Comb & Calm provides AI-powered image screening technology, educational content, consumer products, and related digital services designed to support scalp care. Our live screening feature uses artificial intelligence to analyze scalp images that you voluntarily submit to and generate an informational scalp screening result. The screening result is intended for non-medical informational purposes only and is not medical advice, a medical diagnosis, medical care, or a substitute for evaluation by an appropriately licensed healthcare professional. 

Comb & Calm is not a HIPAA covered entity because we are not a health plan, health care clearinghouse, or covered health care provider that transmits health information electronically in connection with HIPAA standard financial or administrative transactions. HIPAA generally applies to covered entities and their business associates, and consumer-oriented apps, devices, and online services that collect health-related information but do not meet HIPAA’s covered-entity or business-associate criteria generally fall outside HIPAA. Information you submit directly through the Services is governed by this Privacy Policy and applicable consumer privacy, personally identifying, sensitive, and other personal information, health-data, biometric-data, data-security, and consumer-protection laws, rather than by HIPAA, unless we separately enter into a written arrangement that makes us a business associate of a HIPAA covered entity. 

We collect information that you provide directly to us, information generated when you use the Services, information collected automatically from your device, and information generated by our AI-powered screening technology. The information you provide may include your name, email address, mailing address, telephone number, account credentials, payment-related information, customer support communications, marketing preferences, and other information you choose to provide. If you purchase products or services, we collect information necessary to complete your transaction, including order history and transaction details. Payment card information is processed by trusted third-party payment providers and is not stored by Comb & Calm except as permitted by those providers. 

When you use the live screening feature, you voluntarily submit scalp images for automated analysis. We may collect uploaded scalp images, information about the screening session, AI-generated screening results, confidence scores or similar outputs, image-quality information, and related technical or usage information needed to operate and improve the Services. We may also collect device and usage information, including device type, operating system, browser type, app version, IP address, mobile device identifiers, crash reports, diagnostic information, log files, pages viewed, features used, and date and time of access. Device identifiers and similar persistent identifiers may be sensitive when combined with health-related information, and we handle such information in accordance with this Privacy Policy and applicable law.

The Services are intended for adults. Parents and legal guardians may use the Services on behalf of their minor children. By submitting images through the Services, you confirm that you are the individual being screened, the parent or legal guardian of the individual being screened or otherwise authorized to submit images on behalf of the individual being screened. We do not knowingly collect personal information directly from children under 13 without appropriate parental authorization. 

Comb & Calm does not require facial images for the live screening feature and is designed to collect scalp-only images. We do not intentionally collect facial biometric information, faceprints, or scans of face geometry through the live screening feature. Please avoid uploading photographs that show the face, eyes, or other identifying facial features of the person being screened or any other person. If an uploaded image includes a face or other information that is not needed for scalp screening, we may crop, mask, reject, delete, or otherwise process the image to focus on the scalp area, subject to technical feasibility and applicable law. 

Certain laws define biometric identifiers to include retina or iris scans, fingerprints, voiceprints, and scans or records of hand or face geometry. Some biometric laws exclude ordinary photographs, physical descriptions, and certain photograph-derived information, but facial geometry scans derived from photographs may still be treated as biometric identifiers under some authorities. Our Services are not designed to identify or authenticate individuals using facial geometry, fingerprints, voiceprints, iris scans, retina scans, hand geometry, or similar biometric identifiers. If we materially change the Services to collect or use biometric identifiers for identification, authentication, or similar purposes, we will update our disclosures and obtain any consent required by applicable law before doing so.

We collect information that you provide directly to us, information generated when you use the Services, information collected automatically from your device, and information generated by our AI-powered screening technology. The information you provide may include your name, email address, mailing address, telephone number, account credentials, payment-related information, customer support communications, marketing preferences, and other information you choose to provide. If you purchase products or services, we collect information necessary to complete your transaction, including order history and transaction details. Payment card information is processed by trusted third-party payment providers and is not stored by Comb & Calm except as permitted by those providers. 

