At Snapmed we work side by side with technical personnel to develop and provide dermatology advice. At Snapmed, you as an individual and client always comes first, and this Privacy Statement ("Privacy Statement") explains how Snapmed treats your personal information when you seek assessment and advice.
Snapmed explains in this privacy statement how Snapmed works for you as a client and who is responsible for the processing of your personal information. We also describe what personal information about you is being treated when using the services, how Snapmed processes your personal information and why. We also describe the legal basis for Snapmed's treatment and which external parties can process personal information about you to provide you with the services. You also get information about your rights in processing your personal information and about what you can do to exercise these rights.
2. Who is responsible for the processing of personal data?
Snapmed AS, organization no. 917 447 128 ("Snapmed") owns and makes available the technical platform and is the handling officer for the personal information that you register on the web pages. If you have questions or comments regarding the processing of your personal information in connection with your use of the services, you are always welcome to contact us by sending an email to firstname.lastname@example.org.
If you have questions or comments regarding the processing of your personal information in connection with your use of the services, you are always welcome to contact Snapmed by sending an email to email@example.com.
3. Where does Snapmed get your personal information processed when you use the Services?
3.1. Personal information registered through your user account
Snapmed processes your personal information, which you register through the account, such as your name, social security number, address and e-mail address when you open a user account with us, and then any information you register when using the services. In addition, we can collect and process the following information automatically: i) technical information including IP address, login information, type and version of operating system and device, time settings, language settings, cookies and the like; and (ii) information about the services Snapmed delivers to you, as well as keystrokes.
Snapmed calls these categories of personal information, which you specify when using the web pages, "User Data" below.
Snapmed calls these categories of personal information, which you specify when using the web pages, "User Data" below.
3.2. Personal data to and from Snapmed
When you wish to receive advice from Snapmed, you are asked to share information about symptoms of your skin change. You do this mainly by a text description and two images of the area where skin change is visible. This information may include, but is not limited to, information that you are suffering from a disease, your medical history or your physiological or medical condition. The medical personnel who consider the documentation you have submitted will store this information in Snapmed's systems. The information will only be available to you and the physician who provides the assessment, and neither other doctors, other Snapmed employees nor the technical personnel of the subcontractor will have access to this. The basis for storing the information is to give you access to your information in the assessment that has been made and to allow the doctor to see the condition in connection with any future skin changes you want to submit. You are free to retrieve and delete your data after the assessment has been made.
Personal information related to your health as Snapmed uses to provide counseling is referred to below as "User Data".
4. Where are your personal details stored?
The technical platform is owned by Snapmed and controlled by our subcontractor Last Friday ("Subcontractor"). The technology is further developed and quality assured continuously. Most of your personal information we collect when you use the services will not be stored on your smartphone or tablet. Instead, these personal data are stored by the infrastructure provided by our subcontractor. Personal data is handled and stored within the EU / EEA, and no sensitive personal information, such as information about your health, is stored outside the EU / EEA in connection with your use of the Services. Snapmed is obliged to keep patient records when the Services are performed and relevant user data is entered in a patient record system specifically designed to meet the requirements of current legislation. The personal data in your patient record are handled and stored within the EU / EEA.
5. Why is personal information processed when using Snapmed?
5.1. Snapmed´s processing of your user data
Snapmed processes your user data (as described in section 3.1) for the following purposes:
- i) To process your request or terminate your user account,
- ii) To give you permission to log in and use your user account,
- iii) To confirm your identity and age,
- iv) To keep accurate and up to date information about you,
- v) In order for you to be able to monitor and manage assessments,
- vi) To manage your settings and payment information, and
- vii) in other ways to provide the Services to you in accordance with our General Terms and Conditions.
The legal basis for processing your user data is that it is necessary to fulfill Snapmed's contract, which constitutes our General Terms, for the purpose of providing the services, including enabling health professionals to properly evaluate your condition.
5.2. Snapmed´s delivery of advice
Snapmed treats patient data (as described in section 3.2) for the purpose of providing Services in the form of assessment when people experience a skin change they want advice about.
As an adviser in health issues, Snapmed is regulated by its national business. Snapmed therefore processes your personal information in accordance with applicable law. The processing of your patient data required to provide the Services is also required to fulfill any other legal obligations for Snapmed. This implies that health professionals affiliated with Snapmed carry patient records, which Snapmed is obliged to keep for a specified period of time.
Snapmed uses subcontractor to ensure the quality and development of the Services. In this way, the subcontractor can process (work technically and store) sensitive personal information about you to ensure high security and quality in information.
Anonymous data that does not contain personal information may be shared by Snapmed with a subcontractor to develop the Services and develop Snapmed's business activities.
5.3. Delivery of support services in connection with your use of Snapmed
Sapmed and subcontractor can communicate with you as a user of the Services. This includes answering inquiries and investigating complaints and conditions regarding support (including technical support) through our support services by phone or digital channels. Depending on your circumstances, you can share additional user data and patient data that Snapmed then processes to assist you in using the Services in the best possible way.
