At "Origino" we prioritize our users' privacy. This Privacy Policy outlines the types of information collected and recorded by the "Origino" Mobile Application (referred to as the "App") and explains how we utilize this information.
If you have any questions or need further information regarding our Privacy Policy, please feel free to reach out to us.
Definitions
Personal Data (or User Data): Any information that, either on its own or in combination with other data, enables us to identify an individual.
Usage Data and Log Files: Information that is collected automatically through this App (or third-party services used within it). This may include details such as the IP addresses or domain names of devices used by App Users, timestamps of requests, methods of submitting requests to the server, the size of files received in response, numerical codes indicating the server's response status (e.g., success, error), the user's country, browser features, operating system details, time spent on each page within the App, the navigation path taken within the App, and other device-related parameters.
User: An individual who utilizes the App and consents to this Privacy Policy.
Data Subject: The individual to whom the Personal Data pertains.
Data Processor: A natural or legal entity, public authority, agency, or other organization that processes Personal Data on behalf of the Data Controller, as outlined in this Privacy Policy.
Data Controller (or Company): The entity that determines the purposes and means of processing Personal Data, including security measures related to the operation and use of this App. Unless specified otherwise, the Data Controller is the Owner of this App.
Service: The functionality provided by this App, as described in the relevant terms (if available) and on this site/app.
Introduction
At GenAI GmbH. ("we," "us," or "our"), we are dedicated to safeguarding your privacy. This Privacy Policy ("Privacy Policy") outlines our data protection practices and details the types of information we may process when you install and/or use the “Origino” mobile application (the "App," "our App"). In this context, "personal data" or "personal information" refers to any information related to an identifiable individual, either directly or indirectly, particularly through reference to an identification number or specific characteristics of their physical, physiological, mental, economic, cultural, or social status.
This Privacy Policy applies to all Users of the App and anyone who accesses it (“Users”). As defined under the General Data Protection Regulation (GDPR), we act as the data controller, unless stated otherwise.
PLEASE TAKE A MOMENT TO REVIEW THIS PRIVACY POLICY, AS IT CONTAINS CRUCIAL INFORMATION ABOUT HOW YOUR PERSONAL INFORMATION MAY BE HANDLED. BY USING THE APP, YOU CONFIRM THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO COMPLY WITH THIS PRIVACY POLICY.
Log Files and User Data We Collect
The "Origino" app follows standard data collection practices, including the use of log files. This is a common method used by hosting providers for website analytics. The information collected from log files includes IP addresses, browser types, Internet Service Provider (ISP) details, timestamps, referring and exit pages, and click counts. It’s important to note that this information is not personally identifiable. We collect this data to analyze trends, manage the website, track user activity, and gather demographic insights.
In addition to log file data, we collect the following information when you use our App:
Other Identity Data: This includes personal identification information such as your birth date, usernames, full name, and phone number.
Access to Camera and Photos: The App requires access to your device's camera and photos for scanning facial and skin conditions. We do not collect, store, or use any data from your camera roll unless you specifically choose to upload or share it within the App. With your consent, we may also access your geolocation data to provide more accurate search results based on your location.
Content Information Sharing: To offer both basic and advanced features, the App may receive content information, including images.
Please be aware that if you delete your account, all associated information will be permanently lost and cannot be recovered. Logging out of your account will remove your browsing history from the device, but you can restore your history by logging back in with the same account.
Automatic Information Processing
With your consent, our App uses third-party data processing technologies, including API tools and analytics/advertising solutions, to analyze certain data sent from your device. Some of these tools may automatically process your personal data, potentially involving profiling. Profiling entails analyzing personal data to assess characteristics such as interests, preferences, behavior, location, and movements. This automated processing of data only begins after you grant permission for our App to track your activities.
In line with our legitimate interests, we may process certain information related to your device and user activity. This data, described in the "Automatic Processing of Information" section, is typically non-personal and does not identify you directly. We access and analyze this data in aggregate form to improve our App and provide a better user experience.
When using our App on a mobile device (such as a phone, tablet, or smartwatch), certain device details, including "device identifiers," are reported. These identifiers are small files that uniquely identify your device without storing personal information, allowing us to generate generalized reports and offer personalized content and third-party ads.
Types of Data Processed
Device Information: Details such as device type, operating system, model, manufacturer, screen size, audio volume, battery level, and memory usage.
