Privacy Policy

Last updated 1 September 2026

Summary of key points

This Privacy Policy describes how Follisense Limited (“we”, “us” or “our”) accesses, collects, stores, uses and shares your personal information when you use FolliSense.

What personal information do we process? We process personal information depending on how you interact with us and the Services, the choices you make, and the features you use.

Do we process sensitive personal information? Yes. Photographs of your scalp and the symptoms you record concern your physical health, so we treat them as health data. We process them with your explicit consent.

Do we collect information from third parties? Only from Google, if you choose to sign in with a Google account.

How do we process your information? To provide, improve and administer our Services, to communicate with you, for security, and to comply with law. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? With the service providers who host and operate FolliSense on our behalf. We do not sell your personal information and we do not share it for advertising.

How do we keep your information safe? Photographs are held in a private store and served only through short-lived links. Access controls restrict every record to the account it belongs to. However, no electronic transmission or storage technology can be guaranteed to be completely secure.

What are your rights? Depending on where you are, applicable privacy law may give you rights over your personal information, including access, correction and deletion.

How do you exercise your rights? Email hello@follisense.com. We will consider and act upon any request in accordance with applicable data protection laws.

1. What information do we collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, when you participate in activities on the Services, or otherwise when you contact us. The personal information we collect may include the following:

Sensitive information

When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information: health data and account login information.

Photographs of your scalp and the symptoms you record concern your physical health. We ask for your explicit consent before processing them, we record the exact wording you were shown, and you can withdraw that consent at any time.

Google sign-in data

We offer you the option to register using your existing Google account. If you choose to register in this way, we will collect certain profile information from Google, as described in the section called “How do we handle your social logins?” below.

Application data

If you use our application, we also may collect the following information if you choose to provide us with access or permission:

This information is primarily needed to maintain the security and operation of our application, 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

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in section 5 below.

The information we collect includes:

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

The only third party we receive information from is Google, and only if you choose to sign in with a Google account.

If you register or sign in using your Google account, we receive your name, email address and account identifier from Google. Any personal information we receive depends on your Google account's privacy settings. Please note that Google's own use of your information is not governed by this Privacy Policy.

We do not buy personal information from data brokers, marketing partners or public databases, and we do not enrich your record from outside sources.

2. How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

3. What legal bases do we rely on to process your information?

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases:

4. When and with whom do we share your personal information?

We may share your data with third-party vendors, service providers, contractors or agents 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 organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The third parties we may share personal information with are as follows:

We also may need to share your personal information in the following situations:

We do not share your personal information with advertisers or advertising networks, and no other user of FolliSense can see your photographs or your record.

5. Do we use cookies and other tracking technologies?

We use a small number of cookies and similar technologies. Analytics only runs if you agree to it.

We may use cookies and similar tracking technologies to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also use a third-party analytics provider to understand how our Services are used. Analytics is off by default and is only enabled if you agree to it through our cookie banner. You can change your choice at any time.

We do not permit third parties to use tracking technologies on our Services for advertising, and we do not use tracking technologies to tailor advertisements to your interests.

Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. If you choose to do so, this could affect certain features or services of our Services.

6. Do we offer artificial intelligence-based products?

We offer two features powered by automated technologies. Neither of them interprets your health information.

As part of our Services, we offer features powered by artificial intelligence, machine learning or similar technologies (“AI Products”). The terms in this Privacy Policy govern your use of the AI Products within our Services.

We provide the AI Products through third-party service providers (“AI Service Providers”), including Google Cloud Vision and Groq. Your input, output and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products are designed for the following functions:

All personal information processed using our AI Products is handled in line with this Privacy Policy and our agreements with those third parties.

7. How do we handle your social logins?

Our Services offer you the ability to register and log in using your Google account details. Where you choose to do this, we will receive certain profile information from Google. This will usually include your name, email address and account identifier.

We will use the information we receive only for the purposes described in this Privacy Policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by Google. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences.

8. Is your information transferred internationally?

Follisense Limited operates from Kenya. Our service providers store and process personal information in the United States and in Ireland. Regardless of your location, please be aware that your information may be transferred to, stored by and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see “When and with whom do we share your personal information?” above), including facilities in Kenya, the United States, Ireland and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK) or Switzerland, then these countries may not necessarily have data protection laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

European Commission's Standard Contractual Clauses. We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request.

9. How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than the period of time in which you have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible, for example because your personal information has been stored in backup archives, then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. How do we keep your information safe?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. Your photographs are held in a private store, are not publicly reachable, and are served to you only through short-lived links. Access controls at the database level restrict every record to the account it belongs to.

