Last updated: March 22, 2026
WrinkleDoc is a clinical documentation app used by medical professionals to record patient identifiers and muscle-relaxer injection points. This policy explains what data WrinkleDoc processes, why, and what rights you have under the GDPR.
1. Data Controller
WrinkleDoc is managed by Lux49, which acts as the Data Controller for personal data processed through the application.
2. What data do we collect?
WrinkleDoc may collect and process:
- Personal identification information (name, email address, phone number)
- Face photos
- Patient name or identifier, where visible in a photo
- Medical injection points and related annotations
- Metadata such as date, time, and device information
- Doctor or clinician account information, where applicable
3. How do we collect your data?
Data is collected directly when a clinician uses WrinkleDoc to photograph a patient, record injection points, or create an account within the app.
4. Legal basis for processing
Processing is based on the explicit consent of the patient, given prior to any photo or data being recorded.
5. How we use your data
WrinkleDoc uses patient identifiers and injection-point data to support medical documentation and treatment records. Where you have separately consented, data may also be shared with partner services for additional features, such as AI-assisted analysis.
6. How we store your data
Data is stored securely at the device, we do not collect any data.
7. Your data protection rights
Under the GDPR, you have the right to:
- Access – request a copy of the personal data we hold about you
- Rectification – request correction of inaccurate or incomplete data
- Erasure – request deletion of your personal data, under certain conditions
- Restrict processing – request that we limit how your data is processed
- Object – object to our processing of your data
- Data portability – request that your data be transferred to another organization or to you directly
We will respond to any request within one month. To exercise any of these rights, contact us using the details below.
8. Changes to this policy
This privacy policy is reviewed regularly, and any updates will be posted on this page. This policy was last updated on March 22, 2026.
9. Data breach procedure
In the event of a data breach involving personal data, WrinkleDoc will notify the relevant authorities within 72 hours.
10. Contact us
If you have questions about this privacy policy, the data we hold about you, or wish to exercise your data protection rights, please contact us at:
LUX49, 23 Rue Jean Jaurès, L-1836 Luxembourg.