When you use the live screening feature, you voluntarily submit scalp images for automated analysis. We may collect uploaded scalp images, information about the screening session, AI-generated screening results, confidence scores or similar outputs, image-quality information, and related technical or usage information needed to operate and improve the Services. We may also collect device and usage information, including device type, operating system, browser type, app version, IP address, mobile device identifiers, crash reports, diagnostic information, log files, pages viewed, features used, and date and time of access. Device identifiers and similar persistent identifiers may be sensitive when combined with health-related information, and we handle such information in accordance with this Privacy Policy and applicable law.

When you use the live screening feature, the Services guide you through capturing scalp images, including images of areas such as the crown, behind each ear, the neckline, mid-scalp, and hairline. The Services are designed to capture scalp-only images, and images of faces are not required for the screening feature. Submitted images may be automatically processed, cropped, or otherwise prepared to focus on the scalp area before they are analyzed.

Our AI technology analyzes the submitted scalp images and may identify visual patterns that are consistent with lice, dandruff, debris, or other scalp-related indicators. The screening result depends on the images submitted, and image quality, lighting, hair type, hairstyle, camera angle, movement, obstructions, and other factors may affect the result. Artificial intelligence technology is continually improving but is not perfect, and false positives or false negatives are possible. If you have concerns regarding lice or any other medical condition, you should consult an appropriately licensed healthcare professional.

We use your information to provide, operate, maintain, secure, and improve the Services. We use submitted scalp images and related information to generate screening results, operate and maintain the Services, troubleshoot technical issues, improve the performance, accuracy, safety, and reliability of our Services, and train, validate, test, evaluate, and enhance our artificial intelligence technology. We may use account, purchase, device, usage, and communication information to create and manage accounts, process purchases, deliver service-related communications, respond to customer support requests, detect fraud, prevent abuse, address security incidents, comply with legal obligations, and enforce our Terms & Conditions. 

We may use information to develop new products and features, personalize the Services, understand how users interact with the Services, and improve website and application functionality. We may send marketing communications where permitted by law or with your consent, and you may opt out of marketing communications as described in this Privacy Policy. We do not use uploaded scalp images to create facial biometric templates or to identify you by your face.

Your uploaded photos will be de-identified where reasonably feasible before they are used for certain research, analytics, product-improvement, model-development, training, validation, testing, evaluation, or enhancement purposes. De-identification means that we take steps designed to remove or reduce information that directly identifies you, such as account-level identifiers, and to limit the ability to reasonably associate the image or related data with you. De-identified or anonymized information may be retained and used for research, analytics, product improvement, model development, and similar lawful purposes where permitted by applicable law. We do not treat de-identification as a guarantee that information can never be re-identified, and we use administrative, technical, and contractual controls designed to protect de-identified information and restrict inappropriate re-identification. 

We may use de-identified uploaded photos and related screening information to improve the Services, including by helping the AI technology better recognize visual indicators, evaluate model performance, reduce errors, and improve reliability across different lighting conditions, hair types, hairstyles, and image qualities. We may also use de-identified or aggregated information to understand how the Services are used, improve safety and security, validate product performance, and develop new features. If we ask you to share optional anonymous usage data to help improve detection, no photos are sent for that optional usage-data feature unless we clearly state otherwise and obtain any required consent.

We use cookies and similar technologies to remember preferences, improve website functionality, understand how the Services are used, measure performance, and improve the user experience. The technologies we use may collect usage details, IP addresses, operating system information, browser information, logs, device information, and information about the resources and features you access and use. You may disable cookies through your browser settings, although certain features may not function properly. 

We do not authorize analytics, advertising, or other vendors to use your screening information for their own advertising or marketing purposes unless we provide legally sufficient notice and obtain any consent required by applicable law. The FTC has treated unauthorized sharing of health app information for advertising or advertising-related analytics as a potential breach under the Health Breach Notification Rule when inconsistent with consumer expectations or privacy representations. We seek to use service providers only for purposes that support the operation, maintenance, security, analytics, functionality, and improvement of the Services, subject to contractual restrictions designed to protect your information.

