DERMA EXCHANGE LTD ARTIFICIAL INTELLIGENCE (AI) TRANSPARENCY STATEMENT

DERMA EXCHANGE LTD

ARTIFICIAL INTELLIGENCE (AI) TRANSPARENCY STATEMENT

Effective Date: 9/7/2026

Last Updated: 9/7/2026


1. Introduction

Derma Exchange Ltd ("Derma Exchange", "we", "our" or "us") is committed to using technology responsibly, transparently and ethically.

We recognise that Artificial Intelligence ("AI") can enhance customer experience by improving efficiency, providing educational information and supporting administrative processes.

We also recognise that decisions affecting a customer's health should always involve appropriate human oversight.

This AI Transparency Statement explains how AI technologies may be used by Derma Exchange Ltd and the safeguards we have implemented to protect our customers.


2. Our Commitment

Derma Exchange Ltd is committed to ensuring that:

  • AI is used responsibly and ethically;
  • AI does not replace independent clinical judgement;
  • customers remain informed whenever AI supports our services;
  • human oversight is maintained for clinically significant decisions;
  • AI is used in accordance with UK data protection legislation and recognised ethical principles.

3. Where AI May Be Used

From time to time, Derma Exchange Ltd may use AI-assisted technologies to support administrative and customer service functions.

These may include:

  • Website chat assistance;
  • Frequently Asked Questions (FAQs);
  • Customer service support;
  • Appointment booking assistance;
  • Product search functionality;
  • Product recommendation tools based on customer-selected preferences;
  • Website search optimisation;
  • Customer enquiry routing;
  • Drafting customer communications;
  • Fraud detection;
  • Website security monitoring;
  • Analytics and reporting;
  • Translation of website content;
  • Accessibility support.

The use of AI in these areas is intended to improve customer experience and operational efficiency.


4. AI Is Not Used for Clinical Decision-Making

Derma Exchange Ltd does not use Artificial Intelligence to:

  • diagnose medical conditions;
  • prescribe medicines;
  • determine clinical suitability;
  • approve or refuse prescription-only products;
  • replace clinician judgement;
  • make healthcare decisions affecting customers.

All clinical assessments are carried out by appropriately trained, verified and certified clinicians operating under the clinical governance framework of Health Exchange UK.

Prescription decisions remain the sole responsibility of authorised independent prescribers.


5. Human Oversight

Where AI-assisted systems are used, appropriate human oversight is maintained.

Examples include:

  • customer enquiries being reviewed by customer support staff where necessary;
  • consultation bookings being reviewed before confirmation where appropriate;
  • clinicians independently reviewing all consultation information;
  • prescription decisions being made solely by authorised clinicians.

Customers will never be refused treatment or prescribed medication solely on the basis of automated processing.


6. AI-Assisted Product Recommendations

From time to time, our Website may suggest products based upon information such as:

  • products viewed;
  • shopping basket contents;
  • previous purchases;
  • skin concerns selected by the customer;
  • preferred brands;
  • browsing behaviour (subject to cookie preferences).

These recommendations are intended to assist customers in exploring relevant products.

They do not constitute:

  • medical advice;
  • diagnosis;
  • personalised clinical recommendations;
  • prescribing decisions.

Customers seeking personalised skincare advice should book a virtual consultation.


7. Protection of Personal Information

Where AI-assisted systems process personal information, Derma Exchange Ltd remains responsible for ensuring that such processing complies with:

  • UK General Data Protection Regulation (UK GDPR);
  • Data Protection Act 2018;
  • Privacy and Electronic Communications Regulations (PECR);
  • applicable Information Commissioner's Office (ICO) guidance.

We seek to ensure that AI systems used on our Website process only the minimum information necessary for their intended purpose.


8. No Sale of Personal Information

Personal information processed using AI-assisted technologies is not sold to third parties.

We do not permit AI providers to use your personal information for their own advertising or unrelated commercial purposes unless you have been informed and an appropriate lawful basis exists.

Where third-party AI service providers process personal information on our behalf, they do so under contractual obligations requiring confidentiality, security and compliance with applicable data protection legislation.


9. Transparency

Where customers interact directly with AI-assisted tools, we aim to make this clear.

Examples may include:

  • Website chat assistants;
  • automated customer service responses;
  • AI-assisted product search;
  • automated appointment reminders.

Customers may request assistance from a human representative where appropriate.


10. Fairness and Non-Discrimination

Derma Exchange Ltd is committed to ensuring that AI-assisted technologies are used fairly.

We seek to minimise the risk of:

  • unfair bias;
  • discrimination;
  • inaccurate recommendations;
  • inappropriate automated outcomes.

Where concerns are identified, we will review and improve our systems.


11. Accuracy

Although AI technologies can improve efficiency, they are not infallible.

Customers should not rely solely upon AI-generated information when making decisions about their health or skincare.

Where clinical advice is required, customers should seek an assessment from one of our appropriately trained, verified and certified clinicians.


12. Security

AI-assisted systems used by Derma Exchange Ltd are expected to meet appropriate security standards.

We take reasonable steps to ensure that AI technologies used on our Website maintain:

  • confidentiality;
  • integrity;
  • availability;
  • appropriate access controls;
  • secure processing of personal information.

13. Your Rights

Where AI-assisted processing involves personal information, customers retain all rights available under the UK GDPR, including the right to:

  • request access to personal information;
  • request correction of inaccurate information;
  • request deletion where applicable;
  • object to certain processing;
  • restrict processing where appropriate;
  • lodge a complaint with the Information Commissioner's Office.

Further information is available in our Privacy Policy.


14. Future Use of AI

Artificial Intelligence is evolving rapidly.

As Derma Exchange Ltd introduces new AI-assisted technologies, we will:

  • assess privacy and ethical risks before implementation;
  • conduct Data Protection Impact Assessments (where required);
  • maintain appropriate human oversight;
  • update this statement where our use of AI changes materially.

15. Contact Us

If you have questions about our use of Artificial Intelligence or this AI Transparency Statement, please contact:

Privacy Lead

Derma Exchange Ltd

Company Number: 17331624

37 Falshaw Way

Manchester

M18 7TG

United Kingdom

Telephone: 0330 043 1833

Email: privacy@dermaexchange.com

General enquiries:

support@dermaexchange.com

Website:

www.dermaexchange.com


Version Control

Document Title: Artificial Intelligence (AI) Transparency Statement

Version: 1.0

Document Owner: Privacy Lead – Derma Exchange Ltd

Approved By: Director, Derma Exchange Ltd

Review Frequency: Annually, or sooner if there are significant changes to AI technologies, regulatory requirements or business operations.