Your Patients'
Information.
Our Responsibility.

The legal basis for processing depends on the specific processing activity, the jurisdiction and the relationship between the patient, clinic and service provider.

For UK deployments, information concerning health can fall within the UK GDPR's special-category data rules. Processing such information generally requires both an applicable Article 6 lawful basis and an appropriate Article 9 condition, together with any other requirements that apply. The clinic is responsible for establishing the appropriate basis for its patient processing.

For UAE deployments, the clinic and relevant service providers must assess the requirements of the UAE Personal Data Protection Law and any sector-specific requirements that apply to the particular clinic and processing activity.

Where a Data Processing Agreement or similar contractual arrangement applies, the processing responsibilities of NaseemLabs and the clinic are further defined by that agreement.

WhatsApp and Meta are independent third-party services. Their own terms, policies, technical architecture and data handling practices may apply to communications carried through their platform.

Clinics using WhatsApp through FolliCore are responsible for maintaining appropriate patient notices, permissions and consents and for complying with applicable WhatsApp Business and data-protection requirements.

Automated responses may be used as part of the configured workflow. Where WhatsApp's policies require a human escalation route, the clinic must maintain an appropriate and accessible route to human support.

WhatsApp may impose rules concerning message templates, customer-service windows, permitted uses and the handling of sensitive information. Clinics remain responsible for their use of the WhatsApp Business Platform.

Hair-restoration inquiries may contain health-related information. Examples can include descriptions of hair loss, scalp conditions, previous procedures, treatment history, medications or other information a patient voluntarily provides.

Scalp photographs can also reveal information relating to a person's health or physical condition. Such photographs are therefore handled as potentially sensitive information where applicable.

FolliCore is designed to collect only information relevant to the configured patient-progression workflow. Clinics should not configure or request unnecessary medical information.

Patients may voluntarily send scalp photographs through the configured communication channel. These images may be processed by FolliCore to support the clinic's patient-progression workflow.

Depending on the configured workflow, image processing may assist with observations such as apparent hair-loss pattern, Norwood classification or preliminary graft-range information.

These observations are not a substitute for an in-person clinical examination, medical diagnosis or final treatment plan. Image quality, angle, lighting, hair length and other factors can affect the reliability of any image-based observation.

FolliCore can use automated processing to interpret conversation context, organize information, generate summaries, provide configured responses and support workflow progression.

Automated outputs can be incomplete, incorrect or based on incomplete information. Patients should not rely on an automated response as a substitute for professional medical advice.

Where a workflow involves a clinically meaningful decision, the clinic's qualified professionals remain responsible for reviewing the relevant information and making the final decision.

NaseemLabs does not represent that automated processing will always be accurate or available without interruption.

Information may be accessed or processed by service providers required to operate FolliCore, including infrastructure, communications, database, security and other technical providers.

Depending on the deployment, this can include cloud infrastructure, database services, communication platforms and model or processing providers used to deliver configured FolliCore functionality.

Third-party providers process information according to their applicable contractual terms, technical roles and privacy documentation.

We do not sell patient information. We also do not disclose one patient's conversation to another patient.

FolliCore deployments may use region-specific infrastructure. For example, where configured and available, UK clinic data may be hosted on UK infrastructure and UAE clinic data may be hosted on UAE infrastructure.

This regional hosting statement applies to the infrastructure operated or selected by NaseemLabs. It does not mean that information never leaves that jurisdiction, because external services such as WhatsApp/Meta or other required subprocessors may process information in other locations.

Where personal information is transferred internationally, the applicable legal requirements and appropriate safeguards depend on the jurisdiction, provider and contractual arrangement.

We use technical and organisational measures designed to protect information against unauthorised access, accidental loss, misuse, alteration or disclosure.

Security measures may include access controls, authentication, encrypted network communication, infrastructure controls, database security, logging, monitoring and restricted administrative access.

No internet-based system can guarantee absolute security. Security controls are reviewed and improved as the service develops.

Patient and clinic information is retained only for as long as reasonably necessary for the purposes described in this policy, the clinic's configured requirements, contractual obligations, security needs and applicable legal obligations.

Retention periods can differ between patient conversations, images, clinic account information, technical logs, backups and security records.

When a clinic terminates its use of FolliCore, patient data held by NaseemLabs will be returned or deleted according to the applicable service agreement, Data Processing Agreement and legal requirements, subject to legitimate backup or legal retention requirements.

The NaseemLabs website may use essential technologies needed to operate the website, maintain security, remember preferences or understand basic website performance.

Where non-essential cookies or similar technologies are used, the applicable consent and disclosure requirements will be followed.

Website analytics information is separate from the patient conversation data processed through FolliCore unless explicitly connected for a documented operational purpose.

FolliCore is intended for use by hair restoration clinics in connection with their patient inquiries and is not designed specifically for children.

Clinics must ensure that their use of FolliCore is appropriate for the age of their patients and complies with applicable requirements concerning children, consent, parental responsibility and healthcare.

If information relating to a child is processed, the clinic remains responsible for determining the appropriate legal and clinical safeguards.

We maintain procedures intended to identify, investigate, contain and respond to security incidents involving information processed through our services.

Where an incident affects clinic or patient information, we will assess the incident and take actions required by applicable law and our contractual obligations, including notifying affected customers where required.

Because WhatsApp/Meta and other third-party services can form part of the communication chain, incidents occurring within a third-party platform may also be subject to that provider's incident-management and notification processes.

We may update this Privacy Policy when our services, processing activities, legal obligations or security practices change.

Material changes will be communicated through appropriate channels where required. The "Last updated" date at the top of this page identifies the current version.

Clinics should review this policy periodically and ensure that their own patient-facing privacy notices remain consistent with the way they actually use FolliCore.