Map My Mole - Privacy Policy

1. Important information and who we are

Welcome to Map My Mole's privacy policy.

Map My Mole is the trading name of CommunityDermatology Limited (referred to as “Map My Mole”, "we","us" or "our" in this privacy policy).

At Map My Mole, we are committed to protecting and respecting your privacy and your personal data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”),the Data Protection Act 2018 (“DPA 2018”) and all other mandatory laws and regulations of the United Kingdom.

This privacy policy explains how we collect, process and keep your data safe and tells you about your privacy rights, how the law protects you, and informs our employees and staff members of their obligations and protocols when processing data.

The individuals from whom we may gather and use data can include our customers (you), any individuals whose information you submit to us through our app (for example, if you submit an image of a mole for an elderly parent or a child), and any other people that we have a relationship with or may need to contact.

This privacy policy applies to all our employees and staff members and they will process your personal data in accordance with this policy at all times.

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2. Your Data Controller and Data Protection Officer‍

Map My Mole is your data controller and responsible for your personal data.

We have appointed a data protection officer(DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Name: Chris Owen-Smith
Email: dpo@mapmymole.com
Postal address: c/o Lowe Henwood, 12 Mannamead Road, Plymouth, PL4 7AA, United Kingdom

You have the right to make a complaint at any time to the InformationCommissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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3. The data we collect about you

“Personal data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you, but this list sets out the full scope of personal data that we may collect as part of running our business:

Profile/Identity Data: This is data used to identify you and includes your first name, last name, gender, date of birth.

Contact Data: This is data used to contact you and includes your phone number, addresses, email addresses, phone numbers.

Marketing and Communications Data: This is information relating to your preferences in receiving marketing information and other information from us.

Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.

Transactional Data: This is information of your order details and records of all payments you have made for our services or products.

Health Data: This is information relating to your health, including images and/or videos of parts of the body for the purpose of examining skin lesions. Please see the section titled “The Health Data we collect about you” for more information of how we collect and process Health Data.

We also collect, use and share Aggregated Data such as the percentage of submissions that our consultant dermatologists consider may be cancerous.Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connectAggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on personal data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

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4. The Health Data we collect about you

‍For the purposes of our business, we also collect and process information about your health (“HealthData”), including images and/or videos of parts of the body for the purpose of examining skin lesions, and the reports our consultant dermatologist prepares for you.

This is known under the GDPR as one of the Special Categories of personal data.In order to collect this type of data, we need enhanced legal justifications beyond the ordinary legal justifications under the GDPR. We explain which justifications we rely on in the section called “The legal basis for collecting Health Data” below.

We do not collect any other Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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5. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us personal data by filling informs or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
create an account on our website or app;
buy a service from us;
submit an image of a skin lesion or mole for review;
subscribe to our newsletter or request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.

Third parties. We may receive personal data about you from a third party, for example if you ask someone else to submit an image of your skin lesion or mole on your behalf.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

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6. The legal basis for collecting personal data (except Health Data)

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Performance of a contract. We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
Legitimate interests. We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

Generally, we do not rely on consent as a legal basis for processing your personal data (except Health Data, see the section titled “The legal basis for collecting Health Data” below) although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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7. The legal basis for collecting Health Data

For the Health Data we collect, the enhanced legal justification (known as the “condition” for processing under the GDPR) we rely on is explicit consent, meaning that we will only process your Health Data if you have given your explicit consent to the processing of your Health Data.

Note that, due to the nature of our services, we will be unable to provide our Mole Check at Home services to you if you do not consent to our processing of your Health Data. We will need to view an image of your skin lesion or mole to be able to provide a report for you. If you do not wish to share your Health Data with us through the app, you do not have to consent to the processing and you may be able to use our Mole Check in Clinic service instead. Please contact our DPO if you have any questions about how we collect and process your Health Data.

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8. How we use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and the lawful basis for processing that data. We have also identified what our legitimate interests are where appropriate.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further information, please contact our DPO.

