Terms of use and privacy policy

Clause 1 General provisions

1.1 Object

These Terms of Use and Privacy Policy govern the conditions of access, browsing, use and operation of the Skinpaths Platform ( hereinafter Platform ), as well as the processing of personal data collected through it.

Use of the Platform implies full, express and unconditional acceptance of all the provisions contained in this document.

1.2 Scope of Application

These terms apply to any natural or legal person who accesses, consults, browses, uses or interacts with the Platform by any technological means.

1.3 Modifications

Skinpaths may modify these Terms of Use and Privacy Policy in whole or in part when necessary to:

• Comply with regulatory changes.
• Incorporate new functionalities.
• Adapting technological processes.
• Improve the delivery of services.

The modifications will be published on the Platform and will take effect from their publication date.

Continued use of the Platform after a modification will imply acceptance of the new conditions.

1.4 Definitions

For the purposes of this document, the following definitions shall apply:

Cookies: Cookies are files or similar technologies that allow information about a user’s browsing activity to be stored and retrieved.

Personal Data: Information concerning an identified or identifiable natural person.

Sensitive Data: Those related to health status, medical history, symptoms or any information specially protected by Law No. 8968.

Law No. 7472: Law for the Promotion of Competition and Effective Consumer Protection.

Law No. 8968: Law on the Protection of the Person against the Processing of their Personal Data.

Law No. 10.946: Law on the Governance of Digital Services and Electronic Commerce.

Platform: Website managed by Skinpaths that provides access to dermatological information, professional directories, and appointment management systems.

Health Professional: A person duly authorized to practice their profession related to human health, duly registered with the Professional Association for the proper exercise of their profession and who appears in the Platform’s directory.

User: Any person who accesses or uses the Platform.

Clause 2 Identification of the responsible party

2.1 Platform Manager

The Platform is operated and managed by: 3-102-092329 SRL who will be considered responsible for the processing of personal data collected through it.

2.2 Contact Information

Inquiries related to this document may be directed to:

• General Mail: info @skinpaths.com
• Privacy Email : [email protected]
• Telephone: (506)71071824

Clause 3 Legal capacity and registration

3.1 Legal Capacity

Use of the Platform is reserved for persons who have sufficient legal capacity to be bound in accordance with the legislation of the Republic of Costa Rica.

When a person uses the Platform on behalf of a legal entity, they represent and warrant that they have sufficient authority to act on its behalf.

3.2 Information Provided

The user guarantees that all information provided during registration, contact or appointment management processes is truthful, accurate, complete and up-to-date.

The Platform will not be liable for damages arising from incorrect information provided by the user.

3.3 Access Credentials

When account registration exists, the user will be responsible for: (i) maintaining the confidentiality of their credentials, (ii) protecting their passwords, (iii) immediately notifying any unauthorized use.

Clause 4 Object and nature of the platform

4.1 Object

The Platform’s purpose is:

1. Facilitate access to information related to dermatology and health.
2. Publish educational content created by healthcare professionals.
3. Maintain a directory of professionals.
4. Facilitate the scheduling and management of medical appointments.
5. Promote education and scientific dissemination on dermatological topics.

4.2 Technological Nature

The Platform is solely a technological intermediary tool providing access to educational content, search engines, a directory of healthcare professionals, a contact system, a medical appointment scheduling system, and other digital tools related to dermatology and general health. Skinpaths does not provide medical services nor does it intervene in the professional services offered by the professionals listed in the directory.

4.3 Absence of Medical Benefit

The Platform: a) Does not make diagnoses, b) Does not prescribe treatments, c) Does not issue medical prescriptions, d) Does not provide medical consultations, e) Does not offer health care, f) Does not process payments related to medical services.

Clause 5 Directory of health professionals

5.1 Nature of the Directory

The Platform includes a directory of health professionals, mainly dermatologists, whose professional profile must contain:

1. Name and surname.
2. Photograph.
3. Specialty and subspecialties.
4. Academic background.
5. Duly registered with the College of Physicians and Surgeons of Costa Rica. (Indicate membership number and validity period)
6. Languages.
7. Location of the office and/or medical center where he/she provides services.
8. Professional contact information.
9. Accepted insurance policies.
10. Professional biography and/or relevant professional links.

