Privacy Policy

This policy explains what personal data the Halt mobile application and the pages at friio.io/halt collect, why, where it is stored, who receives it, how long we keep it and how you can exercise your rights. Halt works with photos of your head and with information about your hair and your routines. The law treats much of this as health data, and so do we.

Last updated: 22 September 2026

In short. We collect what Halt needs to work: your account, your answers, your scans (photos of your head, including your face) and your routines. They are saved in your private account, on servers located in the European Union (Ireland). We have no ads, we do not track you across apps or websites, and we do not sell or share your personal data. We never use your identifiable photos to train models unless you give a separate opt-in consent. You can delete your account and your data at any time from the app.

1. Who is responsible for your data

The controller of your personal data is FRIIO, a French simplified joint-stock company with a sole shareholder (SASU) with a share capital of 250 euros, registered with the Rouen Trade and Companies Register under number 105 203 152, whose registered office is at 72 Quai Cavelier de la Salle, 76100 Rouen, France (“FRIIO”, “we”, “us”).

For any question or request about your data, write to friio.iocontact@gmail.com. We have not appointed a data protection officer because we are not currently required to; if that changes, we will publish their contact details here.

2. What this policy covers

This policy applies to the Halt app (iOS and Android) and to the web pages under friio.io/halt. It does not apply to websites or services run by others, such as the app stores or the retailers you may reach through a link in the app. If you live in the United States, our Consumer Health Data Privacy Policy also applies to you.

3. The data we collect

3.1 Account data

Your email address and password. The password is stored only in hashed form by our authentication provider; we never see it.
If you sign in with Google (or Apple, when available), the information that provider sends us: your name, email address, profile picture link and a technical account identifier.
Your Halt account identifier, and the dates you created your account and last signed in.

3.2 Your answers

What you tell us during onboarding and in the app: gender, age range, 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, products and equipment you use, hair length, how you track your hair today, your goal, the time and monthly budget you want to spend on it, how you heard about Halt, the date of your commitment, and, if you answer the safety question, whether a treatment must be kept out of your plan for safety reasons.

3.3 Your scans

For each scan, a set of photos of your head (usually six) taken from guided angles, including your face.
Capture information stored with each photo: the orientation of your phone at the time of capture, whether the image is mirrored, the position of your face in the frame and a set of facial landmark points (see section 11).
The estimated measurements the app computes from your scans (for example, coverage by area), and any notes you add.

3.4 Your 3D head model

The app builds a 3D model of your head on your device and calibrates its shape from your scans. Today, these shape parameters are stored only on your device. If a future version saves them in your account, they will be handled exactly like your scans.

3.5 Routines and daily logs

The routines you create (name, type, schedule), your daily check-ins and streaks. Reminders are scheduled locally on your device.

3.6 Purchase data

Your subscription or purchase status, the product bought, purchase, renewal and expiry dates, trial status, transaction identifiers and the country of your store account. Payments are handled by Apple or Google: we never receive your card number.
Our subscription provider RevenueCat receives your Halt account identifier and your email address, so that your purchase follows your account and we can find it when you contact us.

3.7 Usage events

A closed list of neutral events: app opened, onboarding step reached (the name of the step, never your answer), onboarding completed, how you heard about Halt if you answer that question (one choice from a fixed list, such as a social network, a search engine, the app store, a friend or a doctor), offer screen viewed or closed, result of a purchase or sign-up attempt (success or not, and the method used), scan completed, routine added. Each event carries a random session identifier, a timestamp and, once you are signed in, your account identifier.
These events never contain your photos, measurements, answers, notes or any text you type.

3.8 Technical data

When the app or your browser communicates with our servers, our hosting providers process your IP address, device and operating system type, app version and timestamps, in security and server logs.

3.9 Messages you send us

If you email us, your email address and the content of your message.

3.10 What we do not collect

No advertising identifier (IDFA or Android advertising ID), no precise location, no contacts, no microphone, and no data from Apple Health or Health Connect.

