DermLens® Privacy Notice

1. About DERMACODE Ltd

This Privacy Notice explains how DERMACODE Ltd ("DERMACODE", "DermLens", "we", "our" or "us") collects, uses, stores, discloses and otherwise processes personal information obtained through the DermLens® website, device registration portal and our associated business activities.

DERMACODE Ltd is a company incorporated and registered in England and Wales whose registered office is situated at:

52 Thor Drive Bedford MK41 0WP United Kingdom Email: contact@dermlens.net

For the purposes of applicable data protection legislation, including the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018 and any legislation replacing or supplementing them, DERMACODE Ltd acts as the Data Controller in respect of the personal information described within this Privacy Notice unless expressly stated otherwise.

DERMACODE Ltd is committed to processing personal information lawfully, fairly and transparently and to maintaining appropriate technical and organisational measures designed to protect the confidentiality, integrity and availability of the personal information entrusted to us.

2. Scope of this Privacy Notice

This Privacy Notice applies to all personal information collected or processed by DERMACODE Ltd through the DermLens® website, including information submitted through contact forms, warranty registration, device authentication, distributor enquiries, commercial enquiries and any other communications made through the Website.

This Privacy Notice also applies to personal information obtained directly from individuals by telephone, email, correspondence, exhibitions, conferences, meetings, training events, authorised distributors or other legitimate business interactions where DERMACODE Ltd acts as the Data Controller.

This Privacy Notice explains the categories of personal information we collect, the purposes for which such information is processed, the lawful bases relied upon under UK data protection legislation, the circumstances in which personal information may be shared with third parties, the measures implemented to protect that information and the rights available to individuals in relation to their personal information.

This Privacy Notice does not apply to information processed by independent third parties, including authorised distributors, payment providers, courier companies or third-party websites that may be linked from the DermLens® website. Such organisations process personal information in accordance with their own privacy notices and DERMACODE Ltd accepts no responsibility for their privacy practices.

Where separate contractual documentation, warranty terms or commercial agreements contain additional provisions relating to the processing of personal information, those provisions shall apply alongside this Privacy Notice.

3. Categories of Individuals

DERMACODE Ltd processes personal information relating to a number of different categories of individuals in connection with its business activities.

These categories include purchasers of DermLens® products, individuals registering DermLens® devices for warranty validation or product authentication, prospective customers requesting information regarding our products or services, individuals submitting enquiries through the Website or by email, healthcare professionals using or evaluating DermLens® products, authorised distributors and their representatives, suppliers, contractors, consultants, business partners and other individuals with whom DERMACODE Ltd has a legitimate commercial relationship.

We also process limited technical information relating to visitors who browse the DermLens® website, including information collected automatically through cookies and similar technologies in accordance with our Cookie Policy.

DERMACODE Ltd does not intentionally collect personal information from children through the Website, nor is the Website intended for use by individuals under the age of eighteen years.

Furthermore, DERMACODE Ltd does not ordinarily collect or process special category personal data, including information relating to an individual's health, racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data or sexual orientation, through the ordinary operation of the DermLens® website or device registration portal.

Should such information be provided to us inadvertently or where exceptionally necessary, it shall be processed only where a lawful basis exists under applicable data protection legislation.

4. Information We Collect

DERMACODE Ltd collects only the personal information that is reasonably necessary for the operation of its business, the provision of customer support, the registration and authentication of DermLens® devices, compliance with legal obligations and the improvement of our products and services.

Depending upon the nature of your interaction with DERMACODE Ltd, we may collect your name, professional title, organisation or employer, postal address, telephone number, email address, country of residence and any correspondence or communications exchanged with us.

Where you purchase or register a DermLens® product, we may collect information relating to the product itself, including the product serial number, model, purchase date, supplier or authorised distributor, proof of purchase, warranty status and other information reasonably required to authenticate ownership or administer warranty services.

Where you communicate with DERMACODE Ltd, we may retain records of enquiries, correspondence, technical support requests, customer service interactions and any information voluntarily provided by you for the purpose of responding to your enquiry or fulfilling our contractual or legal obligations.

