Consumer Health Data Privacy Policy

This policy describes how FRIIO collects, uses, shares and protects “consumer health data” through the Halt app, as required by the Washington My Health My Data Act, Nevada law (NRS 603A.400 and following) and similar US state laws. It supplements our Privacy Policy.

Effective date: 22 September 2026

In short. We collect consumer health data only to provide the Halt features you ask for. We do not sell it, we do not share it with third parties for their own purposes, we do not use it for advertising, and we do not use geofencing. You can access it, delete it and withdraw your consent at any time.

1. Who we are

FRIIO, SASU registered with the Rouen Trade and Companies Register under number 105 203 152, 72 Quai Cavelier de la Salle, 76100 Rouen, France. Email: friio.iocontact@gmail.com. FRIIO has no affiliates.

2. Consumer health data we collect, and how we use it

Photos of your head, including your face, taken during guided scans, and the estimated measurements derived from them (for example, coverage by area). Used to show your progress over time, compare scans and build your 3D head model.
Face-geometry data (the position of your face and facial landmark points detected on your device). Used only to guide the capture, align your scans and fit your 3D model, never to identify you.
Your answers: gender, the pattern of your hair loss and how long you have been noticing it, the areas that concern you, family history, current or past treatments (and whether a treatment must be kept out of your plan for safety reasons), products and equipment you use, your goal. Used to personalize your plan, your routines and the information shown to you.
Your routines and daily logs, including routines related to treatments you choose to track. Used for reminders, your history and your streaks.
Information that may reveal an interest in hair loss, such as the fact that you have a Halt account or subscription, together with your email address. Used to run your account and your subscription.

We use consumer health data only to provide Halt to you, to keep it secure, and to comply with the law. If we ever wanted to use it for another purpose, we would first ask for your separate consent.

3. Sources

You, directly (your answers, your routines, the photos you take).
Your device (camera, motion sensors used to guide the angle, on-device face detection).
The app itself, which computes measurements and your 3D model from your scans.
Apple, Google and RevenueCat, for the status of your subscription.

4. Sharing

We do not sell consumer health data and we do not share it with third parties or affiliates, within the meaning of these laws. We disclose it only to the service providers (processors) that act on our behalf, under contracts that limit their use of the data to providing their services to us:

Supabase, Inc.: hosting of your account, scans, answers, routines and logs (all categories of section 2).
RevenueCat, Inc.: management of your subscription (your account identifier, your email address and the fact that you are a Halt customer).

We may also disclose consumer health data when the law requires it, for example in response to a valid court order. Third parties cannot collect consumer health data about you over time and across different websites or online services through Halt.

5. Consent

We collect and use consumer health data only as necessary to provide the features you request when you create your account and use Halt. We will ask for your separate consent before collecting or using it for any other purpose, and before sharing it with a third party. We would never sell it without your signed authorization, and we have no intention of doing so.

6. Your rights

You have the right to:

confirm whether we collect, share or sell your consumer health data;
access that data, together with a list of all third parties and affiliates with whom we have shared or sold it and their contact details (today, there are none beyond the service providers listed above);
withdraw your consent to its collection and sharing;
delete it. We then also notify our service providers, which delete it too. Data in backups is deleted within 30 days;
review and correct the answers you gave, in the app or by email.

To delete your data, use Settings, then Account, then Delete account in the app, or follow the steps at friio.io/halt/delete-account. For any other request, email friio.iocontact@gmail.com from the address of your account. We may ask you to confirm that you control the account. We respond within 45 days; if we need more time (up to 45 more days), we will tell you why. Requests are free of charge up to twice a year.

Appeals

If we decline to take action on your request, you can appeal by replying to our decision with the word “Appeal” within a reasonable time. We will respond in writing within 45 days, explaining what we did or did not do and why. If we deny your appeal, you can submit a complaint to the Washington State Attorney General (atg.wa.gov/file-complaint), the Nevada Attorney General (ag.nv.gov) or the Attorney General of your state.

7. Security and access

Access to consumer health data is limited to the people and service providers who need it to provide Halt, and it is protected by encryption in transit and at rest and by access rules that let each account reach only its own records. Details are in section 9 of the Privacy Policy.

8. Changes

If we make a material change to this policy, we will notify you in the app or by email before it takes effect, and we will ask for your consent where the law requires it. The effective date at the top of this page shows the current version.

9. Contact

FRIIO, 72 Quai Cavelier de la Salle, 76100 Rouen, France. Email: friio.iocontact@gmail.com (subject “Halt health data request”).