Privacy at a glance
Table of Contents
This Privacy Policy applies to the Hairmony mobile application ("App") developed and operated by:
PODSuite OÜ
Republic of Estonia, European Union
Email: hairmonyapp@gmail.com
PODSuite OÜ acts as the data controller within the meaning of the EU General Data Protection Regulation (GDPR) in respect of any personal data processed in connection with the App.
Capitalised terms used in this Privacy Policy have the following meanings:
Hair Data — including photos of your scalp, information about hair loss, dandruff, scalp health conditions, and chemical treatment history — is health-adjacent and potentially sensitive personal information. Depending on its content, it may fall within or near the categories of personal data that attract enhanced protection under Art. 9 GDPR (special categories) or equivalent provisions in other jurisdictions.
We take this seriously. We handle all Hair Data and Photos with the same care we would apply to medical or health information:
By choosing to use the App's analysis features, You consent to the processing of this health-adjacent data for the purposes described in this Policy.
The table below describes all categories of data that may be processed in connection with your use of the App, where that data lives, and the legal basis under GDPR.
| Data Category | Examples | Where It Lives | Legal Basis (GDPR) |
|---|---|---|---|
| Hair profile answers | Birth year, hair type, scalp condition, porosity, density, chemical treatment history, reported concerns | Your Device only | Performance of contract (Art. 6(1)(b)) |
| Hair photos | Photos of your hair and scalp taken for AI analysis | Your Device; transmitted to Anthropic during analysis only (see Section 6) | Performance of contract (Art. 6(1)(b)) |
| Analysis results | Hair scores, metric breakdowns, ingredient match lists, suggested products | Your Device only | Performance of contract (Art. 6(1)(b)) |
| Routine and task data | Hair care routine steps, wash frequency, product lists, task history | Your Device only | Performance of contract (Art. 6(1)(b)) |
| Subscription status | Active/inactive subscription state (verified via receipt from Apple/Google) | Apple / Google systems; not stored by us | Performance of contract (Art. 6(1)(b)) |
| Anonymous technical telemetry | App version, device OS, framework errors — collected by Expo SDK; anonymous and non-personal | Expo's infrastructure (see Section 8) | Legitimate interests (Art. 6(1)(f)) — app stability |
We do not collect your name, email address, phone number, or any other directly identifying information. The App has no registration flow and no server-side user profile of any kind.
With the sole exception of photos transmitted to Anthropic during an active scan, all data you enter into Hairmony is stored exclusively on your Device using local on-device storage. PODSuite OÜ operates no servers that receive, store, or process your Hair Data, analysis results, routine, or Photos.
Practical implications:
The hair analysis feature is powered by Claude, an AI model developed by Anthropic, PBC (548 Market St, San Francisco, CA 94104, USA).
What is transmitted: When you initiate a hair scan, your Photo — along with a structured prompt describing your hair profile — is sent over an encrypted HTTPS connection to Anthropic's API. No other Personal Data is included in this request.
Your photos are never used to train any AI model. PODSuite OÜ does not train AI models and does not use your Photos for that purpose. Anthropic's API terms explicitly prohibit the use of API inputs and outputs for model training without opt-in consent. Your photos are processed solely to generate your analysis result and are not retained by Anthropic beyond their standard short-term safety review window (up to 30 days).
How Anthropic handles your data:
International transfer notice: Anthropic is located in the United States. Transmitting your Photo to Anthropic constitutes a transfer of Personal Data to a third country outside the EU/EEA. This transfer occurs at your explicit instruction (by initiating the scan) and is necessary to perform the service you requested (Art. 49(1)(b) GDPR). By using the AI analysis feature, you acknowledge this transfer.
If you do not wish your Photo to be transmitted to Anthropic, you should not use the AI hair analysis feature.
Subscriptions are sold and managed exclusively by Apple (App Store) or Google (Google Play). PODSuite OÜ does not receive your payment card details, billing address, or any financial information.
Subscription validation (checking whether your subscription is active) is performed via the platform's in-app purchase APIs using an anonymous receipt token. We do not store this token beyond the active session, and it contains no Personal Data.
Apple and Google's data practices are governed by their respective privacy policies.
Hairmony is built using the Expo framework (by Expo, Inc.). Expo may collect limited, anonymous technical telemetry as part of its SDK operation — such as framework version, device platform, and anonymised crash or error reports.
This data, if collected, is:
To our knowledge, Expo telemetry does not include your Hair Photos, profile answers, scan results, or any other App-specific content.
PODSuite OÜ does not:
The App's only source of revenue is a direct subscription fee. Your data is not the product.
The App's device-only architecture means that, in normal use, your Personal Data does not leave your country. The sole exception is when you actively use the AI hair analysis feature, which transmits your Photo to Anthropic in the United States.
This transfer is described in detail in Section 6. It occurs only at your explicit instruction, is limited to the Photo and a structured prompt, and is strictly necessary to perform the service you requested. No other Personal Data is transferred outside the EU/EEA by PODSuite OÜ.
Because all App data is stored on your Device, you are always in direct control of deletion. Here is exactly what to do for each data type:
We do not hold any Personal Data on our own servers. There is no account to delete with us, and no request form required for the data we handle — uninstalling the App is sufficient for the data we control.
PODSuite OÜ retains no Personal Data on its own servers because it does not operate servers that receive Personal Data.
We take reasonable steps to protect the data processed in connection with the App:
While we strive to protect your data, no security measure is entirely infallible. We recommend keeping your Device's operating system and the App up to date.
The App is not directed at children under the age of 13. We do not knowingly process Personal Data from children under 13.
Given that the App stores all data locally and we collect no identifying information, we have no technical means to verify a User's age. Parents and guardians are responsible for supervising their children's use of the App.
If you have reason to believe a child under 13 has submitted a Photo via the analysis feature, please contact us at hairmonyapp@gmail.com and we will take appropriate action, including requesting deletion of any associated data from Anthropic.
As a resident of the European Union or European Economic Area, you have the following rights under the GDPR:
Practical note: Because we store no Personal Data on our servers, most of these rights are exercisable directly by you — clearing the App's local storage or uninstalling the App achieves immediate, complete erasure of the data we control. For data processed by Anthropic, we will assist by forwarding your request to them. Contact us at hairmonyapp@gmail.com — we will respond within 30 days.
If you believe that PODSuite OÜ has violated your rights under the GDPR, you have the right to lodge a complaint with a supervisory authority. As an Estonian company, our lead supervisory authority is:
Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate)
Tatari 39, 10134 Tallinn, Estonia
www.aki.ee ·
info@aki.ee
You may also contact the data protection authority in your own EU member state of residence.
We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page. Material changes will be communicated through the App or on this page. Your continued use of the App after any changes constitutes acceptance of the revised Policy.
For any privacy-related questions, requests, or concerns, please contact us:
PODSuite OÜ
Republic of Estonia, European Union
hairmonyapp@gmail.com
We aim to respond to all privacy inquiries within 30 days.