Privacy Policy

Folliculate ("Folliculate," "we," "us," or "our") provides personalized hair-growth treatment matching services through folliculate.com and related services (collectively, the "Services").

This Privacy Policy explains how we collect, use, disclose, store, and protect personal information when you use our Services. By using the Services, you acknowledge the practices described in this Privacy Policy.

1. Information We Collect

Information you provide

We may collect the following information directly from you:

• Quiz responses: Answers to our assessment, including information about your hair condition, hair loss or thinning, daily routine, preferences, budget, and other responses you choose to provide. A small number of questions ask whether certain circumstances apply to you (for example, pregnancy or patchy hair loss). These questions exist solely to determine whether we can safely provide a general product recommendation.
• Email address: If you provide your email address to receive your results, recommendations, updates, or other communications.
• Communications: Information you provide when contacting us, including the contents of your message and any information needed to respond to your request.

Some quiz responses may reveal or allow us to infer information relating to your health, appearance, sex, or hair-loss concerns. This information may be treated as "special category data" under the GDPR, "sensitive personal information" under the CCPA, and/or "consumer health data" under certain U.S. state health privacy laws.

We collect this category of information only with your explicit, opt-in consent, given through a clear consent action presented before you submit the quiz (for example, an unticked consent checkbox). We do not rely on legitimate interests to process this information. You may decline to answer optional quiz questions without losing access to the core Services, though doing so may limit our ability to generate a recommendation for you.

Safety-screening questions and outcome. If you indicate that certain circumstances apply to you (for example, pregnancy, patchy or sudden hair loss, or other flagged conditions), we will not generate or display a product or treatment recommendation. Instead, we will show you a message encouraging you to consult a licensed healthcare professional. We do not use your answer to these questions to diagnose a condition, and we do not pass your answer to advertising platforms, analytics tools, email marketing systems, or affiliate or treatment partners. We retain the minimum information necessary to display this message to you and do not use a disqualifying answer for any other purpose.

Please do not provide information that is not requested or necessary to use the Services.

Information collected automatically

When you use our website, we and our service providers may automatically collect limited technical information, such as:

• IP address
• Browser type and device type
• Operating system
• Pages viewed and links clicked
• Dates, times, and duration of visits
• Referral URLs
• Approximate location derived from IP address
• Information collected through cookies and similar technologies

We use this information to operate, secure, analyze, and improve the Services. We do not send individual quiz answers, inferred health information, or safety-screening outcomes to advertising, analytics, or tracking platforms (such as Meta, TikTok, or Google). Technical and behavioral data collected automatically, as described in this section, is limited to general website usage (for example, that a page was visited or a button was clicked) and does not include the content of your quiz responses.

2. How We Use Information

We may use personal information for the following purposes:

• To provide, operate, and maintain the Services
• To process your quiz responses
• To generate a personalized treatment recommendation and explain why the recommendation may fit your hair concerns, routine, and budget, where our safety screening does not indicate that a recommendation should be withheld
• To send your quiz results or recommendation
• To communicate with you about the Services, including responding to inquiries and providing service-related notices
• To send newsletters, offers, product information, and other marketing communications where permitted by law and consistent with your choices
• To understand how users interact with the Services and improve our website, assessment, recommendations, and content
• To detect, prevent, and address fraud, abuse, security incidents, and technical problems
• To comply with legal obligations and enforce our agreements
• To establish, exercise, or defend legal claims

We take reasonable steps to collect only the personal information necessary for these purposes and to keep it accurate and up to date.

Folliculate provides general informational matching services. Our recommendations are not medical advice, a diagnosis, or a substitute for advice from a licensed medical professional. Prescription treatments, where applicable, must be evaluated and decided by an appropriately licensed clinician. In some cases, based on your responses, we may determine that we cannot provide a recommendation and may instead encourage you to consult a licensed healthcare professional. We do not use this outcome to diagnose a condition or to determine your eligibility for medical care.

3. Treatment Recommendations and Automated Processing

We use your quiz responses, including your stated hair concerns, routine, preferences, and budget, to match you with treatment options that may be suitable for you, unless our safety screening indicates that we should not provide a recommendation.

The matching process may involve automated rules, scoring, or other software-based analysis. This process is designed to provide product and treatment information and does not make decisions about your eligibility for employment, credit, insurance, housing, education, healthcare coverage, or another similarly significant matter.

If applicable law gives you rights relating to automated decision-making or profiling, you may contact us using the details in the "Contact Us" section to ask questions about the process or exercise your rights.

4. Email Communications and Marketing

If you provide your email address, we may use it to:

• Deliver your quiz results or recommendation
• Respond to your requests
• Send service-related communications
• Send marketing communications, where permitted by law and where you have provided any consent required by law

We do not add flagged safety-screening answers, or the underlying quiz responses associated with them, to email marketing lists, automation sequences, or audience segments.