When you access the Website, certain technical information may be collected automatically, including your Internet Protocol (IP) address, browser type, operating system, device type, language settings, pages visited, referring website, date and time of access and other diagnostic or analytical information necessary for maintaining the security, functionality and performance of the Website.

DERMACODE Ltd does not knowingly collect sensitive personal information unless such information is voluntarily provided by an individual or its processing is otherwise required or authorised by law.

We request that individuals do not provide unnecessary personal information or confidential information through the Website or by email unless specifically requested to do so.

5. Device Registration

DERMACODE Ltd provides a Device Registration Portal through which purchasers of genuine DermLens® products may register their device for warranty validation, extended warranty eligibility, product authentication and the provision of customer support services.

In connection with device registration, we may collect information including the purchaser's name, postal address, email address, telephone number, country of residence, product serial number, model number, purchase date, supplier or authorised distributor, proof of purchase and any additional information reasonably required to verify ownership or authenticate the device.

The information collected through the Device Registration Portal is processed for the purposes of confirming the authenticity of DermLens® products, administering warranty entitlements, providing technical support, maintaining accurate product ownership records, communicating important product or safety information where necessary and preventing fraudulent warranty claims or the registration of counterfeit products.

Submission of information through the Device Registration Portal does not create an online user account or customer login and the information provided shall be used solely for the purposes described within this Privacy Notice, the Warranty Policy and any other applicable legal documentation.

DERMACODE Ltd may verify information submitted through the Device Registration Portal by requesting additional documentation, including proof of purchase or information from the authorised distributor from whom the product was acquired.

Where DERMACODE Ltd reasonably believes that information submitted during the registration process is inaccurate, incomplete, misleading or fraudulent, or that a product is counterfeit, unlawfully obtained or otherwise ineligible for registration, we reserve the right to refuse, suspend or cancel the registration and to retain relevant information where necessary for the prevention or investigation of fraud or to comply with our legal obligations.

Information relating to registered devices shall be retained only for so long as is reasonably necessary to administer warranty services, comply with applicable legal obligations, maintain appropriate business records and protect the legitimate interests of DERMACODE Ltd.

6. Website Visitors

DERMACODE Ltd processes limited personal information relating to individuals who visit the DermLens® Website. Certain information is collected automatically through the operation of the Website and associated technologies in order to maintain security, ensure the proper functioning of the Website, improve user experience and understand how the Website is used.

Such information may include your Internet Protocol (IP) address, browser type and version, operating system, device type, language settings, referring website, pages viewed, duration of visits, navigation history, date and time of access and other technical information generated through your interaction with the Website.

Where cookies or similar technologies are used, such processing shall be carried out in accordance with our Cookie Policy and, where required by law, only with your consent.

The information collected from Website visitors is used to administer and secure the Website, identify technical faults, detect malicious or fraudulent activity, analyse Website performance, improve accessibility and functionality, monitor usage trends and maintain the overall integrity and security of our online services.

DERMACODE Ltd does not use automated decision-making or profiling in relation to ordinary Website visitors in any manner which produces legal effects or similarly significant consequences.

7. Customer Enquiries

Where an individual contacts DERMACODE Ltd by email, telephone, through the Website or by any other means, we shall process the personal information provided for the purpose of responding to that enquiry and administering any subsequent correspondence.

Depending upon the nature of the enquiry, this information may include your name, organisation, professional title, telephone number, email address, postal address and any information voluntarily included within your communication.

Where an enquiry relates to an existing or prospective purchase, warranty claim, technical support request or product registration, we may also process information relating to the relevant DermLens® product, including its model, serial number, date of purchase, authorised distributor and supporting documentation.

Correspondence with DERMACODE Ltd may be retained where reasonably necessary to maintain an accurate record of communications, improve customer service, investigate complaints, protect our legal interests, comply with regulatory obligations or establish, exercise or defend legal claims.

Individuals are requested not to include confidential, sensitive or unnecessary personal information within enquiries unless specifically requested by DERMACODE Ltd.

8. Distributor and Business Enquiries

DERMACODE Ltd processes personal information relating to existing and prospective distributors, resellers, commercial partners, suppliers, consultants and other organisations with whom we maintain or intend to establish a legitimate business relationship.

