Data protection
Privacy Policy
This policy explains how Feal collects and processes your personal data.
1. Who is the controller?
The controller is Kermind Technologies, a French limited liability company (SARL) with share capital of €2,000, registered with the Paris Trade and Companies Register (RCS) under number 109 157 495, with its registered office at 6 rue d’Armaillé, 75017 Paris, France.
For any question about your data, write to privacy@feal-app.com or call +33 1 84 16 50 77.
2. What does this policy cover?
It applies to the feal-app.com website, the Feal application and messages you send us.
3. What data is collected?
- Account: email address and technical identifiers needed to sign in.
- Profiles and organisation: name, date of birth, declared sex, appointments, reminders, notes, vehicles, maintenance, animals and due dates.
- Health: health appointments and notes, entered reports, prescription information, vaccination records and practitioner contacts, when you enter them. This information is declarative: Feal does not verify it.
- Contacts: name, phone number, address, speciality and link to a profile.
- Purchases: payment identifier, purchase and subscription rights, without health data.
- Support: your email, the subject of the request and what is needed to reply.
- Crash diagnostics: when the app crashes, technical information: error type and technical code trace, app version, device and system characteristics (manufacturer, model, version, language, time zone, screen, memory, storage, battery, boot time), and a random identifier specific to the app installation, which is linked to neither your account nor your identity. It includes no content you enter, no health data and no email address.
- Calendars: your calendar list (name and identifier, on the device), the chosen calendar, the title, dates, location and note of events you import or export, and the identifier of the original event (for Apple, it may contain the organiser’s domain name) together with a cryptographic hash of its calendar’s identifier; with your agreement, the title and location of events you do not import (section 7).
Prescription PDFs and photos remain on the device. Information about your animals is linked to your account.
Without the data needed for an account, the synchronised service cannot be provided. Missing optional information only prevents the feature that depends on it.
4. Why, on what basis, and for how long?
Processing depends on the services you use and the features you activate.
| Purpose | Legal basis | Retention |
|---|---|---|
| Operate and secure the website | Legitimate interest — Article 6(1)(f) | Technical logs retained by OVH according to security needs and legal obligations applicable to the hosting provider. |
| Reply to your emails | Pre-contractual steps or performance of a contract — Article 6(1)(b); legitimate interest — Article 6(1)(f) | For as long as needed to handle your request. Longer retention only for a legal obligation or dispute. |
| Handle rights requests | Legal obligation — Articles 6(1)(c) and 12 to 22 | Until closure, then only what is needed to demonstrate the response. |
| Provide the account, synchronisation, reminders and purchases | Performance of a contract — Article 6(1)(b) | For the life of the account, subject to deletions you request. |
| Import or export appointments with an external calendar, at your request | Performance of a contract — Article 6(1)(b); explicit consent — Article 9(2)(a) for health appointments; consent — Articles 6(1)(a) and 9(2)(a) for AI sorting | Imported appointments and identifiers: as for other appointments. Titles and locations sorted by AI: not kept. Export links: on the device, while needed to track copies. Copies in your calendar: until you delete them. |
| Manage an accompanied adult’s profile | That person’s consent — Article 6(1)(a) | While the profile is kept or until consent is withdrawn. |
| Process health data | Explicit consent — Article 9(2)(a) | Until consent is withdrawn or the account is deleted. |
| Keep consent evidence and carry out erasure | Legal obligation — Articles 6(1)(c), 7(1) and 17 | Until the account is deleted. |
| Detect and diagnose app crashes | Legitimate interest — Article 6(1)(f) | 30 days at Sentry. |
| Secure and administer the service | Legitimate interest — Article 6(1)(f) | Administration logs: 12 months. Centralised infrastructure logs: 30 days. |
Sign-in email delivery logs are retained for one month by Brevo. Automatic database backups are retained for 35 days. After the authentication account is deleted, Firebase removes the associated information from its live and backup systems within 180 days.
Deletion covers systems under Feal’s control. A copy on an offline device, in a system backup or in an external calendar may require action on your part.
5. How are health data and profiles handled?
Feal is an organisation tool, not a healthcare provider. Health information is entered by the user. It does not have the status of a medical record. Feal provides no diagnosis and no treatment recommendation.
Health features rely on explicit consent, separate from the terms of use and applying to the whole account. Refusing consent leaves the account and other features available.
