This Privacy Notice for DevCore Studio LLC(“we,” “us,” or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:
- Download and use our mobile application (Regrowl: Hair Growth & Scanner), or any other application of ours that links to this Privacy Notice
- Use Regrowl. An iOS app for tracking and caring for your hair. Regrowl builds a personalized daily routine from your goals and hair profile, tracks your progress with photos over time, analyzes your progress photos to estimate visible hair-loss stage, and scans haircare product labels to score their ingredients. Regrowl is not a medical device and does not diagnose, treat, or provide medical advice.
- Engage with us in other related ways, including any marketing or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@regrowl.app.
Summary of key points
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using the table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? Yes. To build and track your routine, we process health-related information — your hair-loss self-report (such as visible stage, family history, current treatments or medications, adherence, and how long you have experienced hair loss), your pregnancy or breastfeeding status, and the scalp and hair photos you submit. We process this information only with your consent, to provide the routine and progress analysis you ask for — never for advertising or profiling. Learn more about sensitive information we process.
Do we collect any information from third parties? We do not buy or gather personal information from data brokers, marketing partners, social media platforms, or public databases. The only outside inputs are the sign-in provider you choose (Apple or Google) when you create your account, and product data from a barcode lookup service, which is product information and not personal information about you. Learn more about information collected from other sources.
How do we process your information? We process your information to provide and personalize your hair-care routine, analyze the progress photos you submit, identify products you scan, manage your subscription and account, keep the Services secure, and respond to your support requests. We do not use your information for advertising. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Table of contents
- What information do we collect?
- How do we process your information?
- When and with whom do we share your personal information?
- Do we offer artificial intelligence-based products?
- How do we handle your logins?
- How long do we keep your information?
- How do we keep your information safe?
- What are your privacy rights?
- Controls for do-not-track features
- Do United States residents have specific privacy rights?
- Do other regions have specific privacy rights?
- Your photos and how they are stored
- Operational data retention
- Do we make updates to this notice?
- How can you contact us about this notice?
- How can you review, update, or delete the data we collect from you?
1. What information do we collect?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- name (from your Apple or Google sign-in, including an Apple Hide My Email relay address)
- email address
- authentication data (your account identifier / UUID and a subscription app user ID)
- age
- gender
- onboarding and profile answers, such as your hair goal and hair-loss stage
- the products, medications, and routine items you choose to log
Sensitive Information. With your consent, and only to provide the routine and progress analysis you ask for, we process the following categories of sensitive information:
- Health self-report— your visible or reported hair-loss stage, family history of hair loss, how long you have experienced it, current treatments or medications, and treatment adherence
- Pregnancy or breastfeeding status, which you may provide so we can tailor product and routine suggestions
- Scalp and hair photos (baseline and checkpoint images), which are health-related imagery
We never use this sensitive information for advertising, and we do not use or disclose it to infer characteristics about you.
Payment Data.We do not collect or receive your full payment card details. All purchases are made through Apple's in-app purchase system — Apple processes your payment as merchant of record — and we receive only your subscription status and entitlements (via RevenueCat).
All purchases are processed by Apple through in-app purchase. Apple is the merchant of record. We never receive or store your full payment card details, billing address, or bank information. We receive only your subscription and entitlement status. Subscription management, cancellations, and refunds are handled through your Apple ID settings.
Sign-in Data. You create your account using Sign in with Apple or Sign in with Google. When you do, the provider shares your name and email address (or, with Apple, a Hide My Email relay address) and an authentication token so we can set up and secure your account. We do not receive your social media contacts, friends list, or public profile. See “How do we handle your logins?” below.
Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
- Mobile Device Access. We may request permission to use certain features of your device, including the camera (to take hair scans and product-label photos), Apple Health / HealthKit (read-only, on your device, to see medications and doses you log there), and iCloud / CloudKit (your own private iCloud, where your daily progress photos are stored). You can grant or revoke any of these permissions at any time in your device settings. We do not request access to your location, microphone, contacts, or your general photo library.
- Usage and Diagnostic Data.When you scan a product or run a hair analysis, our backend records limited diagnostic and usage information linked to your account — such as which feature you used, timestamps, and technical metadata about the request (including token and cost data for AI calls). We use this only for internal analytics, troubleshooting, and to keep the Services secure. We do not embed any advertising, analytics, attribution, or crash-reporting SDKs, and we do not use device advertising identifiers (such as Apple's IDFA) or App Tracking Transparency.
- Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: When you use the app, our backend records limited technical information about the requests you make, so we can run and secure the Services.
When you use features that call our servers — such as running a hair analysis or scanning a product — our backend records service-related, diagnostic, and usage information tied to your account. This does not include browsing history across other apps or websites, precise location, or any advertising identifier. We use this information to maintain the security and operation of the Services and for our internal analytics and troubleshooting.
The information we record includes:
- Log and Usage Data.Diagnostic, usage, and performance information our servers record when you use the Services — such as the date and time of a request, which feature you used, and error reports. Security and rate-limiting logs are retained only briefly (see “Operational data retention”).
- AI Call Metadata. When you run an AI-powered scan or analysis, we record technical metadata about that call, including token and cost data, linked to your account for internal analytics and cost accounting.
Google API
Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
Information collected from other sources
In Short: We do not buy or gather personal information from data brokers, marketing partners, social media, or public databases. The only outside inputs are your sign-in provider and a product-lookup service.
We do not obtain information about you from public databases, data brokers, joint marketing partners, affiliate programs, social media platforms, or other outside sources for advertising or any other purpose. The only information that reaches us from outside sources is:
- Your sign-in provider. When you create your account, Apple or Google (whichever you choose) provides your name, email address (or an Apple Hide My Email relay address), and an authentication token, as described above.
- Product data from a barcode lookup. When you scan a product, we send the barcode to a product-lookup service (Go-UPC) and receive back productinformation — such as the product name and brand. This is data about the product, not personal information about you; no personal data or photos are sent to that service.
2. How do we process your information?
In Short: We process your information to provide and personalize your routine, analyze the photos you submit, identify products you scan, manage your subscription and account, keep the Services secure, and respond to support requests. We do not use your information for advertising.
We process your personal information for the following purposes:
- To provide and personalize your hair-care routine. We process your onboarding answers and health self-report to build and adjust a routine tailored to your goals and hair profile.
- To analyze your progress photos. We process the baseline and checkpoint scalp/hair photos you submit to estimate your visible hair-loss stage and produce progress comparisons over time.
- To identify products you scan. We process barcodes and product-label photos to look up products and score their ingredients.
- To create and manage your account and authentication. We process your information so you can create, log in to, and keep your account in working order.
- To manage your subscription. We process your subscription and entitlement status to give you access to paid features.
- To keep the Services secure. We process limited usage and diagnostic data to protect the Services, prevent abuse, and enforce rate limits.
- To respond to your support requests. We process your information to answer your questions and resolve issues you have with the Services.
- To comply with our legal obligations. We may process your information to comply with the law, respond to legal requests, and establish, exercise, or defend legal rights.
3. When and with whom do we share your personal information?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
We share personal information only with the following service providers (sub-processors), and only the data each one needs to do its job:
- Apple — provides Sign in with Apple (name and email or relay address), processes in-app purchases as merchant of record, and hosts your own private iCloud (CloudKit) where your daily progress photos live. Apple Health data is read on your device only and is never sent to Apple by us.
- Google Sign-In— if you choose it to sign in, provides your email, name, and authentication tokens.
- Google (Gemini API, paid tier)— receives your product-label photos and your baseline/checkpoint scalp and hair photos, together with our prompts, to read ingredients and assess your hair. Under Google's paid-tier terms, Google does not use this submitted content to train its models.
- Supabase(hosted in the United States) — provides our database, authentication, and encrypted storage for your account, profile, health self-report, hair-analysis results, and opt-in checkpoint photos.
- RevenueCat— manages your subscription and entitlements using an app user ID and your Apple purchase receipts.
- Go-UPC— provides barcode-to-product lookups. It receives the barcode only; no personal data or photos are sent to it.
International data transfers.Some of these providers — in particular Google (Gemini) and Supabase — process data on servers located in the United States. If you are located outside the United States, your information may be transferred to, stored in, and processed there. Where required, we rely on appropriate safeguards for these transfers, such as the European Commission's Standard Contractual Clauses (SCCs).
