Patient Privacy Policy

Last updated: March 24, 2026

1. Introduction

HairCare+ is operated by Aleh Leuchanka, Voltastrasse 106, 4056 Basel, Switzerland ("we", "our", or "us"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the HairCare+ mobile application (the "App").

2. Information We Collect

We collect the following types of information:

• Personal Information: Name, email address, and phone number provided during registration via clinic invite code.
• Health Information: Hair transplant surgery date and post-operative care progress data, including daily task completion.
• Photos: Recovery images of the transplant and donor areas captured in the App for progress tracking and clinician follow-up. These images may incidentally include parts of your face.
• Audio: Voice messages recorded in the chat feature for communication with your clinic and AI assistant.
• Location: Approximate (coarse) location, used only when you ask the AI assistant to find nearby pharmacies or clinics. Location is not stored on our servers.
• Device Information: Push notification tokens for delivering reminders and messages.

2.1 Face Data and Biometric Information

The App may process images that incidentally include parts of your face as part of medical recovery documentation.

• We do not use facial recognition.
• We do not create or store biometric templates or face geometry.
• We do not use face data for identity verification, advertising, or profiling.

3. How We Use Your Information

• Provide personalized post-operative care schedules based on your surgery date.
• Enable communication between you and your clinic.
• Power the AI assistant to answer your recovery-related questions.
• Track and visualize your recovery progress through photos, including images that may incidentally contain face data.
• Send push notifications for care reminders and clinic messages.

4. Data Sharing

We share your data only with:

• Your Clinic: The clinic that issued your invite code has access to your profile, progress photos, and chat messages.
• Service Providers: We use Supabase for secure data storage and OpenAI for AI assistant functionality. These providers process data under strict contractual obligations.

We do not sell your personal data to third parties. We do not use your data for advertising or tracking purposes.

Face-related photos are shared only with your clinic and infrastructure providers required to host and deliver the service.

5. Data Storage and Security

Your data is stored on secure cloud infrastructure in the European region with encryption in transit and at rest. Some data (daily tasks, cached messages) is stored locally on your device using an encrypted SQLite database for offline access.

6. Data Retention

We retain your data, including face-related photos, for the duration of your active account. You may request deletion of your account and associated data by contacting your clinic or us directly. We delete requested data unless a longer retention period is required by applicable law or medical record obligations.

7. Your Rights

If you are located in the European Economic Area (EEA), Switzerland, or the United Kingdom, you have rights under the General Data Protection Regulation (GDPR), the Swiss Federal Act on Data Protection (nFADP), or equivalent legislation. These rights include:

• Access the personal data we hold about you.
• Request correction of inaccurate data.
• Request deletion of your data ("right to be forgotten").
• Object to or restrict the processing of your data.
• Export your data in a portable format (data portability).
• Withdraw consent for data processing at any time.
• Lodge a complaint with your local data protection authority.

To exercise these rights, contact us at privacy@haircare.clinic. We will respond to your request within 30 days.

8. Legal Basis for Processing

We process your personal data on the following legal bases:

• Consent: You provide explicit consent when creating your account and granting access to your camera, microphone, and location.
• Contract: Processing is necessary to provide the services you requested through the App.
• Legitimate Interest: We may process data to improve our services and ensure security, where this does not override your rights.

9. Children's Privacy

The App is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes through the App or by other means. Your continued use of the App after such changes constitutes acceptance of the updated policy.

11. Contact Us

If you have questions about this Privacy Policy, please contact us at:

Aleh Leuchanka
Voltastrasse 106, 4056 Basel, Switzerland
privacy@haircare.clinic