Before adding another person’s information, the account holder gives them this policy and obtains their authority. For an adult, processing relies on their consent, which must be explicit for health data. A legal representative acts within their powers. Family ties alone are not enough. That person can exercise rights with Feal, without an account, at privacy@feal-app.com.
6. Where is data stored?
Data remains available on the device. The application provides automatic synchronisation between devices on the same account. Prescription PDFs and photos are not synchronised.
Synchronised application data is hosted in France, with AWS, in the Paris region.
7. What happens with external calendars?
Import from Google Calendar or Apple Calendar/iCloud is one-off, user-initiated and read-only. Only events you approve become Feal appointments.
If you turn export on, Feal may keep the relevant appointments up to date in the chosen calendar. This is not two-way synchronisation.
Google and Apple apply their own rules. A shared calendar may make a title, location or note visible to other people.
AI sorting. During an import, Feal classifies your events on your device. If you agree to it, the title and location of those it cannot classify are analysed by an artificial intelligence model hosted by Amazon Web Services in the European Union, to suggest a domain and a title. This information may relate to your health. It is not kept after the analysis and is not used to train any model. You approve each appointment before it is created, and you can withdraw this agreement at any time in Settings › External calendars.
Google Calendar. When you connect your Google account, Feal requests the account’s basic identity (email address and profile, to recognise the connected account) and only the calendar access needed for the feature you use:
- your calendar list, read-only (
calendar.calendarlist.readonly): to let you choose the calendars to import or the destination calendar for export; - events, read-only (
calendar.events.readonly), for import: events in the period you choose are analysed on your device; with your agreement, the title and location of those it does not recognise are also sorted by AI (section 7); only those you approve become Feal appointments, handled like your other appointments; - events, read and write (
calendar.events), for export: in the chosen calendar, Feal only creates, updates and deletes the events that correspond to your Feal appointments (title, dates, location and, depending on the appointment type, the note), with a technical Feal identifier used to find them. If this access has already been granted, Feal also uses it to read events during an import. It does not change other events, or your calendars’ settings or sharing.
The content of Google events you do not import is not kept after analysis; if you link an event to an existing appointment, only its identifier is kept on the device. An imported appointment is saved with the title, dates, location and note you approved, together with the technical event identifier assigned by Google and a cryptographic hash of its calendar’s identifier, which are used to avoid duplicates. The calendar identifier itself, which may be an email address, stays on your device and is not sent to Feal’s servers; its hash remains personal data, which someone who already knows that address could verify. Like your other appointments, this information is synchronised to Feal’s servers (AWS, Paris region) and to the devices of people who have access to the relevant profile. Your Google access tokens are not sent to Feal’s servers: authorisation stays managed by the Google sign-in component on your device, and links between appointments and exported events stay on the device. Events you do not import are not sent either, except, with your agreement, the title and location of those the on-device analysis does not recognise (section 7).
Google data is not sold, transferred to data brokers, or used for advertising, creditworthiness assessment or training artificial intelligence models. It is only shared with the providers that host the service for Feal (section 8), people you share the relevant profile with and, when you export, your own Google calendar. AI sorting, if you agree to it, is carried out by Feal’s hosting provider. No Kermind Technologies staff member views it, except with your agreement (for example for a support request), for security or to comply with the law. Exchanges with Google and with Feal’s servers are encrypted (TLS); other measures are described in section 10.
You can stop export at any time in Feal: no new additions start afterwards. Events already exported remain in your calendar; Feal only deletes the copy of an appointment you later delete in Feal, while access remains authorised. You can remove Feal’s access to your Google account in your Google Account settings; this deletes neither imported appointments nor exported events. Imported appointments and their identifiers remain in Feal until you delete them or your account, then leave backups within the periods in section 4. You can also request their erasure at privacy@feal-app.com.
Feal’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
8. Who receives the data?
Data is intended for authorised Kermind Technologies personnel, providers needed to run the service, and third parties authorised by law.
For the current website and emails: OVH SAS hosts the pages; Google Workspace hosts the mailbox. Google Workspace may involve processing outside the European Economic Area, including in the United States. Safeguards are set out in its Data Processing Addendum, including standard contractual clauses. A copy can be requested at privacy@feal-app.com.
AWS provides hosting within the scope of its Health Data Hosting (HDS) certification. It also carries out, in the European Union, the AI sorting you can accept during an import (section 7).
