SIMONE Pro —App Privacy Notice

Simone Trichology · Professional Programme

Android app SIMONE Pro (package com.simonehair.pro) · Version 2026-10 · TRICHOMEDIC LABS, S.L.U.

This notice explains how the SIMONE Pro mobile application collects, uses, shares and protects personal data. SIMONE Pro is a professional tool used by registered hair salons, hair clinics and authorised technical points (the “Establishment”) to carry out a dermotrichological hair and scalp analysis of their clients with a clip-on dermatoscope. It is not intended for consumers and is not a medical device.

1. Who is responsible for your data

Clients of an Establishment. The Establishment that performs your analysis is the data controller. TRICHOMEDIC LABS, S.L.U. (SIMONE TRICHOLOGY) provides the technology platform and acts as its data processor under a data processing agreement pursuant to Article 28 GDPR.

Establishments and their staff. For the professional account (establishment name, email, territory, technicians’ names) TRICHOMEDIC acts as controller, to manage the Programme relationship.

TRICHOMEDIC LABS, S.L.U. · Crta. de Ribes, 186 Loc. 2, 08520 Les Franqueses del Vallès (Barcelona), Spain · sales@simonehair.com · +34 615 228 361.

2. Data the app collects

• Client contact details: name, email and phone, entered by the professional.
• Personal characteristics: age range and sex.
• Hair questionnaire (anamnesis) and, optionally, blood-test values provided by the client.
• Photographs: magnified images of the scalp (trichoscopies) and three general views of the head, taken with the device camera through the dermatoscope.
• Hair measurements computed on the device (e.g. fibre thickness, density, scaling) or entered manually.
• Consent evidence: consent text version, signatory name and timestamp, and the separate marketing choice.
• Establishment account data: establishment name, email, territory, technicians’ names, and an app-generated device identifier used to bind the access key to the authorised device.

Scalp images and the questionnaire may reveal information about hair and scalp health. They are processed only on the basis of the client’s explicit consent, collected on the device before the first capture (Articles 6.1.a and 9.2.a GDPR). Without recorded consent the system refuses to create the case.

The app uses the camera only during capture. It does not access contacts, location, microphone or other apps, contains no advertising and no third-party analytics or tracking SDKs, and does not use the advertising ID.

3. How the data is used

• To produce the client’s dermotrichological hair analysis, a technical report for the professional and a client report co-branded with the Establishment.
• To propose a dermocosmetic care protocol and, where applicable, a purchase link to the territory’s store.
• To carry out the follow-up visit at approximately ten weeks, including an automatic reminder email to the client.
• To operate, secure and support the service.

Images, questionnaire and measurements are analysed with the help of artificial intelligence. No automated decisions with legal effects are taken: the result is a dermocosmetic recommendation that the professional reviews before delivering it.

4. Sharing and service providers

Data is never sold and is not shared with third parties for their own purposes. To provide the service we use providers bound by contract: hosting in the European Union (Raiola Networks, Spain); AI analysis engine (Anthropic, USA); content delivery and security (Cloudflare, USA); and, only if the client ticks the separate optional box, an email marketing platform (Klaviyo, USA). Transfers to the USA rely on the EU-U.S. Data Privacy Framework or the EU Standard Contractual Clauses. Reports are sent to the client only when the professional decides to send them (by email or from the Establishment’s own WhatsApp).

Distributors of the Programme may receive aggregated, anonymised activity statistics only — never personal data.

5. Security

All communication between the app and our servers is encrypted in transit (TLS). Each Establishment has its own access key, stored encrypted on the device and bound to that device. Data is strictly isolated per Establishment, images are kept in a private, non-public directory, and listings show abbreviated client names.

6. Retention

Client data is kept while the client remains active with the Establishment and is deleted automatically 12 months after the last visit or follow-up. A case with an ongoing follow-up is not deleted while the follow-up is active. Deletion can be requested earlier at any time.

7. Your rights

Clients may exercise their rights of access, rectification, erasure, objection, restriction and portability, and withdraw consent at any time, by contacting the Establishment that performed the analysis or, if preferred, sales@simonehair.com — we will forward the request to the Establishment. You may also lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

8. Deleting an Establishment account

An Establishment can request the deletion of its SIMONE Pro account and associated data at any time by emailing sales@simonehair.com with the subject “SIMONE Pro account deletion”, from the email address registered for the account and stating the establishment code (e.g. ES-001). We verify the request and delete the account, its access keys, technicians and all client cases and images within 30 days; backups are purged on their rotation cycle (maximum 90 days). Before deletion, the Establishment may ask for an export of its clients’ data.

9. Children

The service is reserved for persons over 18 years of age and is not directed at children.

10. Changes

We may update this notice. The current version is always published at this address with its version date.

See also the SIMONE PRO Programme Terms and our general Privacy Policy · TRICHOMEDIC LABS, S.L.U. · SIMONE TRICHOLOGY