Smart Fixator

Privacy Notice

Smart Fixator® website and web application · Version 1.1 · Last updated: 5 October 2026

This notice explains how Response Ortho processes personal data when you visit www.smartfixator.com, contact us, request an account or use the Smart Fixator web application. It is written to meet the transparency requirements of the EU General Data Protection Regulation (GDPR) and the UK GDPR, and applies to users worldwide. Where the law of your country gives you additional information or rights, you will find it in section 18.

Privacy conditions. When you request access to Smart Fixator you accept these privacy conditions:

  1. this Privacy Notice;
  2. on behalf of your institution — or yourself, if you practise independently — the Data Processing Agreement that governs the patient data you enter. It is accepted online; no signature is needed;
  3. receiving information messages from Smart Fixator about the software and devices you use: updates, safety notices, training and service information (see section 12).

1. Who is responsible for your data

The data controller is Response Ortho Teknolojik Üretim A.Ş., ITOSB, 10. Cadde, No:1, Tuzla, 34959 Istanbul, Türkiye (MERSİS no. 0462038264300019), the manufacturer of Smart Fixator®.

Our affiliate Response Ortho Solutions LLC, 1875 W Woolbright Rd, Boynton Beach, FL 33426, United States, supports customers in the United States.

Privacy contact: info@responseortho.com.

2. Whose data this notice covers

The Smart Fixator software is intended for use by healthcare professionals. It is not directed at consumers.

3. What we collect and how

SourcePersonal data
Account request (from you)First and last name, e-mail address, username, password (stored only as a one-way hash), gender, role (for example surgeon, academic, student), speciality, country, and optionally city, state/province and postal code; your choice about information messages.
Contact form (from you)Name, e-mail address, optional phone number, organisation and country/region, and the content of your message.
Use of the application (automatically)Sign-in and account events with date and time, IP address and browser/operating-system details; security, error and server logs; your account settings.
Website visits (automatically)IP address and technical request data in server logs; the country derived from your IP address by our own web server (used to pre-fill the country fields in our forms, not stored). Only with your consent: Google Analytics usage data and identifiers.
Third partiesGoogle reCAPTCHA's assessment of whether a contact-form submission comes from a person.
Clinical content you enterPatient and case information, radiographs and planning data — see section 6.

We do not ask for special categories of data about you (such as your health). Please do not include information that identifies a patient in the contact form.

4. Why we use your data and our legal bases

PurposeLegal basis (GDPR / UK GDPR)
Creating and managing your account, signing you in, providing the software, password resets and service e-mailsContract (Art. 6(1)(b))
Answering enquiries sent through the contact form or by e-mailSteps at your request before a contract / legitimate interest in answering you (Art. 6(1)(b), (f))
Keeping the website and application secure: spam and abuse prevention (reCAPTCHA), sign-in protection and account blocking after repeated failures, logging and troubleshootingLegitimate interest (Art. 6(1)(f))
Complying with legal obligations, including medical-device regulations (complaint handling, vigilance, post-market surveillance), tax and record-keeping duties and requests from authoritiesLegal obligation (Art. 6(1)(c))
Establishing, exercising or defending legal claimsLegitimate interest (Art. 6(1)(f))
Pre-filling your country in our forms from your IP address (looked up on our own server, not stored)Legitimate interest (Art. 6(1)(f))
Website analytics (Google Analytics)Consent (Art. 6(1)(a))
Sending information messages about the Smart Fixator software and devices you use (updates, safety notices, training, service information)Contract and legitimate interest (Art. 6(1)(b), (f)); safety notices: legal obligation (Art. 6(1)(c))
Developing, improving and validating our products, including AI-assisted measurement, with anonymised case data (see section 6)Anonymised data is not personal data; the anonymisation is carried out on the customer's behalf under the Data Processing Agreement

Outside the EEA and the UK we rely on the equivalent legal bases in the law that applies to you.

Where we rely on consent you can withdraw it at any time (see section 5); this does not affect processing that took place before.

5. Cookies and similar technologies

We use cookies that are strictly necessary for the website and the application to work. Optional analytics runs only if you choose Accept in the privacy banner. You can change your choice at any time using Cookie settings at the bottom of our homepage; rejecting analytics also deletes this site's Google Analytics cookies. We do not use advertising or profiling cookies.

NameProviderPurposeDurationType
smartfixator_consentSmart Fixator (first party)Remembers your privacy choice180 daysStrictly necessary
PLAY_SESSIONSmart Fixator application (first party)Keeps you signed in and secures your sessionUntil you sign out or close the browserStrictly necessary
_GRECAPTCHAGoogle (reCAPTCHA)Distinguishes people from automated abuse when you use the contact formUp to 6 monthsStrictly necessary (security)
_ga, _ga_BM11WMLLJQGoogle Analytics (first-party cookies)Counts visits and measures how the website is used, in aggregateUp to 2 yearsAnalytics — only with consent

When analytics is enabled we send page addresses without query strings, and Google signals and ad personalisation are switched off. To suggest your country in our forms the page asks our own web server for the country of your IP address; no third-party service is involved, only the country code is returned and nothing is stored in a cookie. You can also block or delete cookies in your browser settings; blocking strictly necessary cookies may stop the application from working.

