We at iHairium Inc. care about your privacy and protecting your personal data is very important for us and we are fully committed to protecting and safeguarding the personal data you share with us when you use our service. Please read this privacy policy carefully to help you understand what personal data and how we process, who has access to your data and what rights you have.

If you have any questions, do not hesitate to contact us via the contact details listed at this Policy.

This document can be printed for reference by using the print command in the settings of any browser. The document is posted on the website by the link: https://ihairium.com/privacy_policy

Policy summary
Personal Data collected for the following purposes and using the following services:

  • Firebase
  • Personal Data: Tracker; Usage Data

Beta Testing
  • TestFlight
  • Personal Data: app information; country; device information; device logs; email address; Usage Data; various types of Data as specified in the privacy policy of the service

Contacting the User
  • Contact form
  • Personal Data: name, email address

Handling payments
  • Payments processed via the Apple App Store
  • Personal Data: payment data

Platform services and hosting
  • Apple App Store
  • Personal Data: Usage Data

Contact information
Owner and Data Controller
iHairium Inc, 8 The Green, STE A, Dover, DE, USA, 19901
Owner contact email: support@ihairium.com

Full policy
Owner and Data Controller
iHairium Inc, 8 The Green, STE A, Dover, DE, USA, 19901
Owner contact email: ceo@ihairium.com

1. Introduction
This Privacy Policy applies to your access and use of the Application, Website and services we provide.

Users confirm their agreement with Privacy Policy and Terms of Service has applied through required registration in the iHairium application, and/or browsing of iHairium Website.

If you do not agree with our processing of personal data as described in this Privacy Policy, you cannot continue the use of our Application, Website or Services. If you agree with our Privacy Policy, we hereby welcome you to our service.

We might amend this Privacy Policy from time to time. Visit this page regularly in order not to miss and to understand the changes. If we make important changes, we will always notify you before you use our service.

If you do not agree with our processing of personal data as described in this Privacy Policy, you cannot continue the use of our Services.

1.1. The personal data iHairium collects
To be able to help you monitor the health of your hair and scalp, certain information is necessary for us to be able to provide you with our Services. You can sign up for our service in the App using your email address. When you want to use our paid services, you also have to make in-app purchases via your Apple ID account.

If you are a professional user, we will collect your name and contact details, as well as billing information. If you represent a legal entity, we will also use the details of that entity as your employer or client.

We collect information about the device you use to access our App or Website. The type of information we collect can, for example, include the type of your device, the software you use, location, device language and your IP address. In addition to this, we collect the data you provide in the App including the answers to the questionnaire regarding hair and scalp profile, health parameters and the Images you upload.

1.2. Why iHairium collects your data
We use your data to assist you in the best possible way. We need certain data in order to provide you with our full service and assist you with your health journey (for personal users) or with your professional activities (for professional users). We may also use your data for research purposes to improve our service. And when you using services for selecting clinics, for consultations, transplantation, hair care, the client agrees to the transfer of personal data that is necessary for the provision of services by clinics. Furthermore, your information may be used for customer service, marketing, communications, and for legal purposes.

1.3. iHairium and third parties
iHairium has third party service providers that help us provide or improve our service, this includes service providers, payment providers and financial institutions, business partners or research institutions.

1.4. Privacy, data security, and data retention
iHairium has implemented various measures and procedures to safeguard your personal data, as stipulated by United States and European data protection law. We will retain your data for 12 months after you unsubscribe from our service. iHairium guarantees data security on its servers and uses secure data transmission channels to clinics. iHairium is not responsible for the disclosure of data by clinics to third parties.

1.5. Personal data of children
Our service can only be used when you have reached the age of eighteen (18) years or when you are older.

1.6. Your rights – access to your information
At any time, you can make a request to review, correct, delete, obtain your data. You are also entitled to withdraw consent for the processing of the personal data we hold of you. You can do this by email, using the addresses: support@ihairium.com.

1.7. Responsible party for the processing
iHairium Inc., located in Dover, DE, United States, is the owner and operator of the service and is the controller of personal data processed via the Website and the App.
Please find the full explanation on how we process your data below.

