Privacy Policy for Folicx

Effective date: June 14, 2026

1. Who we are

This Privacy Policy explains how Folicx ("Folicx", "we", "us" or "our") collects, uses, discloses and protects your information when you use:

The Folicx mobile application (the "App"), and
Any related websites, services or communications that link to this Privacy Policy (collectively, the "Services").

If you do not agree with this Privacy Policy, please do not use the Services.

2. Contact details

If you have questions or requests regarding this Privacy Policy or your personal data, you can contact us at:

Email: support@folicxapp.com

3. Information we collect

Depending on how you use Folicx, we may collect the following categories of information:

3.1 Account and profile information

Name, username or display name.
Email address and/or phone number.
Password or authentication tokens (stored in encrypted form, if applicable).
Profile photo or avatar (if you choose to upload one).

3.2 Hair scans and visual data

Because Folicx is a hair tracking app based on visual analysis, we may collect:

Images and/or short videos of your hair and scalp that you capture via the device camera or upload from your gallery.
Derived data from those images, such as detected hair density, thinning patterns, breakage/frizz levels, and similar characteristics, as generated by our algorithms.
Timestamps, session metadata and settings related to each scan (for example, which camera was used, lighting notes you enter, or tags you apply).

Depending on your jurisdiction, this type of data may be considered health-related or sensitive personal data because it can reveal aspects of your physical appearance and health.

3.3 Hair routine and wellness information

To provide reminders and insights, we may collect information you manually log, such as:

Your hair care routine (e.g., shampoo days, oiling, treatments, styling products, heat tools).
Self-reported concerns (e.g., hair fall, dandruff, dryness, scalp irritation).
Goals (e.g., thicker hair, reduced hair fall, grow length to a specific milestone).
Notes you add to your daily entries.

3.4 Usage and device information

When you access or use the Services, we automatically collect certain information, including:

Device identifiers (e.g., device ID, operating system, model, language settings).
App version and configuration.
Log data (e.g., session start/end, features used, screens opened, tap events, crashes).
Approximate location (e.g., country or city) inferred from IP address, if needed for localization, analytics or legal compliance.

We may use third-party tools (such as analytics and crash reporting SDKs) to help us collect and analyze this information.

3.5 Cookies and similar technologies (website)

On our websites, we may use cookies and similar technologies (such as local storage or pixels) to:

Keep you signed in.
Remember your preferences.
Analyze website traffic and usage patterns.

Where required by law, we will request your consent before using non-essential cookies.

3.6 Payment and subscription information

If you purchase a subscription or paid feature:

Payments made through app stores (Apple App Store, Google Play, etc.) are processed by those stores; we do not receive your full payment card details.
We may receive limited payment-related information from the store or payment processor (e.g., transaction ID, subscription status, approximate purchase date, country) for account management, entitlement, and fraud prevention purposes.

3.7 Information from third parties

If you choose to connect Folicx to third-party services (for example, sign-in providers, backup/sync services, or health data platforms, if supported), we may receive information from those services in accordance with their privacy policies and your settings with them. You can disconnect such integrations at any time via the App or via the third-party service.

4. How we use your information

We use the information we collect for the following purposes:

4.1 To provide and maintain the Services

Create and manage your account.
Enable you to capture, store, view, and compare hair scans over time.
Show your daily/weekly/monthly hair progress, logs and trends.
Provide routine reminders and notifications you opt into.
Ensure the technical functioning, security and performance of the App.

4.2 To analyze hair patterns and generate insights

Run visual and statistical analysis on your scans and logs to detect trends, changes or patterns in your hair over time.
Generate daily or periodic insights, summaries and recommendations based on your inputs and historical data.
Personalize parts of the experience (e.g., which tips or educational content to surface).

4.3 To communicate with you

Send service-related emails or push notifications (e.g., account verification, password reset, changes to the Services, important security alerts).
Send reminders about your routine and scans according to your in-app settings.
Respond to your questions, support requests and feedback.

4.4 To improve and develop the Services

Monitor performance, usage and user flows to understand how people use Folicx.
Debug issues, fix bugs and improve app stability.
Develop new features, models and experiences, including training or fine-tuning algorithms (where legally permitted and done with appropriate safeguards, e.g., aggregation, pseudonymization or explicit consent).

4.5 To ensure safety, security and legal compliance

Detect, investigate and prevent fraud, abuse, security incidents or other harmful activity.
Enforce our Terms and Conditions and other policies.
Comply with legal obligations, law enforcement requests, and applicable regulations.