Storage in France does not exclude certain technical or support access from countries outside the European Economic Area. Applicable safeguards are described in the AWS Data Processing Addendum, including standard contractual clauses where applicable. A copy can be requested at privacy@feal-app.com.
The application also uses the following providers, depending on the features used:
- Google / Firebase Auth: sign-in and technical identifiers, processed in the United States, without health content. Transfer safeguards are set out in the Firebase Data Processing Terms.
- RevenueCat, App Store and Google Play: purchases and subscription rights when offered, without health content sent to RevenueCat. RevenueCat uses providers in the United States; its Data Processing Addendum sets out applicable transfer safeguards, including standard contractual clauses.
- Google Calendar and Apple Calendar/iCloud: only if you connect them. They receive the appointments you export and process them under their own terms, as providers of your account rather than as Feal’s providers.
- Sentry (Functional Software, Inc.): diagnosing app crashes. Data is stored in the European Union. Technical crash messages, IP addresses and location are removed on receipt, before any storage, and no artificial intelligence analysis is enabled. Support or operations access may take place outside the EEA, including in the United States and Canada: Sentry is certified under the Data Privacy Framework, Canada benefits from an adequacy decision and its Data Processing Addendum provides standard contractual clauses. You can object to this processing by writing to privacy@feal-app.com. As events are not linked to your account, Feal cannot retrieve them from it.
- Brevo: sending sign-in and activation emails. Support or maintenance access may take place outside the EEA, including in India and the United States, subject to safeguards in its Data Processing Agreement, including standard contractual clauses.
9. What are your rights?
- right of access and to obtain a copy;
- right to rectification;
- right to erasure, in the cases provided by law;
- right to restriction of processing;
- right to object, where processing relies on legitimate interest;
- right to portability, where processing relies on consent or a contract and is automated;
- right to withdraw consent, without affecting earlier lawful processing;
- right to lodge a complaint with the French Data Protection Authority (CNIL).
You can exercise these rights at privacy@feal-app.com. Identity verification may be requested. A reply is generally given within one month.
A person whose information appears in a profile managed by someone else can contact Feal directly, without creating an account. The reply concerns their own data.
Withdrawing health consent closes health features and erases the related health content. The account and other features remain available. A local export may be offered before that withdrawal.
Delete my account
You can request deletion of your Feal account in the app settings, or without reinstalling the app by emailing privacy@feal-app.com with the subject “Delete my Feal account”.
Provide the email address associated with your account. We verify your identity through an appropriate method before carrying out the request. Do not send passwords, sign-in codes or health information. We normally respond within one month and notify you when deletion is complete or explain any justified additional delay.
Deletion removes your account and associated data: profiles, contacts, appointments, notes, health information, vehicles, pets and reminders. Backups and logs follow the periods described under retention (database backups: 35 days; Firebase: up to 180 days; administration logs: 12 months; infrastructure logs: 30 days). Purchase records held by the Stores remain subject to their legal obligations.
Files remaining on your devices, device backups and events exported to an external calendar may require action from you. Deleting your account does not automatically cancel a subscription: manage it in the App Store or Google Play.
10. What security measures are taken?
Kermind Technologies implements technical and organisational measures suited to the nature of the data, including:
- access limited to authorised people;
- encryption of communications (TLS);
- separation of data by account and by profile;
- prescription files kept on the device.
These measures reduce risk. They are not an absolute guarantee.
Feal may link an appointment to a follow-up from a simple word in the title, for example “Dentist”. This recognition stays on the device. When importing a calendar, classification also uses notes and location on the device; with your agreement, the title and location of some events are sorted by AI (section 7). Classification does not make a diagnosis. Suggested reminders remain editable. They are not used for advertising or commercial profiling.
11. What cookies are used?
The website is accessible without an account. It does not use tracking cookies, advertising tools or embedded audience analytics.
In the app, the Sentry diagnostics module stores a random identifier on the device and reads technical device characteristics, solely to diagnose crashes. These operations are strictly necessary for the app to work properly, are not used for advertising or audience measurement, and do not require consent.
OVH processes technical website requests (IP address, date, requested page, browser) for access and security. See the OVHcloud Privacy Policy.
Do not send health data by email.
12. Updates
This policy will be updated if the application opens or if processing changes materially. The version and date remain visible. If a new agreement is required, it will be presented before taking effect.
See also the Terms of Use and the Legal Notice.