5.2 Professional Independence

The professionals included in the directory carry out their professional activity autonomously and independently.

The inclusion of a professional does not imply an employment relationship, an exclusive commercial relationship, a representation and/or association, nor a legal dependence on the Platform.

5.3 Professional Responsibility

Each professional will be solely responsible for:

1. The diagnoses issued.
2. The prescribed treatments.
3. The recommendations made.
4. The medical procedures performed.
5. Compliance with its Code of Ethics, as well as applicable professional and health regulations.
6. Updating your professional profile.

5.4 Absence of Certification

The inclusion of a professional on the Platform does not constitute: a certification, guarantee, endorsement and/or professional support.

Clause 6 Medical information and educational content

6.1 Informative Purpose

The articles, news, scientific publications, comments, educational materials and other content published on the Platform have an exclusively informative, educational and disseminative purpose.

6.2 Exclusion of Medical Act

The information contained on the Platform does not constitute: (i) a medical act, (ii) a diagnosis, (iii) a professional consultation, (iv) a medical prescription, (v) an individualized treatment, and/or (vi) a second professional opinion.

6.3 Publications Signed by Professionals

Articles published on the Platform can be identified by:

1. Author’s name.
2. Professional specialty.
3. Academic credentials.
4. Relevant professional information.

Each author will be responsible for the information published under their name.

Skinpaths strives to provide rigorous, understandable information supported by the medical and scientific knowledge of its authors and contributors. However, medicine evolves, and a publication may require updating as evidence, recommendations, and/or regulations change; therefore, the professional and/or Skinpaths may correct, update, expand, and/or remove publications when they deem it necessary.

6.4 Exclusion of Editorial Responsibility

The publication of content created by professionals does not imply approval, validation, or adoption of said criteria by Skinpaths.

6.5 Mandatory Professional Consultation

All health-related decisions must be made based on the prior opinion of a duly authorized health professional.

The user expressly acknowledges that the published information does not replace individualized medical consultation.

Clause 7 Absence of doctor-patient relationship

7.1 Express Exclusion

The use of the Platform does not create a doctor-patient relationship between the user and: (i) Skinpaths, (ii) the Platform administrators, (iii) the collaborators, and (iv) the content authors.

7.2 Independent Professional Relationship

The eventual doctor-patient relationship can only be established between the user and the selected health professional.

Clause 8 Management of medical appointments

8.1 Purpose of the Appointment Scheduling Service

The Platform provides users with technological tools that allow them to request, coordinate, schedule, modify or cancel appointments with health professionals included in the directory.

The use of these tools does not imply the provision of medical services by the Platform nor the existence of any professional relationship between Skinpaths and the advertised professionals.

8.2 Nature of the Service

The Platform acts exclusively as a technological intermediary between the user and the selected healthcare professional.

Therefore, the Platform does not guarantee:

a) The permanent availability of professionals.

b) Obtaining an appointment on a specific date. (The appointment is subject to availability in the professional’s schedule.)

c) Automatic confirmation of a request.

d) Effective care from the selected professional.

e) The continuity of the availability of the professional agenda.

8.3 Appointment Request

Appointment requests managed through the Platform will be subject to the availability reported by each professional and/or medical center.

The user acknowledges that requesting an appointment does not necessarily imply its definitive confirmation until it is accepted by the corresponding professional, when appropriate.

8.4 Accuracy of Information

The user will be responsible for providing truthful, complete and up-to-date information when managing any appointment.

The Platform will not be responsible for errors derived from inaccurate, incomplete or outdated data provided by the user.

8.5 Appointment-Related Communications

The Platform may send electronic communications related to:

1. Appointment requests.
2. Confirmations.
3. Reprogramming.
4. Cancellations.
5. Reminders.
6. Operational information related to the service.

Clause 9 Cancellation, rescheduling and non-attendance policy

9.1 Cancellation by the User

The user may cancel an appointment using the means enabled by the Platform or those defined by the professional and/or corresponding medical center.

Cancellations should be made as far in advance as possible to facilitate the proper management of the professional schedule.

9.2 Rescheduling Appointments

Rescheduling requests will be subject to availability at the time of the request.

The Platform does not guarantee the immediate availability of new dates or time slots.