4. What happens on your device, and what reaches our servers

Face detection, capture guidance, the 3D reconstruction and the measurements are computed on your device. Face detection uses Google ML Kit in its on-device version: your images are not sent to Google. ML Kit may send Google limited technical diagnostics (device model, operating system and app version, performance metrics, API settings and a per-installation identifier), which contain no image and no health information.

An account is required to use Halt. The data described in sections 3.1 to 3.7 is saved in your private account on our servers, so that your history is kept if you change phones and stays in sync across your devices. This is how the service works.

5. Why we use your data, and on what legal basis

Where the GDPR, UK GDPR or Swiss law applies, we rely on the following legal bases:

Providing Halt (account, storage and sync of your history, measurements, plan, routines, reminders, support): performance of our contract with you (Art. 6(1)(b) GDPR). For health data (your scans, answers, measurements, routines and logs): your explicit consent (Art. 9(2)(a) GDPR).
Subscriptions and purchases: performance of the contract (Art. 6(1)(b)), and compliance with our accounting and tax obligations (Art. 6(1)(c)).
Security (preventing fraud and abuse, protecting accounts, fixing bugs): our legitimate interest in keeping Halt safe and working (Art. 6(1)(f)).
Product statistics from the neutral usage events of section 3.7: our legitimate interest in understanding where the app fails and improving it, using minimal data (Art. 6(1)(f)). You can object at any time by email.
Service messages (for example, a change to our terms or a security notice): performance of the contract and our legal obligations. We do not send marketing messages without your consent.
Legal claims and requests from authorities: our legitimate interest in defending our rights, our legal obligations, and, for health data, Art. 9(2)(f) GDPR.

5.1 Your consent to health data, and how to withdraw it

When you create your account, you explicitly consent to the storage and processing of your health data in your account, for the sole purpose of providing Halt to you. In the European Economic Area, the United Kingdom and Switzerland, this consent is collected with a dedicated statement shown above the sign-up options and a sign-up button that says what it does.

You can withdraw your consent at any time by deleting your account (in the app: Settings, then Account, then Delete account) or by email. Because storing this data in your account is what Halt does, withdrawing consent means that we delete your account and its data, and you can no longer use Halt with that account. Withdrawal does not affect processing that took place before it.

6. Who receives your data

We do not sell or rent your personal data, we do not share it for advertising, and we never disclose your health data to anyone for their own purposes (advertisers, data brokers, insurers or employers). Your data is only disclosed to:

6.1 Our service providers (processors)

They act only on our instructions, under contracts that require them to protect your data.

Supabase, Inc. (United States): database, authentication, file storage and server functions. Your account and your scans are hosted in the European Union (Ireland). Emails such as password reset codes are sent through Supabase's authentication service.
RevenueCat, Inc. (United States): management of subscriptions and purchases.
Vercel Inc. (United States): hosting of the friio.io website.

6.2 Independent companies (their own privacy policies apply)

Apple and Google, for the app stores, payments and refunds, and, if you choose it, sign-in with your Apple or Google account.
Google, for the ML Kit technical diagnostics described in section 4, the fonts loaded by our website (section 15), and our email service when you write to us.
Retailers such as Amazon, only if you tap a partner link (section 14). We send them no personal data.

6.3 Other cases

When the law requires it (for example, a valid court order), or when it is necessary to protect the rights, property or safety of our users, the public or FRIIO.
If FRIIO is involved in a merger, acquisition or sale of all or part of its business, your data may be transferred to the company that takes over Halt, which will be bound by this policy. We will inform you before the transfer and, where the law requires it, ask for your consent.

7. International transfers

Your account and your scans are hosted in the European Union. Some of our providers are US companies whose teams or sub-processors may access data from outside the European Economic Area, for example to provide support. These transfers are covered by the European Commission's Standard Contractual Clauses (with the UK Addendum and the Swiss adjustments where relevant) and, where the provider is certified, by the EU-U.S. Data Privacy Framework and its UK and Swiss extensions, together with technical measures such as encryption in transit and at rest. You can ask us for a copy of these safeguards.

