Forma — Privacy Policy
Effective date: July 8, 2026
Last updated: July 8, 2026
This Privacy Policy explains how A.V. GARCIAN CAPITAL LLC ("Forma," "we," "us," or "our") collects, uses, shares, and protects information when you use the Forma mobile application and related services (the "Service").
By using Forma, you agree to this Policy. If you do not agree, please do not use the Service.
1. Who we are
Forma is operated by A.V. GARCIAN CAPITAL LLC, located at 7901 4th Street North, Ste 300, St. Petersburg, FL 33702, USA. For any privacy questions, contact us at support@forma.hair.
- EU/EEA representative: Not currently appointed; EU/EEA users may contact us at support@forma.hair.
- UK representative: Not currently appointed; UK users may contact us at support@forma.hair.
- Data Protection Officer: Not appointed; privacy questions may be sent to support@forma.hair.
2. Information we collect
a. Information you give us
- Account details: name or username, email address, and (optionally) profile preferences such as hair type, goals, and language.
- Photos and images: photos you upload or capture (for example, selfies and photos of your hair) so Forma can analyze your hair and generate style recommendations and haircut specifications. See Section 3 for how these are handled.
- Subscription information: your plan and purchase history. Payments are processed by the Apple App Store; we do not receive or store your card number.
- Communications: messages you send us (e.g., support requests) and feedback.
b. Information we collect automatically
- Device and technical data: device model, operating system, app version, language, time zone, and general (city-level) location inferred from IP address.
- Usage data: features used, screens viewed, interactions, and diagnostic/crash data.
- Identifiers: app-instance identifiers. We do not use advertising identifiers and we do not serve ads.
c. Information from third parties
- Authentication providers you choose (Sign in with Apple or Sign in with Google), which may share your name and email.
- App stores and analytics providers, which may share aggregate install and performance data.
We do not intentionally collect special-category data beyond what is described in Section 3, and we ask you not to upload sensitive information that isn't needed for the Service.
3. Photos, image analysis, and biometric considerations
This is the most sensitive data Forma handles, so we treat it carefully.
- Purpose. We use the photos you provide solely to analyze hair characteristics (such as texture, length, density, hairline, and growth pattern), assess fit with hairstyles, power the try-on/comparison feature, and generate haircut recommendations and specifications.
- Metadata stripping. Before a photo leaves your device, we re-encode it and remove embedded metadata (such as EXIF location and device-serial information).
- Processing and storage. Photos are uploaded to a temporary, access-restricted storage location, processed, and then deleted promptly after processing. Where you explicitly choose to save a result (such as a try-on image or a saved breakdown) to your Forma history, that result is stored locally on your device until you delete it or uninstall the app.
- AI processing. Image analysis is performed by us and by our AI processors — Anthropic PBC (Claude) and Google LLC (Gemini) — who act on our instructions under contract and are not permitted to use your photos for their own purposes or to train their models.
- No identity matching. We use your photos to analyze hair and style, not to identify you, build a faceprint, or match you against other people.
- Biometric notice and consent (where required). Depending on how your image analysis works and where you live, facial or hair-geometry analysis may be regulated as biometric information (for example under the Illinois Biometric Information Privacy Act, the Texas CUBI Act, Washington's biometric law, or as special-category data under the GDPR/UK GDPR). Where required, we obtain your explicit consent before such processing, do not sell or lease this data, and follow the retention-and-destruction schedule in Section 7. You can withdraw consent at any time by emailing support@forma.hair, though this may stop you from using image-based features.
4. How we use your information
We use information to:
- provide, operate, and maintain the Service and its core features;
- analyze photos and generate recommendations, scores, and specifications;
- create and manage your account and subscription;
- personalize content, including in your selected language;
- communicate with you about updates, security, and support;
- send push notifications you have enabled (you can turn these off in your device settings);
- monitor, troubleshoot, secure, and improve the Service, including aggregated/de-identified analytics;
- detect and prevent fraud, abuse, and violations of our Terms; and
- comply with legal obligations.
Legal bases (GDPR/UK GDPR). Where this law applies, we rely on: performance of a contract (to provide the Service); consent (for photo/biometric processing, push notifications, and optional analytics where required); legitimate interests (to secure and improve the Service, balanced against your rights); and legal obligation (to meet legal requirements).
