Privacy Policy

This Privacy Policy ("Policy") describes how HairLo ("HairLo", "we", "us", or "our") collects, uses, processes, and discloses information in connection with our website, AI-powered hair visualization tool, and related services (collectively, the "Services"). By using the Services, you agree to the practices described in this Policy.

1. Information We Collect

1.1 Information You Provide

When you use HairLo, you may provide us with:

• Photos and images you upload to generate visualizations
• Survey responses including age range, family history of hair pattern changes, hair-related concerns, and similar inputs you provide through forms or questionnaires
• Contact information such as your email address if you choose to receive results, updates, or subscribe to communications
• Communications you send to us, including feedback, support requests, and inquiries
• Demographic or location information you voluntarily provide

1.2 Information Collected Automatically

When you access or use the Services, we and our service providers may automatically collect:

• Device and browser information including IP address, browser type, operating system, screen size, and device identifiers
• Usage data including pages visited, features used, time spent, clicks, referrer URLs, and interactions with content
• Approximate location derived from your IP address
• Cookies, pixels, and similar tracking technologies as described in Section 6

1.3 Information from Third Parties

We may receive information about you from third parties, including advertising partners, analytics providers, marketing partners, social media platforms, and publicly available sources. We may combine this information with data we collect directly from you.

2. How We Use Information

We use the information we collect for purposes including, but not limited to:

• Providing, operating, and maintaining the Services, including generating AI visualizations
• Improving, personalizing, and developing the Services, our content, and new features
• Training and improving our AI models and algorithms
• Communicating with you, including responding to inquiries and sending updates, newsletters, or marketing communications where permitted
• Delivering relevant content, recommendations, and advertising — including from third parties and partners
• Conducting research, analytics, and data analysis
• Detecting, preventing, and addressing fraud, abuse, security incidents, and unlawful activity
• Complying with legal obligations and enforcing our Terms of Service
• Operating and growing our business, including measuring effectiveness of our marketing

3. How We Share Information

We may share information about you in the following circumstances:

3.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including cloud hosting, AI/ML processing, analytics, email delivery, customer support, payment processing, and similar functions.

3.2 Business Partners and Affiliates

We may share information with our business partners, affiliates, advertising partners, marketing partners, and other entities for purposes including marketing, product recommendations, lead generation, joint offerings, and other commercial purposes consistent with this Policy.

3.3 Advertising and Analytics

We may share information with advertising networks, analytics providers, and similar third parties to deliver, measure, and improve advertising and marketing — including interest-based advertising on our Services and elsewhere.

3.4 Aggregated and De-identified Data

We may share aggregated, de-identified, or anonymized information that cannot reasonably identify you with any third party for any purpose.

3.5 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our assets, your information may be transferred as part of that transaction.

3.6 Legal and Safety

We may disclose information when we believe disclosure is necessary to comply with law, legal process, or government request; to enforce our agreements; to protect our rights, property, or safety, or that of our users or others; or as otherwise required or permitted by law.

3.7 With Your Consent

We may share information with third parties when you direct us to or otherwise consent to such sharing.

4. AI Visualizations and Photo Use

When you upload a photo to HairLo:

• Your photo is sent to a third-party AI provider (Google, via the Gemini API) to generate the visualization, and is held only for as long as that takes
• We do not store your photo. It is processed in memory and discarded once the visualization is returned. It is not written to our database
• We do not use photos or visualizations to train AI models, our own or anyone else’s. We use the paid tier of the Gemini API, under which Google does not use submitted content to train or improve its models
• You grant HairLo a limited, non-exclusive licence to process your photo for the sole purpose of generating your visualization. That licence ends when processing completes

Simulations run by a clinic

Where a clinic runs a simulation from its own HairLo Studio account — typically with a patient present during a consultation — a reduced-size before/after thumbnail (320px) is stored in that clinic’s account as a record of the consultation. The original full-resolution photograph is never stored. Each clinic is limited to the 60 most recent, with older entries removed automatically, and a clinic can delete any or all of them at any time from its Studio, or ask us to disable the feature for its account.

This does not apply to the patient-facing widget: simulations run by a patient on a clinic’s website or through a link store nothing.

5. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights with respect to your personal information, including:

• The right to access information we hold about you
• The right to request correction or deletion of your personal information
• The right to object to or restrict certain processing
• The right to data portability
• The right to withdraw consent (where processing is based on consent)
• The right to opt out of marketing communications
• The right to lodge a complaint with a supervisory authority

To exercise these rights, contact us at support@hairloai.com. We will respond in accordance with applicable law.

5.1 California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"), including the right to know what personal information we collect, the right to request deletion, the right to correct inaccurate information, and the right to opt out of the sale or sharing of personal information.

5.2 EU/UK Residents

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR) or UK GDPR. Our legal bases for processing include consent, performance of a contract, legitimate interests, and compliance with legal obligations.

6. Cookies and Tracking Technologies

We and our partners use cookies, web beacons, pixels, tags, scripts, and similar tracking technologies to operate the Services, analyze usage, personalize content, deliver advertising, and measure marketing performance. Most browsers allow you to control cookies through browser settings. Some features may not function properly if you disable cookies.

7. Data Retention

We retain information for as long as necessary to provide the Services and fulfill the purposes outlined in this Policy, including for legal, accounting, business operations, or reporting requirements. Retention periods vary depending on the type of information and the purpose of processing.

8. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission or storage is 100% secure. You acknowledge that you provide information at your own risk.

9. International Data Transfers

HairLo operates internationally. Your information may be transferred to, stored in, and processed in countries outside your country of residence, including the United States, where data protection laws may differ. By using the Services, you consent to these transfers.

10. Children's Privacy

The Services are not intended for children under 18. We do not knowingly collect personal information from children under 18. If you believe a child has provided information to us, please contact us and we will take reasonable steps to delete it.

11. Third-Party Links and Services

The Services may contain links to third-party websites, products, or services, including affiliate links and partner content. This Policy does not apply to those third parties, and we are not responsible for their privacy practices.

12. Do Not Track

Some browsers offer a "Do Not Track" signal. We currently do not respond to such signals.

13. Changes to this Policy

We may update this Policy from time to time. When we make material changes, we will update the "Last updated" date at the top of this page and may provide additional notice.

14. Contact Us

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

HairLo
Email: support@hairloai.com