8. How long we keep your data

Account, answers, scans, photos, measurements, routines and logs: as long as your account exists. When you delete your account, they are deleted from our active systems immediately, and from our hosting provider's encrypted backups within 30 days.
Inactive accounts: if you do not sign in for three consecutive years, we delete your account and its data, after warning you by email at least 30 days in advance.
Deleting a single scan: deleting a scan in the app removes it from your device and, at the next sync, from our servers (its record and its photos), and from our hosting provider's encrypted backups within 30 days.
Usage events: detached from your account when you delete it, after which they no longer identify you. They are kept for at most 24 months, then deleted or aggregated.
Purchase data at RevenueCat: as long as your account exists. After you delete your account, we have your subscriber record deleted within 30 days, except transaction records we must keep for accounting, tax or fraud-prevention purposes. Apple and Google keep their own purchase records under their own policies.
Server and security logs: kept by our hosting providers for a short period, generally a few days and no more than 90 days.
Emails and requests you send us: up to 3 years after our last exchange.
Accounting records: for the period required by law (up to 10 years in France). They never contain photos or health data.
If a dispute arises, we may keep the data strictly needed for it until the dispute is finally resolved.

9. Security

We protect your data with measures suited to its sensitivity: encryption in transit (TLS) and at rest, access rules that let each account reach only its own records and files (row-level security and private storage), hashed passwords, administrative access limited to the people who need it and protected by strong authentication, and minimal data in our usage statistics. No system is perfectly secure. If a breach affects your data, we will inform you and the authorities when and as the law requires.

10. Your rights

10.1 For everyone

Wherever you live, you can ask to access your data and receive a copy of it, to correct it, to delete it, and to withdraw your consent. You can delete your account directly in the app (Settings, then Account, then Delete account) or follow the steps at friio.io/halt/delete-account. For any other request, email friio.iocontact@gmail.com from the address linked to your account. To protect your data, we may ask you to confirm that you control the account. We answer within one month (45 days where US law applies), which may be extended when the law allows it, and your request is free of charge unless it is manifestly unfounded or excessive.

10.2 European Economic Area, United Kingdom and Switzerland

You have the right of access, rectification, erasure, restriction of processing, data portability, the right to object to processing based on our legitimate interests, and the right to withdraw your consent at any time. Halt makes no decision based solely on automated processing that produces legal or similarly significant effects on you: its measurements are estimates for your own information. In France, you can also give instructions on what happens to your data after your death. You can lodge a complaint with the French data protection authority, the CNIL (cnil.fr), with the authority of the country where you live or work, with the UK Information Commissioner's Office (ico.org.uk), or with the Swiss Federal Data Protection and Information Commissioner.

10.3 United States

Depending on your state of residence (for example California, Colorado, Connecticut, Virginia, Utah, Texas or Oregon), you may have the right to know what personal information we collect and to access it, to correct it, to delete it, to obtain a portable copy, and to opt out of the sale or sharing of personal information, targeted advertising and certain profiling.

We do not sell or share your personal information, as those terms are defined by the California Consumer Privacy Act and similar laws. We do not use it for targeted advertising, and we do not profile you in furtherance of decisions that produce legal or similarly significant effects. We have no actual knowledge of selling or sharing the personal information of consumers under 16.
Sensitive personal information (health information, face-geometry data, account log-in credentials) is used only to provide the services you request and for the other purposes permitted by law, so no “limit the use” request is needed.
We do not discriminate against you for exercising your rights. You may use an authorized agent; we may ask for proof of the authorization and verify your identity.
If we deny your request, you can appeal by replying to our answer with the word “Appeal”. We will respond within the period set by your state's law (generally 45 or 60 days). If you disagree with the outcome, you can contact your state Attorney General.
We honor Global Privacy Control signals as an opt-out request, even though we have nothing to opt you out of.
California notice at collection. Categories collected in the last 12 months: identifiers (email, account identifier, IP address); customer records (name and email if you use Google sign-in); commercial information (purchase history); internet or other electronic network activity (usage events); audio, electronic or visual information (photos); biometric information (face-geometry data); inferences (estimated measurements); sensitive personal information (health information, face-geometry data, account log-in). Sources: you, your device, Apple, Google and RevenueCat. Purposes: those of section 5. Disclosed for a business purpose to our service providers of section 6.1 only. Sold or shared: none. Retention: see section 8.
California “Shine the Light”: we do not disclose personal information to third parties for their direct marketing purposes.