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 unauthorised 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.

11. Do we collect information from minors?

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction, or that you are the parent or guardian of such a minor and consent to that minor's use of the Services. If we learn that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hello@follisense.com.

12. What are your privacy rights?

Depending on your state of residence in the US, or if you are in the European Economic Area (EEA), the United Kingdom (UK) or Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change or terminate your account at any time.

In some regions you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv) if applicable, to data portability, and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section “How can you contact us about this notice?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the UK and are unhappy with how we have handled your personal information, you can make a complaint directly to us. This is in addition to the rights you have under the UK General Data Protection Regulation and the Data Protection Act 2018.

How to contact us:

What happens after you complain:

If you are not happy with our final response, you can refer your complaint to the Information Commissioner's Office, the UK supervisory authority.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent in your account settings, or by contacting us using the contact details provided below. However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of reminders

You can turn off email reminders at any time by clicking the unsubscribe link in any reminder email, or in your account settings. Push notifications can be turned off in your device settings. We may still communicate with you to send service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can:

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 comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at hello@follisense.com.

13. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

14. Do United States residents have specific privacy rights?

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.

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 examples are illustrative of each category and do not describe the specific personal information we collect from you. For a full inventory, please refer to section 1 above.

CategoryExamplesCollected
A. IdentifiersContact details, such as real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address and account nameYES
B. Personal information as defined in the California Customer Records statuteName, contact information, education, employment, employment history and financial informationYES
C. Protected classification characteristics under state or federal lawGender, age, date of birth, race and ethnicity, national origin, marital status and other demographic dataYES
D. Commercial informationTransaction information, purchase history, financial details and payment informationYES
E. Biometric informationFingerprints and voiceprintsNO
F. Internet or other similar network activityBrowsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems and advertisementsYES
G. Geolocation dataDevice locationYES
H. Audio, electronic, sensory or similar informationImages and audio, video or call recordings created in connection with our business activitiesYES
I. Professional or employment-related informationBusiness contact details, job title, work history and professional qualificationsNO
J. Education informationStudent records and directory informationNO
K. Inferences drawn from collected personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristicsYES
L. Sensitive personal informationAccount login information and health dataYES

Category C is limited to gender. We do not collect race, ethnicity, national origin, date of birth or marital status. Category D is limited to the products you save or record using, and we do not collect payment card details. Category G is limited to an approximate location inferred from your IP address, and we do not collect precise or GPS location.

We only collect sensitive personal information as defined by applicable privacy laws, for the purposes allowed by law, or with your consent. 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 will use and retain each of the collected categories of personal information for as long as you have an account with us.

How we use and share personal information

We collect and share your personal information through the service providers listed in section 4, and through click redirects when you follow a product link to a third-party retailer such as Jumia or Amazon.

We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be selling of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months: Category A, Category B, Category C, Category D, Category F, Category G, Category H, Category K and Category L.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found in section 4 above.

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:

Depending upon the state where you live, you may also have the following rights:

How to exercise your rights

To exercise these rights, you can email us at hello@follisense.com, or refer to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised 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 authorised agent, we may need to collect additional information to verify your identity before processing your request, and the agent will need to provide 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 hello@follisense.com. 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 decision. 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 using the contact details provided below.

15. Kenya Data Protection Act, 2019

FolliSense is established in Kenya and processes personal data in accordance with the Data Protection Act, 2019. Users in Kenya have the right to be informed of the use of their personal data, to access their personal data, to object to processing, to correction of false or misleading data, and to deletion. Complaints may be made to the Office of the Data Protection Commissioner.

16. Automated processing and what this service does not do

FolliSense is a wellness and self-care tool. It does not diagnose, treat or prevent any medical condition and does not provide medical advice.

Automated processing is limited to two things. An automated image check confirms that an uploaded photograph shows a scalp before it is accepted; it does not analyse or interpret the image. An automated chat assistant answers general hair care questions; it does not read your photographs or health records.

Product suggestions are based on self-reported hair profile and stated goals, never on reported symptoms. No automated decision producing legal or similarly significant effects is made about any user.

17. Do we make updates to this notice?

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated date at the top of this Privacy Policy. If we make material changes, 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 Policy frequently to be informed of how we are protecting your information.

18. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at hello@follisense.com or contact us by post at:

Follisense Limited
Nairobi
Kenya

19. 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, 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.

You can delete your account, and everything in it, from within the app at any time. To request to review, update or delete your personal information in any other way, email hello@follisense.com.