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Activity	Type of data	Legal justification	Explanation
To register you as a new customer	Profile/Identity Contact	Performance of contract	We need this information so that we can create an account and uniquely identify the customer.
To process and deliver your order including: Manage payments, fees and charger Process payments due to us	Profile/Identity Contact Billing Transactional Marketing and Communications	Performance of contract Legitimate interests	We need this data to process and deliver your order, including processing payments due to us.
To process an image you've sent of a skin lesion or mole and to prepare a report for you.	Profile/Identity Health	Explicit consent	We need this data so that our consultant dermatologists can make an informed decision about what the skin lesion is, for example a malignant melanoma, or basal cell carcinoma.

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9. Marketing and content updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

You can ask us to stop sending you marketing messages at any time by You can ask us to stop sending us marketing messages at any time by clicking on the"unsubscribe" link in any email. Where you opt out of receiving these marketing messages, we will continue to retain other personal data provided to us as a result of interactions with us not related to your marketing preferences.

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10. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our DPO.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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11. Your rights and how you are protected by us

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.

Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request").

Right to rectification. You have the right to request correction of the personal data that we hold about you.This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is no tan absolute right and it only applies in certain circumstances, for example:
where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
we are processing your personal data for direct marketing purposes.

Rights to restrict processing. You have the right to request the restriction or suppression of processing of your personal data. Note that this is not an absolute right and it only applies in certain circumstances:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent. You have the right to withdraw consent at any time in cases where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.If you withdraw your consent, we may not be able to provide certain services to you (for example, if you withdraw your consent to us processing your HealthData, we will not be able to provide our services to you). We will let you know if this is the case when you withdraw your consent.

If you wish to make a request under any of these rights, please contact us at dpo@mapmymole.com.

‍No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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12. Your control over Map My Mole’s use of your personal data

You may delete your account at any time – this will remove your account page from our systems and our related software. We guarantee this will delete all stored data, subject to any legal requirements which may require us to retain some of your data (for example, any reports our consultant dermatologist prepares for you).

You can access information associated with your account by logging into your account you created with us.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorised access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

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13. How we protect your personal data

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your personal data on our systems, including implementing certain security measures to ensure the security of your personal data on our systems including being “Cyber Essentials” certified, and encrypting all personal data in transit and at rest in our databases.

Any personal data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your personal data or expose it to security risks that would not have arisen had the data remained in our possession.

However, no transmission of data over the internet is guaranteed to be completely secure.It may be possible for third parties not under the control of Map My Mole to intercept or access transmissions or private communications unlawfully. While we strive to protect your personal data, we cannot ensure or warrant the security of any personal data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

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14. Your data and third parties

Sharing your data with third parties

We may share information that is not considered personal data with third parties.

We may share your personal data with subcontractors or affiliates (including our consultant dermatologists who will review your submission and prepare a report for you), subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions.

We may also share personal data with interested parties if we anticipate a change in control or the acquisition of all or part of our business or assets, or with interested parties in connection with the licensing of our technology.

IfMap My Mole is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your personal data to a third party aspart of or in connection with that transaction. Upon such transfer, the privacy policy of the acquiring entity may govern the further use of your personal data. In all other situations your data will still remain protected in accordance with this privacy policy (as amended from time to time).

We may share your personal data at any time if required for legal reasons or in order to enforce our terms or this privacy policy.

Third-party links

This website may include links to third-party websites, plug-ins and applications, for example the NHS website and resources. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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15. How long we keep your data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep certain information about you (including the reports our consultant dermatologist prepares for you)for [six] years after you cease being a customer.

In some circumstances you can ask us to delete your data: see the section titled “Your legal rights” for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

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16. International transfer of data

Your information may be stored and processed in the UK, or in other countries or jurisdictions outside the UK where Community Dermatology Limited has facilities. By using Community Dermatology Limited, you are permitting and consenting to the transfer of information, including Personal Data, outside of the UK.

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17. Notification of changes and acceptance of policy

We keep our Privacy Policy under review and will place any updates here. This version is dated 10 May 2023.

By using our website or app, you consent to the collection and use of data by us as set out in this privacy policy. Continued access or use of our website or app will constitute your express acceptance of any modifications to this privacy policy.

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