Privacy Policy

This Privacy Notice for Zhuoxue Chen ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application (BraceTime), or any other application of ours that links to this Privacy Notice
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at BraceTimeApp@outlook.com.

Section 01What Information Do We Collect?

Information stored on your device

BraceTime does not require an account. Your aligner or retainer plan, wear sessions, reminders, notes, and progress photos are stored locally on your device. We do not transmit that content to our own servers or to analytics or advertising providers. If you create an export or backup, save content to a system backup, or share content through another app, the destination you choose controls that copy.

Information collected from the app

The app and service providers integrated into the version distributed through the App Store may process the following categories. These data may be associated with pseudonymous app-instance, device, or purchase identifiers. BraceTime does not require an account and does not collect your name or email address automatically through the app:

• Device ID. A device-level identifier, which may include the Apple advertising identifier (IDFA) when you authorize tracking, may be used for analytics and tracking. Tracking includes measuring whether advertising, including Meta advertising, led to an app install or another conversion.
• Product interaction. Events such as opening the app, progressing through onboarding, viewing features, recording a wear session, saving a progress photo, interacting with a comparison, or viewing a paywall may be used to understand feature adoption, product quality, and conversion funnels. The event data does not include the contents of your treatment plan, notes, or photos.
• Purchase history. Product identifiers, purchase or subscription status, trial status, renewal, cancellation, refund, and related transaction metadata may be processed to provide BraceTime Pro, analyze purchase performance, and measure advertising. Apple processes payment credentials; BraceTime does not receive or store your full payment-card details.
• Crash data. Crash logs and related technical information may be used for analytics and app functionality, including identifying failures and improving app reliability.

We do not use these data types to identify you by name or email address. Some providers assign pseudonymous identifiers so events from the same app instance, device, or purchase record can be understood together. Where applicable, advertising measurement also depends on your App Tracking Transparency choice.

Information you choose to disclose outside the app

If you contact us for support, we process the email address and message contents you choose to provide solely to respond to your request. This is optional, infrequent, and not collected automatically by the app.

Sensitive Information

BraceTime is used to record orthodontic routines, which may reveal health-related information. This content remains on your device unless you deliberately export, back up, or share it. We do not use treatment records or progress photos for analytics, advertising, or ad targeting.

Application Data

If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Camera and Photo Library. We may request access so you can capture, select, compare, and save progress photos. The app does not upload those photos to our analytics or advertising providers.
• Push Notifications. We may request permission to send local or remote reminders about app features. You can change notification permissions in iOS Settings.
• App Tracking Transparency. We may request permission to access tracking data such as IDFA so Meta and our attribution providers can measure which advertising campaigns lead to installs or purchases. Denying permission does not disable BraceTime's core features.

You can change camera, photo, notification, and tracking permissions at any time in iOS Settings.

Section 02How Do We Process Your Information?

We process the limited information described in Section 1 to provide, maintain, and improve BraceTime and to measure advertising performance.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• Analytics. We use device or app-instance identifiers, product interactions, purchase history, and crash data to understand feature adoption, conversion funnels, service quality, and purchase performance.
• Tracking and advertising measurement. We may use a device identifier and limited purchase or subscription events to measure whether advertising, including Meta advertising, led to an install, trial, purchase, or another conversion. Where required, this processing depends on your App Tracking Transparency choice.
• App functionality. We use purchase and subscription status to provide and restore BraceTime Pro, and crash data to diagnose failures, reduce crashes, and maintain app reliability.
• Support. We use information you voluntarily send outside the app to respond to your request.

Section 03What Legal Bases Do We Rely On to Process Your Personal Information?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

For device tracking and advertising measurement, we rely on consent where required, including your choice through Apple's App Tracking Transparency framework. For product analytics and crash diagnostics, we rely on our legitimate interests in understanding feature use, reliability, and product performance, except where applicable law requires consent. We process purchase history as needed to provide and restore purchased BraceTime Pro features and to meet related contractual and legal obligations.

