Privacy Policy for Hair Snap – AI Hair Scanner

Last updated: 01.10.2025

This Privacy Policy describes how AppCrafters OÜ (“we”, “us”, “our”) collects, uses, stores, shares, and protects personal data of users of the mobile application Hair Snap – AI Hair Scanner (the “App”). Our app is designed to help you assess and monitor cosmetic hair and skin variances (such as dryness, minor pigmentation, fine lines) — not to diagnose or treat medical conditions.

By downloading or using the App, you consent to the practices described in this policy.

1. Data Controller

AppCrafters OÜ

Registry code: 17240027

Address: Raatuse tn 106-1, 51009 Tartu linn, Tartu maakond, Republic of Estonia

E-mail: appcraftersou@gmail.com

VAT number: EE102860216 (from 14.05.2025)

We are the data controller for the personal data processed in connection with the App.

2. What Data We Collect

2.1 Data you provide:

Photographic images/scans of your hair and/or scalp or skin (if you opt to use that feature) to assess cosmetic variances (e.g., dryness, fine lines, pigmentation).
Device registration/profile information if you create an account (e.g., e-mail address, optional user name).
In-app subscription or purchase information (if you purchase premium features).
Preferences you choose within the App (e.g., notifications, reminders).

2.2 Automatically collected data:

Device identifier (e.g., device ID, advertising ID)
IP address, device type, operating system version, app usage data (time, features used)
Analytics/diagnostics information (errors, performance metrics)

2.3 Data aggregated or anonymised:

We may aggregate usage data to produce anonymised statistics (e.g., how many users use a given feature), which cannot be linked back to an identifiable individual.

3. How We Use Your Data

We use the data we collect for the following purposes:

To provide the core functionality of the App: analysing hair or skin scans for cosmetic variances and returning results.
To maintain your account and process any subscriptions or purchases.
To improve, maintain, and update the App (bug fixes, feature enhancements).
To analyse how users interact with the App (analytics) in order to improve user experience.
To send you notifications or marketing communications only if you have given your explicit consent.
To comply with applicable laws and protect our rights or the rights of others (e.g., fraud detection).

Important: The App is not intended for diagnosing or treating any medical conditions or diseases. The “variances” we refer to (dryness, fine lines, pigmentation irregularities) are cosmetic in nature. If you have concerns about a skin or scalp condition, please consult a qualified medical professional.

We do not sell your personal data to third parties. We may share your data with the following categories of recipients:

Service providers (e.g., cloud hosting, analytics providers) who process data on our behalf under contract.
Payment processors (for subscription/purchase flows) to process your transactions.
Legal authorities or courts, if required by law or to protect our rights.
Aggregated or anonymised data may be shared publicly or with partners, provided it cannot identify you.

We ensure that any third party we engage with provides adequate data protection and only processes your data as instructed by us.

5. Storage and Security of Your Data

We employ organisational and technical security measures (encryption, restricted access, secure servers) to protect your personal data from unauthorised access, alteration, or disclosure. We store data only for as long as necessary to fulfill the purposes outlined in this policy, or as required by law. If you request deletion of your data, we will remove it from our active systems within a reasonable timeframe, except to the extent storage is required by law.

Please note: transmissions over the internet are never 100 % secure; although we take all reasonable steps, we cannot guarantee absolute security of data transferred to the App.

6. Your Rights

Depending on your location, you have certain rights regarding your personal data. These may include:

The right to access the personal data we hold about you.
The right to correct or update your data.
The right to deletion (“right to be forgotten”), subject to retention requirements.
The right to data portability (to receive data in a structured, commonly used format).
The right to restrict or object to certain processing (e.g., analytics).
The right to withdraw your consent (for processing which relied on consent).

To exercise any of these rights, please contact us at appcraftersou@gmail.com. We will respond to your request as required under applicable law.

7. Children and Age Limitations

The App is intended for users aged 13 years or older. We do not knowingly collect personal data from children under the age of 13. If you are a parent or guardian and you become aware that your child under 13 has provided us with personal data, please contact us so we can delete such data promptly.

If you are located in the European Economic Area (EEA), the age threshold may be higher according to your country’s law (typically 16 years). If you believe we have collected data from a minor without appropriate consent, please contact us.

8. Cross-Border Transfers

Since we operate in Estonia (an EU member state), and may use cloud service providers, your personal data may be transferred to and stored in countries outside the European Economic Area (EEA). In such cases, we take steps to ensure appropriate safeguards (e.g., standard contractual clauses) are in place to protect your personal data.

9. Updates to This Privacy Policy

We may update this Privacy Policy from time to time (for example, to comply with changes in the law or features). We will notify you of significant changes by posting the updated version within the App and updating the “Last updated” date above. We encourage you to review this policy periodically.

Your continued use of the App after we make changes implies that you accept those changes.

10. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, you can contact us:

AppCrafters OÜ

Address: Raatuse tn 106-1, 51009 Tartu linn, Tartu maakond, Estonia

Email: appcraftersou@gmail.com