Privacy Policy

Effective as of Jan 2025

Introduction

Welcome to the Alopexia Website (the "Website") and/or Application (the "Application"), provided by Centa Bio. We are committed to safeguarding your privacy and managing your personal data responsibly, in accordance with global standards, including the General Data Protection Regulation (GDPR).

By using this Website and/or Application, you agree to the terms outlined in this Privacy Policy. If you do not agree with any part of it, please do not use the Website and/or Application.

Scope

This Privacy Policy applies exclusively to the Alopexia Website and/or Application. It describes our practices regarding the collection, use, processing, storage, and sharing of personal data as a Data Controller, adhering to GDPR requirements for individuals located in the EU.

Our Commitment to Your Privacy

Centa Bio is committed to maintaining the confidentiality of your personally identifiable information (PII), including sensitive health data. We follow a "Privacy by Design" approach, embedding data protection into every stage of our processes, and ensuring compliance with GDPR principles of transparency, accountability, and minimization.

Data We Collect

We collect and process the following categories of personal data:

1. Personal Identification Information (PII):

Name, email address, phone number, and mailing address

Date of birth and gender

2. Health Data:

Scalp images and related health assessments

Norwood scale classifications and other hair loss metrics

3. Usage Data:

Device details (e.g., IP address, operating system, and browser type)

Time, date, and duration of visits to the Website and/or Application

Pages visited and interactions within the Application

4. Financial Data:

Payment details processed through secure third-party payment gateways

Legal Basis for Data Processing

Under GDPR, we process your data based on the following lawful grounds:

Consent: Your explicit consent to process health data for personalized recommendations and treatments.

Contractual Necessity: Data required for the performance of our services, including prescription generation and treatment delivery.

Legitimate Interests: Improving services and conducting analysis while ensuring no harm to your fundamental rights.

Legal Obligations: Compliance with applicable laws and regulations.

Purposes of Data Processing

We use your personal data to:

Conduct AI-driven hair loss analysis using the Norwood scale

Provide personalized haircare recommendations and treatment plans

Process orders, manage subscriptions, and facilitate delivery of Alopexia products

Monitor and enhance user experience within the Website and/or Application

Maintain regulatory compliance and respond to legal obligations

Data Retention

We retain your personal data only as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements. Usage data is generally retained for a shorter period unless needed for security purposes or service improvement.

Security Measures

Centa Bio applies state-of-the-art security measures, including:

Encryption of sensitive health and financial data during transmission and storage

Two-factor authentication (2FA) for account access

Regular vulnerability assessments and penetration testing

Your Rights Under GDPR

As an EU resident, you have the following rights:

Right to Access: Request access to your personal data and details on how it is processed.

Right to Rectification: Request corrections for inaccurate or incomplete data.

Right to Erasure: Request deletion of your data ("Right to be Forgotten") when no longer necessary.

Right to Restriction: Request limited processing under certain conditions.

Right to Data Portability: Receive your data in a structured, commonly used format and transfer it to another controller.

Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.

Right to Withdraw Consent: Withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise your rights, please contact our Data Protection Officer (DPO): aurora.mateos@centabio.com

Email: contact@alopexia.com
Address: +34 629‑917‑775

Automated Decision‑Making and Profiling

Our AI-driven hair analysis includes profiling to recommend personalized solutions. You have the right to request human intervention, express your point of view, or contest decisions made solely through automated processing.

Cookies and Tracking Technologies

Our Website and/or Application uses cookies to enhance your experience. You can manage your cookie preferences and opt out of non-essential cookies.

Children's Privacy

Our services are intended for individuals aged 18 and older. We do not collect data from minors. If such data is inadvertently collected, we will delete it promptly upon notification.

Changes to This Policy

This Privacy Policy may be updated periodically to reflect changes in our practices or regulatory requirements. Notifications will be provided through the Website and/or Application, with a revised effective date.

Grievance and Complaints

For complaints or grievances, please contact:

Data Protection Officer (DPO): aurora.mateos@centabio.com Email: contact@alopexia.com Phone: +34 629‑917‑775

You also have the right to lodge a complaint with a supervisory authority in your country.