This Privacy Notice for Fllio, LLC ("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:
- Visit our website at evna.me or any website of ours that links to this Privacy Notice
- Use Evna. Evna is an AI-powered facial morphology, digital aesthetics, and hair design simulation platform provided as a Software-as-a-Service (SaaS). The platform analyzes facial traits (including vertical facial thirds, gonial jaw angles, cheekbone prominence, and melanin undertones) to generate simulated haircut previews, style recommendations, and actionable 1-page hairstylist consultation cards.
- Engage with us in other related ways, including any customer support, marketing, or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. 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 [email protected].
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, 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 any sensitive personal information? With your separate photo-processing consent, we analyze visible facial proportions, hairline, hair texture and styling preferences to create your report and images. Reports may retain descriptions or estimated measurements of these traits along with your portraits. We do not maintain a searchable face-recognition template or a database of facial embeddings for identifying people. AI providers may create temporary internal representations while processing your photos.
Evna does not use your portraits or reports to train its own AI models. We send photos and related instructions to hosted AI providers to deliver the service. Those providers handle the inputs under their applicable service terms and account settings.
Do we collect any information from third parties? If you sign in with Google, we receive the identity information needed to create or access your account. Payment and infrastructure providers may also send us transaction or security information.
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.
After you give permission, Evna stores your photos privately and shares them with a third-party provider to analyze your features and create your personalized report and hairstyle images.
How do we keep your information safe? You must sign in to view private reports and portraits, and we check that each report belongs to your account. We use private storage paths and restrict caching of portrait responses. Our hosting and storage providers also apply security controls to their infrastructure.
What are your rights? Depending on where you are located geographically (e.g. EU/EEA, UK, California, Illinois, Texas, etc.), applicable privacy law grants you specific rights regarding your personal and biometric data.
How do you exercise your rights? The easiest way to exercise your rights is through your in-app account settings or by contacting us at [email protected].
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you voluntarily provide 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.
Personal Information Provided by You. The personal information we collect may include:
- names and usernames
- phone numbers and email addresses
- authentication tokens and session identifiers
- contact preferences and communication history
- billing addresses and payment metadata
- uploaded portrait photographs and facial morphology goals
- haircut and aesthetic style preferences (e.g. curl type, color undertone)
- customer support inquiries and feedback
Sensitive Personal & Biometric Information. With your separate photo-processing consent, we analyze visible facial proportions, hairline, hair texture and styling preferences to create your report and images. Reports may retain descriptions or estimated measurements of these traits along with your portraits. We do not maintain a searchable face-recognition template or a database of facial embeddings for identifying people. AI providers may create temporary internal representations while processing your photos.
Payment Data. We collect data necessary to process your purchases. Payment processing is handled by Stripe, Inc. ("Stripe"). Stripe processes your personal data in accordance with its privacy notice, available at https://stripe.com/privacy.
Information automatically collected
In Short: Some information — such as IP address and browser/device characteristics — is collected automatically when you visit our Services.
We automatically collect technical device and usage information when you interact with our platform (such as IP address, browser type, operating system, language preferences, referring URLs, and session logs) to secure our infrastructure and prevent automated abuse.
2. HOW DO WE PROCESS YOUR INFORMATION & LEGAL BASES?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, protect security, and comply with law.
We process your personal information for the following specific purposes and legal bases (including under GDPR Articles 6 & 9):
- To facilitate account creation and authentication (GDPR Art. 6(1)(b) — Performance of a Contract).
- To deliver personalized aesthetic simulations and hair consultation reports by analyzing facial traits and generating simulated cards (GDPR Art. 6(1)(b), with separate affirmative consent for photo processing and, where applicable, explicit consent under Art. 9(2)(a)).
- To process one-time purchases and provide access to paid reports (GDPR Art. 6(1)(b)).
- To respond to customer support inquiries and provide assistance (GDPR Art. 6(1)(b)).
- To protect our Services from fraud, bot attacks, and illegal content (GDPR Art. 6(1)(f) — Legitimate Interests).
- To comply with statutory legal and accounting obligations (GDPR Art. 6(1)(c) — Legal Obligation).
5. HOSTED AI AND PHOTO PROCESSING
After you give permission, Evna stores your photos privately and shares them with a third-party provider to analyze your features and create your personalized report and hairstyle images.
Evna uses hosted AI services to analyze photos and create styling recommendations and images.
- Evna does not use your portraits or reports to train its own AI models. We send photos and related instructions to hosted AI providers to deliver the service. Those providers handle the inputs under their applicable service terms and account settings.
- After you give permission, Evna stores your photos privately and shares them with a third-party provider to analyze your features and create your personalized report and hairstyle images.
- You can withdraw consent for future photo processing for a report in Account & privacy or by contacting [email protected]. Requests already sent may finish. Existing photos and reports are not automatically deleted.
- Aesthetic Simulation Nature: Outputs generated by Evna are artistic and digital aesthetic simulations intended for styling consultation; they do not constitute medical, surgical, or dermatological diagnostics.
6. BIOMETRIC INFORMATION NOTICE & DESTRUCTION SCHEDULE
This section explains how we handle facial information. The legal rights that apply depend on how it is used and where you live.
Biometric Data Processing Standards
- Absolute Non-Sale Guarantee: Evna strictly guarantees that we will never sell, lease, trade, barter, or monetize your biometric identifiers or facial landmark data under any circumstances.
