Terms & Conditions - Online AI Dermatologist

Effective Date: 19 April 2025
Last Updated: 19 April 2025

Skinive Holding B.V. (“we,” “our,” or “us”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, share, and safeguard your personal information when you use the Skinive and Skinive MD mobile applications and our website at www.skinive.com (together, the “Services”).

This Policy complies with the General Data Protection Regulation (GDPR), the Medical Device Regulation (MDR, EU 2017/745) for CE Class I medical software, and other applicable laws and regulations.

By using our Services, you agree to the practices described in this Privacy Policy.

1. Data Controller

Skinive Holding B.V.
1054 ZL, Jacob Van Lennepkade 155 H, Amsterdam, The Netherlands

Chamber of Commerce (KVK) number: 80416780

2. Types of Personal Data We Collect

We only collect personal data that is necessary for the purposes described in this policy.

2.1. General Data

• Email address (if provided voluntarily for support or feedback)
• IP address (anonymized where possible)
• Device information (type, OS version, language settings)
• Approximate location (via IP address)
• Google Advertising ID (AAID/IDFA)
• Usage and behavioral data (via analytics tools)

2.2. Health and Sensitive Data (Special Category under Article 9 GDPR)

• Photos of skin conditions uploaded by users
• AI-generated results and classification
• Metadata from scans (e.g., date, time, image context)
• Optional information (e.g., age, skin type, symptoms, history)

Note: The App may be used anonymously. No account or real-name registration is required to access the core functions.

3. Purposes of Data Processing

Your personal data is used for the following purposes:

• To deliver core functionality: AI-based skin health assessments
• To meet regulatory obligations under MDR and CE certification
• To improve algorithm performance (using anonymized data)
• To respond to support and feedback requests
• To analyze and optimize usability and engagement
• To ensure platform security, detect misuse or fraud
• To display non-personalized or consent-based personalized ads (free version only)

4. Legal Bases for Processing (GDPR Articles 6 & 9)

We process your data under one or more of the following legal bases:

• Consent (Art. 6(1)(a)): For submission of health data and ads personalization
• Contract (Art. 6(1)(b)): To provide services as described in the App
• Legal Obligation (Art. 6(1)(c)): For MDR compliance and safety regulations
• Legitimate Interest (Art. 6(1)(f)): For service integrity, analytics, fraud prevention

For sensitive data (e.g., skin photos), we rely on explicit user consent under Art. 9(2)(a) of GDPR.

5. Data Subject Rights (GDPR Articles 12–23)

You have the following rights regarding your personal data:

• Access to your data
• Rectification of inaccurate or incomplete data
• Erasure (“Right to be forgotten”)
• Restriction of processing
• Data portability
• Objection to certain processing activities
• Withdrawal of consent at any time (does not affect prior lawful processing)

To exercise your rights, contact us at: info@skinive.com

6. Data Retention Periods

We retain your data only as long as needed for the stated purposes:

Data Type	Retention Period
Diagnostic scans & results	Up to 12 months (anonymized)
Support messages	Up to 24 months
Analytics (Firebase, etc.)	Up to 26 months
Ad preferences	Until withdrawn by the user

You can request deletion of your data at any time.

7. Data Security Measures

We implement robust technical and organizational measures to safeguard your data:

• HTTPS for all data transfers
• Encrypted storage of photos and results
• Role-based access control
• Regular vulnerability assessments and audits
• Access logging and monitoring

8. International Data Transfers

Some processors (e.g., Google LLC) are located outside the EEA. Where data is transferred internationally, we ensure:

• Standard Contractual Clauses (SCCs) are in place
• Data minimization and encryption are applied
• Compliance with GDPR adequacy requirements

9. Use of Third-Party Services

We engage the following data processors under GDPR-compliant contracts:

9.1. Google Firebase (Google LLC)

• Purpose: Crash reporting, performance monitoring, analytics
• Data: Device ID, OS version, crash logs
• Location: USA (SCCs apply)

9.2. Google Analytics for Firebase

• Purpose: Usage behavior analysis
• Data: Anonymized IPs, session length, feature use

9.3. Google AdMob

• Purpose: Personalized and non-personalized advertising
• Data: Advertising ID, usage patterns
• Consent: Required from EEA users via Consent SDK

All processors are required to process data solely under our instructions and in accordance with this policy.