2. The personal data iHairium collects
Personal data you provide to us

The data you provide to us is collected and used (“processed”) by us to provide you with our best service. The minimum information you are asked for to provide us is your email address in order to access our service.

In our App, you can provide further information regarding your hair type and risk profile. We also collect the Images you take of your hair and scalp lesions and the way you store, organize and comment on them. Without your explicit consent, we are not allowed to store this type of information, and we cannot provide you with our service.

Other information we collect is your payment information and the information you provide to complete your personal profile: your first name and last name, profile picture, gender, date of birth, email, location, phone number, language.

When you use our AI-diagnostics services and submit a picture of your hair and scalp for analysis by our service, we store the pictures and collect the information of your assessment. We do this to be able to assist you with your health journey. We will ask for your explicit consent to allow us to store this type of information before you use such service, without your consent we cannot provide you with our service.

Payment information may contain identifiers of Apple ID, because all purchases in the iHairium application for iOS are made by Apple ID account. For more information about the terms of purchases, see the section “Fees for Use of the Service and Payment policy” in iHairium Terms of Use.

As part of your health journey, we may send you follow-up emails regarding the provided advice and to assist you by reminding you to seek medical attention when necessary. If you wish to reply to these emails and get in touch with our Customer Support we will collect the information that you provide in these replies from you too.

When you use our App, we also collect data that identifies your mobile device and your use of the platform. The information we store includes notification access, device-specific settings and characteristics, system activity, location details, IP address, language settings, app crashes and other device event information, access dates and times of your usage of the app.

We collect information when you give us feedback via your App Store or the questionnaire.

Personal information you provide us regarding the health of others
Our service is exclusively meant for your personal use. If you want to help others, please do so by encouraging them to download their own version of iHairium. This will help them with their health journey and ensures that any health-related messages will be delivered to the right person.

Personal information you provide us as a professional
When you access and use our service for professional purposes, we collect your name, email address, name of the organization you are employed at or otherwise represent, other contact details (address, email, phone number).

Any personal data you upload when using our services we process on your behalf as a data processor. You, as controller of such data, shall ensure that you comply with all applicable data protection requirements, when processing such data and entrusting its further processing to us. Our processing of such data will be governed by a separate data processing agreement.

Automatically collected personal data
During your visit to our Website or App, we automatically collect certain information of your visit to the service and the device you are using. This data includes data on the hardware, software, operating system, internet browser, IP address, language and application settings and version. We also collect data about when and how you used the service, including interaction with the elements on it and which pages you visited in the App or on the Website.

3. Why iHairium collects your data
We use your data to assist you in the best possible way, your data may be used for the following reasons:

Health journey: The main reason why we collect your personal data is to supply you with our core service: assistance with your hair and scalp health journey and assist you with the early detection of some negative patterns.

Management and improvement of our Services: We use your information to manage our Website, App, and business and to improve our services continuously.

Customer Service: Our customer service is here to help you and we use your data to do so. We may send you email notifications and/or in-App messages relating to the results of the diagnostics, this includes emails in which we provide you with information and ask you to provide us with information about possible follow-up actions.

Marketing: In order to keep you informed, we may send you communications relating to our business, by email or other contact details you provided to us, we may send you a questionnaire or invite you to provide a review of your experiences with our service, and we also may get in touch with you regarding feedback, inquiries, and complaints you made regarding our Website and App, provided that you did not opt-out from receiving such communication. If you submit personal information for publication on our Website, we will use that information in accordance with the license you grant to us.
All data about your health that you provide to us, strictly won't be used for marketing purposes.

Communications: We will send you communication regarding assessments you make via the App.

Research activities: In order to support the research on hair loss and detection methods, we may use your data, depersonalitic (without a direct link to your identity) or anonymized (without us being able to identify you at all), for healthcare research purposes and to improve iHairium service delivery to you. This may include sharing your data with carefully selected third party research institutions, but only through acceptance to these sharing. By uploading your images in the App, you explicitly consent to the images being processed for the purposes of the provision of the services and to be used anonymously for the purposes of research and testing of our services.

Legal purposes: In certain cases, we may need to use your information to handle and resolve legal disputes, for regulatory investigations and compliance, or to enforce the terms of use of the service as reasonably expected.

