Privacy Notice
How Layon Med collects, uses, and protects personal data — including patient imaging data submitted by healthcare professionals — under the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (revFADP).
This document is provided in several languages for convenience. In case of any discrepancy, the English version prevails.
1. Controller
The controller responsible for processing personal data through this website and in connection with Layon Med's design services is:
Insert legal entity name, registered seat, commercial register number, VAT/UID, contact email on the owned domain, and (where applicable) Data Protection Officer / Data Protection Advisor details.
2. What we collect and why
| Category | Purpose | Lawful basis |
|---|---|---|
| Case-intake form (name, institution, country, work email, specialty, surgery date, case description) | Respond to your enquiry; scope and prepare a planning proposal | Art. 6(1)(b) GDPR (steps preceding a contract) / FADP Art. 31(2)(a) |
| Server logs (visitor IP, user-agent, request time) | Operate the site, detect abuse, maintain security | Art. 6(1)(f) GDPR (legitimate interest in IT security) / FADP Art. 31(1) |
| Patient imaging data (DICOM, CT, CBCT, dental scans) and clinical case files — submitted only through a separately arranged secure channel | Design the patient-specific device requested by the prescribing clinician | Art. 9(2)(h) GDPR (provision of healthcare under contract with a healthcare professional) / FADP Art. 31(2)(c) |
| Correspondence (email, written communication) | Operational delivery and after-sales / vigilance follow-up | Art. 6(1)(b) and (f) GDPR / FADP Art. 31(2)(a) |
Patient data is never accepted through the public website form. We arrange a secure, access-controlled transfer channel after your initial enquiry. The treating clinician is responsible for obtaining patient consent before transferring any identifiable imaging data.
3. Where data is processed and stored
- Website hosting: Netlify (currently the static-site host). Patient imaging data is not stored on the website host.
- Case-intake form submissions: stored by the form processor on the website host and forwarded to the operational email address.
- Patient imaging data and case files: stored only on the secure transfer channel and on Layon Med's internal CAD systems, under appropriate technical and organisational measures.
Confirm the secure-channel provider (e.g. Tresorit, Kiteworks, dedicated SFTP) and its hosting region (EU / CH).
Confirm web fonts hosting: currently Google Fonts is loaded from googleapis.com (US). To eliminate the cross-border transfer, fonts should be self-hosted under /fonts/.
4. Sub-processors
Layon Med engages the following categories of sub-processor to deliver its service. A current list of named sub-processors is available on request.
- Cloud hosting and form-handling provider (currently Netlify)
- Web font provider (currently Google Fonts — to be self-hosted)
- Secure file-transfer provider (to be confirmed)
- Manufacturing partner(s) producing the finished medical device — acting as separate controller and/or processor under their own quality management system
5. International data transfers
Where personal data is transferred outside Switzerland or the EEA, Layon Med relies on appropriate safeguards under GDPR Chapter V and revFADP, including Standard Contractual Clauses and supplementary measures where required following the Schrems II judgment. Layon Med aims to minimise such transfers, particularly for special-category health data, by selecting providers with EU / Swiss hosting.
6. Retention
- Website server logs: typically 90 days.
- Case-intake enquiries that do not become projects: typically 12 months from last contact.
- Case files of completed projects: retained for the period required by Regulation (EU) 2017/745 Art. 10(8) — at least 10 years from placing the last device on the market, and at least 15 years for implantable devices — and as required by Swiss MedDO.
Confirm retention periods against contractual obligations to clinical customers and any tax/accounting law obligations.
7. Your rights
Under GDPR and revFADP you have the right to:
- request access to your personal data and information about how it is processed;
- request rectification of inaccurate or incomplete data;
- request erasure ("right to be forgotten") where conditions are met and no legal obligation requires retention;
- request restriction of processing or object to processing;
- request data portability for data you provided to us, where technically feasible;
- withdraw consent at any time, without affecting the lawfulness of prior processing;
- lodge a complaint with the competent supervisory authority — the Federal Data Protection and Information Commissioner (FDPIC) in Switzerland, or your national supervisory authority in the EU/EEA.
To exercise your rights, contact the operational email address on the home page and reference "Privacy — Data subject request".
8. Patient data — clinician's role
When patient imaging data is submitted, the prescribing clinician (or their institution) acts as data controller for that patient; Layon Med acts as data processor under a Data Processing Agreement signed before any patient data is transferred. The clinician is responsible for obtaining patient consent under the applicable national law before transferring imaging.
9. Security
Layon Med applies technical and organisational measures appropriate to the nature of the data and the state of the art, including transport encryption (TLS), access control and authentication, role-based access on internal systems, logical separation of case data, and confidentiality obligations on all personnel and sub-processors. Notwithstanding these measures, no transmission or storage system is entirely free from risk; please report any suspected incident promptly using the contact channel above.
10. Cookies and similar technologies
Under the revised Swiss FADP and the FDPIC's 2025 cookie guidance, Switzerland applies a tiered model: strictly necessary cookies require no consent but must be disclosed; functional cookies may use an opt-out; advertising and profiling technologies require explicit opt-in. The same logic aligns with GDPR and the EU ePrivacy rules.
What this website uses today:
- Strictly necessary (no consent required, disclosed here): a single first-party value,
lm_consent, that records your cookie choice so the notice is not shown again. The chat assistant uses only your browser's local storage for the current session and sets no tracking cookie. - Advertising / cross-site tracking: none. The website runs no advertising, no third-party ad or social pixels, and no cross-site tracking.
- Analytics (consent required — opt-in via “Accept all”): with your consent, we use privacy-friendly first-party analytics that we host ourselves. It stores a first-party identifier in your browser's local storage and records pages viewed, links and buttons clicked, approximate location (country, region and city), device, browser, language and any questions put to the chat assistant — so we can understand how the site is used and improve it. To estimate the city, your IP address is looked up via a geolocation provider (ip-api.com); we then keep only a truncated IP, never the full one. Apart from that lookup, the data stays on our own infrastructure, is never sold or shared, and is never used for advertising. Choose “Essential only” and no analytics runs.
- Third-party request: the site loads typography from Google Fonts (Google LLC). This transmits your IP address to Google as part of the font request; it is a network request rather than a cookie. We intend to self-host the fonts to remove this transfer.
A cookie notice is shown on your first visit with an "Accept all" and an "Essential only" choice. You can change your choice at any time via the Cookie settings link in the footer.
If analytics, a chat provider that sets cookies, embedded video, maps, or any marketing pixel is added later, classify it correctly and gate non-essential categories behind the consent stored in lm_consent before activation. Re-confirm before public launch.
11. Changes to this notice
Layon Med may update this notice from time to time. Material changes are highlighted on the home page. The date of the current version is recorded below.
12. Contact
For privacy enquiries, please use the contact channel published on the home page and reference "Privacy — data subject request" or "Privacy — general enquiry".
Insert dedicated privacy email (e.g. privacy@<owned-domain>) and, where required by GDPR Art. 37, Data Protection Officer name and contact.