PRIVACY POLICY

OMHU A/S

This Privacy Policy explains how Omhu A/S (“We”, “Us”) processes your personal information when you use the Hudsvar application (“App”).

The App is primarily designed to answer questions regarding your symptoms and take and upload images of your skin to send to a dermatologist who will review your case and send you back an assessment.

The second purpose of the App is the development of AI for medical image analysis.

1. DATA CONTROLLER

The entity responsible for the processing of your personal information is:

Omhu A/S
Silkegade 8,
CVR no. 41600039
1113 Copenhagen
Denmark

The contact details of our data protection officer are as follows:

E-mail: dataprivacy@omhu.com
Phone: +45 2993 7003

2. DESCRIPTION OF THE PROCESSING
A. Purpose
Purpose #1 - Provision of the Hudsvar App

Personal data is used in order to assist you in taking pictures of your skin in order for you to receive a symptom assessment from a dermatologist. The App is primarily designed to take, and upload images of your skin, which may contain health data about you in the form of a skin disease.

Personal data is also used for the purpose of communicating with you, including sending you notifications you received the results of your assessment request.

You can use the App without creating an account.

Purpose #2 - Optimizing the user experience and functionality of the App, including sending feedback to the Hudsvar team.

Personal data is collected for the purpose of conducting statistics and optimizing the user experience and the functionalities of the App. For these purposes we are collecting information about your mobile device and your use of the App.

Purpose #3 - Scientific research

When you use the App to assess a potential skin disease, we use the images collected in the App, to develop and improve the App's algorithm for scientific purposes. The processing of such personal data makes it possible to find patterns in the content of the images, and thereby assist the process of diagnosing and predicting the development of the potential skin disease.

B. Categories of personal data
We process the following categories of personal data about you:

a) Ordinary personal data:

• Unique User ID,
• IP-address,
• Self declared age, gender, previously diagnosed skin condition(s), treatment used, existing allergies, contact with person diagnosed with scabies or a rash and itch similar to yours.
• Self-assessed itch presence and level, rash presence and locations, appearance.
• Metadata included in the images, i.e. filetype and size.

b) Sensitive personal data:

• Images of skin diseases (health data).

We process the following categories of personal data about you:

a) Ordinary personal data:

- Email address if you use the contact form in the app to contact us
- Unique User ID
- Device ID
- Information regarding your use of the app
We process the following categories of personal data about you:

a) Ordinary personal data:
· Unique User ID

b) Sensitive personal data:
· Images of skin diseases (health data)

C. Source of the personal data
We collect your personal data from the following source(s):
• Directly from you.

D. Legal basis for the processings
We process your personal data on the following legal bases:
• Article 6.1.b (performance of a contract)
• Article 6.1.a and 9.2.a (consent)

We process your personal data on the following legal bases:
• Article 6.1.f (necessary for the pursuit of our legitimate purposes, including information necessary for the function of the App and receiving feedback regarding the App)

We process your personal data on the following legal bases:
• Article 6.1.a (consent)
• Section 10 in the Danish Data Protection Act.

E. Recipients
We share your personal data with:
• Omhu Group entities
• Technical service providers that, as data processors, will assist us with processing activities.

We share your personal data with:
• Omhu Group entities
• Technical service providers that, as data processors, will assist us with storage and analytics of the use of the use of the app.

We share your personal data with:
• Omhu Group entities
• Technical service providers that, as data processors, will assist us with processing activities.

F. Data retentions
We will retain personal data processed for this purpose for:
• As long as you are using the Imagine App.
• The personal data will be deleted from the App 12 months after your last use of the App.

We will retain personal data processed for this purpose for:
• As long as you are using the Imagine App.
• The personal data will be deleted / anonymized.

We will retain personal data processed for this purpose for:
As long as it is useful and necessary for the purpose of improving the algorithm. The personal data will be deleted if we evaluate that it is no longer useful for improving the algorithm.
PurposeCategories of personal dataSource of the personal dataLegal basis for the processingRecipientsData retention

Purpose #1 – Provision of the Hudsvar App

Personal data is used in order to assist you in taking pictures of your skin in order for you to receive a symptom assessment from a dermatologist. The App is primarily designed to take, and upload images of your skin, which may contain health data about you in the form of a skin disease.

Personal data is also used for the purpose of communicating with you, including sending you notifications you received the results of your assessment request.

You can use the App without creating an account.

We process the following categories of personal data about you:

a) Ordinary personal data:

– Unique User ID,

– IP-address,

– Self declared age, gender, previously diagnosed skin condition(s), treatment used, existing allergies, contact with person diagnosed with scabies or a rash and itch similar to yours.

– Self-assessed itch presence and level, rash presence and locations, appearance.

– Metadata included in the images, i.e. filetype and size.

b) Sensitive personal data:

– Images of skin diseases (health data)

We collect your personal data from the following source(s):

– Directly from you.