9.3 Cancellation by the Professional

Medical professionals or centers may cancel or reschedule appointments for medical, operational, administrative, technical or force majeure reasons.

When reasonably possible, the user will be informed in a timely manner of any changes.

9.4 User Absence

When a user fails to appear for a scheduled appointment without prior notice, the professional or medical center may apply the internal policies it deems appropriate, in accordance with applicable legislation.

The Platform will not be responsible for the application of these policies.

9.5 Absence of Payments Managed by the Platform

The Platform does not receive payments related to medical consultations nor does it participate in economic transactions between healthcare professionals and patients.

Any aspect related to charges, fees, refunds, returns or commercial conditions will be managed directly between the user and the corresponding professional.

9.6 Exclusion of Liability

The Platform will not be responsible for: (i) Cancellations, (ii) Rescheduling, (iii) Absences, (iv) Delays, (v) Professional breaches, (vi) Disputes arising from the relationship between the user and the selected professional.

Clause 10 Obligations of the user

10.1 Use in Compliance with the Law

The user agrees to use the Platform diligently, responsibly, ethically and in accordance with the current legislation of the Republic of Costa Rica.

10.2 Obligation of Truthfulness

The information provided by the user must be accurate, complete, up-to-date and verifiable where applicable.

10.3 Prohibited Conduct

It is expressly prohibited:

1. Using false or misleading information.
2. Impersonating others.
3. Gaining unauthorized access to computer systems.
4. Introduce viruses, malware, or malicious code.
5. Interfering with the operation of the Platform.
6. Using the Platform for illegal activities.
7. Collecting information from third parties without authorization.
8. Using automated mechanisms to extract information from the site without the express authorization of the Owner.

10.4 Responsibility for Use

The user will be responsible for any damages that may arise from any breach of the obligations set forth in these terms.

Clause 11 Intellectual and industrial property

11.1 Ownership of Rights

The material and content on this website is protected under current and valid Costa Rican legislation and international conventions regarding intellectual property rights. The user expressly acknowledges and accepts that the use of material or content published on the Platform is not permitted for commercial purposes or any other purposes not described herein. Therefore, the user may not copy, download, market, modify, publish, distribute, create derivative works from, or otherwise exploit any material or content without the prior written authorization of Skinpaths.

Trademarks, photographs, scientific publications, logos, and other materials belonging to third parties retain the rights of their respective owners. Their presence on skinpaths.com does not imply a transfer of rights or authorization for users to reuse them beyond the limits permitted by law or by their respective owners.

11.2 License Agreement

Use of the Platform grants exclusively a limited, revocable, personal, non-exclusive and non-transferable authorization to access and use the content in accordance with these terms.

11.3 Restrictions

It is prohibited to: (i) Reproduce, (ii) Distribute, (iii) Transform, (iv) Commercialize, (v) Adapt, and/or (vi) Economically exploit any content without prior written authorization from the corresponding owner.

11.4 Third-Party Content

Publications made by health professionals will retain the ownership corresponding to their respective authors, without prejudice to the licenses necessary for their publication within the Platform.

Clause 12 Protection of personal data

12.1 Data Controller

The entity responsible for processing the personal data collected through the Platform will be: 3-102-092329 SRL

12.2 Applicable Regulatory Framework

The processing of personal data will be carried out in accordance with:

1. Law No. 8968, Law on the Protection of the Person against the Processing of their Personal Data and its Regulations.
2. Law No. 7472, Law for the Promotion of Competition and Effective Consumer Protection and its Regulations.
3. Law No. 30, Civil Code of Costa Rica.
4. Law No. 7739, Code of Childhood and Adolescence.
5. Law No. 10.946, Law on the Governance of Digital Services and Electronic Commerce.

12.3 Applicable Principles

The Platform will process personal data respecting the principles of:

1. Informed consent.
2. Data quality.
3. Purpose.
4. Proportionality.
5. Security.
6. Confidentiality.
7. Accuracy.
8. Update.
9. Informational self-determination.

Clause 13 Categories of data collected

• Identification Data

The Platform may collect: name, surname, identity document when necessary and date of birth.

• Contact Information

The following may be collected: email address, telephone number, physical address and alternative means of contact.

