Privacy Policy

1.1 Basic Identifying Information

When you create an account or communicate with us, we collect information such as your name, email address, username, and any contact preferences you provide. This information helps us recognize you as a user, maintain your account, and communicate with you when needed.

1.2 Hair & Scalp Profile Information

Qutessy is designed to help users better understand and manage their hair and scalp health. For that reason, you may choose to provide information such as your hair texture, scalp type, color, concerns, goals, sensitivities, and any other information that you decide to submit.

This information is provided voluntarily and is used for general wellness and cosmetic recommendations, not for medical diagnosis or treatment.

This information is not used for biometric identification or medical diagnosis and is intended for general cosmetic and wellness purposes. We do not intend or design the Services to collect or process medical data, biometric identifiers, or other data classified as “special category” or “sensitive” under applicable laws.

We do not intentionally collect information relating to medical conditions, diagnoses, or treatments, and users should not submit such information.

1.3 Photos and Images

You may upload images or photos for us to analyze. We use these images solely for providing automated analysis, feedback, and recommendations within the services as described in this policy.

Qutessy may store uploaded images in your account history until you delete them through the app or request deletion via customer support. Deleted images are queued for removal from our systems within a reasonable period subject to technical, operational, and legal constraints, unless legally required, and residual copies may persist temporarily in secure backups before being permanently erased.

Uploaded images are sent to a third-party service provider for analysis. Such providers may include AI-based analysis services as described below.

By uploading photos or images, you consent to the processing of those images for analysis, feedback, and recommendation purposes as described in this Privacy Policy. You may request withdrawal of this consent at any time, subject to technical feasibility, legal obligations, and processing already completed prior to withdrawal.

Users are responsible for ensuring that uploaded images do not contain personal data of others, sensitive personal data, or content they do not have the legal right to share. Qutessy does not independently verify the legality or ownership of user-submitted content and disclaims responsibility for unlawful or unauthorized submissions by users, except where required by law.

1.4 Device Information and Usage Data

When you use our mobile application, we automatically receive certain information from your device. This can include your device type, operating system, app version, IP address, mobile advertising identifiers, error logs and any other technical information provided by the operating system. We also gather information about how you navigate the app, which features you use, and the links you click.

1.5 Affiliate Link Interaction Data

When you click an affiliate link within Qutessy, we may collect information that identifies the click and attributes it to a purchase or action on the affiliate partner’s website. We receive only limited reporting and do not receive full details of your purchases unless the partner provides aggregated insights.

2.1 Directly from You

You provide information when you create an account, complete a hair/scalp assessment, upload photos, submit a review, speak with customer support, or participate in social media interactions.

Users are responsible for ensuring that they do not submit personal data that they are not legally permitted to share or that falls outside the intended scope of the Services.

2.2 Automatically from Your Device

Qutessy uses platform APIs to passively collect information as you interact with the app. These information help us improve performance, diagnose issues, and understand how users engage with our content, and may change over time as permitted by law.

2.3 From Third-Party Partners

We may receive limited information from:

• app stores confirming your subscription
• analytics vendors
• affiliate platforms
• advertising partners

3.1 Legal Basis for Processing (EEA and UK Users)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data only when we have a valid legal basis to do so, including:

• Your consent, such as when you upload photos, provide hair or scalp profile information, or opt in to communications;
• Performance of a contract, where processing is necessary to provide the Services, manage your account, or process subscriptions;
• Legitimate interests, such as improving our Services, analytics, fraud prevention, and customer support, provided those interests are not overridden by your rights; and
• Legal obligations, where processing is required to comply with applicable laws and regulations.

3.2 Service Providers

We partner with vendors who assist with hosting, data storage, analytics, messaging, customer support, and subscription management. These service providers are required to handle personal information solely on our behalf.

We do not control the independent privacy practices of third-party service providers. Qutessy is not responsible for the acts or omissions of service providers acting independently or outside our documented instructions.

• Mixpanel: Mixpanel is an analytics service provided by Mixpanel, Inc. Mixpanel helps us to analyze and improve user experience.
• Firebase: Firebase is an application development platform provided by Google Inc. You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy. For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners' sites or apps webpage: https://policies.google.com/technologies/partner-sites.
• OpenAI: We use application programming interfaces (APIs) provided by OpenAI to process user inputs, including uploaded images, for analysis and recommendation purposes. Personal data is processed solely to provide the requested functionality and is processed in accordance with OpenAI’s applicable data usage policies. For more information about OpenAI’s data handling practices, please review OpenAI’s Privacy Policy at https://openai.com/policies/privacy.

3.3 Affiliate Partners

When you click on affiliate links, we may share very limited information—usually click identifiers or referral data—to attribute your interaction. We do not share sensitive profile information or photos with affiliate partners.

We do not sell, rent, or license personal data, and we do not knowingly process sensitive personal data beyond what users voluntarily provide for cosmetic and wellness-related functionality.

Affiliate partners may independently collect information through their own technologies once you leave the Services, which is governed by their respective privacy policies.

3.4 Legal Disclosures

Under certain circumstances, we may be required to disclose personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

We may disclose your personal data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

3.5 Business Transfers

If Qutessy undergoes a merger, acquisition, restructuring, or similar event, personal information may be transferred to the relevant parties as permitted by law.

3.6 With Your Consent

In any situation not covered above, we will disclose personal information only with your explicit permission.