We process your personal data on the following legal bases:

– Article 6.1.b (performance of a contract)

– Article 6.1.a and 9.2.a (consent)

We share your personal data with:

– Omhu Group entities

– Technical service providers that, as data processors, will assist us with processing activities

We will retain personal data processed for this purpose for:

– As long as you are using the Imagine App.

– The personal data will be deleted from the App 12 months after your last use of the App.

Purpose #2 – Optimizing the user experience and functionality of the App, including sending feedback to the Hudsvar team.

Personal data is collected for the purpose of conducting statistics and optimizing the user experience and the functionalities of the App. For these purposes we are collecting information about your mobile device and your use of the App.

We process the following categories of personal data about you.

a) Ordinary personal data:

– Unique User ID

b) Sensitive personal data:

– Images of skin diseases (health data)

We collect your personal data from the following source(s):

– Directly from you

We collect your personal data from the following

We process your personal data on the following legal bases:

– Article 6.1.f (necessary for the pursuit of our legitimate purposes, including information necessary for the function of the App and receiving feedback regarding the App)

We share your personal data with:

– LEO Pharma Group entities

– Technical service providers that, as data processors, will assist us with storage and analytics of the use of the use of the app.

We will retain personal data processed for this purpose for:

– As long as you are using the Imagine App.

– The personal data will be deleted / anonymized.

Purpose #3 – scientific research

When you use the App to assess a potential skin disease, we use the images collected in the App, to develop and improve the App’s algorithm for scientific purposes. The processing of such personal data makes it possible to find patterns in the content of the images, and thereby assist the process of diagnosing and predicting the development of the potential skin disease.

We process the following categories of personal data about you:

a) Ordinary personal data:

– Unique User ID

b) Sensitive personal data:

– Images of skin diseases (health data)

We collect your personal data from the following source(s):

– Directly from you

We process your personal data on the following legal bases:

  • Article 6.1.a (consent)
  • Section 10 in the Danish Data Protection Act

We share your personal data with:

  • Omhu Group entities

·                 Technical service providers that, as data processors, will assist us with processing

We will retain personal data processed for this purpose for:

As long as it is useful and necessary for the purpose of improving the algorithm. The personal data will be deleted if we evaluate that it is no longer useful for improving the algorithm

3. CONSEQUENSES OF THE PROCESSING

As described above you use the App for the purpose of documenting and tracking how your skin is affected in various situations. We are as mentioned in purpose 4 using the images to develop and improve an algorithm that, in time, will be able to assist you and other people suffering from skin diseases with the treatment of these diseases. Consequently, the photos that you upload to Hudsvar will be included in the training of the algorithm to make it possible to identify patterns in the content of the pictures, and thereby diagnosing and predicting the development of the potential skin disease.

4. TRANSFERS TO COUNTRIES OUTSIDE THE EU/EEA

We will use service providers (i.e. data processors acting only on our instructions), some of which may be located outside of the region or country from where you reside, in order to provide technical support, services in the area of maintenance and development of the App. We may decide to host the data at one of our group companies or use a service provider, who is using a cloud structure.

This means that the data may be transferred to servers outside the EU/EEA, including the USA. For more information, including on the specific countries, please contact privacy@leoilab.com.

Such transfers will take place on the basis of the following legal basis:

a) The EU-US Privacy Shield – https://www.privacyshield.gov/list

b) The country/countries has/have not been deemed by the Commission of the European Union to have an adequate level of protection of personal data. We will provide appropriate safeguards for the transfer:

– Through the use of “Model Contracts for the Transfer of Personal Data to Third Countries”, as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities. You may obtain a copy of the contract/agreement by contacting Us at privacy@omhu.com.

5. YOUR RIGHTS

You have the following rights:

  • You have the right to request access to, rectification or erasure of your personal data.
  • You also have the right to have the processing of your personal data restricted.
  • If processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent. You may withdraw your consent by contacting Omhu/Hudsvar using the contact form in the app .
  • You have the right to receive your personal information in a structured, commonly used and machine-readable format (data portability).
  • You may always lodge a complaint with a data protection supervisory authority, e.g. The Danish Data Protection Agency.

Furthermore, you have the right to object to processing of your personal data as follows.

  • If processing of your personal data is based on article 6(1)(e) or article 6(1)(f), see above regarding legal basis, you have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data.
  • Where your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data about you for such marketing.

 

You can take steps to exercise your rights by sending us an email via the App contact form. The email will thus contain your anonymous user ID, allowing us to trace back which data are yours. If you need help performing any of those steps, contact Omhu at privacy@omhu.com.

There may be conditions or limitations on these rights. It is therefore not certain for example you have the right of data portability in the specific case – this depends on the specific circumstances of the processing activity.

 

Should I write more about that and explain the reasons why (we don’t collect personal contact information such as email, therefore we need to know the anonymous user ID of the user for us to trace back the user and delete/rectify etc his rights. When using the contact form, the anonymous user id is sent together with the mail.

Last updated: 02.09.2020