Such information may include the name, professional title, employer, business address, business telephone number, email address and other contact information relating to representatives of those organisations, together with records of meetings, correspondence, quotations, contractual negotiations and other commercial communications.

This information is processed for the purposes of evaluating commercial opportunities, administering business relationships, negotiating and performing contracts, maintaining accurate business records, communicating product information, providing distributor support, complying with legal and regulatory obligations and protecting the legitimate commercial interests of DERMACODE Ltd.

DERMACODE Ltd shall process only such personal information as is reasonably necessary for these purposes and shall retain such information only for so long as is necessary to manage the relevant business relationship or to comply with applicable legal, accounting or regulatory obligations.

9. Lawful Basis for Processing

DERMACODE Ltd processes personal information only where a lawful basis exists under the UK General Data Protection Regulation and the Data Protection Act 2018.

Depending upon the circumstances, we may process personal information because such processing is necessary for the performance of a contract or in order to take steps at the request of an individual prior to entering into a contract. This includes, for example, responding to requests relating to the purchase of DermLens® products, administering warranty services, processing device registrations and providing customer support.

We may also process personal information where such processing is necessary for compliance with a legal obligation to which DERMACODE Ltd is subject, including obligations relating to taxation, accounting, product safety, regulatory compliance, fraud prevention and the establishment, exercise or defence of legal claims.

In many circumstances, DERMACODE Ltd relies upon its legitimate interests as the lawful basis for processing personal information. These legitimate interests include operating and improving the Website, maintaining the security of our systems, protecting our intellectual property, administering customer relationships, communicating with distributors and business partners, preventing fraud, improving our products and services and managing our business efficiently.

Where required by law, DERMACODE Ltd shall obtain an individual's consent before processing personal information. This may include, for example, the placement of non-essential cookies or the sending of electronic marketing communications where consent is required under applicable legislation.

Where processing is based upon consent, the individual shall have the right to withdraw that consent at any time. Withdrawal of consent shall not affect the lawfulness of any processing carried out prior to its withdrawal.

10. Sharing Information

DERMACODE Ltd does not sell, rent or otherwise disclose personal information to third parties for their own marketing purposes.

Personal information may be shared only where such disclosure is reasonably necessary for the operation of our business, the provision of our products and services, compliance with legal obligations or the protection of our legitimate interests.

Accordingly, DERMACODE Ltd may disclose personal information to carefully selected third-party service providers who provide services on our behalf, including information technology providers, website hosting providers, cloud service providers, payment processors, courier and logistics companies, customer relationship management providers, professional advisers, insurers, accountants, auditors and other service providers engaged in connection with our legitimate business activities.

Where products are purchased through authorised distributors, DERMACODE Ltd may exchange limited information with the relevant distributor where reasonably necessary to verify warranty entitlement, authenticate a product, investigate suspected counterfeit devices, administer product recalls, resolve customer enquiries or otherwise provide appropriate customer support.

DERMACODE Ltd may also disclose personal information where required to do so by law, pursuant to a court order, regulatory requirement, statutory obligation or lawful request from a governmental authority, law enforcement agency or competent regulator.

In the event of a merger, acquisition, corporate restructuring, sale of assets or other business reorganisation involving DERMACODE Ltd, personal information may be transferred to the acquiring or successor organisation, subject always to appropriate safeguards and compliance with applicable data protection legislation.

Where DERMACODE Ltd engages third-party processors to process personal information on its behalf, such processing shall be governed by appropriate written agreements requiring those processors to process personal information only in accordance with our documented instructions, maintain appropriate security measures and comply with all applicable data protection legislation.

11. International Transfers

DERMACODE Ltd principally stores and processes personal information within the United Kingdom. However, in the course of operating our business, certain third-party service providers engaged by DERMACODE Ltd may process personal information outside the United Kingdom.

Where personal information is transferred to a country which has not been recognised by the UK Government as providing an adequate level of protection for personal information, DERMACODE Ltd shall ensure that appropriate safeguards are implemented in accordance with applicable data protection legislation.

Such safeguards may include the use of the International Data Transfer Agreement (IDTA), the UK Addendum to the European Commission's Standard Contractual Clauses or any other transfer mechanism recognised under UK data protection legislation.