5. How we share information
We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We share it only as follows:
- Service providers / processors who help us run Forma, under contracts that limit their use of the data to providing services to us:
- Supabase, Inc. — cloud hosting, database, and temporary photo storage;
- Anthropic PBC and Google LLC — AI hair analysis and image generation;
- RevenueCat, Inc. — subscription management;
- Functional Software, Inc. (Sentry) — crash reporting;
- PostHog, Inc. — product analytics. - Apple Inc. — app distribution and payment processing to complete and manage your purchases.
- Legal and safety disclosures when required by law, or to protect the rights, safety, and property of Forma, our users, or others.
- Business transfers in connection with a merger, acquisition, financing, or sale of assets — we will notify you of any change in ownership or use of your personal information.
- With your direction, such as when you choose to share or export a recommendation.
A current list of subprocessors is available on request at support@forma.hair.
6. Data retention
We keep personal information only as long as needed for the purposes described here:
- Photos: deleted promptly after processing; results you choose to save are stored locally on your device until you delete them or uninstall the app.
- Account data: kept while your account is active and for up to 30 days after closure, then deleted or de-identified.
- Transaction records: subscription and purchase records retained as required by tax and accounting law (typically up to 7 years).
- Diagnostic/usage data: retained for up to 24 months in identifiable form.
7. Biometric retention and destruction (if applicable)
If we process biometric information, we will permanently destroy it when the purpose for collection has been satisfied or within 3 years of your last interaction with the Service, whichever occurs first, unless a longer period is required by law. We will not sell, lease, trade, or otherwise profit from your biometric information.
8. Security
We use administrative, technical, and physical safeguards — including encryption in transit, access controls, and restricted, short-lived storage of photos — designed to protect your information. No system is perfectly secure, so we cannot guarantee absolute security. If we become aware of a breach affecting your information, we will notify you and regulators as required by law.
9. International data transfers
We may process and store information in countries other than yours, including the United States. Where we transfer personal data out of the EEA, UK, or Switzerland, we use appropriate safeguards such as the European Commission's Standard Contractual Clauses and equivalent mechanisms. You can request a copy of these safeguards at support@forma.hair.
10. Your rights and choices
Depending on where you live, you may have the right to: access, correct, delete, port, restrict, or object to processing of your personal information; to withdraw consent; and to opt out of sale/sharing (note: we do not sell or share). You also have the right to non-discrimination for exercising these rights.
- EEA/UK (GDPR): the rights above, plus the right to lodge a complaint with your supervisory authority.
- California (CCPA/CPRA): the rights to know, delete, correct, and opt out of sale/sharing and limit use of sensitive personal information. We do not sell or share personal information.
- Other US states (including Virginia, Colorado, and Connecticut) and other jurisdictions: comparable rights as provided by your local law.
To exercise any right, contact support@forma.hair or use the in-app controls under Account settings. We will verify your request and respond within the time required by law. You may use an authorized agent where permitted.
You can also:
- delete your photos or account in-app at any time;
- turn off push notifications in device settings; and
- manage tracking permissions in your device's privacy settings.
11. Children's privacy
Forma is intended for users aged 18 and older and is not directed to children. We do not knowingly collect personal information from anyone under 18. If you believe a child has provided us information, contact support@forma.hair and we will delete it.
12. Cookies, SDKs, and analytics
The app and any related web pages use limited cookies, SDKs, and similar technologies for authentication, preferences, security, and analytics. Where required, we ask for your consent before using non-essential technologies, and you can manage choices in your device settings and the in-app privacy controls. We honor recognized opt-out preference signals (such as Global Privacy Control) where applicable.
13. Third-party links and services
The Service may reference third-party platforms (for example, social media or your barber's booking system). Their privacy practices are governed by their own policies, and we are not responsible for them.
14. Changes to this Policy
We may update this Policy from time to time. If we make material changes, we will notify you in-app or by email and update the "Last updated" date. Your continued use of the Service after changes take effect means you accept the revised Policy.
15. Contact us
A.V. GARCIAN CAPITAL LLC
7901 4th Street North, Ste 300
St. Petersburg, FL 33702, USA
Email: support@forma.hair