01Who we are
hairtrack (the app and hairtrack.ai) is run by Rate Me Inc., a Delaware corporation ("we", "us"). For the purposes of EU and UK data protection law, Rate Me Inc. is the controller of the personal data described here.
Questions, requests and complaints go to support@ratewithai.co.
02What we collect
Only what the measurement needs, plus what it takes to run the app. In full:
- Photographs
- The views of your head you take in the app, and any reference photos you add. Faces are pixellated on your phone before upload. One exception: a small unblurred crop around the eyes from the front photo, used only to measure the distance between your pupils so we can turn pixels into millimetres.
- Measurements
- What we derive from the photos: zone readings, pattern and Norwood stage, hairline position, donor estimates, and how each changes over time.
- What you tell us
- Age, sex, family history, your main concern, treatments and medication you log, and any earlier procedure.
- Journey
- If you use the transplant companion: surgery date, clinic name and phone number, technique, graft count, appointments, care items and check-ins.
- Account
- An anonymous ID created when you first open the app. If you sign in, your email address or your Apple or Google sign-in ID.
- Purchases
- What you bought, when, and whether a plan is active. Apple or Google takes the payment; we never see your card.
- Device and usage
- App events (which screens and features are used), crash reports, device model, operating system and app version, and a push token if you allow notifications.
- Location
- Only when you search for clinics near you, and only the coordinates of that search.
- Referrals
- Your referral code, who joined with it, and the points it earned.
- Website
- Your email if you join the waitlist, and aggregate visit counts (see "The website").
We do not collect your contacts, your photo library (beyond photos you pick), or anything from other apps.
03What we do with it, and on what basis
Each use, with the legal basis EU and UK law asks us to name:
- Measure your scans and build your reports
- To provide the service you asked for (contract). Because the photos and readings are health information, and the eye crop and head landmarks can count as biometric information, we also rely on your explicit consent, given in the app before your first scan.
- Keep your history so later scans can be compared
- Contract, and the same explicit consent.
- Run Journey, reminders and notifications
- Contract. Notifications only if you allow them on your phone.
- Sell and restore purchases
- Contract, and our legal duty to keep financial records.
- Improve the measurement models
- Only with your opt-in, which is off unless you turn it on. It covers cropped scalp regions, never your face. Turning it off stops any future use.
- Fix crashes, keep the service secure, prevent abuse
- Our legitimate interest in a working, safe service.
- Understand which features are used
- Our legitimate interest in improving the app. Never joined to your photos, and never used for advertising.
- Email you about the launch
- Your consent, when you join the waitlist. One email when we open.
We do not sell personal information, we do not share it for cross-context behavioural advertising, and we do not use it to make decisions about you that have legal or similarly significant effects.
04Your face, and biometric information
Some US state laws, including Illinois (BIPA), Texas and Washington, give special protection to biometric identifiers. This is our written notice and retention policy under them.
- What touches your face. On your phone, face detection finds faces so they can be pixellated before upload. On our servers, the measurement models locate points on your head (such as the hairline and ears) to place each zone, and the eye-region crop gives your pupil distance for scale.
- What we never do. We do not create or keep a faceprint or face template, we never use any of this to identify you, and we never sell, lease, trade or otherwise profit from it.
- Who else sees it. Only the providers who run the measurement for us (see "Who else handles it"), or anyone the law compels us to give it to.
- Consent. You give it in the app before your first scan, and you can withdraw it by deleting your photos or your account.
- Retention and destruction. It is deleted with your photographs: 24 months after you last use hairtrack, or as soon as you delete your photos or your account, and in no case later than three years after your last interaction with us.
05Health data
Under the EU and UK GDPR, information about hair loss, treatment and surgery is "special category" health data, which is why we ask for explicit consent. Under the Washington My Health My Data Act, Nevada and Connecticut law, the same information is "consumer health data".
We collect it from you and from the photos you take, for the purposes above and nothing else. We share it only with the providers listed below, who act on our instructions, or with someone you choose to send a report to. We do not sell it, and we do not use geofencing around any health facility. You can see it, export it, delete it or withdraw consent at any time (see "Your rights").
06Who else handles it
Providers that run parts of hairtrack for us. Each is bound by contract to use the data only to provide its service to us:
- Supabase
- Database, encrypted photo storage, sign-in and server functions.
- RunPod
- The GPU servers that run our measurement models on your photos.
- Google Firebase
- In-app usage analytics, crash reports and remote settings.
- RevenueCat
- Records of purchases and subscriptions.
- Apple and Google
- The app stores, payments, refunds, push notifications, and Sign in with Apple or Google.
- Google Places
- Finding clinics near a location you search from.
- Twilio SendGrid
- Delivering sign-in emails.
- Vercel
- Hosting the website.
- Google Analytics
- Counting website visits, without cookies.
Beyond them, your data goes only where you send it — a share link, or a report you give a clinic — or where the law requires it, or to a company that takes over hairtrack, which would be bound by this policy.
07Share links
You choose how long a link lasts: 7 days, 30 days, or until you switch it off. Your photos and your name are left out unless you choose to include them. Anyone who has the link can open it while it is live, so send it only to people you mean to. You can revoke a link from the app at any time.
08How long we keep it
- Original photos
- Encrypted. Kept while you use hairtrack, and deleted automatically 24 months after you last open the app.
- Measurements, reports, Journey
- Kept while you have an account, so your trend stays intact.
- Purchase records
- As long as tax and accounting law requires.
- Crash reports and usage analytics
- No more than 14 months.
- Waitlist email
- Until you unsubscribe or ask us to remove it.
Deleting your account removes your photographs, then every record tied to you, straight away. Copies in our providers’ encrypted backups age out within 30 days.
09Security
Data is encrypted in transit and at rest, access is limited to the people who need it to run the service, and apart from the eye crop, the faces in your photos never reach us unblurred. No system is perfectly secure; if a breach affects your data, we will tell you and the regulators as the law requires.
10Where it is processed
Rate Me Inc. is a US company, and our providers process data in the United States and other countries. When data leaves the EU, the UK or Switzerland, we rely on the European Commission’s Standard Contractual Clauses, the UK addendum to them, or a provider’s certification under the Data Privacy Framework.
11Your rights
From the app’s Privacy and data screen (in the menu), without asking anyone: download your readings and photographs, delete your photos and keep your measurements, or delete your account and everything in it.
By writing to support@ratewithai.co, wherever you live:
- see what we hold about you, and get a copy
- correct anything that is wrong
- have it erased
- restrict or object to how we use it
- withdraw a consent you gave, without affecting what was done before
EU and UK. You can also complain to your data protection authority — in the UK, the Information Commissioner’s Office.
California and other US states. You have the right to know, access, correct and delete, and to opt out of sale, sharing and targeted advertising — we do none of those. We use sensitive information only to provide the service and, if you opt in, to improve the models. You can use an authorised agent, we will not treat you differently for exercising any right, and if we turn a request down you can appeal by replying to our answer.
We verify requests against the account they concern and answer within 30 days, or tell you why we need longer where the law allows it.
12Age
hairtrack is for adults. You must be 18 or older to use it, and we do not knowingly collect data from anyone younger. If we learn that we have, we delete it.
13The website
hairtrack.ai uses Google Analytics with every consent type set to denied, so it sets no cookies and cannot follow you between sites; what we see is aggregate — how many visits, which pages, roughly where from. The only cookies the site sets are the ones that keep you signed in, if you sign in.
14Changes
When this policy changes, the date at the top changes with it. If a change affects how we use data you have already given us, we will tell you in the app before it applies.