Pimsy the Pimple Privacy Policy

Pimsy the Pimple (“Pimsy”) is an AI skin companion designed for general guidance, education, and support around skin and skincare.

Pimsy is smart, but not always right.

Pimsy is non-medical and non-pharmaceutical and does not provide medical advice, diagnosis, or treatment. AI-generated responses may sometimes be inaccurate, incomplete, outdated, or unsuitable for a user's specific situation.

Please use your own judgment and consult a qualified healthcare professional for medical concerns.

§ 1 General Information

(1) The responsible party pursuant to Art. 4 (7) of the European General Data Protection Regulation (GDPR) is System Akvile GmbH, Gänsemarkt 33, c/o Impact Hub, 20354 Hamburg, team@systemakvile.com, as also stated in the imprint.

(2) You can contact our data protection officer by emailing team@systemakvile.com or writing to us at our postal address in the form of a letter addressed to “the data protection officer”.

(3) If you contact us by e-mail or post, we will store your e-mail address and, if provided by you, your name and telephone number in order to process and respond to your request. We delete the data accrued in this context once storage is no longer necessary, unless legal retention obligations apply.

(4) Alongside our online offerings, we provide the AI web application “Pimsy the Pimple” (“Pimsy”), which can be accessed via supported browsers and devices. In the following sections, we inform you about the processing of personal data when using Pimsy. This privacy policy can be accessed at any time via the “Privacy Policy” section within the website or application.

(5) Pimsy is a non-medical, non-pharmaceutical AI skin companion designed for general guidance, education, and support around skin and skincare. Pimsy does not provide medical advice, diagnosis, or treatment.

§ 2 Collection and Processing of Personal Data

(1) Pimsy is designed to minimize personal data collection and currently does not require account creation.

(2) When using Pimsy, the following categories of data may be processed:

• chat and text inputs entered by users;
• voice input converted into text in real time;
• technical information such as browser type, device information, IP address, and interaction data.

(3) Audio recordings are not stored by Pimsy. Voice interactions are processed in real time and converted into text input.

(4) User input may contain information relating to skin conditions, symptoms, or other health-related topics. These are considered “special categories of personal data” under Art. 9 GDPR. By entering such information, you explicitly consent to the processing of this data for the purpose of generating AI responses.

(5) Users are requested not to share unnecessary sensitive personal information such as addresses, financial information, passwords, or government identification numbers within chat conversations.

§ 3 Purpose of Processing

We process personal data for the following purposes:

• to operate and maintain Pimsy;
• to generate AI-supported responses;
• to improve functionality, stability, and performance;
• to analyze usage trends and improve user experience;
• to ensure platform security and prevent misuse.

§ 4 Use of AI Systems and Third-Party Providers

(1) Pimsy uses artificial intelligence technologies and third-party service providers to generate responses and operate the platform.

(2) These providers may include:

• Amazon Web Services (AWS)
• Firebase
• Google Tag Manager
• TikTok (ByteDance)
• Groq
• ElevenLabs
• LLaMA

(3) These providers may temporarily process user input data to enable the functionality of Pimsy and generate AI-supported outputs.

(4) Some providers are based in the USA. To ensure a level of data protection consistent with the GDPR, we rely on the EU-U.S. Data Privacy Framework or Standard Contractual Clauses (SCCs) approved by the European Commission.

(5) AI-generated responses may be inaccurate, incomplete, outdated, or unsuitable for a user's specific situation.

§ 5 Cookies and Analytics

(1) Pimsy uses cookies and similar technologies necessary for the operation and security of the platform.

(2) Subject to user consent, analytics and tracking technologies such as Firebase, Google Tag Manager, and TikTok Pixel may be used to analyze usage behavior, track marketing campaigns, and improve platform performance.

(3) Users may accept or reject non-essential cookies through the cookie consent banner.

§ 6 Data Storage and Retention

(1) We aim to process and store data within the European Union, including through AWS infrastructure located in Frankfurt, Germany.

(2) Certain third-party providers may process data outside the European Union where necessary to provide their services.

(3) Pimsy does not create persistent user profiles.

(4) Chat data may be temporarily stored for operational and security purposes and may be automatically deleted or anonymized after a limited retention period where technically feasible.

§ 7 User Rights

(1) Users have the rights granted under GDPR, including the right to request information regarding the processing of personal data and the right to withdraw consent where applicable.

(2) You may withdraw your consent for the processing of health-related data at any time by ending the chat session and clearing your browser cache.

(3) Because Pimsy does not require an account, we may not be able to identify your specific chat history once a session has ended.

§ 8 Children and Minors

(1) Pimsy may be used by minors.

(2) By using Pimsy, you confirm that you are at least 16 years of age or have obtained the consent of a legal guardian. We do not knowingly collect data from children under 16 without such consent.

§ 9 Disclaimer and Limitation of Liability

(1) Pimsy is intended solely for informational and educational purposes.

(2) Pimsy is not a doctor, medical service, or emergency tool and does not replace professional healthcare advice.

(3) Any decisions, actions, skincare routines, purchases, or outcomes resulting from the use of Pimsy are the sole responsibility of the user.

(4) System Akvile GmbH shall not be liable for damages or outcomes resulting from reliance on AI-generated responses, except where liability is mandatory under applicable law.