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Last updated: 23 December 2025
Your privacy is important to us. This policy explains how SkinWell collects, uses, and protects your personal data in compliance with UK GDPR and Data Protection Act 2018.
Data Controller: The MedTech Incubator LTD - 16240488 (trading as SkinWell)
ICO Registration Number: Available Soon
Contact:
Email: info@skinwell.uk
Address: 1st Floor, 21 Poland Street, London, United Kingdom,
W1F 8QG
Data Protection Officer: dpo@skinwell.uk
SkinWell is a teledermatology platform that connects patients with GMC-registered practitioners through secure video consultations, AI-powered assessments, and medication delivery services.
Processing necessary to provide our teledermatology services, consultations, prescriptions, and medication delivery as agreed in our Terms of Service.
Healthcare providers must maintain medical records for regulatory compliance, including CQC regulations, MHRA requirements, GMC standards, and NHS Digital guidelines.
In emergencies where patient health requires immediate action and consent cannot be obtained.
Processing health data for medical diagnosis, healthcare provision, treatment management, and healthcare system management by qualified healthcare professionals.
For specific processing activities including AI analysis, marketing communications, consultation recordings, and research participation (always optional and withdrawable).
For service improvement, fraud prevention, security measures, and business analytics (with appropriate safeguards and balancing of interests).
All service providers are bound by Data Processing Agreements compliant with Article 28 GDPR.
We will never sell your personal or health data to third parties. We do not share your data with advertisers or marketing companies without your explicit consent.
When you delete your account, we archive medical records as required by law but immediately remove marketing data and non-essential personal information. Your account becomes inaccessible, but legal retention requirements for medical records remain in effect.
Request a copy of all personal data we hold about you. We will respond within 30 days. Access your data via your account dashboard or contact privacy@skinwell.co.uk.
Correct inaccurate personal data via your account settings or contact us. Medical records require verification for clinical safety.
Request deletion of your data. Important: Medical records must be retained for legal and regulatory periods even after account deletion. Non-essential data will be deleted immediately.
Request that we limit how we use your data in certain circumstances, such as during disputes or verification of accuracy.
Receive your data in a machine-readable format (CSV/JSON) or request transfer to another provider where technically feasible.
Object to processing based on legitimate interests, direct marketing, or research purposes. Marketing opt-outs are always honored immediately.
Our AI analysis is for preliminary assessment only. All clinical decisions are made by qualified dermatologists. You have the right to human review of any AI-generated assessment.
Withdraw consent for specific processing activities (marketing, AI analysis, recordings) at any time via account settings or by contacting us. This does not affect processing based on other legal grounds.
We will respond within 30 days (extendable to 90 days for complex requests). We may require identification verification to protect your data.
In the unlikely event of a data breach, we will notify the ICO within 72 hours (if required) and affected individuals without undue delay. We have incident response plans and cyber insurance in place.
Your data is primarily stored and processed in the United Kingdom. Where we use service providers located outside the UK/EU, we ensure adequate protection through:
Current International Transfers:
Medical data remains in UK/EU data centers only.
Essential for the platform to function. Cannot be disabled.
Enable enhanced features and personalization.
Help us understand how users interact with the platform.
Used to deliver relevant advertising and measure campaign effectiveness.
You can manage cookie preferences through:
- Cookie consent banner on first visit
- Account Settings → Privacy → Cookie Preferences
- Browser settings (may affect functionality)
Our mobile app may collect:
Manage app permissions through your device settings.
Under 18s: SkinWell can provide services to patients under 18 with parental/guardian consent. The account holder must be over 18.
Under 13s: All processing requires explicit parental consent. We may request verification of parental authority.
Gillick Competence: In accordance with UK law, we may provide confidential services to children deemed competent to consent to treatment without parental knowledge, following GMC guidelines.
Safeguarding: We have robust safeguarding procedures. If we identify child protection concerns, we may need to breach confidentiality and contact appropriate authorities.
Data Retention: Children's medical records are retained until age 25 or 8 years after last contact, whichever is longer (NHS standard).
How AI is Used: SkinWell uses AI to provide preliminary analysis of skin condition photos to assist dermatologists. AI does not make final diagnoses or treatment decisions.
Human Oversight: Every case is reviewed by a qualified GMC-registered dermatologist. You have the right to request that decisions are not based solely on automated processing.
Consent: AI analysis requires your explicit consent, which can be withdrawn at any time without affecting your access to human practitioner consultations.
Transparency: When AI is used in your care, you will be informed. AI-generated assessments are clearly marked in your consultation notes.
Training and Improvement: With your consent, anonymized/pseudonymized data may be used to improve AI algorithms. You can opt out of this at any time.
Bias Mitigation: We regularly audit our AI systems for fairness and bias across diverse populations and skin types.
Our platform may contain links to third-party websites, services, or apps:
Important: We are not responsible for the privacy practices of third-party websites. Please review their privacy policies before providing personal information. This privacy policy applies only to SkinWell services.
GP Sharing: We can share consultation summaries and treatment plans with your GP to ensure coordinated care. This requires your explicit consent and can be managed in your account settings.
What We Share: When authorized:
NHS Spine Access: We do not currently connect to NHS Spine but may implement this in future with appropriate patient consent and technical safeguards.
Referrals: If we refer you to NHS services, we will share relevant clinical information with your consent.
We may update this privacy policy to reflect:
Notification: We will notify you of material changes via:
Your Rights: If you disagree with changes, you have the right to close your account (subject to medical record retention requirements).
Version History: Previous versions of this policy are available upon request.
Last Updated: 23 December 2025
If you have concerns about how we handle your data:
We will investigate and respond within 30 days.
You have the right to lodge a complaint with the UK data protection regulator:
Website: https://ico.org.uk
Helpline: 0303 123 1113
Address:
Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire
SK9 5AF
For complaints about clinical care quality:
Personal Data
Any information relating to an identified or identifiable individual.
Special Category Data
Sensitive personal data including health information, requiring enhanced protection under GDPR.
Data Controller
The organization that determines how and why personal data is processed (SkinWell).
Data Processor
Third-party organizations that process data on behalf of the controller (e.g., cloud hosting providers).
Pseudonymization
Processing data so it can no longer be attributed to a specific individual without additional information.
Anonymization
Irreversibly removing identifying information so individuals cannot be identified.
Data Breach
Unauthorized access, loss, or disclosure of personal data.
UK GDPR
UK General Data Protection Regulation - the UK's version of GDPR post-Brexit.
DPA 2018
Data Protection Act 2018 - supplements UK GDPR with additional UK-specific provisions.
For Privacy and Data Protection Matters:
Email: privacy@skinwell.co.uk
Data Protection Officer: dpo@skinwell.co.uk
Phone: [Privacy Team Number]
For General Enquiries:
Email: support@skinwell.co.uk
Phone: [Support Number]
Live Chat: Available in app and website
Registered Address:
MedTech Inc (trading as SkinWell)
[Company Address]
Company Number: [Companies House Number]
ICO Registration: [ICO Registration Number]
CQC Registration: [CQC Registration Number]
Download SkinWell and get a expert diagnosis within 24 hours. The future of skincare is in your pocket.
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