Privacy Policy

Last updated: March 18, 2026

1. Introduction

Etapa Vanguarda, Lda. ("Company", "we", "us") operates MotionSmile. This Privacy Policy explains how we collect, use, and protect your personal data in compliance with the General Data Protection Regulation (GDPR) and Portuguese data protection law.

2. Data Controller

Etapa Vanguarda, Lda.
Portugal
Email: info@motionsmile.com

3. Data We Collect

Data	Purpose	Legal Basis
Email address	Account creation, communication	Contract performance
Name	Account personalization	Contract performance
Phone number	Identity verification (free trial abuse prevention)	Legitimate interest
Payment information	Subscription billing	Contract performance
Uploaded photos	AI smile generation	Contract performance
Generated content	Service delivery	Contract performance
Usage data	Service improvement, quota tracking	Legitimate interest

4. How We Use Your Data

To provide and maintain the Service
To process payments through Stripe
To send service-related communications
To track usage quotas and billing
To improve the Service

We do not use your uploaded photos or generated content to train AI models. Your patient data remains private and is not shared with third parties for marketing purposes.

5. Third-Party Processors

We use trusted third-party service providers for the following purposes:

Authentication and data storage
Payment processing
AI image and video generation
SMS verification
Transactional email delivery
Cloud hosting

All processors are contractually bound to comply with GDPR requirements. Uploaded photos are processed in real-time by our AI provider and are not permanently stored on their servers. A complete list of sub-processors is available upon request at info@motionsmile.com.

6. Data Storage and Security

Your data is stored on servers within the EU/EEA where possible. We use encryption in transit (TLS) and at rest. Access to personal data is restricted to authorized personnel only. Uploaded photos are processed in real-time and not permanently stored on AI processing servers.

7. Data Retention

Account data: Retained while your account is active, deleted within 30 days of account deletion.
Generated content: Stored while your account is active.
Payment records: Retained for 7 years as required by Portuguese tax law.
Phone number: Retained while your account is active, used solely for trial verification.
Server logs: Retained for up to 30 days.

8. Your Rights (GDPR)

Under GDPR, you have the right to:

Access your personal data
Rectify inaccurate data
Erase your data ("right to be forgotten")
Restrict processing of your data
Port your data to another service
Object to processing based on legitimate interest
Withdraw consent at any time

To exercise any of these rights, email us at info@motionsmile.com. We will respond within 30 days.

9. Cookies

MotionSmile uses only essential cookies required for authentication and session management. We do not use tracking cookies or third-party analytics cookies.

10. Children's Privacy

The Service is not directed to individuals under 18. We do not knowingly collect data from minors. If you believe a minor has provided us with personal data, please contact us.

11. International Transfers

Some data may be processed outside the EEA by our third-party providers. In such cases, we ensure appropriate safeguards are in place (Standard Contractual Clauses or adequacy decisions).

12. Changes to This Policy

We may update this Privacy Policy periodically. We will notify registered users of material changes via email. Continued use of the Service constitutes acceptance of the updated policy.

13. Contact and Complaints

For privacy-related inquiries: info@motionsmile.com

You also have the right to lodge a complaint with the Portuguese Data Protection Authority (CNPD) at www.cnpd.pt.