10. Children’s Privacy

Our Services are not intended for individuals under 16 years of age without verifiable parental consent. We do not knowingly collect personal data from children.

11. Cookies and Tracking Technologies

We use cookies and similar tools for the following purposes:

• Essential cookies: Enable basic App/website features
• Analytics cookies: Monitor usage (Google Analytics)
• Consent management tools: For GDPR/EEA users

You can manage your cookie preferences in-app, via device settings, or the cookie banner on the website.

12. Advertising and User Consent

In the free version of the App, we use Google AdMob to show ads:

• Consent for personalized ads is requested during onboarding (for EEA users)
• You can withdraw or change your consent anytime via App settings
• No email marketing or newsletters are sent unless explicitly opted in

13. Medical Disclaimer

Skinive is a CE Class I medical device designed for self-monitoring and educational purposes. It is not a substitute for professional medical advice, diagnosis, or treatment. Users should consult healthcare providers for clinical concerns.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates will be reflected by a new “Effective Date” at the top of this page. We encourage you to review the Policy regularly.

15. Contact Us

For questions, concerns, or data subject rights requests:

Skinive Holding B.V.
1054 ZL, Jacob Van Lennepkade 155 H, Amsterdam, The Netherlands
Send email: https://skinive.com/contacts/ 

 

Effective Date: 19 April 2025
Last Updated: 19 April 2025

At Skinive, we are committed to protecting your privacy and complying with applicable regulations, including the General Data Protection Regulation (GDPR) and the EU Medical Device Regulation (MDR, Class I). As CE-marked medical software, we ensure that all data collected and processed — including data through cookies and similar tracking technologies — is handled transparently, securely, and with your informed consent.

This Cookie Policy explains what cookies are, how and why we use them on our website and apps, and how you can control your cookie preferences.

For more information on how we handle your personal data, please refer to our full Privacy Policy.

1. What Are Cookies?

Cookies are small text files that websites store on your device to collect certain information about your visit. They are commonly used to enable core website functionality, enhance user experience, and gather analytics.

Cookies used on this site may be:

• First-party cookies (set by Skinive)
• Third-party cookies (set by external providers such as Google, Meta, or Firebase)

Some cookies are essential for the operation of our site or medical-grade digital services. Others help us improve usability, performance, and marketing effectiveness.

2. Legal Basis for Processing

In compliance with GDPR Article 6, we use cookies based on the following lawful bases:

• Strictly necessary cookies: Legitimate interest (for site/app operation)
• Analytics, marketing, and preference cookies: Your explicit consent, which can be managed or withdrawn at any time via the Cookie Banner or Settings.

As a CE-marked medical software provider, we take extra care to ensure that data collected via cookies is not used for medical profiling or automated decision-making without your knowledge and consent.

3. Why We Use Cookies

We use cookies and similar technologies for the following purposes:

• 🔧 Strictly Necessary – To ensure basic functionality, security, and user session management.
• 🎛️ Preferences – To remember your settings and user interface choices.
• 📈 Analytics – To understand how users interact with our website or app (e.g., via Google Analytics, Firebase).
• 📢 Marketing and Advertising – To deliver relevant ads and measure ad performance (e.g., via Google AdMob).
• 🔗 Third-Party Integrations – To provide enhanced services (e.g., embedded videos, social media buttons).

