Privacy Notice
1. Who we are
DenBrain is a software service provided by DenBrain Ltd, a company registered in England and Wales (company number 17494466), registered office 3 Chrislea Close, Hounslow, TW5 0DL. DenBrain helps dental practices turn online patient interest into enquiries and booking requests, including through Smile Preview, an illustrative image of a possible smile.
You can contact us about privacy, and to exercise your rights, at hello@denbrain.co.uk.
2. Our role: controller or processor
The role we play depends on whose data it is. We are neither always a controller nor always a processor.
- Practice customers and website visitors: for the data we use to run DenBrain accounts, billing, security, service administration, legal compliance and direct communications with practice customers, DenBrain Ltd is the controller (Part A).
- Patients who use a practice's Smile Preview or widgets: the dental practice is the controller, because it decides to offer the service and what to do with the enquiry. DenBrain Ltd acts as the practice's processor, handling this data only on the practice's documented instructions and under the data processing agreement published at /dpa (Part B).
Part A - Practice customers and visitors: what we collect
When a practice creates or uses a DenBrain account we collect:
- account details: first and last name, email address and practice name; your password is stored only as a protected hash, never in readable form;
- plan, subscription status and usage of your allowance; payments are handled by Stripe and we do not store full card numbers;
- what you configure in DenBrain (for example Smile Preview settings, treatments and booking links);
- technical and security information, including IP address, browser details and request logs created by our servers;
- emails we send you (for example welcome, password reset and billing notices) and messages you send us.
Part A - Why we use it and our lawful bases
Under UK GDPR we rely on these lawful bases for our own processing. We do not rely on consent for everything.
- Contract - to set up and manage your account, provide the service you signed up for, and take payment.
- Legal obligation - to keep accounting, tax and company records and to respond to lawful requests.
- Legitimate interests - to keep the service secure, prevent misuse, diagnose problems, administer the service, communicate with practice customers about their service, and run our business, where we have balanced these interests against your rights and they do not override them.
- Consent - only for optional processing where we ask for it, such as any marketing communications that need consent. You can withdraw consent at any time, without affecting what was done before.
Part B - Patients using Smile Preview: what is collected
When you use a practice's Smile Preview, DenBrain collects on the practice's behalf:
- the details the practice has chosen to ask for: first and last name, email address, mobile number, an optional message and the treatment you are interested in;
- the treatment you choose, and anything you write about your goals or concerns;
- one photo of your smile that you upload or take (a camera is only switched on if you choose it, and the picture stays on your device until you use it);
- your consent choices;
- the web page address and referrer your visit came from, and usage events about the journey (for example that a page was viewed, a photo was uploaded, a preview was created, or a booking or phone button was clicked), so the practice can see how its Smile Preview performs;
- enquiry and appointment-request records created when you send an enquiry, and a record that you opened the practice's booking link or tapped its phone number.
Part B - Booking, enquiries and what each action means
Each practice chooses how its AI Smile Simulator handles booking, and you are shown only that option. In every case the practice, not DenBrain, arranges and confirms your appointment.
- If the practice takes enquiries: when you press the enquiry button, the details you already gave are sent to the practice as an appointment request. You see a thank-you message, or are taken to a thank-you page on the practice's own website, only after DenBrain has accepted the request. We may email you to acknowledge it. An enquiry is a request: it is not a booked appointment.
- If the practice uses its own online booking page or a connected booking system: opening it is recorded as the start of a booking. You then leave DenBrain and the practice's or the booking system's own privacy information applies. A booking is only recorded as booked when the practice or its booking system confirms it, never because a button was pressed.
- Tapping the practice's phone number is recorded as a phone click. It is not a request and not a booking.
Part B - What the AI provider receives
The image-generation provider (fal.ai, see /subprocessors) receives your photo and an instruction describing the treatment you chose, built from fixed options. What you type about your goals or concerns is not passed to the provider as you wrote it: it is used only to pick among those fixed options and is stored with your request so the practice can read it. Names, email addresses and phone numbers are not sent to the provider.
Part B - Analytics, advertising and your consent on a practice's website
The AI Smile Simulator is embedded in the practice's website, and the practice (as controller) decides whether it uses analytics or advertising tools there and runs the website's cookie or consent banner. The simulator shows no banner of its own and adds no extra consent step. It relies on the signal the practice's website gives it about whether you have agreed to advertising or marketing tracking, and treats a missing, unclear or withdrawn signal as no consent.