We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We also may need to share your personal information in the following situation:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
4. Do we offer artificial intelligence-based products?
In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.
As part of our Services, we offer features powered by artificial intelligence (collectively, “AI Products”). We use these tools to (a) read the ingredient labels on products you scan and (b) assess the baseline and checkpoint hair photos you submit to estimate your visible hair-loss stage.
Use of AI Technologies
We provide the AI Products through Google's Gemini API (paid tier). When you scan a product or run a hair analysis, the relevant photo and our prompt are sent to Google for processing, and the result is returned to the app. Under Google's paid-tier terms, Google does notuse the content you submit to train its models. You must not use the AI Products in any way that violates Google's terms or policies.
Our AI Products
Our AI Products are designed for the following functions:
- Reading and scoring the ingredient labels on products you scan
- Assessing your baseline and checkpoint hair photos to estimate visible hair-loss stage and progress
These results are estimates, not a diagnosis
The output of our AI Products is an informational estimate to help you track your routine. It is not a medical diagnosis, and Regrowl is not a medical device. Always consult a qualified healthcare professional before starting, stopping, or changing any treatment.
How to Opt Out
Running an AI analysis is something you choose to do. You can decline to submit photos, and you can turn off optional storage of your checkpoint photos in the app under Settings → Data & privacy. To otherwise control how your data is used, you can:
- Update your account and settings in the app
- Contact us using the contact information provided
5. How do we handle your logins?
In Short: You sign in with Apple or Google, and we receive only your name, email, and an authentication token.
You create and access your account using Sign in with Apple or Sign in with Google. When you do, we receive your name, your email address (or, with Apple, a Hide My Email relay address), and an authentication token that confirms your identity. We do not receive your contacts, friends list, or public profile.
We use this information only for the purposes described in this Privacy Notice — setting up and securing your account. Please note that we do not control, and are not responsible for, how Apple or Google otherwise handle your information. We recommend you review their privacy notices to understand how they process your data and how you can set your privacy preferences.
6. How long do we keep your information?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.
We keep your account, profile, health self-report, subscription status, hair-analysis results, and any opt-in checkpoint photos for as long as your account is active, unless a longer retention period is required or permitted by law (such as tax or accounting requirements).
You can delete your account at any time from within the app. When you do, we remove your server-side data from our active databases. Your daily progress photosare never stored on our servers in the first place — they live on your device and in your own private iCloud, so you control them directly through your device and iCloud settings.
You can also submit a data subject access request to review or delete your information. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if that is not immediately possible (for example, because it is in a backup archive), we will securely store it and isolate it from further processing until deletion is possible.
7. How do we keep your information safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
8. What are your privacy rights?
In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “How can you contact us about this notice?” below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Apple Health (HealthKit)
If you grant permission, Regrowl reads certain medication and dose entries from Apple Health (HealthKit) on your device only. This data is used on-device to help you log your routine; it is read-only (we never write to Apple Health), it is never uploaded to our servers, and it is never used for advertising. You can revoke this access at any time in iOS Settings → Health.
If you have questions or comments about your privacy rights, you may email us at privacy@regrowl.app.
9. Controls for do-not-track features
We do not track you across other apps or websites. Regrowl includes noadvertising, analytics, attribution, or crash-reporting SDKs, and it does not use device advertising identifiers (such as Apple's IDFA) or App Tracking Transparency (ATT). Because we do not engage in cross-app or cross-site tracking, our answer to whether we track you for advertising is simply No.
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature you can activate to signal your privacy preference. Because we do not track your activity across apps or sites in the first place, there is nothing for a DNT signal to limit. California law requires us to let you know how we respond to browser DNT signals; since there is no uniform standard for them and we do not track you across sites, we do not need to respond to them.
10. Do United States residents have specific privacy rights?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect
The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section “What information do we collect?”
