Privacy Policy

Introduction

scottigkys B.V. ("we", "our", or "us") is committed to protecting your privacy and personal data. This privacy policy explains how we collect, use, and protect your information when you use our virtual skincare consultation platform and services.

Data Controller

scottigkys B.V. is the data controller for your personal information. Our registered office is located at Schoolstraat 94, 4888 HD Breda, North Brabant, Netherlands. Company registration number: B62325230, VAT number: NL620325148B02.

Legal Basis for Processing

We process your personal data under the following legal bases as defined by the General Data Protection Regulation (GDPR):

• Contractual necessity for providing our consultation services
• Legitimate interests for improving our services and communication
• Legal compliance for tax and regulatory requirements
• Consent for marketing communications and cookies

Data Collection

The data we collect includes personal information such as your name, email address, phone number, fitness activities, skin concerns, and consultation preferences. We also collect technical information about your device and usage of our website through cookies and analytics tools. During video consultations, we may record sessions with your explicit consent for quality assurance and follow-up care purposes.

How We Use Your Information

We explain how we use your information to provide and improve our virtual skincare consultation services. Your personal data is used to schedule and conduct consultations, provide personalized skincare recommendations, communicate with you about your appointments, process payments, and send relevant health and skincare information. We also use aggregated, anonymized data to improve our services and develop new consultation offerings.

Data Sharing

We do not sell, rent, or trade your personal information to third parties. We may share your data with:

• Certified dermatologists and skincare experts providing your consultation
• Technical service providers who help us operate our platform
• Payment processors for transaction processing
• Legal authorities when required by law

Data Retention

We retain your personal data for as long as necessary to provide our services and comply with legal obligations. Consultation records are kept for 7 years as required by healthcare regulations. Marketing data is retained until you opt out. Account information is deleted within 30 days of account closure, unless longer retention is required by law.

Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

• Right to access your personal data
• Right to rectification of inaccurate data
• Right to erasure (right to be forgotten)
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent
• Right to lodge a complaint with supervisory authorities

Cookies and Tracking

Our website uses cookies to improve your experience and analyze usage patterns. We use both essential cookies required for website functionality and optional cookies for analytics and marketing purposes. You can manage your cookie preferences through our cookie consent banner or browser settings. For detailed information about our cookie usage, please see our Cookie Policy.

Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. This includes encryption of data in transit and at rest, secure video conferencing platforms, regular security audits, and staff training on data protection.

International Transfers

Your data is primarily processed within the European Economic Area (EEA). If we need to transfer data outside the EEA, we ensure appropriate safeguards are in place, such as adequacy decisions or standard contractual clauses approved by the European Commission.

Children's Privacy

Our services are intended for individuals aged 16 and over. We do not knowingly collect personal data from children under 16. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately.

Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by email or through our website. The updated policy will be effective from the date posted.

Contact Information

If you have questions about this privacy policy, want to exercise your rights, or need to contact us regarding your personal data, please reach out to us:

Supervisory Authority

If you have concerns about how we handle your personal data, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or your local supervisory authority in the EU.