- With your separate photo-processing consent, we analyze visible facial proportions, hairline, hair texture and styling preferences to create your report and images. Reports may retain descriptions or estimated measurements of these traits along with your portraits. We do not maintain a searchable face-recognition template or a database of facial embeddings for identifying people. AI providers may create temporary internal representations while processing your photos.
- Informed Consent: Before a photograph is analyzed, the upload flow asks you to affirm that you are an adult (18+), that the portrait is yours or you are authorized to submit it, and that you consent to the stated photo processing.
Biometric Data Retention & Permanent Destruction Schedule
We keep your portraits and finished reports in your account until you delete it or it reaches the stated inactivity period. Account deletion removes data from active systems through a retried cleanup process. Restricted backups and provider-held records follow their applicable schedules, and records needed for legal, tax or payment duties may be retained separately.
Account deletion blocks access and queues removal of account data, reports and photos from our active systems. Failed deletion steps are retried. Restricted backup copies and service-provider records follow their applicable retention schedules; we do not promise immediate removal from every backup or provider system. Records required for legal, tax or payment obligations may be retained separately with restricted access.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information only as long as necessary to fulfill service purposes or meet legal requirements.
We retain account information, photos, facial-analysis results and styling reports until you request account deletion or the account reaches 12 months of inactivity. We send reminders 30 days and 7 days before inactivity deletion. Sign in and select “Keep my account” to start a new 12-month period. Signing in or using your account also starts a new 12-month period.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We protect your personal data through industry-standard organizational and technical security measures.
You must sign in to view private reports and portraits, and we check that each report belongs to your account. We use private storage paths and restrict caching of portrait responses. Our hosting and storage providers also apply security controls to their infrastructure.
9. DO WE COLLECT INFORMATION FROM MINORS?
Evna is for adults. Automated screening may reject an unsafe submission.
Evna is for adults. If automated screening flags a photo as showing a minor or otherwise unsafe content, we reject it and flag it for review. We may restrict an account, preserve evidence or make a report when appropriate or required by law. Screening can be mistaken; it does not determine age or illegality.
10. WHAT ARE YOUR PRIVACY RIGHTS & GDPR / UK RIGHTS?
In Short: Depending on your location, you have statutory rights to access, rectify, export, or delete your personal data.
Under GDPR, UK GDPR, and relevant data protection laws, your rights include:
- Right of Access: Request copies of personal data and biometric records we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete personal information.
- Right to Erasure ("Right to be Forgotten"): Request permanent deletion of your account, photos, and consultation reports.
- Right to Restriction & Objection: Object to or restrict certain types of data processing.
- Right to Data Portability: Receive your data in a structured, commonly used, machine-readable format.
- You can withdraw consent for future photo processing for a report in Account & privacy or by contacting [email protected]. Requests already sent may finish. Existing photos and reports are not automatically deleted.
- Right to Lodge a Complaint: Lodge a complaint with your local EU Data Protection Supervisory Authority or the UK Information Commissioner's Office (ICO).
11. INTERNATIONAL DATA TRANSFERS
Fllio, LLC is based in the United States. Our service providers may process personal data in the United States and other countries. Contact [email protected] for information about the providers and transfer safeguards relevant to your data.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most browsers include a Do-Not-Track ("DNT") setting. As no uniform industry standard exists, our systems do not currently respond to automated DNT browser signals.
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Residents of California, Illinois, Texas, Virginia, Colorado, Connecticut, and other states have specific statutory privacy rights.
The table below outlines categories of personal information processed in the preceding twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Name, email address, phone number, IP address, unique user ID | YES |
| B. Customer Records | Name, contact details, payment confirmation records | YES |
| C. Protected Classifications | Age (18+), gender styling preferences | YES |
| D. Commercial Information | Purchase history and payment transactions | YES |
| E. Biometric Information | Facial landmark geometry calculated from uploaded portraits for hair design (non-sale) | YES |
| F. Internet / Network Activity | Interactions with the website, session logs, browser characteristics | YES |
| G. Geolocation Data | Country or coarse location based on IP address | YES |
| H. Audio / Sensory Information | Uploaded user portrait photographs | YES |
| I. Professional Information | Stylist or salon professional notes (optional) | NO |
| J. Education Information | Student records | NO |
| K. Inferences | AI style compatibility and hair texture classification | YES |
| L. Sensitive Personal Information | Account login credentials, facial biometric geometry | YES |
California "Shine The Light" Law
Under California Civil Code Section 1798.83, California residents may request details regarding disclosures to third parties for direct marketing. Evna does not disclose or sell personal data to third parties for direct marketing purposes.
14. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we update this notice as necessary to maintain regulatory compliance.
We may update this Privacy Notice periodically. The updated version will be marked with a revised "Last updated" date at the top.
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
Fllio, LLC — Evna Privacy Office
7901 4th St N, Suite 300, St. Petersburg, FL 33702, United States
Email: [email protected]
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
You can request account deletion in Account & privacy, or contact [email protected] for access, export or deletion requests.
Account deletion blocks access and queues removal of account data, reports and photos from our active systems. Failed deletion steps are retried. Restricted backup copies and service-provider records follow their applicable retention schedules; we do not promise immediate removal from every backup or provider system. Records required for legal, tax or payment obligations may be retained separately with restricted access.