Privacy Policy

This policy explains what personal data the Halt mobile application collects, why, how it is protected, who it is shared with, and what your rights are. Because Halt deals with photos of your scalp and hair-related information, we treat everything it handles as sensitive by default.

Last updated: August 20, 2026

1. Who is responsible

Halt is published by FRIIO, a French company (SASU) registered with the Rouen Trade and Companies Register under number 105 203 152, headquartered at 72 Quai Cavelier de la Salle, 76100 Rouen, France.

For any question about your data or to exercise your rights: friio.iocontact@gmail.com.

2. What we collect

2.1 Account data (required)

• Email address and password (the password is stored hashed, never in clear text).

2.2 Health-related data (the core of the app)

• Photos of your scalp and head taken during guided scans.
• The 3D reconstruction and measurements derived from those photos (zone coverage, hairline position, evolution over time).
• Your questionnaire answers (age range, hair-loss pattern, history, routine habits, goals).
• Your routines and their completion history.

2.3 Purchase data

• Subscription status and purchase receipts, processed by RevenueCat and the app stores. We never see or store your card number.

2.4 Usage data

• Strictly neutral technical events (e.g. "app opened", "onboarding completed"). These events never contain your photos, measurements, zones, scores or questionnaire answers.

3. What we never do

• We never sell your personal data, to anyone.
• We never use your photos or measurements for advertising.
• We never share health-related data with third parties for their own purposes.
• We never use your data to train models without your explicit, separate consent.

4. Legal bases

• Contract — account data and purchase data are needed to provide the service.
• Explicit consent — cloud storage of health-related data (Art. 9 GDPR). Withdrawable at any time.
• Legitimate interest — neutral usage events, used solely to keep the app working and improve it.

5. Where your data lives and who processes it

• Supabase — database, authentication and storage infrastructure hosting your account and, with your consent, your synced health data. Access is restricted row-by-row to your account.
• RevenueCat — subscription management (receipt validation, entitlement status).
• Apple / Google — payment processing through their stores.

These processors act under contract and only on our instructions.

6. Affiliate links

The app may show links to third-party retailers (e.g. Amazon) for over-the-counter products. If you open one, the retailer's own privacy policy applies. What we recommend is decided by measured and declared data only — never by commissions — and no health data is transmitted through those links.

7. Retention

• Account and synced health data: kept while your account exists.
• When you delete your account, your data is permanently erased from our systems.
• Local data (on-device photos and history) is removed when you uninstall the app or delete your account from the app.

8. Your rights

Under the GDPR (and equivalent laws such as the CCPA where applicable), you can access, correct, export, restrict or delete your data, and withdraw consent at any time. Most of it is doable directly in the app (Settings → account, cloud sync consent, delete account). For anything else, write to friio.iocontact@gmail.com — we answer within 30 days. To delete your account and all associated data, see friio.io/halt/delete-account. You may also lodge a complaint with the CNIL (cnil.fr) or your local authority.

9. Not a medical service

Halt provides measurements and general information. It is not a medical device, does not diagnose any condition, and never replaces a consultation with a doctor or dermatologist.

10. Changes

If we materially change this policy, we will notify you in the app before the change applies. The latest version always lives at friio.io/halt/privacy.