6. Patient data in the Smart Fixator application

Clinicians use the application to plan and follow deformity corrections. The application can hold patient information such as name, date of birth, gender, contact details, radiographs (including DICOM file headers), measurements, correction plans and prescriptions. Radiographs and treatment information are health data, a special category of personal data.

7. Who receives your data

We do not sell your personal data or share it for targeted advertising. We disclose it only as needed for the purposes above:

RecipientWhyLocation
DigitalOcean (hosting)Runs our servers: the application and website; the Response Ortho contact service that forwards contact-form messagesNetherlands (application and website); United States (contact service)
Microsoft (Microsoft 365)Delivers contact-form messages to info@responseortho.com and sends account e-mailsMicrosoft data centres
Google (reCAPTCHA; Analytics with consent)Abuse prevention; website measurementUnited States and other countries
Competent authorities and courtsWhere required by law, including medical-device vigilance reportingAs required
Professional advisers and auditors; a successor in a merger or acquisitionAdvice, audits, corporate transactions, under confidentialityAs applicable

Service providers act on our instructions under written contracts and may not use your data for their own purposes, except where they act as independent controllers under their own terms (for example Google for reCAPTCHA).

8. International transfers

Your data may be processed outside your country: application data in the Netherlands, the contact service in the United States and Google services in the United States and elsewhere. For transfers out of the EEA or the UK we rely on adequacy decisions (including the EU–US Data Privacy Framework where the recipient is certified) or the European Commission's standard contractual clauses. Where the law of another country restricts transfers, we use the safeguards that law provides (see section 18). You can ask us for information about these safeguards.

9. How long we keep your data

DataRetention
Account dataWhile your account is active; after it is closed, only for as long as the law requires or allows us to keep it — for example until legal claims are time-barred
Contact-form messagesFor as long as needed to deal with your enquiry and any follow-up, unless they become part of a contract or complaint file
Sign-in, security and server logsFor as long as needed to protect the service and investigate incidents, and as required by law
Complaint, vigilance and other regulatory recordsFor the periods required by medical-device law
Google Analytics data (with consent)For the retention period configured in Google Analytics
Patient data in the applicationAs instructed by the healthcare provider under the Data Processing Agreement; when the service ends it can be exported for 30 days and is then deleted within 60 days

When a retention period ends we delete, destroy or anonymise the data.

10. How we protect your data

We use technical and organisational measures appropriate to the risk, including encrypted connections (HTTPS), passwords stored only as salted one-way hashes, role-based access limited to people who need it, account blocking after repeated failed sign-ins, logging, and confidentiality obligations for our staff and providers. No system is completely secure; if a personal data breach occurs we will notify the authorities and the people affected where the law requires.

11. Your rights

Depending on the law that applies to you, you may have the right to:

How to exercise them. Write to us at the address in section 1 or e-mail info@responseortho.com. We may ask you to confirm your identity before we act. We reply free of charge within one month, unless the law allows an extension or a fee. Country-specific application procedures are in section 18.

US residents. Residents of some US states have similar rights (to know, delete, correct and opt out), the right to appeal a refusal, and the right not to be discriminated against for using them. We do not sell or share personal information as those laws define it. You can send a request by the means above, including through an authorised agent.

12. Information messages

Information messages about the Smart Fixator software and devices you use — updates, safety notices, training and service information — are part of the privacy conditions you accept when you request access. You can stop them at any time through the link in each message or by writing to info@responseortho.com; safety notices required by medical-device law and messages needed to run your account (such as password resets) are always sent. We do not send promotional messages about other products without your separate consent.

13. Children

Our website and application are intended for healthcare professionals and are not directed at anyone under 18. We do not knowingly collect personal data about children as users. If you believe a child has given us personal data, contact us and we will delete it. Clinicians may enter information about patients of any age, which is covered by section 6.

14. Automated decisions

We do not take decisions about you that are based solely on automated processing and that have legal or similarly significant effects. Automatic account blocking after repeated failed sign-ins is a security measure that you can resolve through the unblock link we e-mail you.

Our pages link to other websites, such as responseortho.com and Google's policies. Those sites have their own privacy practices, and we are not responsible for them.

16. Changes to this notice

We may update this notice when our services or the law change. The date at the top shows the latest version. If we make material changes we will tell account holders by e-mail or in the application before the changes take effect.

17. How to contact us

Response Ortho Teknolojik Üretim A.Ş., ITOSB, 10. Cadde, No:1, Tuzla, 34959 Istanbul, Türkiye · info@responseortho.com

18. Country-specific information

Türkiye

If you are in Türkiye, the Law on the Protection of Personal Data No. 6698 (KVKK) applies. Our information notice under that law — with the legal bases we rely on, transfers within and outside Türkiye, your rights under Article 11 and how to apply to us — is available in Turkish: KVKK Aydınlatma Metni. Applications under that law can also be sent by registered electronic mail (KEP) to response.ortho@hs01.kep.tr. You can also complain to the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu).