Privacy Policy

1. Introduction

SafeSkin.ie (“SafeSkin”, “we”, “us”, “our”) is committed to protecting your personal data. This Privacy Policy explains what personal data we collect, how and why we use it, who we share it with, how we keep it secure, and your rights under data protection law. It applies to safeskin.ie and any related services, tools, APIs, and email communications (the “Platform”). This Policy is incorporated into our Terms of Service.

SafeSkin operates from Ireland and complies with the EU General Data Protection Regulation (GDPR), the Irish Data Protection Act 2018, and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (as amended).

2. Data Controller and Contact

SafeSkin is the data controller for personal data processed through the Platform. We have not appointed a statutory Data Protection Officer, as we are not required to do so under Article 37 GDPR. For all data protection enquiries, including to exercise any of your rights, contact us at [email protected]. We aim to respond within 30 days.

3. Categories of Personal Data We Collect

Platform Visitors (Consumers)

• Approximate geolocation coordinates, provided by your browser with your explicit consent, used only for location-based clinic search.
• Contact form submissions: your name, email address, subject, and message.
• Enterprise enquiries: your name, email, organisation, and message.
• IP address, device type, operating system, browser type, and referrer (logged as part of standard web-server operation and analytics).
• An anonymous session identifier, visit count, page view events, search events, clinic view events, and button-click events — recorded for Platform improvement and for aggregated statistics displayed to Clinic Owners. These events are linked to a random session ID and not to any personal identifier.
• Cookie preferences.
• Quiz answers (stored only in the browser URL for the purpose of generating your results — not persisted on our servers).
• Cost calculator inputs (processed in the browser and not persisted on our servers).

Reviewers

• Name you provide with your review (displayed publicly as first name + last initial).
• Email address (used for moderation, spam prevention, and duplicate-review checks — never displayed publicly).
• Review content, rating, title, treatment received (optional), and approximate visit date (optional).
• Timestamp and basic event metadata.

Clinic Owners (Account Holders)

• Account information: name, email address, password (hashed, never stored in plain text), and phone number.
• Clinic business information: name, address, phone, email, website, description, images, opening hours.
• Practitioner information: registration body, registration number, role, bio (optional), photo (optional).
• Proof-of-ownership documents submitted as part of a claim request.
• Subscription tier, billing history, and payment references. Card details are collected and stored by Stripe — SafeSkin never stores full card numbers.
• Analytics about listing performance (views, clicks, lead events) in aggregated form.

Free-listing Submitters (the public submission form)

• Clinic business information as above (name, address, contact details, treatments/concerns selected).
• Lead practitioner’s name, qualification, registration body, and registration number — used to verify the clinic against the relevant statutory register before publishing.
• Registration certificate file you upload. This certificate is stored in a private, admin-only location, is never shown on the public clinic listing, and is accessible only to SafeSkin admin staff via short-lived access links for the purpose of verification and ongoing compliance checks.
• Submitter email (the address you provide on the form) is used to send a submission-received confirmation and any follow-up needed to complete verification. We do not create an account from this submission.

We do not knowingly collect data from anyone under 18. If you believe we have collected data from a minor, please contact us so we can delete it.

We do not collect special category (“sensitive”) personal data such as health, biometric, or genetic data. Do not submit health information, photographs of medical conditions, or medical records through the Platform. Any such information received via contact forms or reviews may be deleted without response.

4. Patient Enquiries

Some clinics choose to accept enquiries directly from their SafeSkin listing. If you send one, this section explains what happens to it.

• What we collect: your name, email address, phone number (optional), and your message.
• Why: to deliver your enquiry to the clinic you chose. That is the only purpose we use it for.
• Who receives it: the clinic you contacted. Once the clinic receives your enquiry, it is responsible for its reply and for any personal data you exchange with it afterwards. The clinic will reply to the email address you provide.
• What SafeSkin does with it: we store your enquiry so we can deliver it, and we monitor enquiry volumes to keep the service working properly. This means SafeSkin admin staff can see enquiries. We do not use your enquiry for marketing and we never sell it.
• Retention: enquiries are deleted automatically 12 months after they are sent, whatever their status.
• Consent: you are asked to consent before sending, and we record the version of the consent wording you agreed to alongside your enquiry.

Please do not include health information, photographs of medical conditions, or medical records in an enquiry — discuss anything clinical directly with the clinic at your consultation. All of the rights described in section 11 apply to your enquiry data; to exercise them, contact us at [email protected].

5. Why We Process Your Data (Purposes and Lawful Bases)

Automated decision-making and profiling. Search result ordering is partly influenced by paid subscription tier and distance from the search location. These are simple ordering criteria and do not constitute automated decision-making producing legal or similarly significant effects on any User under Article 22 GDPR.

