Privacy Policy

Effective date: 21.09.2025

This Privacy Policy explains how the Bracely app (the “App”) processes users’ personal data.

1) Who we are & contact

Data controller: Individual Entrepreneur MAKSIM TETERIN
Privacy & data inquiries: [email protected].

2) Age restrictions

The App is intended for users 16+. We do not knowingly target or collect data from users under 16.

3) Account model

No separate user account is created. On first launch, the App generates and stores in the system keychain a unique technical identifier (“deviceId”) used for authentication and data sync with our services.

4) Data we process

Profile: name (nickname), avatar, date of birth.
Orthodontic parameters: date braces were fitted, braces type, elastics, treatment plan (short notes), visits and events (incl. reminders), complaints/symptoms (as entered by you).
Photo reports: “before/after” and other photos you upload.
Technical data: deviceId, device model, OS/app versions, logs, diagnostics and crash data.

Note: we do not position this information as medical data and we do not provide medical services. Nevertheless, the information can be sensitive; please handle it carefully.

5) Data sources

Data is provided directly by you in the App or generated automatically during use (e.g., logs, device identifiers).

6) Purposes of processing

to provide App functionality (calendar, reminders, progress tracking, photo history);
to sync data between installations via our server;
to provide support, debugging, security and abuse prevention;
to perform analytics and improve services (in anonymized/aggregated form);
to send service-related notifications (e.g., reminders, critical messages).

7) Legal bases

We process data based on: (i) performance of a contract with you (providing the App’s services), (ii) our legitimate interests (support and improvement, fraud prevention), and (iii) your consent where required by law (e.g., to receive push notifications).

8) Storage & international transfers

Data is processed on servers located in the USA. If you are located outside the USA, your data may be transferred to the USA.

9) Third-party providers

Analytics: Firebase Analytics, Amplitude, Smartlook.
Stability: Firebase Crashlytics.
Notifications: Firebase Cloud Messaging (FCM).
Media storage: Firebase Storage.
Billing/entitlement validation: Adapty (no specific pricing/plans listed here).
AI Assistant: Qwen (LLM provider). Conversations are sent solely to generate responses; we do not permit using them to train the provider’s models.

Third parties operate under their own privacy policies. We share only the minimum data required for the relevant functionality.

10) Files & photos

Images and files you upload are stored in cloud storage. Do not upload materials you do not wish to store in the cloud. You can delete uploaded materials through the App.

11) Retention

We retain your data while your profile/installation (deviceId) remains active and you use the App. When you delete data in the App (see section 12), related records are flagged for deletion and removed within a reasonable timeframe, with backups handled per our internal schedule.

12) Your rights

Deletion: available directly in the App (core user data and uploaded photos).
Access & correction: you can view and edit most data in the App UI.
Withdraw consents: disable notifications in OS/App settings; camera/photos/calendar permissions are managed in OS settings.

13) Security

We apply organizational and technical safeguards (including access control, in-transit encryption, environment isolation). However, no method of transmission or storage is absolutely secure.

14) Push notifications & permissions

The App requests permission to send notifications for reminders. For photo reports it requests access to the camera/photo library. You can change permissions in OS settings.

15) Children

We do not allow the App to be used by individuals under 16. If you believe we accidentally collected such data, contact us — we will delete it.

16) Medical disclaimer

Bracely is not a medical device and does not provide medical advice. Information is for reference only and does not replace an orthodontist’s consultation. Always seek professional advice.

17) Changes to this Policy

We may update this Policy. The current version will be available in the App/website with the effective date shown. Material changes may be accompanied by an in-app notice.

18) Contact

Data & privacy inquiries: [email protected].
Governing law & jurisdiction: Georgia.