HairDAO’s Privacy Statement

Last Updated: October 20, 2023

This Privacy Statement applies to all websites and apps owned and operated by HairDAO Association and its’ affiliates (“HairDAO”), including www.hairdao.xyz and any other websites, pages, features, or content we own or operate, and to your use of the HairDAO mobile app and any related Services.

The information HairDAO collects.

Your Personal Information can be either:

• Individual-level Information: information about a single individual, such as hair loss data, their genotypes, diseases or other traits or characteristics.
• De-identified Information: information that has been stripped of identifying data, such as name and contact information, so that an individual cannot reasonably be identified.

Here are the types of Personal Information we collect:

• Registration Information: information you provide during account registration or when signing up the Services, such as a name, user ID, password, date of birth, or contact information (e.g., email, phone number).
• Self-Reported Information: information you provide to HairDAO including your hair loss treatment data, gender, disease conditions, health-related information, ethnicity, or anything else you provide to us within our Service(s).
• User Content: information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials, generated by users of HairDAO Services and transmitted, whether publicly or privately, to or through HairDAO.
• Web-Behavior Information: information on how you use our Services or about the way your devices use our Services is collected through log files, cookies, web beacons, and similar technologies (e.g., device information, device identifiers, IP address, browser type, location, domains, page views).

Aggregate Information is different from Personal Information

Aggregate Information is not Personal Information because Aggregate Information does not contain information about, nor can it reasonably be linked to, a specific individual. Aggregate Information is information about a group of people, such as an analysis or evaluation of a group. Aggregate Information describes the group as a whole in such a way that no specific individual may be reasonably identified. For example, the number of HairDAO customers with a specific variant or health condition is Aggregate Information.

How we collect information

• You: We collect information you provide to us when you register with us (including when you link your account on a third-party site or platform with your HairDAO account, such as via Google or Apple), participate in forums or other activities on our sites, features, and applications, or otherwise interact with us using one or more devices.
• Service Providers: We may collect information through service providers who use a variety of technologies and tools, such as cookies, analytics tools, software development kits, application program interfaces, web beacons, pixels, and tags when you visit, use or interact with our Services. For more detail on how we collect and use Web-Behavior Information, please see our Cookie Policy .
• Other Third Parties: We may receive information about you from other users, individuals, our corporate affiliates, or other third parties.
• HairDAO: We may infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics.

How we use your information

We use your information to:

• Provide our Services, including to develop, operate, improve, maintain, and safeguard our Services, including developing new product tools and features
• Analyze and measure trends and usage of the Services
• Communicate with you, including customer support, or to share information about our Services or other offers or information we think may be relevant to you
• Personalize, contextualize and market our Services to you
• Provide cross-context behavioral or targeted advertising
• Enhance the safety, integrity, and security of our Services, including prevention of fraud and other unauthorized or illegal activities on our Services
• Verify your identity and administer your User Account
• Enforce, investigate, and report conduct violating our Terms of Service or other policies
• Conduct surveys or polls, and obtain testimonials or stories about you
• Comply with our legal, licensing, and regulatory obligations
• Conduct research, if you choose to participate

HairDAO Recommendations

HairDAO allows you to upload your personal data including hair loss treatment data, bloodwork, images, photos and videos. Using your personal information and AI technologies, the Site will generate recommendations to you for your hair loss treatment.

HairDAO may also conduct independent research using your personal information for the purpose making new discoveries about hair loss and other factors behind diseases and traits. Such research activities shall be performed by HairDAO, either independently or jointly with third parties.

How does HairDAO protect my information in Research?

HairDAO Research analyses are conducted with information that has been stripped of your identifying Registration Information.

Data sharing

Who we share with:

Service providers: Our service providers and contractors help us provide our Services and act on our behalf to get things done. We implement procedures and maintain contractual terms with each service provider and contractor to protect the confidentiality and security of your Personal Information.

Commonly owned entities, affiliates and change of ownership: If we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your Personal Information may be accessed, sold or transferred as part of that transaction and this Privacy Statement will apply to your Personal Information as transferred to the new entity. We may also disclose Personal Information about you to our corporate affiliates to help operate our services and our affiliates’ services.

Third parties related to law, harm, and the public interest: HairDAO will not​ provide information to ​law enforcement​​ unless required by law to comply with a valid court order, subpoena, or search warrant. We require all law enforcement inquiries to follow a valid legal process, such as a court order or search warrant, and are prepared to exhaust available legal remedies to protect customer privacy. If we are compelled to disclose your Personal Information to law enforcement, we will try our best to provide you with prior notice, unless we are prohibited from doing so under the law.

Security Measures

We implement physical, technical, and administrative measures aimed at preventing unauthorized access to or disclosure of your Personal Information. Our team regularly reviews and improves our security practices to help ensure the integrity of our systems and your Personal Information.

Please recognize that protecting your Personal Information is also your responsibility. Be mindful of keeping your password and other authentication information safe from third parties, and immediately notify HairDAO of any unauthorized use of your login credentials. Your password is not visible to HairDAO staff, and we encourage you not to share your password with HairDAO or any third parties. HairDAO cannot secure Personal Information that you release on your own or that you request us to release.

Third Party Content and Integrations

Our Services may contain third party content, integrations or links to third party websites operated by organizations not affiliated with HairDAO. Through these integrations, you may be providing information to the third party as well as to HairDAO. Since we can only control our own Services, we are not responsible for how those third parties collect or use your information so please review the privacy policies of every third-party service that you visit or use, including those third parties you interact with through our Services.

Federal, State, and Region-Specific Information

California, Virginia and Colorado residents have the rights listed here. However, these rights are not absolute and exceptions apply, so in certain cases we may decline your request as permitted by law.

Resident of the European Economic Area (EEA), the UK, Switzerland and others have their rights listed here.

Retention of Personal Information

We retain Personal Information for as long as necessary to provide the Services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significawntly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.

Changes to this Privacy Statement

‍We may make changes to this Privacy Statement from time to time. We’ll let you know about those changes here or by reaching out to you via email or some other contact method, such as through in-app notification, or on another website page or feature.

Contact Information

‍If you have questions about this Privacy Statement, or have a complaint or inquiry, please email HairDAO’s Privacy Administrator at privacy@hairdao.xyz, call us at 1-917-204-6427, or send a letter to:

Privacy Administrator; HairDAO; 7750 Okeechobee Blvd, Ste 4 PMB3085, West Palm Beach, FL 33411, USA.