If you are located in the EU or UK

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

Section 04When and With Whom Do We Share Your Personal Information?

We disclose only the data types and purposes described in Section 1:

• Meta Platforms and advertising attribution providers. A device identifier and limited purchase or subscription events may be processed for tracking and advertising measurement. Depending on your device, settings, and consent, this may include IDFA or another device-level identifier. Meta's handling of information is governed by its Privacy Policy.
• Analytics and diagnostics providers. Device or app-instance identifiers, product interaction events, purchase-related analytics, and crash data may be processed to understand product use, conversion, and reliability. These providers may associate events with pseudonymous identifiers, but the app does not provide them with your treatment records, notes, or progress photos.
• Purchase service providers. Apple and RevenueCat may process product identifiers, purchase and subscription status, trial status, renewals, cancellations, refunds, and related transaction metadata to complete purchases, restore entitlements, provide subscription analytics, and support advertising measurement. Apple, rather than BraceTime, processes your payment credentials.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Legal Requirements. We may disclose information when required by law or reasonably necessary to protect rights, safety, and security.

We do not sell personal information for money. The use of a device identifier for advertising measurement may be considered tracking or "sharing" for cross-context behavioral advertising under some privacy laws.

Section 05How Long Do We Keep Your Information?

We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

Your treatment plan, wear history, reminders, and photos remain on your device until you delete them, delete the app, or manage them through any backup or export destination you choose.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Section 06How Do We Keep Your Information Safe?

We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Section 07What Are Your Privacy Rights?

Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in Section 11 below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Tracking choices

You can allow or deny app tracking when iOS presents the App Tracking Transparency prompt. You can later review or change that choice in Settings > Privacy & Security > Tracking. Denying tracking permission does not affect BraceTime's core features. You may also contact us to exercise any applicable right to opt out of targeted advertising or sharing.

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time by contacting us using the contact details provided in Section 11 below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at BraceTimeApp@outlook.com.

Section 08Tracking and Do-Not-Track Controls

BraceTime follows the tracking choice you make through Apple's App Tracking Transparency framework. If you deny permission, the app will not receive permission to access IDFA for tracking. Other limited, non-identifying identifiers may still be processed for analytics as disclosed above.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

Section 09Do United States Residents Have Specific Privacy Rights?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months.

We use Category A device identifiers for analytics and tracking, Category D purchase history for app functionality, analytics, and advertising measurement, and Category F product interactions for analytics and product improvement. We retain optional support contact information only as long as reasonably necessary to answer the request and meet legal obligations. BraceTime does not require an account.

How We Use and Share Personal Information

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We do not sell personal information for money. During the preceding twelve (12) months, we may have disclosed device identifiers and limited purchase or subscription events to Meta and attribution providers for advertising measurement; product interaction data and pseudonymous device or app-instance identifiers to analytics providers; purchase history to Apple and RevenueCat for app functionality, analytics, and advertising measurement; and crash data to diagnostics providers. Data used for advertising measurement may be considered "sharing" under some US state privacy laws. These providers may associate events with pseudonymous app-instance, device, or purchase identifiers, but BraceTime does not require an account and does not automatically collect your name or email address through the app.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including Connecticut)
• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at BraceTimeApp@outlook.com, or by referring to the contact details in Section 11 of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at BraceTimeApp@outlook.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in Section 11 below.

Section 10Do We Make Updates to This Notice?

Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

Section 11How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may contact us by email or post:

Section 12How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

You can delete local treatment records and photos using the controls available in BraceTime or by deleting the app, subject to any device backups or exports you control. Automatically collected device identifiers, product interactions, purchase history, and crash data are generally associated with pseudonymous identifiers rather than your name or email address, so we may not be able to locate a specific provider-held record using your name or email address alone.

To request to review, update, or delete your personal information, please contact us at BraceTimeApp@outlook.com.