You may unsubscribe from marketing emails at any time by selecting the "unsubscribe" link in the email or contacting us at help@folliculate.com. Unsubscribing from marketing communications will not prevent us from sending non-promotional messages that are necessary to provide the Services, respond to your request, or comply with legal obligations.

We will maintain suppression or unsubscribe information as necessary to honor your request.

5. Legal Bases for Processing

Where data protection laws such as the EU General Data Protection Regulation or UK GDPR apply, we may process your personal information on one or more of the following legal bases:

• Consent: For certain marketing communications, non-essential cookies, or other processing where consent is required
• Performance of a contract or steps at your request: To provide quiz results, recommendations, and requested Services
• Legitimate interests: To operate, secure, analyze, and improve the Services, prevent misuse, and communicate with users where permitted by law
• Legal obligations: To comply with applicable law, regulatory requirements, legal process, or lawful requests
• Explicit consent for special category / sensitive health data (GDPR Article 9(2)(a)): To process quiz responses and related inferences that may reveal information about your health, sex life or sexual orientation, or other special category data, including responses used for safety screening

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing that occurred before withdrawal or processing that we may lawfully continue on another legal basis.

6. How We Share Information

We do not sell your personal information.

We may disclose personal information to the following categories of recipients:

Service providers

We may use vendors and contractors that process information on our behalf, such as providers of:

• Website hosting and infrastructure
• Email delivery and communication services
• Analytics and performance measurement
• Security, fraud prevention, and technical support
• Customer support
• Data storage and backup services

These providers are permitted to use personal information only as necessary to provide services to Folliculate or as otherwise permitted by law. Analytics and performance-measurement providers do not receive individual quiz answers or safety-screening outcomes.

Treatment and product partners

We may share relevant quiz responses, email information, or recommendation-related information with the following categories of partners only, and only when a recommendation is actually generated for you: (1) licensed telehealth providers or licensed clinicians, where applicable; (2) hair-treatment product manufacturers or sellers; and (3) fulfillment and shipping partners — to provide, facilitate, or explain a recommendation, direct you to a partner's service, or respond to your request.

The information shared will be limited to what is necessary for the relevant purpose. We do not share safety-screening answers, or the fact that a recommendation was withheld, with any partner. Folliculate will not share inferred health information with partners for the partner's own marketing purposes without your separate opt-in consent. A partner may process information under its own privacy policy when you visit its website, purchase a product, contact it, or otherwise interact with it directly.

Folliculate may receive a commission if you purchase certain products through links or referrals on our website. Any such commission does not change the price you pay or determine which option we recommend.

Legal and business disclosures

We may disclose information:

• When required by law, subpoena, court order, or legal process
• To protect the rights, property, or safety of Folliculate, our users, or others
• To investigate fraud, security issues, or violations of our terms
• In connection with a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction
• With your direction or consent

We do not share your personal information with third parties for their own direct marketing purposes unless permitted by law and authorized by you where required.

7. Cookies and Similar Technologies

We may use cookies, pixels, tags, local storage, and similar technologies to:

• Keep the website functioning
• Remember preferences
• Understand website traffic and usage
• Measure the effectiveness of content and campaigns
• Protect the website from fraud and abuse
• Improve the Services

We configure our advertising and analytics tags so that quiz answers, inferred health information, and safety-screening outcomes are never included as event parameters, audience criteria, or conversion data sent to any advertising or analytics platform. Only generic, non-health-related interactions (such as a page view or a general "quiz completed" event without answer content) may be shared with these tools.

Some cookies are strictly necessary for the operation of the website. Other cookies, including certain analytics or advertising-related technologies, may require your consent depending on applicable law.

You can manage cookies through your browser settings and, where available, our cookie preference tool. Disabling certain cookies may affect the functionality of the Services. Where required by law, we will request consent before placing or accessing non-essential cookies and will provide a mechanism to withdraw that consent.

8. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain business and legal records, resolve disputes, enforce agreements, and comply with legal obligations.

Unless a longer period is required or permitted by law:

• Quiz responses and related recommendation information are generally retained for up to 24 months after your last interaction with the Services
• Safety-screening answers that result in a withheld recommendation are retained only as long as necessary to display the relevant message to you, and are not retained in a form linked to your email address or other identifiers beyond that purpose
• Email addresses used for marketing are retained until you unsubscribe or we otherwise determine that the information is no longer needed
• Unsubscribe and suppression records may be retained as necessary to honor your opt-out request

We may retain information in anonymized or aggregated form for longer periods where it can no longer reasonably identify you.

9. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

However, no method of transmission or storage is completely secure. We cannot guarantee the absolute security of your information. You are responsible for using a secure email account and for notifying us if you believe your interaction with the Services has been compromised.

