Privacy Policy & Data Protection

1. INTRODUCTION

This Privacy Policy explains how Adept Surgical Limited ("we", "us") processes personal data in connection with Dermafocal ("the App"). Use of the App is subject to our Terms of Use.

Regulatory Status: The App is registered with the UK Medicines and Healthcare products Regulatory Agency (MHRA) as a Class I Medical Device. We are committed to handling personal data in line with the Data Protection Act 2018 and UK GDPR.

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy covers personal data controlled by Adept Surgical Limited (for example support correspondence and operational/business records).

It does not govern patient-identifiable clinical records entered by healthcare professionals into Derma Capture in standard local-only operation, where the clinician and/or employing organisation acts as Data Controller.

3. CONTROLLER ROLES IN DERMA CAPTURE

FOR DERMA CAPTURE CLINICAL DATA, YOU ARE THE DATA CONTROLLER.

Dermafocal is a local-first software tool. Patient data, notes, and photographs entered in Derma Capture are stored within local app storage on your device. In normal operation, we do not routinely access, view, upload, or harvest this patient-identifiable data.

As Data Controller, you are responsible for:
(a) lawful basis and Article 9 condition;
(b) patient information/transparency and consent governance;
(c) device security and local information governance compliance;
(d) retention/deletion, rights handling, and complaints handling;
(e) incident response and breach reporting obligations where required.

4. DERMA CAPTURE AND CLINICAL PHOTOGRAPHY

Derma Capture allows clinicians to take clinical photographs. Images are stored in a secure local container within the app and are not automatically saved to your main Photos library.

SECURITY WARNING:

If you export a clinical record using the Share Sheet, data may leave the app and may sync to external services (including personal iCloud) depending on destination selected and device settings. Export only through approved organisational channels and in line with local policy.

Eligibility boundary: Derma Capture is intended only for patients who can provide their own informed consent in this release model. It is not intended for patients under 18 years, adults lacking capacity, or cases requiring proxy/parental consent.

5. WHAT PERSONAL DATA WE PROCESS (SUPPLIER-SIDE)

For Adept Surgical Limited controlled processing, we may process:

• support correspondence details (e.g., sender email, issue description);
• operational and compliance records;
• App Store commercial/subscription reporting data provided via Apple.

We do not operate a routine supplier-hosted clinical database for Derma Capture patient records.

6. LAWFUL BASIS (SUPPLIER-SIDE)

For support and operational correspondence, our lawful basis is legitimate interests and/or legal obligations, depending on context (for example safety, compliance, and record-keeping obligations).

7. THIRD-PARTY SERVICES

Payments and subscription administration are handled through Apple App Store infrastructure. Billing/account data is managed under Apple’s terms and privacy documentation.

8. DATA RETENTION AND BACKUPS

Derma Capture records are stored locally on device in standard operation. We do not operate a central clinical storage backend for those records.

IMPORTANT - DEVICE MIGRATION:

To reduce accidental cloud leakage risk, app data is excluded from automated iCloud and iTunes backups by default.

• New devices: on restore/upgrade, Dermafocal data may not transfer automatically.
• Deleting the app: uninstalling the app permanently deletes locally stored data.

Supplier-side support/compliance correspondence is retained only as long as necessary for support, safety, legal, and audit requirements.

9. YOUR RIGHTS (UK GDPR)

For personal data controlled by Adept Surgical Limited, you may request access, rectification, or erasure where applicable. For App Store billing/account rights, contact Apple Support directly.

You also have the right to raise concerns with the UK Information Commissioner’s Office (ICO).

10. SECURITY INCIDENTS

If you suspect unauthorised access, loss, or disclosure related to app use, follow local incident processes immediately and notify support@dermafocal.com without undue delay where product behaviour may have contributed.

11. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. The latest version and effective date will be published on this page and in the App legal section.

12. CONTACT US

For privacy and security queries, contact:

Adept Surgical Limited, The Lexicon Second Floor, Mount Street, Manchester, England, M2 5NT.