4. Cookies and Services We Use

Category	Provider	Purpose	Examples	Duration
Strictly Necessary	Skinive	Session control, cookie banner, security	cookie_consent, session_id	Session / 1 year
Preferences	Skinive	Save language or layout settings	lang_pref, user_ui_settings	6 months – 1 year
Analytics	Google Analytics, Firebase	Track usage and performance metrics	_ga, _gid, _firebase_analytics	1 day – 2 years
Marketing & Ads	Google AdMob	Show relevant ads, measure conversions	IDE, ANID, gads, fcid	1 month – 1 year
Social / Embedded Media	YouTube, Facebook	Embedded videos, social sharing functionality	YSC, VISITOR_INFO1_LIVE, fbp	Session – 6 months

All third-party providers are selected based on their compliance with GDPR and their commitment to secure processing. Data may be stored or processed in the EEA or in third countries with appropriate safeguards (e.g., Standard Contractual Clauses).

5. Managing Your Cookie Preferences

You can manage or withdraw your consent at any time through:

🧭 Cookie Banner or Consent Manager

• Accept all cookies
• Reject non-essential cookies
• Customize preferences by category

🌐 Browser Settings

You can also disable cookies through your browser settings. For example:

• Chrome
• Firefox
• Safari
• Edge

Note: Disabling cookies may affect functionality of the site or app features, especially those related to user login, personalization, or analytics.

6. Use of Cookies in the Skinive App

Our mobile apps also use cookies and SDK-based tracking technologies to support essential features and analytics. These include:

• Firebase Analytics (to track app usage)
• Firebase Crashlytics (to detect errors)
• Google AdMob SDK (for monetization and ad targeting)

You can opt out of ad personalization in the app’s settings or in your device settings (e.g., “Limit Ad Tracking” on iOS or “Opt out of Ads Personalization” on Android).

7. Changes to This Policy

We may update this Cookie Policy to reflect changes in our technology, regulations, or company practices. Any updates will be posted on this page with the updated effective date.

Last updated: 19 April 2025

8. Contact Us

For questions about this policy or your data rights, please contact:

Skinive Holding B.V.
1054 ZL, Jacob Van Lennepkade 155 H, Amsterdam, The Netherlands
Send email: https://skinive.com/contacts/ 

Terms of Use – Skinive
Last updated: [April 2025]

Welcome to Skinive! These Terms of Use (“Terms”) govern your use of our mobile applications (Skinive App and Skinive MD App) and website (skinive.com), operated by Skinive B.V., a company registered in the Netherlands. Please read them carefully before using our Services.

These Terms are originally written in English. In case of translation into other languages, the English version shall prevail in the event of conflict.

1. Acceptance of Terms

By accessing or using the Services, you agree to be bound by these Terms. If you do not agree, do not use the Services.

2. Description of Services

Skinive offers AI-powered skin monitoring and risk assessment tools that help users screen visible skin conditions. These Services are intended for informational and educational purposes only and are not a substitute for professional medical advice, diagnosis, or treatment.

Intended Purpose

Skinive App is a software medical device (SaMD) classified as Class I under MDR (EU) 2017/745. It analyses images of human skin (3- 65+ years old) captured with a smartphone camera to assist users in recognising visual similarities between skin conditions and reference cases in the database.

The app assists users in identifying and documenting potential skin conditions for further medical evaluation, enhancing skin health monitoring and awareness.

It supports users in monitoring skin lesions and determining whether to seek professional medical advice. It is not a diagnostic tool and is not intended to replace consultation with healthcare professionals.

This classification (Class I MDR) applies only to the Skinive App / Skinive MD app in its intended use and may be subject to different classification in other jurisdictions.

3. AI-Based Technology and Data Sources

The AI Skin Scanner uses advanced artificial intelligence to assess images of skin lesions and moles. It is trained on an extensive medical database that includes clinical guidelines and peer-reviewed literature from sources such as:

• PubMed
• American Academy of Dermatology (AAD)
• Skin Cancer Foundation
• National Rosacea Society
• National Center for Biotechnology Information (NCBI)
• ResearchGate

The AI system is continuously updated with recent clinical studies to improve its ability to recognize both common and potentially serious skin diseases. Each image submitted by the user is analyzed using AI-driven pattern recognition and compared with medical reference data. Users receive a preliminary risk rating along with informative content to help them make informed decisions about seeking professional medical care.

