Privacy Policy

Effective Date: Apr. 6, 2017

SkinIO understands how important the privacy of personal information is to our users. You can visit SkinIO.com without revealing personal information. However, you are required to provide identifiable information to obtain personalized information and services. This Privacy Policy will tell you what information we collect about you. We urge you to read this Privacy Policy carefully. If you have any questions, please contact our Privacy Officer by email at privacy@skinio.com.

We have organized this Privacy Policy under the following topics:

About Our Privacy Policy

We adhere to healthcare industry privacy standards and comply with our own privacy practices. We will inform you of the following in this Privacy Policy:

Use of Our Service

This Privacy Policy applies to the SkinIO website, software, interactive tools, and applications owned and operated by SkinIO, LLC. For purposes of this Agreement, the term “Service” shall also include SkinIO software, applications, and interactive tools (unless otherwise noted).

The SkinIO Service contains links to other websites. Once you enter another website (whether through a service or content link), be aware that SkinIO is not responsible for the privacy practices of these other websites. We encourage you to look for and review the privacy statements of each and every website that you visit.

We hope that reading our Privacy Policy helps you understand how we manage information about you. While you may use some of the functionality of SkinIO without registration, many of the specific tools and services require registration. If you use our services without registering, the only information we collect will be Non-Personal Information through the use of Cookies or Web Beacons. If you choose to register for services, we require you to submit Personally Identifiable Information. Depending on the service you have selected, we may also collect information related to your health. For purposes of this policy, we will generally refer to your health information as “Personal Health Information.” You are responsible for ensuring the accuracy of the Personally Identifiable Information and Personal Health Information you submit to SkinIO. Inaccurate information will affect the information you receive when using our Website and tools and our ability to contact you as described in this Privacy Policy. For example, your email address should be kept current because that it is how we communicate with you.

Non-Personal Information We Collect About You

Even if you do not register with SkinIO, we collect Non-Personal Information about your use of our services. Non-Personal Information includes any information that we gather as you navigate our Service, such as your browser type, pages viewed, and the time spent on the Service.

IP Addresses

We collect and log the IP address of all visitors to SkinIO. An IP address is a number automatically assigned to your computer whenever you access the Internet. IP addresses allow computers and servers to communicate with one another. We collect IP address information so that we can properly administer our system and gather aggregate information about how our Website is being used, including the pages visitors are viewing. To maintain your anonymity, we do not associate IP addresses with records containing personal information. We will use IP address information, however, to personally identify you in order to enforce our legal rights or when required to do so by law enforcement authorities.

Cookies

We collect Non-Personal Information about your use of our Service. Every device access of the SkinIO Service is assigned a different cookie by SkinIO. The information collected by cookies (i) helps us generate content on Web pages, and (ii) allows us to statistically monitor how many people are using our Service. We may use cookie information to determine the popularity of certain content. Cookies are also used to facilitate a user’s log-in, as navigation aids, as session timers, and to restrict underage use.

Most browser software can be set to reject all cookies. You can generally find instructions on how to reset the browser to reject cookies in the “Help” section of the toolbar. If you reject our cookies, certain functions and conveniences may not work properly, but you do not have to accept our cookies in order to productively use the Service. We do not link Non-Personal Information from cookies to Personally Identifiable Information without your permission and do not use cookies to collect or store Personal Health Information about you.

Web Beacons

We also may use web beacons to collect Non-Personal Information about your use of our Service. The information collected by web beacons allows us to statistically monitor how many people are using our Service. Our web beacons are not used to track your activity outside of our Service. We do not link Non-Personal Information from web beacons to Personally Identifiable Information without your permission and do not use web beacons to collect or store Personal Health Information about you.

Unique Identification Key

A unique identification key is a string of characters that is incorporated into a device by its manufacturer and can be used to uniquely identify that device (for example an IMEI-number of a mobile phone). Different device identifiers vary in how permanent they are, whether they can be reset by users, and how they can be accessed. A given device may have several different unique identification keys. Unique identification keys can be used for various purposes, including security and fraud detection. We collect unique identification keys so that we can properly administer our system and gather aggregate information about how our applications and interactive tools are being used. To maintain your anonymity, we do not associate unique identification keys with records containing Personally Identifiable Information and Personal Health Information.

Personally Identifiable Information We Collect About You

You may need to provide personal information in order to use some of our services. We collect Personally Identifiable Information – like your name, email address, date of birth, and location – you provide to us when you register as a member of SkinIO and/or when you update your member profile. We use this Personally Identifiable Information to respond to your questions, provide the specific services you and your healthcare provider select, send you emails about maintenance and updates, and inform you of significant changes to this Privacy Policy.

Registered Users

As a registered member of SkinIO, you may choose to use certain SkinIO interactive content, applications, tools, and services that may ask you to voluntarily provide other types of information about yourself. We use Personally Identifiable Information, such as your name, address, telephone number, email address, healthcare provider affiliation, address, user name and password, to uniquely identify you and your use of SkinIO services. SkinIO may use your Personally Identifiable Information to: (1) authenticate your use of our services; (2) provide requested services (including but not limited to the sharing of image notes between you and your healthcare provider); and (3) analyze de-identified data in aggregate.

