Privacy Policy

1 . OWNERSHIP AND EDITORIAL RESPONSIBILITY

The Site is the property of the company Feeli, a simplified joint-stock company (société par actions simplifiée) with a share capital of 250.000 euros, registered with the Paris Trade and Companies Register (RCS) under number 841 870 678, whose registered office is located at 88 Avenue Charles de Gaulle, 92200 NEUILLY-SUR-SEINE, represented by Mr Benjamin ZERAH acting in his capacity as President (hereinafter «FEELI»).

To provide the Site and the Services, FEELI must collect Personal Data that is necessary for its proper functioning.

FEELI must also process data of a sensitive nature (medical data) in order to provide the teleconsultation service. Particular precautions are therefore implemented in order to secure your Personal Data in accordance with the applicable regulations.

The confidentiality of your Personal Data is of the utmost importance to FEELI.

You must carefully read this Privacy Policy relating to the use of Personal Data.

You are fully informed that the Personal Data submitted and collected will be subject to automated processing.

2 . DEFINITIONS

For the purposes of this Privacy Policy, the following definitions shall apply to all terms beginning with a capital letter (except where otherwise indicated in the definition), in the singular and the plural:

• «GTC » or «General Terms and Conditions» : the general terms and conditions of the Site, accessible on the Site.
• «User Account » : your account on the Site, accessible using your login and your password, and containing your personal information as well as your history on the Site;
• «Personal Data » : the personal data collected by FEELI in connection with your use of the Site.
• «Privacy Policy » : the present document, which informs you of the conditions applicable to the processing of your personal data within the Site.
• «User » or «you » (with or without capitals): you, user of the Site, whether you are a patient or a partner of FEELI.
• «Services» : the services provided by FEELI on the Site.
• «Site» : the website www.feeli.io and its components (computer code, graphic elements, databases, documentation, etc.) published by the company FEELI, on which the Services are provided, as well as any other means of displaying the site (for example a mobile application).

3 . Scope and modification of the Privacy Policy

3.1. This Privacy Policy governs the collection, processing and disclosure of your Personal Data by FEELI in connection with the provision of the Services. It also informs you of your right of access to your Personal Data.

3.2. Registration for and use of the Site imply that you read and accept without reservation the entirety of the Privacy Policy.

This acceptance will be expressed by ticking the box corresponding to the sentence accepting the Privacy Policy when registering on the Site, having for example the wording « I acknowledge that I have read and accepted the Privacy Policy of the Site ».

Ticking this box shall be deemed to have the same value as a handwritten signature on your part.

3.3. FEELI reserves the right to modify the Privacy Policy at any time by publishing a new version on the Site, by notifying you by email or by a notification upon your next login to the Site.

In the absence of acceptance of the modified Privacy Policy, you may exercise your right of refusal by deleting your User Account on the Site. Before this deletion of the User Account, you will have the possibility to retrieve your data.

The Privacy Policy applicable to the use of the Site is the one in force on the date of use.

3.4. If you click on a link that takes you to another site, that site may have a different privacy policy and FEELI will not be liable for it.

4 . The collection of personal data

FEELI may collect your Personal Data in various ways when you use the Site:

• When you fill in a form on the Site (creation and editing of a User Account, payment),
• When you use the Site and the Services,
• When you answer a pre-consultation form on the Site,
• When you upload content to the Site (for example a photograph),
• When you consult a doctor on the Site,
• When you inform FEELI of a problem using the Site,
• When you contact FEELI.

5 . what personal data is collected?

FEELI may collect the following Personal Data when you use the Site:

Non-sensitive personal data (patients and partners of FEELI)

• Your contact details and information (name, email address, telephone number, age/date of birth, address);
• Your connection information (IP address, browser type, place and time of connection, identifier of your device);
• Details of your use of the Site, in particular by means of cookies, which includes for example: quantity of data received, pages viewed, actions performed on the Site;

This Personal Data is necessary for the proper performance of its contractual obligations by FEELI.

Sensitive personal data (patients only)

• Medical information necessary for the consultation of the doctor on the Site and for the diagnosis by the latter.
• Photographs, videos and other content related to a medical consultation.
• Data related to the medical consultation, in particular exchanges with the doctors.
• Medical documents.
• Social security number.
• Information related to your complementary health insurance (mutuelle).

This information is necessary for the proper performance of the teleconsultation Services by FEELI's partner doctors. The medical information and the medical documents are only accessible by the doctors handling your file. They are encrypted end-to-end and are not accessible to FEELI.

6 . What use?

Non-sensitive Personal Data is collected to enable FEELI to fulfil its contractual obligations towards you, and in particular to:

• Enable the functioning of the Site,
• Provide the Services,
• Provide a personalised experience,
• Manage your use of the Site,
• Improve the Site,
• Provide support for the use of the Site,
• Verify your identity,
• Resolve disputes related to the Site,
• Notify you of changes relating to the Site.

With your specific agreement, non-sensitive Personal Data may also be used to inform you of FEELI's commercial news.