We collect and process your data based on the following legal grounds

Contractual necessity: In order to fulfill the contract, you enter into with us when you use our Services, we have to process some essential information. When you wish to use one of our paid services we may need to process your email address, pictures of skin lesions, risk assessment, payment information.

Legitimate interests: We are committed to improving and growing our service. Some of your data can help us to improve and promote our Service and Website, other data we may need for administrative, legal purposes or anti-fraud activities.
Legal obligations: We have to comply with certain laws and (country specific) regulations. In order to comply with these, we need information about your location and date of birth.

Consent: For certain promotional and marketing activities, we may ask additional consent. When you wish to withdraw your consent, please contact us via the email to: support@ihairium.com.

Explicit consent: Data regarding the health of your hair and risk assessments is a more sensitive category of data. In order to lawfully process this data for you, we will ask your explicit consent before we can assist you. When you wish to withdraw your consent, please contact us via the contact details at the bottom of this Policy. When you withdraw your consent, we will not be able to provide you with our Services and you should discontinue using our Services.

4. iHairium and third parties
For some specific reasons, iHairium may share your personal data with carefully-selected third parties, such as our IT service providers, insurers, and tax authorities.

5. Data privacy, security, and data retention

All data you provide to us and we collect from you is stored on secure cloud servers (the Servers) in the territory of the United States. As a result, your personal information may be transferred to and stored at, a destination outside your country. By submitting your personal information, you agree to the transfer of your personal information to the servers.

Personal information may also be processed by staff or by other third party service providers operating outside your country who work for us. We take such steps as are necessary for the circumstances to ensure that any third party service providers treat your data securely and in accordance with applicable laws.

Data security
All data that you provide through the App and/or the Website is encrypted when it is transferred to or from the servers using industry-standard encryption (TLS). Furthermore, data is stored in encrypted form when at rest on the servers.

We store your account information and your digital images in separate data stores. The cloud server infrastructure is protected using firewalls and monitoring.

We work with appropriate procedures to prevent unauthorized access to and/or misuse of your personal data.

iHairium uses appropriate procedures and business systems to safeguard your personal data. Furthermore, we use security procedures and technical and physical restrictions for accessing and using the personal data on our servers. Only authorized personnel can access your personal data.

Data retention
iHairium will destroy or de-identify your personal information once it is no longer required for the purpose or purposes for which it was collected.

If you terminate the Services and delete your account, we will retain your personal information for a period of 12 months, after which we will delete your data. We will retain the images you have uploaded prior to termination in anonymous form only, for the purposes of medical, clinical and commercial research, and for testing of the Services. We will ask for your consent to process your data anonymously for research purposes.

We will retain (electronic) documents containing personal information:
  • to the extent that we are required to do so by law;
  • if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
  • in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

6. Personal data of children
Our service can only be used when you have reached the age of eighteen (18) years or when you are older. When we identify personal information of children younger than eighteen (18) years old, we shall delete the data based on our legal obligations.

7. Your rights – access to your information
We will, upon your request, provide you with access to your personal information that is held by us. We will provide the data to you in a structured, understandable and machine readable way. We request that you provide us with appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport plus an original copy of a utility bill showing your current address). We will require you to make your personal identification number and picture invisible to us.

In your request for access, we also request that you identify, as clearly as possible, the type(s) of information you wish to have access to. We will comply with your request to provide access to your personal information within 30 days and if you agree we may charge you our reasonable costs incurred in supplying you with access to this information.

At any time, you can make a request to review, correct, delete, or obtain your data. You can also withdraw consent for the processing of the personal data we hold of you. You can make such request by mail or email, using the addresses listed below.
You also have the right to launch a complaint with the Data Protection Authority of your country, when you have concerns about your rights, or if you feel that we are unlawfully processing your data.

You may oppose the processing of personal information concerning you, even if they are relevant to the purpose of the collection.

You may instruct us at any time not to process your personal information for marketing purposes and we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

8. Responsible party for the processing of your data
The Website and the App are owned and operated by iHairium Inc. You can contact us by feedback form in the App or by email to support@ihairium.com.

Privacy Policy

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