- Without that consent: nothing identifying you is stored by the simulator in your browser, no advertising identifiers are read, no conversion is sent to advertising platforms, and your treatment choice is not passed to the website's marketing tools. The simulator still works, and the practice still receives your enquiry.
- With that consent: the simulator may read advertising identifiers that the practice's own tags have set (for example _ga, _fbp, _fbc or _ttp), keep a record of which campaign brought you to the page in your browser's local storage on that website, tell the website's tag manager which treatment you chose and that a button was pressed, and let the practice's DenBrain account send conversion events to the advertising or analytics services the practice has set up (for example Google, Meta or TikTok; these are the practice's own services, chosen and set up by the practice).
- What is sent: an event name, a random event identifier, a time, the page address and advertising or browser identifiers. Names, email addresses, phone numbers, photos, image links and the text you wrote are never included.
- Whether a website's consent banner is set up correctly is the practice's responsibility. DenBrain does not decide for the practice that its banner is lawful.
Part B - Special category data, explicit consent and marketing
The practice, as controller, is responsible for its lawful basis and for the information it gives patients. A photo of your smile used to create a health-related visualisation may reveal information about your health, so DenBrain treats it as special category data. Before your photo is used, DenBrain asks for your explicit consent to the photo being processed to create your preview, and separately asks you to acknowledge that the result is illustrative only. The photo is not processed without these. You can withdraw consent at any time by contacting the practice or us; withdrawal does not affect processing already carried out.
Marketing is separate. Agreeing to receive updates, offers or information from the practice is a separate, optional choice that is not ticked by default and is never a condition of using Smile Preview.
Part B - How your photo and preview are handled
Your photo is checked (file type, size and dimensions), stored in private object storage - never in our database - and only accessed through short-lived links.
Original uploaded photos are deleted immediately after successful processing where possible. Failed or abandoned uploads are removed by an automated cleanup process that runs hourly and deletes originals more than 24 hours old. Generated Smile Preview images (the preview and the 'before' image shown beside it) are temporary: they are available for 24 hours and are then deleted automatically, unless the practice deliberately saves them from its DenBrain dashboard. Images a practice saves are held as that practice's own record, for as long as the practice keeps them, outside this temporary window.
DenBrain does not use patient photos to train AI models.
If your practice offers the AI Teeth Scan, the photos you take for the scan are checked, held in private storage, and sent over HTTPS to an AI image-analysis provider only after you agree, to produce a written overview of what is visible. The overview is not a diagnosis. AI Teeth Scan photos are deleted as soon as the scan has been analysed. Photos from a failed or abandoned scan are removed by the same automated hourly cleanup that removes Smile Preview originals after 24 hours. The written scan summary is kept for 24 hours so the patient can read it and book, and is then deleted, unless the patient chooses to send it to the practice with an enquiry, in which case the practice holds it as part of that enquiry.
Your photo is sent to our image-generation provider, fal.ai, to create the preview. DenBrain instructs fal.ai not to store the request, and receives the result directly. The periods above describe DenBrain's own storage; the provider's own terms, including how it uses anonymised or aggregated usage data, are summarised at /subprocessors.
Your Smile Preview is an illustrative visualisation only. It is not a diagnosis, a treatment plan, or a prediction or guarantee of any clinical outcome. Only an assessment by a dental professional can say what is suitable for you.
Smile Preview does not make decisions about you with legal or similarly significant effects. It generates an image; any decision about treatment is made by people at the practice.
How long we keep data
We keep personal data for the periods below. They reflect how the service actually works.
- Original patient photo: Original uploaded photos are deleted immediately after successful processing where possible. Failed or abandoned uploads are removed by an automated cleanup process that runs hourly and deletes originals more than 24 hours old.
- Generated Smile Preview (and the 'before' image shown beside it): Generated Smile Preview images (the preview and the 'before' image shown beside it) are temporary: they are available for 24 hours and are then deleted automatically, unless the practice deliberately saves them from its DenBrain dashboard. Images a practice saves are held as that practice's own record, for as long as the practice keeps them, outside this temporary window.
- AI Teeth Scan photos and written scan summary: AI Teeth Scan photos are deleted as soon as the scan has been analysed. Photos from a failed or abandoned scan are removed by the same automated hourly cleanup that removes Smile Preview originals after 24 hours. The written scan summary is kept for 24 hours so the patient can read it and book, and is then deleted, unless the patient chooses to send it to the practice with an enquiry, in which case the practice holds it as part of that enquiry.
- Patient enquiries and appointment (booking) requests: Kept for as long as the practice's account is active, because they are the practice's records; deleted earlier if the practice deletes them or instructs us to; deleted or returned after the account ends as set out under 'Account closure'.