App Data: The App automatically processes and reports data such as the App's name, version, and unique API key. Some services may record a list of installed or active apps on your device.
App Analytics: Our analytics tools may automatically log actions within the App, such as taps, screens visited, in-app purchases, and custom events.
Third-Party Data Processing Disclaimer
Please be aware that we do not control the data shared with third-party tools and cannot be held responsible for their processing of this data. Certain services may create profiles based on your personal data or device information using technology outside our control. For example, if linked to Facebook, your device information may be used in combination with your Facebook profile data (age, gender, demographics). Any questions about third-party data handling should be directed to those providers (see the "Sharing of Your Information" section).
Sharing Your Information
We only disclose your information to third parties as outlined in our Privacy Policy. We adhere to the U.S. Digital Advertising Alliance’s Self-Regulatory Principles for the Mobile Environment, partnering exclusively with third parties who have assured us of implementing appropriate technical and organizational measures to protect your personal data. However, we cannot guarantee the security of information transmitted directly from the App to these third parties and are not responsible for accidental loss or unauthorized access to your personal data due to their actions.
We do not rent or sell your personal data to third parties. However, we may share certain information, such as log files, device identifiers, and location data, with third-party providers that offer automatic data processing technologies for the App. We do not control these third parties’ tracking technologies or how they may use the data.
Please be aware that facial and skin scanning technology is provided by a third party, which processes the images you upload to deliver scan results, potential diagnoses, and recommendations. All user-uploaded images are transferred to this third party and stored on their servers solely for refining algorithms and improving the App’s AI system. These materials are not sold or distributed further.
We do not use, publish, or sell any media content provided by users for scanning purposes. All user-submitted media is used exclusively to enhance the App’s algorithms and object recognition capabilities. Media content is deleted from our cloud storage systems within one hour of scan completion and is solely used for training the neural network within the App. Users can access their scan history in their personal account, and this history remains available until the user chooses to delete it.
To provide essential infrastructure and improve our services, we currently work, or may work in the future, with the following third-party service providers:
ChatGPT (OpenAI) – An AI chatbot provider. Privacy Policy
Facebook (Meta Platforms, Inc.) – Offers analytics and ad management services. Privacy Policy
Google LLC – Provides analytics and ad management services. Privacy Policy
Please note that this list is not exhaustive and may change without prior notice.
Data Usage
We use your data solely for the following purposes:
Collecting Personal Data: The primary purpose of collecting personal data is to ensure the smooth operation of the "Origino" App. This includes resolving technical issues, troubleshooting, and keeping the App up-to-date.
Compliance with Legal Requirements: We may need to disclose personal data to law enforcement, regulators, or other entities as required by applicable laws, regulations, legal processes, or government requests. When possible, we will attempt to notify you before disclosing your information in response to such requests.
Gathering Feedback: We may use personal data to communicate with you about your experiences, preferences, and concerns regarding the App. You may be contacted via email or other communication channels associated with your account.
Legal Claims and Fraud Prevention: Personal data may be used to establish, exercise, or defend legal claims, as well as to prevent or detect fraud when necessary.
Please note that providing your personal data is entirely voluntary, but choosing not to may impact the availability and functionality of the App.
In general, we retain your personal data for as long as necessary to provide our App’s services and fulfill legal obligations. If additional storage is required by legal obligations (such as taxation, accounting, or auditing) or for safety, fraud prevention, or security reasons, the data may be retained for a specific period, no longer than legally required.
Third-Party Privacy Policies
For more information on the privacy practices of third-party services (including opt-out options), please consult their respective websites and privacy policies. We are not responsible for any misuse of your personal data by these third parties if they act beyond our instructions.
Our App may contain links to third-party websites or services, or you may access the App through a third-party site. We are not responsible for the privacy practices of these third-party sites or services, nor for the information or content they contain.
We may disclose your personal information if necessary for objective reasons, the public interest, or in unforeseen circumstances, including:
As required by law.
When we believe, in good faith, that disclosure is necessary to protect our rights, ensure your safety or the safety of others, investigate fraud, or respond to a government request.
If we are involved in a merger, acquisition, or asset sale, we will notify you via email and/or a prominent notice in our App of any changes in ownership or personal information usage, along with any choices you may have regarding your personal information.