• Technical Data

The Platform may collect: IP address, device type, browser, operating system, activity logs, security information, among others.

• Appointment-Related Data

Data may be collected relating to: the medical specialty requested, the professional selected, the date of care and the general reason for consultation.

• Sensitive Health Data

When strictly necessary for appointment management or handling requests, the user may voluntarily provide information related to: symptoms, medical conditions, reason for consultation and/or relevant background.

Such data will be considered sensitive data in accordance with Law No. 8968.

Clause 14 Purposes of the processing

14.1 Platform Management

Personal data may be used for:

a) Manage user accounts.

b) Manage information requests.

c) Coordinate medical appointments.

d) Facilitate communication between users and professionals.

e) Handle support requests.

14.2 Legal Compliance

The information may be processed to: comply with legal obligations, respond to requests from competent authorities, manage security incidents and/or ensure the integrity of the systems.

14.3 Improvement of Services

The data may be used to improve the functionality, security, user experience and quality of the Platform.

Where possible, data anonymization or aggregation techniques will be used.

14.4 Prohibition of Incompatible Use

The information collected will not be used for purposes incompatible with those expressly informed to the user.

In particular, health data will not be used for:

• Marketing.
• Creation of advertising profiles.
• Commercial segmentation based on medical conditions.

Clause 15 Consent for the processing of sensitive data

15.1 Express Consent

In accordance with Law No. 8968, data relating to health status constitutes sensitive data.

The user acknowledges and accepts that they may voluntarily provide information related to their health to manage appointments, contact forms or specific requests.

By providing this information and accepting these terms, the user gives free, informed, specific, unambiguous and express consent for its processing.

15.2 Scope of Consent

The consent given will only cover the processing of information strictly necessary for:

1. Manage appointments.
2. Facilitate communication with professionals.
3. Coordinate service requests.
4. Fulfill legal obligations associated with the service.

15.3 Enhanced Protection Measures

The Platform will implement reasonable measures designed to protect the confidentiality and integrity of health information.

Access to this data will be limited to authorized personnel and, where appropriate, to the health professional involved in the requested care.

15.4 Revocation of Consent

The data subject may revoke the consent given at any time by means of a written request sent to the privacy email address indicated by the Platform.

However, the revocation will not affect the lawfulness of processing carried out previously or that which is necessary to comply with current legal obligations.

15.5 Health and Advertising Data

Health data will never be sold, traded, or used for marketing based on users’ medical conditions.

Clause 16 Transfer and communication of personal data

16.1 Data Communication

The Platform will only communicate or make available personal data when this is necessary for the fulfillment of the purposes described in this document and there is a legal basis that enables it.

16.2 Authorized Recipients

Personal data may be communicated, where appropriate, to:

1. Healthcare professionals selected by the user for appointment management.
2. Technology providers that offer hosting, maintenance, support, development or IT security services.
3. Electronic communication service providers.
4. Legal advisors, accountants or professionals subject to confidentiality obligations.
5. Administrative, judicial or regulatory authorities when there is a legal obligation or formal requirement.

16.3 Data Processors

When external providers process information on behalf of Skinpaths, they will act as data processors and will be obliged to:

1. Maintain the confidentiality of the information.
2. Apply appropriate safety measures.
3. Use the data only for authorized purposes.
4. Comply with applicable regulations regarding the protection of personal data.

16.4 International Transfers

In the event that certain technology providers store or process information outside of Costa Rican territory, the Platform will ensure that such transfers are carried out under reasonable security and confidentiality conditions compatible with the nature of the data processed.

16.5 Marketing Prohibition

The Platform will not sell, rent, exchange or market personal data or sensitive health data of users.

Clause 17 Preservation and security of information

17.1 Duty of Safety

Skinpaths will implement reasonable technical, administrative, and organizational measures designed to protect information against:

1. Unauthorized access.
2. Accidental loss.
3. Improper alteration.
4. Unauthorized disclosure.
5. Unlawful destruction.

17.2 Protection Measures

The measures may include, among others:

1. Access controls.
2. Credential management.
3. Encryption where appropriate.
4. Backup copies.
5. Security monitoring.
6. Incident management protocols.
7. Training and confidentiality of authorized personnel.