We may disclose personal information to trusted third-party service providers that help us operate the Services, including providers of cloud hosting, payment processing, analytics, communications, authentication, customer support, security, diagnostics, and related services. These providers process information on our behalf under contractual obligations designed to protect the information and use it only for the purposes for which we disclose it. We may also disclose information where required by law, in response to lawful governmental requests, to protect the rights, safety, or property of Comb & Calm, our users, or others, or in connection with a merger, acquisition, financing, restructuring, reorganization, bankruptcy, or sale of assets. 

We do not sell your personal information as the term “sell” is defined under applicable privacy laws. We do not sell, lease, trade, or otherwise profit from facial biometric information because the Services are not designed to collect facial biometric information. If we disclose information that may be considered sensitive personal data, consumer health data, biometric data, or other specially protected information under applicable law, we will do so only as permitted by applicable law and this Privacy Policy.

Comb & Calm is based in the United States. If you access the Services from outside the United States, you understand that your information may be transferred to, processed, and stored in the United States, where privacy laws may differ from those in your jurisdiction. By using the Services or submitting information to us, you acknowledge that your information may be processed in the United States and other locations where we or our service providers operate, subject to this Privacy Policy and applicable law. 

The Services may link to or be made available through third-party websites, platforms, app stores, payment processors, or services. This Privacy Policy does not apply to information collected by third parties through websites, applications, content, platforms, or services that we do not control. Your use of Apple, Google, payment providers, or other third-party platforms may be subject to those third parties’ own terms and privacy policies. We encourage you to review the privacy policies of any third-party services you use.

Depending on where you live, you may have the right to access personal information we maintain about you, correct inaccurate information, request deletion of eligible information, receive a copy of certain information, withdraw consent where applicable, opt out of marketing communications, opt out of certain sales or sharing, opt out of targeted advertising, or opt out of certain profiling activities. The exact scope of these rights varies by state, and there may be exceptions that allow or require us to retain or continue processing certain information. To exercise your rights, please contact us using the contact information below or use any request mechanism we make available through the Services. 

You may request deletion of your account at any time. We may retain certain information where required or permitted by law, including where retention is necessary to complete transactions, resolve disputes, detect fraud, prevent abuse, enforce our agreements, protect our legal rights, comply with legal obligations, maintain security, or preserve de-identified or anonymized information for lawful purposes. You may opt out of marketing communications by following the instructions in the communication or by contacting us. You may also control certain cookies and device permissions through your browser or device settings.

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy or as otherwise permitted or required by law. We retain uploaded images only for as long as reasonably necessary to provide the requested Services, improve and maintain our technology, train and validate our artificial intelligence models, troubleshoot technical issues, comply with legal obligations, and protect our legal rights. Where permitted by law, we may retain de-identified or anonymized information for research, analytics, product improvement, model development, and related purposes. At the end of the applicable retention period, personal information will be deleted, destroyed, or de-identified, subject to applicable law and technical feasibility.

We maintain administrative, technical, and physical safeguards designed to protect personal information from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. We apply heightened care to information that may be sensitive, including health-related screening information, uploaded images, account credentials, and device identifiers associated with screening activity. No website, mobile application, system, electronic storage method, or online service is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for promptly notifying us of any unauthorized use of your account.

We may update this Privacy Policy from time to time. When material changes are made, we will update the “Last updated” date above and provide additional notice where required by law. If we materially change how we collect, use, disclose, retain, de-identify, or otherwise process uploaded images, health-related screening information, AI training data, or sensitive personal information, we will provide notice and obtain any consent required by applicable law. Your continued use of the Services following any changes means that you acknowledge the revised Privacy Policy.

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or want to ask about our handling of uploaded images, AI screening information, de-identified information, or sensitive personal information, please contact us at the information below.

Comb & Calm Inc.

contact@combcalm.com.