This policy describes how My Data My Care collects, processes, and protects your data. It complements our Terms of Service and our technical commitments.
1. Data controller
My Data My Care, [[SIRET + address]], is the controller of your personal data within the meaning of the GDPR (EU Regulation 2016/679) and the amended French "Informatique et Libertés" Act.
2. Data collected
2.1 Identification data
- Last name, first name, date of birth
- National Health ID (INS), after verification with the INSi service
- Email address, phone number
- Cryptographic public key of your device (WebAuthn / passkey)
2.2 Health data (sensitive data)
- Medical history, allergies, treatments
- Test results, imaging, reports
- Prescriptions, vaccinations, physiological metrics
- Data from connected health devices (with your consent)
End-to-end encryption. Your health data is encrypted on your device before transmission. We host opaque encrypted blobs. Even our technical teams cannot access them without your explicit cryptographic authorization.
2.3 Log data
- Access dates and times, IP addresses, device type (for security purposes)
- Log of sharing events and revocations (recorded on an immutable audit chain)
3. Purposes of processing
- Service delivery: creation and management of your health passport (legal basis: performance of the contract)
- Regulatory compliance: legal obligations under Ségur, Mon Espace Santé, INS (legal basis: legal obligation)
- Security: fraud detection, audit, access traceability (legitimate interest)
- Communication: product updates, support (legal basis: consent)
We never resell or transfer your data to third parties for commercial, advertising, or marketing research purposes. No exception, no condition.
4. Recipients
- You and your legal beneficiaries (close caregivers, legal guardians)
- The healthcare professionals you invite, for the duration you define
- Our HDS-certified host, under a GDPR data-processing agreement
- No foreign authority. Since our servers are located in France with a certified French host, no jurisdiction outside the EU can compel access
5. Retention period
- Health data: 20 years after your last access, in accordance with the French Public Health Code (R. 1111-1)
- Account data: for the duration of your registration + 3 years after inactivity
- Connection logs: 12 months maximum (LCEN obligation)
- Upon account deletion: complete erasure within 30 days, excluding legal retention obligations
6. Your rights
Under the GDPR, you have the following rights, exercisable at any time:
- Right of access (Article 15 GDPR)
- Right to rectification (Article 16 GDPR)
- Right to erasure / right to be forgotten (Article 17 GDPR)
- Right to restriction of processing (Article 18 GDPR)
- Right to data portability (Article 20 GDPR) — complete FHIR R4 export available in 1 click
- Right to object (Article 21 GDPR)
- Post-mortem directives — you may designate a trusted third party
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Data protection — France
Processing of your health data complies with:
- GDPR (EU Regulation 2016/679) — main legal basis
- French Data Protection Act n° 78-17 of 6 January 1978 as amended by Act n° 2018-493
- Public Health Code, art. L1111-8 — mandatory HDS-approved hosting
- Art. 56 FR DPA — processing for health research
- ANS standards: PGSSI-S, National Health Identifier (INS)
Health data hosting : Exclusively in France at a HDS v2-certified provider. No transfer outside the EU for operational processing. End-to-end client-side encryption (zero-knowledge architecture).
Supervisory authority : CNIL — Commission Nationale de l'Informatique et des Libertés, 3 Place de Fontenoy — TSA 80715 — 75334 Paris Cedex 07
Governing law : French and European law. Complaint open directly to the CNIL at any time, without prior recourse to the controller.
7. Cookies
See our dedicated cookie policy.
8. Amendments
This policy may be updated. Any substantial change will be notified to you by email and within the application, with 30 days' notice before it takes effect.