Privacy Policy – KESHAH
Effective Date: March 30, 2025
Last Updated: March 30, 2025

Thank you for choosing KESHAH. We are committed to protecting your personal data and ensuring transparency about how we collect, use, and safeguard your information. This Privacy Policy applies to the KESHAH mobile application (the "App"), website, and services (collectively, the "Platform").

1. Information We Collect

a. Personal Information

• Full name, email address, phone number, shipping and billing address

• Account credentials and referral activity

• Communication preferences

b. Health and Wellness Data

• Scalp and hair health condition, photos, treatment goals

• Treatment history, product usage, daily consistency logs

c. Usage Information

• App interactions, feature usage, session lengths

• IP address, browser type, device model, OS version, crash logs

d. Referral and Rewards Data

• Referral link usage, referred users, referral success tracking

e. Cookies and Local Storage (Web Platform)

• Session cookies, preference cookies, and analytics cookies

• Saved preferences to streamline repeat logins

f. Location Information (Optional)

• With permission, to offer localized services and support

2. How We Use Your Information

We use your information to:

• Personalize your treatment experience

• Track your progress and streaks

• Unlock new techniques, tools, and community perks

• Process and fulfill orders

• Communicate with you (reminders, updates, promotional offers)

• Improve app performance and user experience

• Power the referral program and community impact features

3. Legal Basis for Processing (GDPR Compliance)

If you are in the European Economic Area (EEA), we process your information based on:

• Your consent

• The performance of a contract (e.g., delivering your products)

• Legal obligations

• Legitimate interests (e.g., improving services)

4. Sharing Your Data

We do not sell your personal data. We only share data with:

• Service Providers: Payment processors, analytics providers, email and SMS delivery platforms, hosting partners

• Team Experts: To personalize and design your treatment program

• Legal Entities: If required by law or to protect our rights

5. International Data Transfers

If you access the Platform from outside the United States, please note that your data may be transferred to and stored in servers located in the U.S. or other jurisdictions. We use standard contractual clauses and safeguard mechanisms where applicable.

6. Your Rights

Depending on your jurisdiction, you may:

• Access, correct, or delete your personal data

• Request a copy of your treatment progress data

• Object to or restrict certain data processing

• Withdraw consent at any time

To exercise any of these rights, please email: contact@keshah.com

7. Data Retention

We retain your data as long as:

• Your account is active

• Necessary to support your treatment history and progress

• Required for legal, regulatory, or operational purposes

You may request account deletion at any time.

8. Data Security

We implement physical, technical, and administrative safeguards to protect your data, including:

• End-to-end encryption for sensitive fields

• Secure storage for photos and personal data

• Access limited to trained personnel

9. Scalp Photography Data

9.1 Collection and Storage of Scalp Photos

9.1.1 What Scalp Data We Collect

Our app allows you to capture, upload, and store photographs of your scalp and hair for the purpose of tracking changes and progress over time. These photographs may include limited portions of your forehead or neck as necessary to document the scalp/hair area of interest. We do not use these images for facial recognition, biometric identification, or any purpose beyond providing you with the ability to monitor your hair and scalp condition.

9.1.2 How Scalp Photos Are Captured and Stored

When you use our photo capture feature, images are:

- Initially processed and stored locally on your device

- Optionally uploaded to our secure servers when you choose to back up or sync your data

- Encrypted during transmission and storage using industry-standard protocols

- Associated only with your user account and not publicly accessible

- Never used for training AI models or other purposes beyond providing you with the requested services

9.2 Use of Scalp Photography Data

9.2.1 Primary Uses

We use your scalp photographs solely to:

- Display them to you within the app interface

- Organize them chronologically to show your progress over time

- Enable side-by-side comparison features as you track changes

- Deliver the core functionality you expect from our hair/scalp tracking service

9.2.2 Technical Processing

Our app may process your photos to:

- Optimize image quality and visibility

- Adjust lighting or contrast to improve clarity

- Generate thumbnails for the gallery view

- Calculate approximate coverage percentages when this feature is used

All technical processing occurs either on your device or on our secure servers and is performed solely to enhance your user experience.

9.3 Sharing and Disclosure of Scalp Photos

9.3.1 User Control Over Sharing

Your scalp photos are private by default. You may choose to:

- Keep photos entirely private and accessible only to you

- Share specific photos with healthcare providers through our secure sharing feature

- Export your photos for your personal records

9.3.2 No Sharing with Third Parties

We do not share your scalp photos with third parties.

9.3.3 No Commercial Use

We do not:

- Sell your scalp photos to third parties

- Use your photos for marketing or advertising purposes

- Share your photos with data brokers or analytics companies

9.4 Data Retention and Deletion

9.4.1 Retention Period

We retain your scalp photos for as long as you maintain an active account with us. This allows you to track long-term progress and changes over extended periods.

9.4.2 Your Deletion Rights

You have complete control over your scalp photos and can:

- Request deletion of all photos associated with your account

- Have all photos permanently removed if you delete your account

9.4.3 Deletion Process

When you ask us to delete a photo:

- It is immediately removed from your visible gallery

- It is marked for deletion from our backup systems

- It is permanently deleted from all our systems within 30 days

9.5 Security Measures

9.5.1 How We Protect Your Scalp Photos

We implement multiple layers of security to protect your sensitive scalp photos:

- End-to-end encryption during transmission

- Secure, encrypted storage on our servers

- Access controls limiting who can view your data

- Regular security audits and testing

- Industry-standard data protection protocols

9.5.2 Data Breach Notification

In the unlikely event of a data breach affecting your scalp photos, we will:

- Notify you promptly in accordance with applicable laws

- Inform you of the steps we're taking to address the breach

- Provide recommendations for protecting your information

10. Children’s Privacy

The Platform is not intended for users under 16 years of age. We do not knowingly collect or store data from minors.

11. Referral Data Privacy

When you refer a friend:

• Your referral ID is tracked for rewards

• We do not share your name unless you choose to

If you were referred:

• Your information remains private from the referrer

• Your activity is only linked for reward processing

12. Automated Decision-Making

We may use algorithms to suggest treatment routines. You may request a human review of automated recommendations by emailing our team.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material updates will be communicated via email or within the app.

14. Contact Us

For questions or concerns: KESHAH Support Team
Email: contact@keshah.com