We also collect and transmit Personal Health Information that either you or your healthcare provider submits to SkinIO.

Communication With and By Providers

SkinIO has the ability to use your Personally Identifiable Information to send you emails notifying you of new or additional image notes submitted by your healthcare provider(s). You also have the ability to create image notes to be viewed or shared with your participating healthcare provider(s).

By registering with SkinIO, you specifically authorize SkinIO to use and disclose your Personal Health Information and Personally Identifiable Information electronically to your healthcare provider(s) and as further set forth in our agreement with your participating healthcare provider(s).

You specifically acknowledge and understand that when you register with SkinIO, both you and your participating healthcare provider(s) will have access to your Personal Health Information and Personally Identifiable Information (including but not limited to uploaded image notes taken by either you or your healthcare provider).

If you do not want your healthcare provider(s) to have access to your Personal Health Information or Personally Identifiable Information through SkinIO, do not upload images and unsubscribe to our services.

We enter into separate agreements with participating healthcare providers. Some of the tools do not retain your Personal Health Information, while others store your Personal Health Information in accordance with our agreements with your healthcare provider(s) or how you otherwise authorize us.

Emails You Send to SkinIO

This Privacy Policy does not apply to content, business information, ideas, concepts, or inventions that you send to SkinIO by email. If you want to keep such information private or proprietary, do not send it in an email to SkinIO. Email communication that you send to us via the email links on our Service may be shared with a customer service representative, employee, or agent that is most able to address your inquiry. We make every effort to respond in a timely fashion once communications are received. Once we have responded to your communication, it is discarded or archived, depending on the nature of the inquiry.

The email functionality on our Service does not provide a completely secure and confidential means of communication. It is possible that your email communication may be accessed or viewed by another Internet user while in transit to us. If you wish to keep your communication private, do not use our email.

BY USING THIS WEBSITE, YOU AGREE NOT TO USE EMAIL AND OTHER FORMS OF ELECTRONIC COMMUNICATION FOR TREATMENT PURPOSES.

Disclosure of Your Information

The primary purpose of SkinIO is to facilitate the informed tracking of your skin through images, an activity which may also include electronic delivery of images between you and your healthcare provider(s). By registering with SkinIO for our services, you authorize the electronic use and disclosure of your Personal Health Information and Personally Identifiable Information between you and your healthcare provider(s). Except as described in this Privacy Policy or as specifically agreed to by you, SkinIO will not disclose any Personally Identifiable Information or Personal Health Information it gathers from you to anyone other than your healthcare provider(s) unless necessary - to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order. In the event that we are legally compelled to disclose your Personally Identifiable Information or Personal Health Information to a third party, we will attempt to notify you unless doing so would violate the law or court order. In addition, we may disclose Personally Identifiable Information or Personal Health Information upon your authorization or as otherwise described in this Policy or as described below.

Disclosure to SkinIO Operations and Maintenance Contractors

SkinIO operations and maintenance contractors sometimes have access to your Personally Identifiable Information and Personal Health Information in the course of providing products or services to SkinIO. These contractors include vendors and suppliers that provide us with technology, services, and/or content for the operation and maintenance of our services. Information provided to these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for SkinIO. We also contractually require that our operations and maintenance contractors (1) protect the privacy of your Personally Identifiable Information and Personal Health Information consistent with this Privacy Policy, and (2) not use or disclose your Personally Identifiable Information and Personal Health Information for any purpose other than providing us with products and services or as required by law.

Disclosure to Linked Sites

For your convenience there are links to Third Party websites operated by companies that are not affiliated with SkinIO and that do not have contracts to provide content or services through SkinIO. These links may be referenced within content. SkinIO does not disclose your Personal Information or Personal Health Information to these Third Party websites without obtaining your authorization. Further, SkinIO does not endorse and is not responsible for the privacy practices of these websites. If you choose to link to one of these Third Party websites, you should review the website’s privacy policy to understand how it collects and uses your Personally Identifiable Information.

Disclosure of Aggregate Information

SkinIO may provide Aggregate Information to third parties. For example, we might inform third parties on the number of users of our services and the activities they conduct while using our services. Depending on the circumstances, we may or may not charge third parties for this Aggregate Information. We require parties with whom we share Aggregate Information to agree that they will not attempt to make this information personally identifiable, such as by combining it with other databases.

How SkinIO Handles Privacy and Security Internally

Here Are Some of the Security Procedures that SkinIO Uses to Protect Your Privacy:

SkinIO Provides Additional Protection for Your Personal Health Information as Follows:

Despite SkinIO’s efforts to protect your Personally Identifiable Information and Personal Health Information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted.

Updating Your Information and Contacting SkinIO

Updating Your Personally Identifiable Information

SkinIO applications, services, or tools that collect and store self-reported data allow you to update or review information you have submitted by going back to the specific application or service and logging in. SkinIO may store user submitted data in an active database for a period of six months. After six months, user submitted data, will be held in an active database or on an inactive back-up medium for a period of not less than six years unless otherwise required by our participating agreement with your healthcare provider(s) or law.