17.3 Data Retention

The information will be kept only for the period reasonably necessary to:

1. To fulfill the purposes described.
2. To fulfill legal obligations.
3. To defend rights or claims.
4. Ensure the traceability and security of the systems.

Once these purposes have been fulfilled, the data may be deleted, blocked or anonymized as appropriate.

17.4 Technological Risk

The user acknowledges that no technological system can guarantee an absolute level of security.

Consequently, although the Platform will take reasonable protective measures, it does not guarantee the absolute absence of security incidents arising from circumstances beyond its reasonable control.

Clause 18 Rights of users

18.1 Recognized Rights

In accordance with Law No. 8968, users may exercise the following rights:

1. Access.
2. Rectification.
3. Update.
4. Cancellation or deletion where appropriate.
5. Opposition when legally applicable.
6. Revocation of consent.

18.2 Exercise of Rights

Applications must be sent to the privacy email address provided by the Platform and include at least:

• Full name of the applicant.
• Means to receive notifications.
• Clear description of the request.
• Reasonable elements that allow verification of the applicant’s identity.

18.3 Response Time

The Platform will process requests within the time limits established by current regulations or, failing that, within a reasonable time.

18.4 Supervisory Authority

If the user believes that their rights have been violated, they may appeal to the Data Protection Agency of the Inhabitants (PRODHAB), without prejudice to any judicial or administrative remedies that may be appropriate.

Clause 19 Cookies and similar technologies policy

19.1 Purpose

The Platform may use cookies to:

1. Ensure the technical functioning of the site.
2. Facilitate authentication processes
3. Maintain active sessions.
4. Remember browsing preferences.
5. Obtain statistical information on the use of the Platform.

19.2 Cookie Categories

a) Necessary Cookies

They are essential for the operation of the Platform and the provision of its essential services.

b) Preference Cookies

They allow you to remember settings or preferences selected by the user.

c) Analytical Cookies

They allow obtaining aggregated statistical information on navigation, performance and use of the Platform.

d) Third-Party Cookies

Certain external services integrated into the Platform may use their own tracking technologies in accordance with their respective policies.

19.3 Consent

Where legally required, the installation of non-essential cookies will be subject to the user’s prior consent.

The user may accept, reject or configure the available cookies through the mechanisms enabled for this purpose.

19.4 Revocation of Consent

The consent given for the use of cookies may be modified or revoked at any time through the configuration tools available on the Platform.

19.5 Health Data Protection

The Platform will not use cookies or tracking technologies to infer, profile, market or segment information related to medical conditions, diagnoses, treatments or health status of users.

Clause 20 Limitation of liability

20.1 Platform Availability

The Platform will endeavor to maintain the continuity of its services; however, it does not guarantee that these will be permanently and uninterruptedly available.

20.2 Exclusion of Technological Guarantees

The Platform is provided «as is» and as available.

Unless otherwise required by law, Skinpaths does not guarantee:

1. The absence of errors.
2. Continuous system availability.
3. Compatibility with all devices.
4. The absence of interruptions, failures, or vulnerabilities.

20.3 Limitation due to Actions of Third Parties

The Platform will not be responsible for:

• Actions of independent health professionals.
• Medical decisions.
• Diagnostics.
• Treatments.
• Prescriptions.
• Clinical results.
• Conduct of third-party users.

20.4 Medical Content

The use of medical information published on the Platform is the sole responsibility of the user.

No content should be interpreted as a substitute for professional medical advice.

20.5 Indirect Damages

To the maximum extent permitted by applicable law, Skinpaths will not be liable for indirect damages, lost profits, loss of opportunity, loss of information, or similar losses arising from the use of the Platform.

Clause 21 Protection of consumer rights

21.1 Respect for Inalienable Rights

Nothing contained in these Terms of Use and Privacy Policy shall be construed as a limitation, waiver or restriction of the rights recognized to consumers by Costa Rican law.

21.2 Application of the Consumer Protection Law

The relationship between the Platform and users will be governed, where applicable, by Law No. 7472, Law for the Promotion of Competition and Effective Consumer Protection, as well as by its complementary regulations.

21.3 Contractual Good Faith

The interpretation and execution of these conditions must be carried out in accordance with the principles of good faith, contractual balance and transparency.