Snapmed and Subcontractor provide support as described above as part of the Services (ie, required to fulfill the contract with you and Snapmed). To the extent that the support services are associated with counseling or treatment of patient data (or sensitive personal information about you), the treatment takes place to provide advice as part of the Services and to ensure high quality advice. The processing of your personal information regarding support services may also take place in order for Snapmed to comply with its legal obligations in accordance with current health legislation (see also section 5.5 below).
5.4. In order to market products and services and improve your user experience
Snapmed processes some of your user data (as described in section 3.1) for the following purposes: direct marketing to you by email or through text messages, or other similar electronic communications channels, for example in connection with promotions and offers in collaboration with Snapmed partners .
The information about you as a user is also used for marketing purposes. Marketing is sent to you by email on the basis of your consent, which you may at any time withdraw in accordance with section 9 below.
5.5. In order to fulfill legal obligations
Snapmed and Subcontractor may process your User Data and Patient Data (as described in Section 3.1-3.2) as necessary to fulfill its legal obligations as set out in statutes, court orders or decisions by public authorities.
Otherwise, Snapmed stores and processes your personal information to the extent necessary to fulfill our legal obligations and requirements.
5.6. In order to evaluate, develop and improve the quality of services
Snapmed and Subcontractor can process your user data to develop and improve the Services and IT systems used to deliver the Services. This is done on the basis of our legitimate interests in constantly improving the security and processing of personal data and for making the services more user friendly, for example, by changing the user interface to facilitate the flow of information or to highlight features commonly used by users.
Snapmed only treats sensitive personal information about you in order to provide advice on issues related to high quality skin changes and provide advice in accordance with applicable legislation. All other development of our Services is carried out using anonymous data.
6. How long does Snapmed store your personal information?
Snapmed processes your personal information only for as long as necessary for the purpose of processing the relevant information, in accordance with Section 5 above. This means as long as it is necessary to provide good advice or to otherwise provide services to you or to fulfill legal obligations. Snapmed has the duty to store patient records in connection with counseling to you for a specified period of time. Snapmed also has procedures for how Snapmed stores or anonymizes personal information to ensure that your personal information is always sufficient and relevant to Snapmed's continued delivery of the Services. Your user data will be deleted or anonymized within six (6) months of the date you have terminated your user account, provided that it is not necessary to store personal information in order for Snapmed to fulfill our legal obligations or if the information is required otherwise to enforce legal requirements.
After the purpose of processing personal information is met, all information that is not required for the fulfillment and development of the Services, or to ensure quality, anonymous and stored, or deleted automatically. User data stored on the basis of your consent will be deleted by Snapmed if you withdraw your consent. You can read more in Section 9 on how to exercise your right to withdraw your consent.
8. Transfers to third countries
Snapmed and Snapmed's subcontractor do not use IT vendors for operating services outside the EU / EEA. This means that Snapmed and Subcontractor will not transfer your personal information outside the EU / EEA.
9. Your rights as registered as Snapmed user
You are entitled to receive information about what personal information about you Snapmed treats, the purpose of the treatment, whether such personal data has been transferred to a third country and which parties have received your personal information.
To clarify this, you can contact Snapmed at any time to:
- Ask for access to, and information about, the personal information processed in connection with your use of Snapmed;
- Ask Snapmed to correct any errors in your information;
- Ask Snapmed for your personal information to be deleted (however, Snapmed asks you to note that Snapmed has certain statutory obligations to store personal information, especially in relation to patient data, including the keeping of patient records in connection with the use of the Services). At your request, all patient data such as Snapmed will not have a legal obligation to store will be deleted;
- Ask Snapmed to restrict the processing of your personal information when you believe that these data are incorrect; that Snapmed's treatment is illegal; or that Snapmed no longer needs to process this data for a particular purpose unless Snapmed is unable to erase data due to a legal obligation or other obligation or because you do not want Snapmed to delete them;
- Protest against the processing of your personal data when the legal reason for Snapmed's processing of your personal information is Snapmed's legitimate interest. Snapmed will comply with your request unless Snapmed has heavily legitimate reasons for the treatment that overrides your interests and rights, or if Snapmed may continue to process the data in order to maintain, exercise or defend a legal claim;
- If Snapmed uses your personal information on the basis of your consent, you may at any time withdraw your consent at no charge. This also includes if you wish to opt out of marketing notices. Note that Snapmed and Snapmed's subcontractor handle your personal information for various purposes (both as a technical supplier, but also as a supplier of advice). Withdrawal of consent does not affect Snapmed's obligation to keep patient records or process your personal information in accordance with applicable law; or
- Request that your personal information be transferred to another personal data controller, insofar as you have provided them, in an electronic format commonly used to transfer them to another party (the right to data portability).
If you wish to contact Snapmed regarding any of the above items, Snapmed encourages you to send an email to firstname.lastname@example.org.