Face Data
Our app allows users to capture or upload facial images (front, left, and right angles) for the purpose of providing skin analysis and general skincare insights.
What data we collect:
We collect facial images provided by the user solely for analysis purposes. We do not collect biometric identifiers and do not use the data for identity recognition.
How we use the data:
The facial images are processed to analyze visible skin characteristics (such as texture and appearance) in order to generate general, non-medical skincare insights.
Third-party processing:
To perform this analysis, images may be securely transmitted to a third-party AI service provider (OpenAI). This processing is strictly limited to generating analysis results and is not used for any other purpose.
Data storage and retention:
We do not store facial images on our servers. All images are processed temporarily and are deleted immediately after analysis is completed.
User control:
Users may delete any associated data at any time using the in-app “Delete Data” feature.
Consent:
Before any facial image is processed, users are informed and must explicitly agree to the processing of their data.
Security
We are committed to protecting your personal information and follow strict industry standards to ensure its security. We use robust measures to guard against loss, misuse, unauthorized access, disclosure, alteration, or destruction of your data, whether in transit or stored with us.
To uphold data protection principles, we implement essential technical and organizational safeguards, including data minimization and built-in security practices. Whenever possible, we encrypt your personal data using reliable encryption algorithms and apply hashing techniques for additional protection.
Despite our efforts, no method of data transmission over the Internet or electronic storage is completely secure. Therefore, we cannot guarantee absolute security. If a security breach occurs that compromises your personal information, we will notify you promptly, as required by applicable law.
Charges and Payment
Our e-commerce providers manage all billing, processing, and charges for in-app purchases. They securely handle your personal information as part of fulfilling the contract between you and us, ensuring its safety. We do not have access to your credit or debit card information and cannot use it.
Please note that we are not responsible for processing subscription payments; all payment matters are handled exclusively by the App Store. For any questions or concerns regarding payments, please contact App Store Support directly.
International Data Transfers
If you reside in the European Union or in any region with data protection laws that differ from those in the United States, please be aware that we may transfer your information, including personal data, to a country or jurisdiction that may not provide the same level of data protection as your own. As we operate globally and offer our App to users worldwide, this cross-border data transfer is essential for the automated processing of information by us, third-party organizations, and our advertising partners.
We will implement all necessary measures to ensure that any recipient of your personal data provides adequate protection in accordance with applicable data protection laws. By using our App, you consent to the potential transfer of your personal information to a third country, specific sectors within that country, or to an international organization.
We are dedicated to ensuring that the recipients of your personal data maintain an appropriate level of protection for the information received, in line with relevant legislation. While the level of protection may not be identical to that in your country, we take the necessary steps to safeguard your personal information.
Minors
To download, install, access, or use the App, you must be at least eighteen (18) years old. If you are under 18, please discontinue using our mobile application immediately. Additionally, individuals under the age of thirteen (13) are not permitted to download, install, access, or use the App.
If you are under 18 and wish to use our application, please have your parent or guardian contact us to review these terms of use for the mobile application.
“Origino” does not knowingly collect any Personally Identifiable Information from children under the age of 13. If you believe that your child has provided such information on our website, please contact us immediately so that we can take prompt action to remove it from our records.
Manage Your Usage Data and How to Opt Out
You have the right to request copies of your personal information, delete, amend, or update your personal data, restrict its use, or withdraw your consent for its processing at any time. Please note that if you withdraw your consent for the use of personal data, certain functionalities of the app may no longer be available to you.
To exercise your rights regarding your personal data, please contact us at floriang@genaigmbh.com.
In some cases, if your personal information is processed automatically, you may have the right to object to such processing. If your personal information is used for direct marketing, you can request that this processing cease. For further information on how to exercise this right, please refer to the third-party services mentioned in Section VI of our Privacy Policy. Instructions can be found on their respective privacy pages, including options such as functional APIs.
Consent
By using our website, you consent to our Privacy Policy and agree to its Terms and Conditions.
Disclaimer
This app is designed for general skin care assistance only and does not replace professional medical advice. For health-related concerns, please consult a qualified healthcare provider.
Changes to This Privacy Policy
We periodically review and update our privacy policies and procedures to enhance our practices. If we make any significant changes to how we process your data, we will notify you through this Privacy Policy and by posting a notice in the App. If you disagree with any changes, you may stop using the App.
Any Questions?
If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at floriang@genaigmbh.com.