Privacy Policy

2Data Controller / Fiduciary and Data Protection Officer

3Definitions

• “Personal data” means any information relating to an identified or identifiable natural person.
• “Sensitive / biometric-adjacent data” means scalp and hair photographs and any analysis derived from them.
• “Report” means an entirely AI-generated output, including automated scalp cosmetic scores and hair density estimates.
• “AI Processor” means the third-party AI infrastructure provider engaged to generate Reports, as described in Section 6.
• “Processing” means any operation performed on personal data, whether automated or not.

4Age Restrictions and Children’s Data

We apply age-verification clickwrap gating during onboarding. If we discover an Account was created by someone under 18, we immediately delete all associated photographs, records, metrics, and profile data, subject only to the minimum recordkeeping legally mandated. If you believe a minor has submitted personal data to us, contact privacy@sanviau.com and we will delete it.

5Personal Data We Collect

Providing sensitive/biometric-adjacent data is optional, but the Platform’s core analysis service cannot be delivered without it. All payment card data is collected and processed directly by Apple or Google under their respective billing systems - Sanviau never receives or stores your card details.

6Photographic Data Processing and AI Architecture

The core ScalpSense engine processes photographic input to generate machine-computed cosmetic metrics. This processing operates under the following guardrails:

Biometric Shielding via Automated Cropping

Before analysis, we apply automated pre-processing filters that crop uploaded images to focus on hair partings, density patches, or crown areas, dropping surrounding facial elements or identifying eye/facial features wherever technologically viable.

Zero-Retention AI Pipeline

To compute structural density markers, cropped image tokens are transmitted through an encrypted API to models hosted by our enterprise AI providers, Anthropic/OpenAI. This transmission is governed by a signed Data Processing Addendum (DPA). Under that DPA, Anthropic/OpenAI is contractually restricted from caching, logging, retaining, or reviewing your image assets, and is prohibited from using any user data to train its models. API sessions are ephemeral and images are not stored by the AI Processor beyond the single request needed to generate your Report.

Pure Algorithmic Loop

The entire assessment cycle is machine-driven. No human - clinical, trichological, dermatological, or otherwise - reviews your images or Reports at any stage. This is consistent with our Terms & Conditions, under which the Platform is a cosmetic wellness tool only and not a medical device.

7Purposes of Processing and Legal Basis

We rely on your explicit, affirmative consent - obtained via clickwrap before activating your camera or any AI image-analysis pipeline - as our legal basis for processing sensitive/biometric-adjacent data under Article 9 GDPR, the DPDP Act, and equivalent frameworks elsewhere.

8No Advertising, No Data Monetization, and Third-Party Sharing

We Do Not Sell Your Data

We never sell, rent, lease, or monetize your scalp photographs, hair metrics, or profile attributes to insurance companies, data brokers, pharmaceutical companies, or marketing aggregators. We share personal data only in the following circumstances:

• With our AI Processor (Anthropic/OpenAI), strictly under the zero-retention Data Processing Addendum described in Section 6;
• With our cloud hosting infrastructure providers (AWS Mumbai and Frankfurt), under confidentiality and data-processing agreements;
• With Apple or Google, solely to process your in-app purchase;
• With regulators, law enforcement, or courts, where we are legally compelled to disclose.

9International Data Transfers and Localization

Indian user data is hosted on AWS Asia Pacific infrastructure (Mumbai region) to meet data-localization expectations under Indian frameworks. As the Platform expands to the EU, UK, US, Canada, and Australia, user data originating from those regions is hosted on AWS Frankfurt infrastructure. Where personal data is transferred across a jurisdictional boundary, the transfer is protected by Standard Contractual Clauses, Binding Corporate Rules, or an equivalent safeguard recognized under the GDPR and comparable frameworks.

10Storage, Security, and Retention

Retention Lifecycle

We retain your photographs, metrics, and Reports for as long as your Account remains active, to support historical tracking and re-access to Reports you have purchased. If an Account is inactive for 24 consecutive months, it is flagged for automated lifecycle review and purge, with prior notice to the email on file where practicable.

Deletion Timeline

You may trigger deletion at any time via “Delete Account & Clear Profile Data” in app settings, or by emailing privacy@sanviau.com. On deletion, your images, database fields, and profile are permanently purged from our production systems within 30 days, and from routine backups within a further 90 days, leaving only anonymized transaction records required for statutory accounting and tax purposes.

No method of transmission or storage is completely secure. While we apply the safeguards above, we cannot guarantee absolute security.

11Your Rights

Subject to the conditions of applicable law, you may exercise the following rights by contacting privacy@sanviau.com:

• Access - obtain a copy of the personal data we hold about you;
• Rectification - correct outdated, incomplete, or inaccurate data;
• Erasure - request complete deletion of your photographs, identifiers, and tracking history;
• Portability - receive your data in a structured, machine-readable format;
• Restriction - limit how we process your data;
• Objection - object to processing carried out on the basis of legitimate interests;
• Withdrawal of consent - withdraw consent at any time, which will end our ability to generate further Reports and will terminate your active Account;
• Complaint - lodge a complaint with the supervisory authority in your jurisdiction (see Section 12).

We acknowledge rights requests within 72 hours and respond substantively within 30 days. We may ask you to verify your identity before acting on a request.

12Jurisdiction-Specific Rights and Supervisory Authorities

13Cookies and Tracking

14Marketing Communications

Where we send marketing communications about ScalpSense features or products, you may opt out at any time using the unsubscribe link in any email or from your account settings. Opting out of marketing does not stop transactional messages relating to your Account, purchases, or Reports.

15Changes to This Policy

We may update this Privacy Policy from time to time. Updates are posted to this page with a revised effective date. Where a change materially affects your rights, we will provide additional notice, consistent with the amendment process described in our Terms & Conditions.

16Contact and Complaints

For any question about this policy or how we handle your personal data, contact privacy@sanviau.com or our Data Protection Officer / Grievance Officer at legal@sanviau.com. You also have the right to lodge a complaint with the supervisory authority in your jurisdiction, as listed in Section 12.

This Privacy Policy is for informational purposes and does not constitute legal advice. For medical advice or diagnosis, consult a qualified professional; Reports are AI-generated and may contain errors.