10. International Data Transfers

Folliculate and our service providers may process and store personal information in countries other than the country where you live. Those countries may have data protection laws that differ from the laws in your jurisdiction.

Where required by law, we use appropriate safeguards for international transfers, which may include:

• Transfers to countries recognized as providing an adequate level of data protection
• Standard Contractual Clauses approved or recognized by the relevant data protection authority
• The UK International Data Transfer Agreement or UK Addendum, where applicable
• The EU-U.S. Data Privacy Framework or another lawful transfer mechanism, where applicable
• Additional contractual, technical, or organizational safeguards

You may contact us using the details below for more information about the safeguards applicable to your personal information.

11. Your Privacy Rights

Depending on where you live and subject to applicable legal exceptions, you may have the right to:

• Request access to personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information
• Request restriction of certain processing
• Request a copy of information in a portable format
• Object to processing based on legitimate interests or to direct marketing
• Withdraw consent where processing is based on consent
• Lodge a complaint with a data protection authority

To exercise a right, contact us at help@folliculate.com. We may need to verify your identity before completing a request. We will not discriminate against you for exercising privacy rights. If we deny your request, we will explain the reason where required by law and provide any available appeal process.

12. California Privacy Rights

If you are a California resident, the California Consumer Privacy Act, as amended, may provide you with additional rights, subject to applicable exceptions. These may include the right to:

• Know the categories and specific pieces of personal information we collect, use, disclose, or otherwise process
• Know the categories of sources from which personal information is collected
• Know the business or commercial purposes for collecting or disclosing personal information
• Know the categories of third parties to whom personal information is disclosed
• Correct inaccurate personal information
• Request deletion of personal information
• Opt out of the sale or sharing of personal information
• Limit certain uses and disclosures of sensitive personal information, where applicable
• Receive equal treatment for exercising privacy rights

Folliculate does not sell personal information and does not share personal information for cross-context behavioral advertising as described by California law. Accordingly, there is currently no sale or sharing for which you need to opt out. If our practices change, we will update this Privacy Policy and provide any legally required opt-out mechanism.

Sensitive personal information: We use and disclose sensitive personal information (such as information that may reveal hair loss, pregnancy, or other health-related inferences) only as necessary to perform the Services, including to determine whether it is appropriate to provide a recommendation and to direct you to a partner at your request. If you are a California resident, you may request to limit our use and disclosure of sensitive personal information to what is necessary to perform the Services by contacting us at help@folliculate.com.

To submit a California privacy request, contact us at help@folliculate.com. You may submit a request yourself or through an authorized agent. We may request information reasonably necessary to verify your identity and authority to make the request. We will not use personal information collected for verification for any purpose other than fulfilling the request, except as permitted by law.

13. State Health Privacy Laws

Certain U.S. state laws provide additional rights for "consumer health data," including laws such as Washington's My Health My Data Act and similar laws in Connecticut and Nevada. In our Services, "consumer health data" may include information about hair loss or thinning, pregnancy, or other circumstances disclosed through the quiz, and related information we infer from your quiz responses.

Folliculate does not sell consumer health data. We collect consumer health data only where you have provided consent through a clear, affirmative, opt-in action taken before submitting the quiz, or where collection is strictly necessary to provide a Service you have requested (for example, determining whether we can safely generate a recommendation for you). We do not use consumer health data for advertising, and we do not share it with advertising networks, data brokers, or partners for their own purposes.

You may withdraw your consent to our collection and use of consumer health data at any time by contacting us at help@folliculate.com and requesting that we stop processing consumer health data. You may also request deletion of consumer health data specifically by contacting us at help@folliculate.com and specifying that your request relates to consumer health data collected through the quiz; we may need to verify your identity before completing your request.

14. Children's Privacy

The Services are not directed to children under 13, and Folliculate does not knowingly collect personal information from children under 13.

If you are under the age required to consent to data processing in your jurisdiction, do not use the Services or provide personal information without the involvement and consent of a parent or legal guardian where required.

If we learn that we have collected personal information from a child in violation of applicable law, we will take reasonable steps to delete it. A parent or legal guardian who believes that a child has provided us with personal information may contact us at help@folliculate.com.

15. Third-Party Websites and Services

The Services may contain links to websites, products, or services operated by third parties, including treatment or product partners. This Privacy Policy does not apply to those third-party websites or services.

We encourage you to review the privacy policies of any third party before providing information or completing a purchase. Folliculate is not responsible for the privacy, security, or content practices of third parties.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or Services.

When we make changes, we will update the effective date at the top of this Privacy Policy. If a change is material, we will provide additional notice where required by law. Your continued use of the Services after an updated Privacy Policy becomes effective means that you acknowledge the revised policy.

17. Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy or Folliculate's privacy practices, contact us at:

Folliculate
Privacy Contact: help@folliculate.com
Website: https://folliculate.com/