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Your name, email address, and a unique account identifier (UUID). We do not collect your postal address, phone number, or Internet Protocol (IP) address as part of your profile. | YES |
| B. Personal information as defined in the California Customer Records statute | Name and subscription/financial status (we do not collect your education, employment history, or payment card details) | YES |
| C. Protected classification characteristics under state or federal law | Race and ethnicity, national origin, religion, marital status, and similar characteristics (we do collect age and gender as part of your profile, but not race, ethnicity, or other protected-class data) | NO |
| D. Commercial information | Subscription and purchase status | YES |
| E. Biometric information | Fingerprints, voiceprints, or facial-recognition templates used to identify you | NO |
| F. Internet or other similar network activity | In-app usage and diagnostic data (which features you use and related technical metadata). We do not collect your browsing history across other apps or websites. | YES |
| G. Geolocation data | Precise or coarse device location | NO |
| H. Audio, electronic, sensory, or similar information | The scalp/hair and product-label photos you choose to submit. We do not collect audio, video, or call recordings. | YES |
| I. Professional or employment-related information | Job title, work history, and professional qualifications | NO |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from collected personal information | Profiles or summaries about your preferences or characteristics. We do not build advertising or behavioral profiles about you. | NO |
| L. Sensitive personal information | Health information (your hair-loss and treatment self-report and pregnancy/breastfeeding status) and the scalp/hair photos you submit | YES |
We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
- Category A — As long as the user has an account with us
- Category B — As long as the user has an account with us
- Category D — As long as the user has an account with us
- Category F — As long as the user has an account with us
- Category H — As long as the user has an account with us
- Category L — As long as the user has an account with us
Sources of Personal Information
Learn more about the sources of personal information we collect in “What information do we collect?”
How We Use and Share Personal Information
Learn more about how we use your personal information in the section “How do we process your information?”
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section “When and with whom do we share your personal information?”
We may use your personal information for our own business purposes, such as internal research and technological development. This is not considered to be “selling” of your personal information.
We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We have not sold or shared any personal information in the preceding twelve (12) months. We have disclosed the following categories of personal information to our service providers (sub-processors) for the business purposes described in this notice in the preceding twelve (12) months:
- Category A. Identifiers
- Category B. Personal information as defined in the California Customer Records law
- Category D. Commercial information
- Category F. Internet or other electronic network activity information
- Category H. Audio, electronic, visual, and similar information
- Category L. Sensitive personal information
You have the right to limit the use and disclosure of your sensitive personal information. We only use your sensitive personal information to provide the routine and analysis you request, and never to infer characteristics about you or for advertising.
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “When and with whom do we share your personal information?”
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
- Right to know whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)
Depending upon the state where you live, you may also have the following rights:
- Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
- Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
- Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
- Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
- Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
- Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
- Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)
How to Exercise Your Rights
To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at privacy@regrowl.app, or by referring to the contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@regrowl.app. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
California “Shine The Light” Law
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “How can you contact us about this notice?”
11. Do other regions have specific privacy rights?
In Short: You may have additional rights based on the country you reside in.
Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).
This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:
- offer you the products or services that you want
- respond to or help with your requests
- manage your account with us
- confirm your identity and protect your account
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section “How can you review, update, or delete the data we collect from you?”
If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.
Republic of South Africa
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section “How can you review, update, or delete the data we collect from you?”
If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:
The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za
12. Your photos and how they are stored
Regrowl handles photos in three different ways, depending on what they are for.
Daily progress photos remain on your device and, if you use iCloud, in your own private iCloud (CloudKit) container. We cannot access these photos and they are never uploaded to our servers.
Baseline and checkpoint hair photosthat you submit for analysis are sent to Google (via the Gemini API, paid tier) to produce your hair assessment. A limited set of these checkpoint reference images may also be retained in our private, access-controlled backend — but only if you turn on Photo storage under Settings → Data & privacy. That setting is off by default and can be switched off at any time. These photos are never shown to other users.
Product-label photos you submit are sent to Google (via the Gemini API) to read the ingredients, and may be added to our shared product catalog as reference data visible to other users. Your progress photos, checkpoint photos, and hair-analysis results are never shared with other users.
13. Operational data retention
Some records follow different schedules than your account data. Security and rate-limiting logs are automatically deleted after approximately two days. Anonymized usage and cost records, which contain no information identifying you, are retained after account deletion for accounting purposes.
14. Do we make updates to this notice?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
15. How can you contact us about this notice?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at privacy@regrowl.app, or contact us by post at:
DevCore Studio LLC
Data Protection Officer
2108 N St Ste N
Sacramento, CA 95816
United States
16. How can you review, update, or delete the data we collect from you?
Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.