6. Who We Share Your Data With (Processors and Recipients)

We never sell personal data. We share personal data only with the following processors and recipients, each bound by contractual and legal obligations to protect your data:

• Supabase Inc. — database hosting, authentication, file storage.
• Stripe Payments Europe, Ltd. — payment processing and subscription billing.
• Vercel Inc. — website hosting, edge serving, and analytics.
• Resend (or equivalent transactional email provider) — sending transactional emails.
• Google Analytics 4 — anonymised website usage analytics, only where the user has consented to analytics cookies.
• OpenStreetMap contributors and map-tile providers — rendering maps (no account data shared).
• Professional advisers — accountants, lawyers, auditors, where necessary and on confidentiality terms.
• Regulators, law enforcement, or courts — where required by law, court order, or to protect our legal rights.
• Successors — in the event of a merger, acquisition, sale of assets, or insolvency, data may be transferred to the successor entity, subject to equivalent privacy protections.

7. International Transfers

Some processors may store or process data on servers outside the European Economic Area (EEA), including in the United Kingdom (covered by the UK adequacy decision) and the United States. Where this occurs, we rely on appropriate safeguards under GDPR, such as the European Commission’s Standard Contractual Clauses (SCCs) and, where applicable, supplementary measures. You can request a copy of the safeguards applicable to a specific processor by contacting [email protected].

8. Cookies and Similar Technologies

We use cookies, browser local and session storage, and similar technologies for essential functionality (such as authentication and consent state) and, with your consent, for analytics and preferences. For full details, please see our Cookie Policy.

9. Data Retention

• Contact form submissions: 12 months, then deleted.
• Patient enquiries to clinics: 12 months, then deleted automatically.
• Reviewer name and email: retained for the lifetime of the review; if a review is deleted, the email is retained for up to 12 months for duplicate/spam prevention, then deleted.
• Review content: retained until deletion request or admin removal.
• Clinic Owner accounts: duration of the account plus 24 months, then data is deleted or anonymised.
• Subscription, invoice, and payment records: 7 years (Irish Revenue requirement).
• Analytics events: up to 26 months, after which personal identifiers are removed.
• Server access logs: up to 30 days.
• Marketing consent records: for as long as consent is active, plus 24 months.
• Browser session and local storage data (favourites, recently viewed, compare selection): stored on your device only, cleared by you or the browser.

10. Security

We implement appropriate technical and organisational measures to protect personal data, including encryption in transit (TLS/SSL), encryption at rest for our primary database, strong password hashing, row-level security rules, role-based access controls, and separation of service-role credentials. Payment card data is collected and handled directly by Stripe (a PCI-DSS Level 1 service provider); it does not pass through SafeSkin servers.

Breach notification. In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the Data Protection Commission within 72 hours where required, and will notify affected individuals without undue delay where the breach is likely to result in high risk.

No online service can guarantee absolute security. You are responsible for keeping your Account credentials secure and for notifying us promptly of any suspected unauthorised access.

11. Your Rights under GDPR

Subject to applicable exemptions, you have the following rights in respect of your personal data:

• Access — a copy of the personal data we hold about you.
• Rectification — correction of inaccurate or incomplete data.
• Erasure (“right to be forgotten”) — deletion of your data where no longer needed or where consent is withdrawn.
• Restriction of processing in certain circumstances.
• Data portability — receive your data in a structured, commonly used, machine-readable format.
• Object to processing based on legitimate interests, including direct marketing.
• Withdraw consent at any time where processing is based on consent (without affecting the lawfulness of earlier processing).
• Not be subject to solely automated decisions producing legal or similarly significant effects (we do not carry out such processing).
• Lodge a complaint with the Irish Data Protection Commission (see section 12).

To exercise any right, email us at [email protected]. We may need to verify your identity before acting on a request. We aim to respond within 30 days and may extend by a further 60 days for complex requests, notifying you of any extension.

12. Complaints

If you are not satisfied with how we handle your data, you have the right to lodge a complaint with the Irish Data Protection Commission:

Data Protection Commission
21 Fitzwilliam Square South, Dublin 2, D02 RD28
Website: www.dataprotection.ie
Phone: +353 (0)1 765 0100

13. Changes to This Policy

We may update this Policy from time to time. The current version is always available at this URL with the “Last updated” date above. Material changes will be notified on-site and, where we hold your email address, by email. Continued use of the Platform after a change takes effect constitutes acceptance of the updated Policy.

14. Contact

For any data protection question or request, contact us at [email protected].