If you live in Washington, Nevada or another state with a consumer health data law, read our Consumer Health Data Privacy Policy.

10.4 Other countries

If the law of your country gives you other rights over your data (for example in Brazil, Canada, Japan, South Korea, Australia or India), we honor them. Contact us by email.

11. Face-geometry data

To guide the capture, align your photos from one scan to the next and fit the 3D model of your head, the app detects the position of your face and a set of facial landmark points on your device. These points are saved with your scans. Some laws, such as the Illinois Biometric Information Privacy Act, the Texas Capture or Use of Biometric Identifier Act and Washington law, may treat this kind of data as biometric data. Whatever the law where you live, we commit to the following:

Purpose: we use it only to align and compare your own scans and build your 3D model. We never use it to identify or recognize you or anyone else, or to verify identity.
No sale, no profit: we never sell, lease or trade it, and never otherwise profit from it.
No disclosure: it is disclosed only to the hosting provider that stores it for us (section 6.1), or where required by law or with your consent.
Retention and destruction: we permanently destroy it when the purpose for which it was collected is fulfilled, that is when you delete your account or the related scan is deleted from our servers, and in any case no later than three years after your last interaction with Halt, whichever comes first.
Protection: we store and protect it with at least the same care as our other sensitive data.

By creating your account and taking a scan, you acknowledge this notice and consent to the collection, storage and use of face-geometry data as described in this section.

12. Anonymous statistics and model training

We may create aggregated or anonymized statistics that can no longer identify you (for example, the average number of scans per month). They are not personal data; we may use and publish them, and keep them after your account is deleted. We keep such data in de-identified form, we do not attempt to re-identify it, and we require anyone who receives it not to do so.
Photos of a head cannot truly be anonymized, so we never treat them as anonymous.
We never use your identifiable photos, face-geometry data or scans to train or improve machine-learning models, and never provide them to anyone for that purpose, unless you give a separate, specific, opt-in consent in the app, which you could withdraw at any time. No such option exists today.

13. Children

Halt is intended for adults and requires you to be at least 18. It is not directed to children and we do not knowingly collect personal data from anyone under 18 (or under 13 within the meaning of the US Children's Online Privacy Protection Act). If we learn that an account belongs to a minor, we delete it and its data. If you believe a minor is using Halt, please contact us.

14. Partner links

Halt may show links to third-party retailers, such as Amazon, for over-the-counter products. We may earn a commission when you buy through them. As an Amazon Associate, FRIIO earns from qualifying purchases. If you tap such a link, you leave Halt and the retailer's own privacy policy applies. We send the retailer no personal or health data: the link only contains our partner tag, and we only receive aggregated sales reports that do not tell us who bought what. Commissions never influence what the app recommends.

15. Cookies and similar technologies

The app contains no advertising or tracking technology and no third-party analytics SDK. It stores on your device only what it needs to work (your sign-in session in the device's secure storage, a local database and your photos).

The friio.io/halt pages set no cookies and use no analytics. A small script picks the language of the page from your browser settings without storing anything. The pages load their fonts from Google Fonts, which receives your IP address and browser information when you open them, and our host Vercel keeps server logs.

16. Changes to this policy

We may update this policy, for example when the app or the law changes. If a change is material, we will tell you in the app or by email before it takes effect, and where the law requires it (for example, a new use of your health data) we will ask for your consent. The date at the top of this page shows the latest version, which always lives at friio.io/halt/privacy. Previous versions are available on request.

17. Contact

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

A French translation of this policy is available at friio.io/halt/fr/privacy. If the two versions differ, the English version prevails, unless the law of your country requires otherwise.