DERMACODE Ltd shall take reasonable steps to ensure that all international transfers of personal information are subject to appropriate contractual, organisational and technical safeguards designed to protect the confidentiality, integrity and security of the information transferred.

Further information regarding the safeguards applied to international transfers may be requested by contacting DERMACODE Ltd using the contact details set out within this Privacy Notice.

12. Data Security

DERMACODE Ltd is committed to protecting personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access or any other unlawful form of processing.

We maintain appropriate technical and organisational measures designed to safeguard the confidentiality, integrity and availability of personal information having regard to the nature of the information processed, the risks presented by the processing and the current state of technological development.

Such measures may include secure hosting environments, encrypted communications where appropriate, restricted access controls, authentication procedures, password protection, firewall technologies, malware protection, software updates, data backup procedures, monitoring of system security and appropriate staff training regarding information security and data protection.

Access to personal information is restricted to those employees, contractors, professional advisers and authorised service providers who require access for legitimate business purposes and who are subject to appropriate contractual or professional duties of confidentiality.

Whilst DERMACODE Ltd implements appropriate security measures, no method of electronic transmission or electronic storage can be guaranteed to be completely secure. Accordingly, although we endeavour to protect personal information using reasonable and appropriate safeguards, we cannot guarantee absolute security.

Should DERMACODE Ltd become aware of a personal data breach which presents a risk to the rights and freedoms of individuals, we shall respond in accordance with our legal obligations under applicable data protection legislation, including notification to the Information Commissioner's Office and affected individuals where required.

13. Data Retention

DERMACODE Ltd shall retain personal information only for as long as is reasonably necessary to fulfil the purposes for which it was collected, including the administration of customer relationships, product registration, warranty services, technical support, contractual obligations, legal compliance and the protection of our legitimate business interests.

The period for which personal information is retained will vary depending upon the nature of the information concerned, the purpose for which it was collected and any applicable legal, regulatory, contractual or accounting requirements.

Information relating to product purchases, warranty registration, product authentication and customer support may be retained for the duration of the applicable warranty period together with such additional period as DERMACODE Ltd reasonably considers necessary for legal compliance, product traceability, regulatory obligations, dispute resolution, fraud prevention and the establishment, exercise or defence of legal claims.

Business correspondence and commercial records may be retained where reasonably necessary to administer ongoing commercial relationships, comply with statutory obligations or maintain appropriate corporate records.

Where personal information is no longer required for the purposes for which it was collected, DERMACODE Ltd shall securely delete, anonymise or otherwise dispose of that information in accordance with our internal retention procedures and applicable legal requirements.

14. Your Rights

Subject to applicable data protection legislation, individuals whose personal information is processed by DERMACODE Ltd may be entitled to exercise certain rights in relation to that information.

These rights may include the right to request access to personal information held by DERMACODE Ltd, the right to request the correction of inaccurate or incomplete personal information, the right to request the erasure of personal information in certain circumstances, the right to request the restriction of processing, the right to object to particular forms of processing and the right to request the transfer of personal information to another organisation where the legal requirements for data portability are satisfied.

Where processing is based upon consent, an individual shall also have the right to withdraw that consent at any time. Withdrawal of consent shall not affect the lawfulness of any processing undertaken prior to its withdrawal.

The exercise of these rights is not absolute and may be subject to exemptions or limitations under applicable data protection legislation. Where DERMACODE Ltd is unable to comply with a request, we shall explain the reasons for our decision unless prevented from doing so by law.

Requests relating to personal information should be submitted using the contact details provided within this Privacy Notice. DERMACODE Ltd may request reasonable information to verify the identity of the individual making the request before responding.

DERMACODE Ltd shall respond to valid requests within the time periods prescribed by applicable data protection legislation.

15. Marketing Communications

DERMACODE Ltd may use your contact information to provide updates regarding DermLens® products, product launches, educational content, training opportunities, exhibitions, company news, promotional offers and other information which we believe may be of legitimate interest to you.

Electronic marketing communications shall be sent only where permitted by applicable law and, where required, only with your prior consent.

Where marketing communications are sent on the basis of consent, you may withdraw that consent at any time by following the unsubscribe instructions included within the communication or by contacting DERMACODE Ltd directly.