The AI-generated risk assessments are not intended to replace clinical judgment or be used as the sole basis for clinical decision-making.

4. Intellectual Property

All content, algorithms, trademarks, AI models, and intellectual property associated with the Services are owned by Skinive Holding B.V. or its licensors. Unauthorized use, reproduction, or modification is strictly prohibited.

5. Eligibility

You must be at least 16 years old or have the consent of a legal guardian to use our Services. By using the Services, you confirm that you meet this requirement.

6. Right of Withdrawal

You have the right to withdraw from your subscription within 14 days of purchase and request a refund according to App Store or Google Play refund policies via your account settings in App Store or Google Play.

7. Subscriptions and Payments

Some features require a paid subscription. Payments are processed through the Apple App Store or Google Play Store.

• Free Trial: If eligible, your subscription will auto-renew unless canceled at least 24 hours before the trial ends.
• Auto-renewal: Subscriptions renew automatically unless canceled. You can cancel via your device settings.

8. Modifications to Terms

We may update these Terms periodically. If material changes are made, we will notify you by email or in-app message. Continued use after updates means you accept the new Terms. Material changes include but are not limited to changes in intended use, functionality, legal disclaimers, or user rights under applicable laws.

9. License and Restrictions

We grant you a limited, non-exclusive, non-transferable license to use the Services for personal, non-commercial use. You agree not to:

• Copy, modify, or distribute the Services or their content;
• Use the Services for unlawful or harmful purposes;
• Reverse engineer or attempt to extract source code.

10. No Medical Advice

The Services do not provide medical advice and are not intended to diagnose, treat, cure, or prevent any disease. Always seek the advice of a qualified healthcare provider for medical concerns. By using the Services, you confirm your understanding of this limitation.

Skinive does not assume any liability for clinical decisions or medical outcomes resulting from the use or interpretation of information provided by the Services.

11. Important Warnings and Limitations

• The Skinive App is not a diagnostic tool.
• The app is intended only for informational support.
• The AI-generated assessments must not be used as the sole basis for any healthcare decisions.
• Always consult a healthcare professional if you have any concerns about your skin or health.

Skinive shall not be held liable for actions taken by users based on the information provided by the app, including any health-related decisions.

12. Privacy

Your privacy is important to us. Our Privacy Policy explains how we collect, use, and protect your data.We process your personal data in accordance with the EU General Data Protection Regulation (GDPR). By using our Services, you consent to data processing as described in PRIVACY POLICY.  

13. Termination

We reserve the right to terminate or suspend your access if you violate these Terms. You may stop using the Services at any time by deleting your account or/and app. Upon termination, your license to use the Services ceases immediately. We may retain your data for a limited period in accordance with our Privacy Policy and applicable law.

14. Governing Law and Jurisdiction

These Terms are governed by the laws of the Netherlands. Any disputes shall be submitted to the competent court in the Netherlands unless otherwise required by EU consumer protection laws.

15. Availability and Compliance

The Skinive App is intended for use in jurisdictions where it complies with local medical device regulations and where CE-marked Class I medical devices may legally be distributed and used.

It is the user’s responsibility to ensure that using the Services is legal in their local jurisdiction, particularly in relation to the use of AI-based medical software.

16. Force Majeure

Skinive shall not be liable for any failure or delay in performance resulting from causes beyond its reasonable control, including but not limited to pandemics, regulatory changes, sanctions, supplier failures, acts of God, cyber attacks, internet outages, or governmental actions.”

17. Contact Us

Skinive Holding B.V.
1054 ZL, Jacob Van Lennepkade 155 H, Amsterdam, The Netherlands
Send email: https://skinive.com/contacts/