This privacy policy applies to the iCalvo app (hereby referred to as "Application") for mobile devices that was created by David Ariño (hereby referred to as "Service Provider") as a Freemium service. This service is intended for use "AS IS".

Information Collection and Use

The Application collects information when you download and use it. This information may include information such as

• Your device's Internet Protocol address (e.g. IP address)
• The pages of the Application that you visit, the time and date of your visit, the time spent on those pages
• The time spent on the Application
• The operating system you use on your mobile device

The Application does not gather precise information about the location of your mobile device.

The Application uses Artificial Intelligence (AI) technologies to enhance user experience and provide certain features. The AI components may process user data to deliver personalized content, recommendations, or automated functionalities. All AI processing is performed in accordance with this privacy policy and applicable laws. If you have questions about the AI features or data processing, please contact the Service Provider.

The Service Provider may use the information you provided to contact you from time to time to provide you with important information, required notices and marketing promotions.

For a better experience, while using the Application, the Service Provider may require you to provide us with certain personally identifiable information, including but not limited to Email address, Name, Photos, Hair health data, Medication information, Diary entries. The information that the Service Provider request will be retained by them and used as described in this privacy policy.

Third Party Access

Only aggregated, anonymized data is periodically transmitted to external services to aid the Service Provider in improving the Application and their service. The Service Provider may share your information with third parties in the ways that are described in this privacy statement.

The Service Provider may disclose User Provided and Automatically Collected Information:

• as required by law, such as to comply with a subpoena, or similar legal process;
• when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• with their trusted services providers who work on their behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
   

Use of Artificial Intelligence and Data Sharing with Third Parties

Features that do NOT use external AI: The Hair Analyzer (Hair Scanner) feature performs all processing locally on the user's device. No photos, images, or personal data are sent to any external server for this functionality. The analysis is generated using local algorithms based on the selected Norwood level and the user profile stored on the device.

Features that use external AI: The "Dr. Capilo" feature (hair health conversational assistant) uses an external artificial intelligence service provided by Rork AI to generate personalized responses.

Data collected and sent to Rork AI:

• User's hair profile (hair type, scalp condition, Norwood scale level)
• Active medications and treatment adherence data
• Hair diary entries
• Norwood analysis history
• Messages written by the user in the Dr. Capilo chat

Data that is NOT sent:

• Photos or images from the hair scanner
• Payment or billing data
• Contact information (email, phone number)

How data is collected: Data is collected directly from the user's interaction with the app (profile completed during registration, manual diary entries, medication selection, and messages written in the chat).

Purpose of data use: Data is used exclusively to generate personalized hair health responses within the Dr. Capilo chat. It is not used for advertising, marketing, nor sold to third parties.

Data protection by the AI service:

• Data is transmitted via encrypted connection (HTTPS)
• Data is not permanently stored on Rork AI servers
• Rork AI processes data solely to generate the requested response
• Rork AI does not share user data with additional third parties

User consent: Before using Dr. Capilo for the first time, the app displays an explicit consent screen informing the user what data is sent, who it is sent to, and how it is protected. The user must actively accept before any data is shared. This consent can be revoked at any time from Settings > AI Privacy within the app, which immediately disables data transmission to the AI service.

Third-Party Artificial Intelligence Use — Dr. Capilo

The "Dr. Capilo" feature in iCalvo uses an external artificial intelligence service provided by Rork AI (operated by Rork Inc., rork.com) to generate personalized hair health responses.

What personal data is sent to Rork AI?

• User's hair profile: hair type, scalp condition, head shape, and Norwood scale level
• Active registered medications: medication name, dosage, frequency, and adherence percentage
• Hair diary entries: mood, hair condition, products used, and notes
• History of registered Norwood levels (date and level)
• Hair report results: health scores, density, strength, hair cycle phases, miniaturization ratio, and projections
• Responses provided during the onboarding process (hair goals, habits)
• Text messages the user writes in the Dr. Capilo chat

How is this data collected? Data is voluntarily provided by the user when creating their profile, registering medications, writing in their hair diary, performing hair analyses, and sending messages in the Dr. Capilo chat.

Who is the data sent to? Data is sent exclusively to Rork AI (Rork Inc., https://rork.com), an external artificial intelligence service acting as a data processor under iCalvo's instructions.

For what purpose is data sent? Data is used solely to generate personalized responses from the Dr. Capilo virtual assistant. Rork AI does not use this data to train artificial intelligence models, does not store it permanently, and does not share it with third parties.

How is data protected?

• All communication is encrypted via HTTPS/TLS
• Sent data is used exclusively to generate the response to the query and is discarded after processing
• Rork AI provides an equivalent level of protection as described in this privacy policy

What data is NOT sent to third parties?

• Photographs captured with the hair scanner are processed exclusively on the user's device and are never sent to external servers
• The Norwood analysis, hair report, and head shape analysis are generated locally on the device
• Name, email address, and payment data are never shared with the artificial intelligence service

User Consent Before using the Dr. Capilo feature for the first time, the app requests explicit user consent through a screen detailing what data is sent, who it is sent to, and for what purpose. The user may revoke this consent at any time from Profile > AI Privacy, which will prevent any data from being sent to the external service.

Opt-Out Rights

You can stop all collection of information by the Application easily by uninstalling it. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

Data Retention Policy

The Service Provider will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. If you'd like them to delete User Provided Data that you have provided via the Application, please contact them at daviarino@gmail.com and they will respond in a reasonable time.

Children

The Service Provider does not use the Application to knowingly solicit data from or market to children under the age of 13.

The Service Provider does not knowingly collect personally identifiable information from children. The Service Provider encourages all children to never submit any personally identifiable information through the Application and/or Services. The Service Provider encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide personally identifiable information through the Application and/or Services without their permission. If you have reason to believe that a child has provided personally identifiable information to the Service Provider through the Application and/or Services, please contact the Service Provider (daviarino@gmail.com) so that they will be able to take the necessary actions. You must also be at least 16 years of age to consent to the processing of your personally identifiable information in your country (in some countries we may allow your parent or guardian to do so on your behalf).

Security

The Service Provider is concerned about safeguarding the confidentiality of your information. The Service Provider provides physical, electronic, and procedural safeguards to protect information the Service Provider processes and maintains.

Changes

This Privacy Policy may be updated from time to time for any reason. The Service Provider will notify you of any changes to the Privacy Policy by updating this page with the new Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

This privacy policy is effective as of 2026-02-28

Your Consent

By using the Application, you are consenting to the processing of your information as set forth in this Privacy Policy now and as amended by us.

Contact Us

If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at daviarino@gmail.com.