Updating Your Personal Health Information

Self-Reported Information – Please log in to the SkinIO and access your “settings” tab; the functions will show you how to update or review your information. We remove Personal Health Information only at the request of the authorized user. In order to verify that only authorized users may request removal of their Personal Health Information, we require you to send a signed statement, including your name, address, email address and birth date, to the address below authorizing SkinIO to remove your Personal Health Information from our active databases. Upon receiving your request, your personal health identifiers stored in active databases will be removed so that you cannot be identified or associated with any Personal Health Information you have previously provided. Mail your requests to:

SkinIO
320 West Ohio Street 3W
Chicago, IL 60654

We will notify you within 30 days of receipt of your letter to confirm that your personal health identifiers have been removed.

Limitations on Removing or Changing Information

You should be aware that it is not technologically possible to remove from our servers and the servers of our contractors each and every record of the information you have provided to SkinIO.

We are not responsible for any information provided to your healthcare provider(s). Once your healthcare provider has access to Personal Health Information or Personally Identifiable Information provided through SkinIO, such information will become part of your healthcare provider’s medical record and maintained in accordance with applicable laws.

Changes to this Privacy Policy

Personally Identifiable Information – We will inform you of a material change to the Privacy Policy, which means a change that expands the permissible uses or disclosures of Personally Identifiable Information allowed by the prior version of the Privacy Policy. Your continued use of the SkinIO Service will indicate acceptance of the changes. You may, of course, choose to Opt-out of continuing to use the SkinIO Service. Please exit the Service immediately if you do not agree to the terms of this Privacy Policy or any revised policy.

Personal Health Information – We will inform you if a material change in the Privacy Policy is made that involves the use of your Personal Health Information, and your express authorization will be requested. If you choose not to accept the new Privacy Policy, then the current Privacy Policy conditions will remain in effect, as long as SkinIO continues to make the functionality available. SkinIO reserves the right to discontinue or limit functionality in all its products.

Non-Significant Changes – SkinIO may make non-significant changes to the Privacy Policy that do not affect Personally Identifiable Information or Personal Health Information. In these instances, SkinIO may not notify you of such non-significant changes. If we decide to change our Privacy Policy, we will post those changes to this privacy statement and the home page, and other places appropriate throughout our Service so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this Privacy Policy from time to time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email (if applicable) and by means of a notice on our home page.

Our Users and Certain Disclosures

Our users come to SkinIO for varied reasons. In each case the user will be asked to provide certain information that may include Personally Identifiable Information or Personal Health Information. The provision of Personally Identifiable Information or Personal Health Information makes each user subject to the applicable terms and conditions of SkinIO’s Privacy Policy.

Informational User

An informational user will view information about SkinIO’s products and services and the information SkinIO provides concerning skin cancer. The Personally Identifiable Information supplied in the case of such a user will be no more than that user’s IP address.

Patient and HealthCare Provider Users

Patient and Healthcare Provider users are those SkinIO users who seek to store images and notes on SkinIO’s Service. Patient users and Healthcare Provider users will be providing both Personally Identifiable Information and Personal Health Information in connection with their use.

Images of skin conditions are stored by users in a third-party secured server. Users who seek to store images of skin conditions and/or to provide medical information will be subject to the terms and conditions of both SkinIO and the third-party secured servers concerning this storage.

These users will provide Personally Identifiable Information or Personal Health Information that includes email address, name, age and photographs of skin. This Personally Identifiable Information and Personal Health Information will be protected by the Privacy Policy of SkinIO and the privacy policy of the third-party secured server. In addition, any such images and medical information will be stored with the third-party secured server and will be further protected by the privacy policy of the secured server.

As more fully explained in SkinIO’s Legal Terms and Conditions of Use in Section 3, the provision of images of user’s skin conditions does not constitute any diagnosis of any such condition by SkinIO. Nor does SkinIO, by agreeing to store and/or transmit Personally Identifiable Information or Personal Health Information, agree that the patient user needs or does not need treatment for any such condition nor does SkinIO recommend any particular treatment. Diagnosis and treatment are not features or functions of SkinIO. Such diagnosis and treatment may be provided only by a licensed physician.

The user hereby releases SkinIO from all liability in connection with any diagnosis and/or treatment of any skin condition, which skin condition is the subject of an image stored or transmitted by SkinIO.

No Minors

Minors should not use the Service. Neither SkinIO nor any of its services is designed or intended to attract children under the age of 18. We do not collect Personally Identifiable Information from any person we actually know to be under the age of 18.

Contacting SkinIO

If you have a complaint or problem, please use our Customer Support Form (Contact Us). Our customer service department will forward your complaint to the appropriate internal SkinIO department for a response or resolution. We try to answer every email within 48 business hours, but may not always able to do so.

If you do not receive adequate resolution of a privacy related problem, you may write to SkinIO’s Privacy Office at:

SkinIO, LLC
320 West Ohio Street 3W
Chicago, IL 60654

We will notify you of receipt of your letter to confirm that your personal identifiers have been removed.