Where DERMACODE Ltd relies upon its legitimate interests to communicate with existing customers or business contacts, individuals shall have the right to object to receiving such communications at any time, following which we shall cease sending marketing communications unless another lawful basis applies.

The withdrawal of consent or objection to marketing communications shall not affect service-related communications which are necessary for the administration of product registrations, warranty services, customer support, product safety notifications, regulatory updates or the performance of our contractual obligations.

16. Cookies

The DermLens® Website uses cookies and similar technologies to support the operation, security and performance of the Website, to improve user experience and, where appropriate, to collect analytical information regarding how visitors interact with the Website.

Cookies are small text files placed on your device when you visit a website. They enable websites to recognise a user's device, remember preferences, improve functionality and assist in the provision of certain online services.

DERMACODE Ltd uses only those cookies which are necessary for the proper operation of the Website unless you have provided your consent for the use of additional categories of cookies, including analytical or functional cookies where required by applicable law.

Further information regarding the categories of cookies used, the purposes for which they are deployed, the duration for which they remain on your device and the choices available to you in relation to cookie preferences is set out in the DermLens® Cookie Policy.

You may amend your cookie preferences at any time through the Website's cookie management tools or by adjusting your browser settings. However, disabling certain cookies may affect the functionality, performance or availability of parts of the Website.

17. Third-Party Websites

The DermLens® Website may contain hyperlinks to third-party websites, applications or online services operated independently of DERMACODE Ltd.

This Privacy Notice applies solely to personal information processed by DERMACODE Ltd and does not extend to the privacy practices of third-party organisations whose websites or services may be accessible through hyperlinks appearing on the Website.

DERMACODE Ltd has no control over the content, security, availability or privacy practices of third-party websites and accepts no responsibility or liability for the manner in which such organisations collect, process, store or disclose personal information.

Individuals who choose to access third-party websites should review the applicable privacy notice, cookie policy and terms of use published by the relevant organisation before providing any personal information.

The inclusion of a hyperlink on the DermLens® Website shall not constitute any endorsement, approval or recommendation by DERMACODE Ltd of the linked website, its operator or the products or services offered through it.

18. Contact Details

Questions, requests or concerns relating to this Privacy Notice or the processing of personal information by DERMACODE Ltd should be directed to us using the contact details below.

DERMACODE Ltd 52 Thor Drive Bedford MK41 0WP United Kingdom Email: contact@dermlens.net

DERMACODE Ltd shall endeavour to respond to all legitimate privacy enquiries promptly and in accordance with the requirements of applicable data protection legislation.

Where an individual wishes to exercise any of their rights under UK data protection legislation, DERMACODE Ltd may request reasonable information to verify that individual's identity before responding to the request.

19. Complaints to the Information Commissioner's Office

DERMACODE Ltd is committed to resolving any concerns relating to the processing of personal information promptly, fairly and transparently. Individuals are encouraged to contact DERMACODE Ltd in the first instance so that we have the opportunity to investigate and resolve any concerns.

Without prejudice to any other administrative or judicial remedy available, individuals have the right to lodge a complaint with the Information Commissioner's Office ("ICO") if they believe that DERMACODE Ltd has processed their personal information in a manner that is inconsistent with applicable data protection legislation.

The Information Commissioner's Office is the independent supervisory authority responsible for overseeing compliance with data protection legislation within the United Kingdom.

Further information regarding the submission of complaints may be obtained directly from the Information Commissioner's Office through its official website or by contacting the ICO using the contact details published by that organisation from time to time.

20. Changes to this Privacy Notice

DERMACODE Ltd reserves the right to amend, update or replace this Privacy Notice at any time to reflect changes in applicable legislation, regulatory guidance, business operations, Website functionality, data processing activities or other legitimate business requirements.

Any revised version of this Privacy Notice shall become effective upon publication on the DermLens® Website unless otherwise stated.

Individuals are encouraged to review this Privacy Notice periodically to ensure that they remain informed of how DERMACODE Ltd collects, uses and protects personal information.

Where changes are required by law or materially affect the manner in which personal information is processed, DERMACODE Ltd shall take such additional steps to notify affected individuals as may be required by applicable data protection legislation.

Version: 1.0 Last Updated: July 2026