5. Legal bases for processing (where applicable)

Where data protection laws (such as the EU/UK GDPR or similar) apply, we process your personal data under one or more of the following legal bases:

Performance of a contract: To provide the Services you request (e.g., account, hair tracking, reminders).
Consent: For certain activities such as camera access, notifications, some analytics, and processing of sensitive data where required. You can withdraw your consent at any time via device or in-app settings (this will not affect processing that has already occurred).
Legitimate interests: To improve our Services, maintain security, and prevent fraud, provided these interests are not overridden by your rights and interests.
Legal obligation: To comply with applicable laws, regulations, or valid legal requests.

6. How we share your information

We do not sell your personal data. We may share your information with:

6.1 Service providers

Trusted third-party vendors that perform services on our behalf, such as:

Cloud hosting and storage providers.
Analytics, crash reporting and performance monitoring tools.
Customer support and communication tools.
Payment processors or subscription management providers.

These providers are only allowed to use your information as necessary to provide their services to us and are bound by appropriate contractual safeguards.

6.2 Business transfers

If we are involved in a merger, acquisition, financing, restructuring, bankruptcy, or sale of all or part of our assets, your information may be transferred as part of that transaction, subject to any applicable legal requirements and your rights.

6.3 Legal and safety reasons

We may disclose information if we believe in good faith that it is reasonably necessary to:

Comply with applicable law, regulation, legal process or enforceable governmental request.
Enforce our Terms and Conditions or protect our operations.
Protect the rights, privacy, safety or property of Folicx, our users, or the public.

6.4 With your consent

We may share certain information with third parties when you explicitly ask us to or when you provide your consent (for example, if in the future we enable you to export reports to a doctor or share progress with a coach, friend or family member).

7. International data transfers

We may process and store your personal data in countries other than the one you reside in. These countries may have data protection laws that differ from those in your jurisdiction. Where required, we implement appropriate safeguards (such as standard contractual clauses or equivalent mechanisms) to protect your information in connection with such transfers.

8. Data retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

In general:

Account and profile data are kept while your account is active and for a reasonable period thereafter for backup, dispute resolution and legal obligations.
Hair scans, logs and derived data are retained while your account is active, unless you delete them or your account.
Log and analytics data may be retained for shorter or longer periods in aggregated or pseudonymized form.

If you delete your account, we will delete or irreversibly anonymize your personal data, subject to any legal obligations to retain certain information.

9. Your rights and choices

Depending on your location and applicable law, you may have the following rights regarding your personal data:

Access: Request confirmation whether we process your data and obtain a copy.
Rectification: Request correction of inaccurate or incomplete data.
Deletion: Request deletion of your data (subject to legal exceptions).
Restriction: Request that we restrict certain processing of your data.
Portability: Receive your data in a structured, commonly used, machine-readable format and request we transmit it to another controller, where technically feasible.
Objection: Object to processing based on legitimate interests or direct marketing.
Withdraw consent: Where processing relies on your consent, you can withdraw it at any time.

You can exercise many of these rights through in-app settings (for example, updating your profile, deleting scans, or disabling notifications). For other requests, contact us at support@folicxapp.com.

You also have the right to lodge a complaint with your local data protection authority if you believe your rights have been violated.

10. Children's privacy

Folicx is not intended for children under the age of 16. We do not knowingly collect personal data from children below this age.

If you are a parent or guardian and believe your child has provided us with personal data, please contact us at support@folicxapp.com so we can take appropriate action, such as deleting the account or data as required by law.

11. Third-party links and services

The Services may contain links to third-party websites, apps or services that are not operated by us. If you click a third-party link, you will be directed to that third party's site or service. Their privacy practices are governed by their own policies, and we are not responsible for them. We encourage you to review the privacy policies of every site or service you visit.

12. Security

We use reasonable and appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, misuse or alteration (for example, encryption in transit, restricted access, and secure development practices). Nonetheless, no system can be guaranteed to be 100% secure, and you are responsible for keeping your device, account and credentials safe (e.g., using strong passwords and enabling device-level security features).

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Effective date" at the top and, where appropriate, provide additional notice (such as a notice in the App or by email).

Your continued use of the Services after the updated Privacy Policy becomes effective means that you accept the changes.

14. Contact us

If you have questions, concerns or requests regarding this Privacy Policy, please contact us at:

Email: support@folicxapp.com