Sensitive Personal Data is collected to enable FEELI to fulfil its contractual obligations towards you, and in particular to:

• Enable the teleconsultation of doctors via the Site,
• Enable the creation of your online health record.
• Enable your reimbursement of health costs related to your use of the Site.

This sensitive Personal Data is never used for other purposes.

7 . Location of data storage

The Personal Data collected is stored within the European Union, by a provider that applies industry standards in terms of computer security.

The Personal Data is stored securely on the Site.

FEELI and its database are hosted by a health data host approved by the French National Authority for Health (Haute Autorité de Santé - HAS) and ASIP Santé in accordance with article L1111-8 of the French Public Health Code (Code de la santé publique).

No data will be transferred outside the European Union.

8 . Disclosure of Personal Data

The Personal Data will never be transferred to a third party without your prior consent.

Non-sensitive Personal Data may only be accessed by the authorised staff and subcontractors of FEELI. These subcontractors are as follows:

• Host: Amazon Web Services

Sensitive Personal Data will only be disclosed to the doctors responsible for handling your file. FEELI will not be able to access it, nor will any third party.

Your social security number may also be transmitted to third parties whose information you have provided to FEELI, in order to allow the reimbursement of health care within the framework of the care pathway (complementary health insurers, national health insurance fund). By transmitting the information of these third parties to FEELI, you authorise FEELI to transmit to them your social security number as well as your identity information, to enable them to process these reimbursements.

FEELI may however transfer your Personal Data under the following conditions:

• If FEELI is acquired by a third party, in which case the Personal Data will be transferred to the acquirer, who will be substituted for FEELI in the application of this Privacy Policy.
• If FEELI is required to transmit the Personal Data in response to a legal obligation.

9 . Security of Personal Data

FEELI ensures that your data is stored under conditions respecting industry standards.

The Site is secured via an SSL certificate.

FEELI ensures that its employees and providers responsible for processing the Personal Data are subject to an appropriate obligation of confidentiality.

Only the employees and providers of FEELI who need to access your Personal Data to carry out their tasks may access it. Access to it is strictly limited.

In the event of a breach of Personal Data, FEELI will inform you as soon as possible.

FEELI will store your non-sensitive Personal Data for the period of validity of the User Account.

FEELI will store your sensitive Personal Data for a period of 10 years from the date of their upload.

If your User Account has not been active for more than one (1) year (date of last login), or in the event of deletion of your User Account by you, the Personal Data will be deleted automatically.

In this case, FEELI will delete all your Personal Data, with the exception of that which is strictly necessary for the maintenance of its commercial accounts and compliance with its legal obligations.

10 . Rights of users

In accordance with the Loi Informatique et Libertés (French Data Protection Act) and the RGPD (GDPR), you have the following rights for all Personal Data transmitted to FEELI:

• Right of access,
• Right of rectification and modification,
• Right to restrict processing,
• Right to object,
• Right to portability.

You may exercise these rights by contacting FEELI at the following contact address: infos@feeli.io.

You have the possibility, at any time, to delete the information contained in your User Account, and in particular within your electronic health record.

You may provide instructions regarding the processing of your Personal Data in the event of death.

In accordance with its legal obligations, FEELI will comply within a maximum period of one (1) month from receipt of the request.

11 . Payment information

In the event of payment on the Site, you may be invited to enter your payment information. FEELI will not have the payment information.

All transactions are carried out by a payment provider complying with the obligations applicable to this activity.

The payment information only passes through FEELI's payment provider.

FEELI's payment provider is: Stripe

The general terms and conditions of the payment provider are accessible at the following address: https://stripe.com/fr/legal

12 . Cookies

FEELI may use the following cookies on the Site:

• Session cookies. These cookies are intended to allow you to log in to your User Account on the Site. They are necessary for the proper functioning of the Site.
• Google Analytics (https://marketingplatform.google.com/about/), These cookies are intended to allow FEELI to collect attendance statistics. You have the possibility to exclude their installation, as these are not mandatory for the proper functioning of the Site.

You can prevent the installation of cookies on your device in the following way:

• By refusing them on the banner that will be displayed on your first visit to the Site.
• By deleting them via the appropriate option in your browser.
• Google Chrome: Tool Menu / Settings / Show advanced settings / Content Settings / Allow local data to be set.
• Internet Explorer:https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies
• Mozilla Firefox:https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
• Safari:https://support.apple.com/fr-fr/guide/safari/sfri11471/mac

Only technical cookies cannot be refused, as these are necessary for the proper functioning of the Site.

These cookies are installed for a maximum period of thirteen (13) months.

13 . Applicable law and disputes

The law applicable to these terms is French law, regardless of your country of origin.

The Privacy Policy is written in French, and the French version shall prevail even in the event of translation into another language.

You may submit to the CNIL any dispute relating to the performance or interpretation of the Privacy Policy that has not been resolved amicably between the Parties.

It may also be submitted to the competent court of FEELI's registered office, including in summary proceedings, a warranty claim or a plurality of defendants, and regardless of your country of origin.