This Privacy Policy explains how POFKARIO HOLDINGS LIMITED, a Cyprus company with registration no. ΗΕ 467843 and registered address Thessalonikis 43, office/flat 301 Thessaloniki Court, 3025 Limassol, Cyprus (referred to as "Hairio", "Company", "us", or "we") collects, stores, uses, and protects your personal data in connection with your use of our mobile application "Hairio" (the "App"), our website (hairio.app), and all related services, features, and content (collectively the "Services"). This Privacy Policy also explains the rights you have in respect of the personal data we hold about you and the practices we implement to protect your privacy.
For the purposes of this Privacy Policy, Hairio acts as the Data Controller of your personal data.
Any translation of the English version of this Privacy Policy is provided solely for your convenience. In case of any differences between the English version and any other translation, the English version shall prevail and shall be the only legally binding version.
If you do not want us to process your personal data as described in this Privacy Policy, please do not use our Services.
1. What personal data we collect and why
When you use our Services, we collect the following data about you:
| Purpose of collection and processing | Data categories | Collection means | Legal basis for collection and processing |
|---|---|---|---|
| To provide core features of the App: AI hairstyle analysis, hair health assessment, and personalized style recommendations | Unique user ID, username, face and hair photos, hair type, texture, thickness, scalp condition, style preferences, age, gender, device data | You provide it to us or collected automatically | Contract, Consent |
| To verify user eligibility for premium features | Payment data, subscription data | You provide it to us | Contract, Legal obligation |
| To personalize AI recommendations | Onboarding responses, style and hair preferences, data shared in the App | You provide it to us or collected automatically | Legitimate interest, Consent |
| To create and manage your account | Name, email address, age, country, device data | You provide it to us | Contract |
| To send technical notices and updates | Email address | You provide it to us | Legitimate interest |
| For research and product improvement | App usage data, anonymized data | Collected automatically | Legitimate interest |
Note about payment data: When you make payments through the Services, your payment information (e.g., credit card number) is handled by third-party payment processors. We do not store full credit card details.
2. Personal data retention
We retain your personal data for as long as your account is active or as needed for the purposes of processing. You may delete your account and associated data at any time through the App settings or by contacting us at support@hairio.app. Please note, certain data may be retained as required by law or for dispute resolution purposes.
3. Your data protection rights
If you are an EEA/UK resident, you have rights under the GDPR, including:
- Access to and portability of your data
- Correction and deletion of your data
- Restriction or objection to processing
- Withdrawal of consent for specific purposes
- Filing complaints with your local data protection authority
To exercise these rights, contact us at support@hairio.app.
4. Security measures
We implement technical and organizational measures to protect your personal data, including:
- Encryption
- Systematic vulnerability scanning
- Access control policies
Despite our efforts, no security measures can guarantee complete safety. Any data transmission is at your own risk.
5. Children’s privacy
Our Services are not directed to individuals under 18 years of age. If we learn that we have collected personal data from a child under 18, we will delete it promptly. Parents or guardians may contact us at support@hairio.app if they believe their child has provided us with personal data.
6. Sharing of your personal data
We may share your data with:
- Affiliates and subsidiaries
- Service providers (e.g., cloud storage, email delivery, analytics tools)
- Payment processors
- Regulatory authorities, where legally required
7. Cross-border data transfers
Your data may be transferred and processed outside the EEA, where it may be governed by different data protection laws. We ensure appropriate safeguards (e.g., Standard Contractual Clauses) are in place for such transfers.
8. Cookies, software development kits, and other tracking technologies
We use cookies and similar technologies to provide and improve our Services. For more information, please see our Cookie Notice on hairio.app.
9. Your choices about our communications with you
You may opt out of marketing communications by following the "Unsubscribe" link in our emails.
10. Contact us
If you have questions or concerns about this Privacy Policy, please contact us:
- Email: support@hairio.app
- Address: Thessalonikis 43, office/flat 301 Thessaloniki Court, 3025 Limassol, Cyprus
11. Changes to our Privacy Policy
We may update this Privacy Policy from time to time. Significant changes will be communicated to you via the App or email. The latest version is always available on our website.
See also our Terms of Use.