete case file or backup.

When you use AirDrop, email, Files or another sharing service, that service processes the supplied content under its own terms. Copies already transferred or saved are not automatically recalled when information is later changed or deleted in ImplTrack. The practice must establish an appropriate legal basis and any necessary agreements for disclosing health information.

6. ImplTrack Patient

The free patient app imports implant passports using a QR code or file. Existing paper passports can be captured using the camera and read using on-device text recognition. Passport data remains within the app’s storage area on the iPhone; no ImplTrack account is required.

Users can share passport data themselves as a QR code, file or PDF and use optional reminders and protection features. The copy in ImplTrack Patient is separate from the practice’s records. Changes at the practice do not automatically update a previously imported passport. The app does not replace medical advice or the practice’s clinical records.

7. Camera, speech and permissions

The camera and selected photos are used for labels, passports and documentation images. Text recognition uses Apple’s on-device functions. Voice notes are stored locally and transcribed using Apple’s on-device speech recognition. The app requires local recognition and does not send recordings to OpenAI or an external transcription service. Local language models may need to be downloaded from Apple.

Camera, photos, microphone, speech recognition, notifications and Face ID permissions are requested in connection with the relevant feature. You manage these permissions in system settings. Without permission, the corresponding feature may be limited. When using Apple Watch, information required for the selected companion feature is transferred between your paired devices.

8. App Store, purchases and entitlements

Downloads, payments, subscriptions and any offer codes are handled through Apple. The app processes product and transaction information as needed to unlock features, verify entitlements and restore purchases. The app provider does not collect full payment or card details. Information Apple itself processes about your Apple Account is governed by Apple’s terms.

9. Website, hosting and security cookies

When you visit impltrack.at, delivery and security services process technically necessary access information, including IP address, time, requested URL, browser, device and error information. The website is provided through Sites and delivered and protected by Cloudflare. The purposes are operation, troubleshooting and preventing abuse; the legal basis for these interests is Article 6(1)(f) GDPR.

The website does not operate its own advertising or analytics tracking. The hosting service may set technical security cookies, such as Cloudflare’s __cf_bm for detecting automated traffic. According to Cloudflare, this cookie expires after 30 minutes of continuous inactivity. Links to the App Store or other external services lead to services with their own privacy terms; the website does not send case files to them.

10. Support and legal bases

When you contact us, we process your sender address, message and voluntarily supplied technical details to answer your request. Support email is processed through Gmail/Google. Please do not send identifiable patient information, radiographs or complete case files.

The legal basis is Article 6(1)(b) GDPR for contract-related enquiries, otherwise Article 6(1)(f) GDPR for handling and securing communications; legal obligations may require processing under Article 6(1)(c) GDPR. Necessary contact details are required to respond. Health information processed by a practice also requires an applicable condition under Article 9 GDPR, determined by that responsible organisation. An operating-system permission does not replace this legal basis.

11. Service providers and international processing

Depending on use, recipients may include Apple (App Store, iCloud and operating-system services), providers of the export method you select, the technical website infrastructure and Google for support email. These international providers may process information outside the European Economic Area. The specific service and its privacy and transfer terms apply, including any applicable adequacy decisions or standard contractual clauses. Use of the app does not imply a promise of storage exclusively in Austria or Europe.

12. Retention and deletion

You manage active, archived and deleted cases in the app. Archiving or moving a case to “Deleted” is not the same as permanently removing it. Before permanent deletion, consider the documentation obligations that apply to your practice.

Removing the app does not automatically erase previous exports, recipients’ copies, cloud content or backups. These locations must be considered separately. Ending a subscription does not delete your documentation; existing information remains editable, readable and exportable. Support information is kept only as long as needed to handle the request, meet legal obligations or defend specific claims. Technical access information is processed according to the operational and security retention rules of the hosting service used.

13. Your rights and contact

Subject to the GDPR, you have rights of access, rectification, erasure, restriction, portability and objection. You may withdraw consent for the future without affecting the lawfulness of earlier processing. For case records, contact the documenting practice; for our website or support processing, use the contact address above.

You may complain to a competent supervisory authority, in particular the Austrian Data Protection Authority, Barichgasse 40–42, 1030 Vienna, dsb@dsb.gv.at. This policy is updated when features or processing practices change.

Further information

• Apple — Privacy
• Cloudflare — Privacy Policy
• Cloudflare — Cookies
• Google — Privacy
• Austrian Data Protection Authority — Your rights