Clause 22 Third-party links, content and services

22.1 External Links

The Platform may contain links to third-party websites, services, or resources for informational or reference purposes.

22.2 Independence from Third Parties

The existence of a link does not imply: approval, endorsement, recommendation and/or commercial association between Skinpaths and the corresponding third party.

22.3 Exclusion of Liability

Skinpaths does not control or assume responsibility for:

1. Content published by third parties.
2. Third-party privacy policies.
3. Availability of external services.
4. Security of websites external to the Platform.
5. Products or services offered by third parties.

22.4 Review of External Conditions

Before providing personal information to third parties, the user should review the terms of use and privacy policies applicable to those services.

Clause 23 Minors

23.1 Services Directed at the General Public

The Platform is primarily aimed at adults with sufficient legal capacity to enter into contracts and accept the conditions set out in these Terms of Use and Privacy Policy.

23.2 Information Related to Minors

When it is necessary to manage a medical appointment or a request related to a minor, the corresponding information must be provided by the person who validly exercises parental authority, guardianship, legal representation or any other legally recognized figure.

23.3 Consent of the Legal Representative

The Platform may request reasonable evidence of legal representation when necessary to protect the rights and interests of the minor.

The legal representative will be responsible for ensuring the accuracy and legality of the information provided.

23.4 Reinforced Protection

Skinpaths will endeavor to apply enhanced confidentiality and security measures when dealing with information related to minors, especially when such information involves health data.

23.5 Detection of Information Collected Without Authorization

If Skinpaths becomes aware that personal data of a minor has been collected without the authorization required by applicable law, it may take the necessary steps to delete or block such information, without prejudice to any other actions that may be appropriate.

Clause 24 Modifications to the terms of use and the privacy policy

24.1 Power of Modification

The Owner reserves the right to modify, update, supplement or replace these Terms of Use and Privacy Policy when necessary to:

1. Comply with legislative or regulatory changes.
2. Adapting to new technological functionalities.
3. Improve operating procedures.
4. Strengthen security and data protection measures.
5. Incorporate new services or functionalities.

24.2 Publication of Changes

The modifications will be published on the Platform indicating the corresponding update date.

24.3 Entry into Force

Unless otherwise stated, the modifications will come into effect upon their publication on the Platform.

24.4 Continuous Use

Continued use of the Platform after the posting of changes will constitute acceptance of the modified terms.

Clause 25 Express consents

25.1 General Acceptance

By using the Platform, the user declares that they have read, understood and accepted these Terms of Use and Privacy Policy.

25.2 Consent for the Processing of Personal Data

☐ I have read and agree to the Terms of Use and Privacy Policy.

☐ I authorize the processing of my personal data for the purposes described in this document.

25.3 Consent for the Processing of Health Data

☐ I expressly authorize the processing of the health data that I voluntarily provide for the management of medical appointments and other purposes described in this Privacy Policy.

25.4 Informative and Educational Communications

☐ I wish to receive informative, educational communications and news related to dermatology, health and activities of the Platform.

25.5 Revocation

The user may revoke any of the consents granted when legally appropriate and through the mechanisms enabled for that purpose.

Clause 26 Legal notice

26.1 Informative Nature of the Content

All information, articles, news, publications, educational materials, research, comments, professional opinions and other content available on the Platform have an exclusively educational, informative and informative purpose.

26.2 Exclusion from Diagnosis and Treatment

No content published on the Platform should be interpreted as:

a) Medical diagnosis.

b) Professional consultation.

c) Medical act.

d) Pharmacological prescription.

e) Individualized treatment.

f) Substitute for a professional medical assessment.

26.3 Mandatory Professional Consultation

Health-related decisions should be made exclusively through direct consultation with a duly authorized health professional.

Each medical condition requires an individualized and personalized assessment.

26.4 Medical Emergencies

The Platform does not provide emergency medical services.

Contact forms, messaging systems, emails, or other means enabled by the Platform do not constitute channels for the urgent care of medical conditions.

In the event of a medical emergency, the user should immediately contact the appropriate emergency services or go to the nearest medical center.

26.5 Limitation of Liability for Medical Content

Skinpaths will not be responsible for decisions, actions or omissions taken by users based solely on information published on the Platform.

The use of the available information is the sole responsibility of the user.