PRIVACY POLICY

Last updated: May 15, 2026

This Privacy Policy for Anianos Investments Ltd (doing business as Rix: Track Hair Growth & Loss) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at rixapp.cs@gmail.com.

Summary of Key Points

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

Do we process sensitive personal information? We may process sensitive personal information (such as health data) when necessary with your consent or as otherwise permitted by applicable law.

Do we collect information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

How do we keep your information safe? We have organizational and technical processes in place to protect your personal information. However, no electronic transmission over the internet can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request or by contacting us at rixapp.cs@gmail.com.

Table of Contents

  1. What Information Do We Collect?
  2. How Do We Process Your Information?
  3. What Legal Bases Do We Rely On?
  4. When and With Whom Do We Share Your Personal Information?
  5. How Long Do We Keep Your Information?
  6. How Do We Keep Your Information Safe?
  7. Do We Collect Information from Minors?
  8. What Are Your Privacy Rights?
  9. Controls for Do-Not-Track Features
  10. Do United States Residents Have Specific Privacy Rights?
  11. Medical Disclaimer
  12. Do We Make Updates to This Notice?
  13. How Can You Contact Us About This Notice?
  14. How Can You Review, Update, or Delete the Data We Collect?

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, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. The personal information we collect may include:

Sensitive Information. With your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information: health data (including hair growth/loss progress photos and treatment information).

Payment Data. We may collect data necessary to process your payment if you choose to make purchases. All payment data is handled and stored by RevenueCat. You may find their privacy policy at: https://www.revenuecat.com/privacy.

Application Data

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

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, and information about how and when you use our Services. This includes:

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for the following reasons:

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

If you are located in the EU or UK, we rely on the following legal bases to process your personal information:

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 ("third parties") 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 designed to safeguard your personal information.

Third-party service providers we use include:

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

We do not sell your personal information to third parties.

5. 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. We retain your personal information for as long as you have an account with us. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. 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. You should only access the Services within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect, solicit data from, or market to children under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 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 rixapp.cs@gmail.com.

8. WHAT ARE YOUR PRIVACY RIGHTS?

Depending on your location, you may have the following rights regarding your personal information:

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you have the right to complain to your Member State data protection authority or the UK Information Commissioner's Office (ICO).

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 by contacting us at rixapp.cs@gmail.com or updating your preferences in the app.

Account Information

If you would like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account, or contact us using the contact information provided. 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, or comply with applicable legal requirements.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems 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 recognizing and implementing DNT signals has been finalized. 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.

10. 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, 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.

Categories of Personal Information We Collect

CategoryExamplesCollected
A. IdentifiersEmail address, IP address, account name, unique personal identifierYES
B. California Customer Records statuteName, contact information, financial informationNO
C. Protected classification characteristicsAge, demographic dataYES
D. Commercial informationTransaction information, purchase history, payment informationYES
E. Biometric informationHair progress photographs used for tracking purposesYES
F. Internet or other similar network activityBrowsing history, search history, interactions with our applicationYES
G. Geolocation dataDevice locationYES
H. Audio, electronic, sensory, or similar informationImages and photos created in connection with our ServicesYES
I. Professional or employment-related informationJob title, work historyNO
J. Education informationStudent recordsNO
K. Inferences drawn from collected personal informationProfile or summary about individual's preferencesNO
L. Sensitive personal informationAccount login information and health dataYES

We will use and retain the collected personal information for as long as the user has an account with us (Categories A, C, D, E, F, G, H, L).

Your Rights

You have the following rights under applicable US state data protection laws:

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing rixapp.cs@gmail.com, through in-app support, or by referring to the contact details at the bottom of this document.

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 rixapp.cs@gmail.com. If your appeal is denied, you may submit a complaint to your state attorney general.

11. MEDICAL DISCLAIMER

Rix: Track Hair Growth & Loss is designed for personal tracking and informational purposes only. The app does not provide medical advice, diagnosis, or treatment. Any information or content provided through the app, including progress reports and educational articles, should not be used as a substitute for professional medical advice. Always consult a qualified healthcare provider regarding any medical conditions or treatment decisions.

12. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws. We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification at least 7 days before such changes take effect. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us or contact us by post at:

Anianos Investments Ltd (Rix)

Leonida Kiouppi, Apartment 9A

6030 Larnaca, Cyprus

Email: rixapp.cs@gmail.com

14. 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 in the US, 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.

To request to review, update, or delete your personal information, please contact us at rixapp.cs@gmail.com.