- Account data (name, email, practice name, hashed password, plan and usage): Kept while the account is active; deleted or returned after the account ends as set out under 'Account closure', except billing records.
- Practice configuration (Smile Preview settings, treatments, booking links, widgets): Kept while the account is active; deleted after the account ends as set out under 'Account closure'.
- Usage and journey events, and in-product audit records: Kept with the practice's account data while the account is active; deleted after the account ends as set out under 'Account closure'.
- Billing records (invoices, subscription and payment records): Kept for as long as necessary for accounting, tax, legal, fraud-prevention, dispute-resolution or other legitimate business requirements, subject to applicable law.
- Application and web-server logs (include IP addresses): Held in rotating log files capped at five files of 10 MB for each of the application, worker and web-server services; the oldest entries are overwritten automatically. In practice this is a short, size-bounded period rather than a fixed number of days.
- Rejected inbound webhook records: Deleted automatically after 30 days.
- Encrypted database backups: Backups older than 35 days are deleted automatically (a minimum number of the newest backups is always kept so a failed run cannot leave no backup). Data deleted from the live service therefore leaves backups within 35 days. Backups are encrypted and are not restored into the live service for the sole purpose of removing individual records.
Account closure and deletion requests
When a practice's account ends, or a practice asks us in writing, we will, at the practice's choice, return or delete its data within 30 days of the request, except for billing records, which are kept as described in the retention schedule above. This is handled by DenBrain staff rather than a self-service tool. Copies in encrypted backups expire automatically within 35 days after that.
International transfers
Some of our providers process personal data outside the United Kingdom, and we do not claim that all data stays in the UK. Where personal data is transferred outside the UK we rely on the mechanisms each provider publishes, which are, in summary:
- Hostinger: Hostinger's data processing agreement applies the EU Standard Contractual Clauses and the UK International Data Transfer Addendum to transfers of UK personal data.
- Cloudflare R2: Cloudflare's customer data processing agreement applies the EU Standard Contractual Clauses with the UK Addendum, and Cloudflare states that it participates in the EU-US Data Privacy Framework and its UK Extension.
- fal.ai: fal.ai's data processing addendum applies the EU Standard Contractual Clauses (Module 2) and the UK International Data Transfer Addendum to the EU Standard Contractual Clauses. DenBrain is not aware of a Data Privacy Framework certification by fal.ai and does not rely on one.
- Stripe: Stripe's Data Transfers Addendum applies the EU-US Data Privacy Framework (including its UK Extension) where available, and otherwise the EU Standard Contractual Clauses with the UK International Data Transfer Addendum.
Security
We use measures appropriate to the risk, including encrypted connections (HTTPS), private object storage with short-lived access links, separation of each practice's data from other practices' at database level, role-based access controls, hashed passwords and encrypted backups. No system is perfectly secure. A more detailed description is published at /security.
If something goes wrong: personal data breaches
We have procedures to detect, assess and respond to security incidents. Where a personal data breach affects data we process for a practice, we will tell the practice without undue delay after becoming aware of it and give the information it needs to meet its own obligations. Where we are the controller, we will notify the ICO and affected individuals where the law requires.
A practice, as controller, may have its own legal duty to report a breach to the ICO within 72 hours of becoming aware of it.
Your rights
Under UK GDPR and the Data Protection Act 2018 you have the right:
- to be informed about how your personal data is used (this notice);
- of access to your personal data;
- to have inaccurate personal data rectified;
- to have personal data erased, in certain circumstances;
- to restrict processing, in certain circumstances;
- to data portability, in certain circumstances;
- to object to processing based on legitimate interests;
- not to be subject to solely automated decisions with legal or similarly significant effects, and rights relating to profiling, where applicable;
- to withdraw your consent at any time where we rely on consent, without affecting processing already carried out.
How to exercise your rights
For data about your use of a DenBrain account, email hello@denbrain.co.uk.
If your data was collected through a practice's Smile Preview, the practice is the controller, so your request may need to be made to that practice. DenBrain Ltd will give the practice appropriate assistance and, if you contact us instead, will tell you how to reach the practice or pass your request on where we can.
Complaints
Please contact us first at hello@denbrain.co.uk so we can try to put things right. You also have the right to complain to the Information Commissioner's Office (ICO), the UK data protection regulator, at ico.org.uk.
Changes to this notice
We may update this notice. The date of the latest version is shown below. Last updated: 28 October 2026.
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