PRIVACY POLICY FOR SKINCHANGE.AI

This privacy policy governs your use of the services provided by SkinChange.AI ApS (hereinafter referred to as 'SkinChange.AI', 'we', 'us', or 'our'). Our main purposes are (1) to assist with the identification and tracking of skin changes via our Skin Monitoring APP, and (2) to provide users with quick responses to skin-related inquiries from our team of dermatologists through our Clinic App.
If you have any questions or comments about this privacy policy, you can contact us at info@skinchange.ai.

**Data controller**
SkinChange.AI is the controller for the personal data collected from users. We are committed to handling your personal data in compliance with the European General Data Protection Regulation (GDPR) and applicable local laws. If you reside outside the EU, local data protection laws may also apply, but we will follow the GDPR standards.

We collect only the information necessary for the satisfactory and safe use of our products. You will be asked to give explicit and specific consent for each category of information we collect, and you can withdraw your consent at any time by contacting us at info@skinchange.ai.
When you register for our application, the following information is collected:
- Email address: For sending a sign-in link to verify your identity and grant access to our services.
- Transaction-related information: This includes any information required for billing or purchases you make.
- Images: If you upload pictures of your skin for analysis, they are stored securely for the purpose of providing the service.
- Support data: Any information you provide when contacting our support team.
- Optional Personal Data: You may choose to upload personal details, such as name, date of birth, address, and phone number. Except for the phone number, this is required for identity verification by Danish health authorities and is used for this purpose. Your phone number is used for login and emergency calls.
- Health related data: When uploading a case in our Clinic App, you will be prompted for health-related data relevant to the case.
**Purpose of Use:** This data is used for user authentication, providing personalized service, and fulfilling legal obligations such as identity verification.
We will also use your contact information to send you important notifications, training materials, and, with your consent, marketing materials. You will be able to manage your preferences for receiving marketing communications directly in the app or by emailing us at info@skinchange.ai.

We collect certain information automatically to enhance the app experience:
- Device Information: Including mobile device type, operating system version, and unique device identifiers.
- Interaction Data: Data on how you use the app, such as feature usage and uploaded content.
**Purpose of Use:** Automatically collected data helps us troubleshoot issues, improve app performance, and enhance user experience.

We use cookies and similar technologies to improve the app experience. Cookies help store preferences and enhance performance. You can manage or disable cookies through your browser settings.

Our application does **not** collect precise real-time location information as it is not necessary for the quality of our service.

We do not sell your personal data or share it with third parties for marketing purposes.
Anonymized and aggregated data may be shared with third-party service providers to improve our application, but this data cannot be traced back to you.

We share data with trusted third-party providers who are bound by our privacy policies and the GDPR. These providers include:
- Cloud Storage Providers: For securely storing data.
- Medical clinic partners: For applying and maintaining proper diagnostics.
- Scientific institutions: For understanding app usage patterns and improving functionality.
- Analytics Services: For understanding app usage patterns and improving functionality.
- Payment providers: For state-of-the-art service and secure payment options.

We may also disclose your information:
- As required by law (e.g., to comply with legal obligations or respond to legal processes).
- To protect safety (e.g., if we believe it’s necessary to protect the safety or rights of users, investigate fraud, or comply with government requests).
- In the event of a merger or acquisition: You will be notified via email and/or a prominent notice on our website if there is a change in ownership or use of your data.

As a user, you have specific rights under GDPR regarding your personal data. These include:
- Right to Access: You may request a copy of the personal data we hold about you at any time. Please contact us at info@skinchange.ai to make a request.
- Right to Rectification: You have the right to correct any inaccuracies in your personal data. This can be done via your account settings or by emailing us.
- Right to Erasure ("Right to be Forgotten"): You can request the deletion of your personal data, subject to certain legal conditions. Data that is critical to the functioning of the apps may be retained until your account is deleted.
- Right to Restrict Processing: You can request that we limit the processing of your data under certain conditions (e.g., during disputes regarding accuracy).
- Right to Data Portability: You can request a copy of the personal data you have provided in a machine-readable format. This will be provided to you via email or a download link.
- Right to Object: You may object to the processing of your data, particularly in cases of direct marketing. To exercise this right, adjust your settings within the apps or email us at info@skinchange.ai.
- Right to Withdraw Consent: You may withdraw your consent to data processing at any time by emailing us or using the settings within the apps.

When you request access, rectification, erasure, or portability, we may require additional information to verify your identity before fulfilling your request, ensuring the security of your data.

You have the right to complain regarding the processing of personal data concerning you to the supervisory authority, which in Denmark is the Danish Data Protection Agency:
Datatilsynet Borgergade 28, 1300 København K, Phone no.: +45 3319 3200, E-mail: dt@datatilsynet.dk.

We retain user-provided information for as long as your account remains active and for a reasonable time thereafter, subject to legal requirements. Automatically collected data is retained for up to 24 months.
**Retention Periods:**
- Images and health-related data: Retained for 6 months after account deletion, unless legally required to retain for longer.
- Transaction and support data: Retained for legal and audit purposes for up to 7 years.
- Automatically collected data: Retained for 12 months after inactivity.

You can request data deletion at any time by contacting info@skinchange.ai.

You can manage your data preferences within the apps by adjusting the privacy settings or contacting us directly. To request account deletion, please email info@skinchange.ai. Note that uninstalling the app will not automatically delete your data.

Our services are intended for individuals aged 18 and older, or the legal age in your jurisdiction for consent to internet services. We do not knowingly collect data from children under this age. If a parent or guardian becomes aware that their child has provided us with personal information without their consent, they should contact us at info@skinchange.ai, and we will promptly delete such data.

We are committed to safeguarding your personal data. We use industry-standard security measures, including:
- Encryption: All sensitive data (e.g., images, personal data) is encrypted in transit.
- Access Controls: Only authorized personnel with a legitimate need can access your personal data.
- Regular Audits: We conduct regular security audits to ensure the safety of our systems. In the event of a security breach, we will notify affected users within 72 hours, in compliance with GDPR and other applicable laws.

We may update this privacy policy from time to time. You will be notified of any material changes via email or within the app. Continued use of the apps after such changes indicates your acceptance of the updated policy.

We comply with the European General Data Protection Regulation ("GDPR"). By using our services, you consent to our processing of your information as described in this privacy policy now and as amended by us in the future. 'Processing' means using cookies on a computer/handheld device or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining, and disclosing information, all of which will take place within the EU. If you reside outside Denmark, your information will be transferred, processed, and stored there in accordance with Denmark’s privacy standards, which comply with GDPR.

If you have any questions about privacy while using our services or have questions about our practices, please contact us via email at info@skinchange.ai.