Privacy policy for the Solsius SelfCare mobile application

Date of last update : 25/09/2025

Version 2.0

Preamble

This privacy policy describes our policies and procedures relating to the collection, use and disclosure of your information when you use the service and informs you of your privacy rights and how the law protects you.

We use your personal data to provide and improve the Service. By using the Service, you consent to the collection and use of information in accordance with this Privacy Policy.

Table of contents

1. Interpretation and definitions
2. Collection and use of your personal data
3. Children's privacy
4. Changes to this privacy policy
5. Contact the CNIL
6. Contact us

1. Interpretation and definitions

1.1 Interpretation

Words whose initial letter is capitalized have meanings defined in the following conditions. The following definitions will have the same meaning whether they appear in the singular or plural.

1.2 Definitions

For the purposes of this privacy policy :

• The Company (referred to in this Agreement as «the Company», «We», «Us» or "Our") refers to Solsius, 12 bis Rue des Tours, 59800 LILLE.
• Account means a unique account created to enable you to access our service or parts of our service.
• Affiliated company means an entity that controls, is controlled by or is under common control with a party, where «control» means ownership of 50 % or more of the shares, holdings or other securities carrying the right to vote in the election of directors or other management authorities.
• The Application refers to Solsius SelfCare, the mobile Application provided by the Company.
• Soles refers to the Solsius SelfCare connected insoles.
• The country refers to : France
• Device means any device that can access the Service, such as a smartphone or tablet.
• Personal data means any information that directly or indirectly identifies a natural person.
• Service refers to the Application and the Solsius SelfCare medical device.
• Service provider means any natural or legal person who processes data on behalf of the Company.
• Usage Data refers to data collected automatically, either generated by use of the Service or from the Service infrastructure itself.
• You means the person accessing or using the Service, or the company or other legal entity on whose behalf that person accesses or uses the Service.

2. Collection and use of your personal data

2.1. Data types

2.1.1. Personal data

When using our service, we may ask you to provide certain personally identifiable information that may be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• E-mail address
• First name and surname
• Usage data
• Specific personal data: age, weight, date of birth, shoe size, etc.
• Medical data such as the names of medical professionals involved in your care, dates of consultations, etc.

2.1.2. Usage data

Usage data is collected automatically when you use the service, as soon as you register.

When you access the Service via a Mobile Device, we may automatically collect certain information including, but not limited to, the type of mobile device you are using, the unique identifier of your Mobile Device, the IP address of your Mobile Device, your operating system, unique device identifiers and other diagnostic data.

2.1.3. Location data

When using the Application, we may use data relating to the location of your smartphone. This data is never recorded and is used solely to ensure the correct operation and, in particular, the optimisation of communications between the Insoles and the Application.

The use of localisation allows you to : 

• Wake up the Application in the background so that it automatically connects via Bluetooth to the Insoles worn by the user; ;
  
• Provide certain technical functions linked to the use of Insoles and the Application, without you having to intervene.

Under no circumstances will this data be used for advertising or commercial purposes. It is strictly limited to technical use, with the sole aim of ensuring the correct operation of the Application and the Device. 

When the collection of location data is not essential, no data is recorded. If certain functionalities require your specific authorisation, you will be clearly informed.

2.1.4 Information collected when using the Application

We collect your personal data for specific purposes and on different legal grounds.

As part of the provision of our mobile application, Solsius SAS uses the following personal data in particular:

2.2. Use of your personal data

The Company may use Personal Data for the following purposes:

• To provide and maintain our service, including to monitor the use of our service.
• To manage your account to manage your registration as a user of the Service.
• To contact us to contact you by e-mail, telephone calls and SMS or other forms of electronic communication regarding updates or informative communications.
• To manage your requests To respond to and manage your requests to us.
• For company transfers We may use your information to evaluate or carry out a merger, assignment, restructuring, reorganisation, dissolution or any other sale or transfer of all or part of our assets.
• For other purposes We may use your information for other purposes, such as data analysis, identifying usage trends, evaluating and improving our service.

We may share your personal information in the following situations:

• For company transfers : we may share or transfer your personal information as part of, or during the negotiation of, any merger, sale of the company's assets, financing or acquisition of all or part of our business to another company.
• With affiliates : We may share your information with our affiliates, in which case we will require those affiliates to comply with this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

2.3 Storage of your personal data

The Company will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our legal agreements and policies.

The Company will also retain usage data for internal analysis. Usage data is generally retained for a shorter period, except where such data is used to enhance security or improve the functionality of our service, or where we are legally required to retain such data for longer periods.

2.4. Transfer of your personal data

Your information, including your personal data, is processed at the Company's operational offices and at any other location where the parties involved in the processing are located. This means that this information may be transferred to and stored on computers located outside your state, province, country or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction.

Your consent to this privacy policy followed by your submission of this information represents your agreement to this transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your personal data will take place to any organisation or country unless adequate controls are in place, including the security of Your data and other personal information.

Your data will be stored on a secure HDS (Healthcare Data Hosting) server, hosted by ATE, a French company with ISO/ IEC 27001 certification.

2.5. Your rights - Access/ Rectification/ Deletion of your personal data

You are the only person to have communicated the data in our possession, via the Application. You have rights over your personal data. In accordance with the regulations on the protection of personal data, in particular articles 15 to 22 of the RGPD, and after proving your identity, you have the right to ask us to access, rectify or delete your personal data. With regard to the personal data we collect, you may exercise the following rights:

• A right of access (Article 15 of the RGPD): you have the right to request access to the personal data we hold about you.
• A right of rectification (Article 16 of the RGPD): you can request rectification of any inaccurate data concerning you
• A right to erasure or «right to be forgotten».» (Article 17 of the RGPD): you can request the deletion of your personal data in certain circumstances
• A right to portability (Article 20 of the RGPD): under certain conditions you can receive all your personal data in a structured format.
• The right to object to processing by invoking legitimate interests (Article 21 of the RGPD)
• The right to define what happens to your data after your death (Article 40-1 of the French Data Protection Act)

Contact us to exercise your rights:

Email : dpo@solsius.fr
Postal address: 12 bis Rue des Tours, 59800 Lille, FRANCE

2.6. Disclosure of your personal data

2.6.1. Commercial transactions

If the Company is involved in a merger, acquisition or sale of assets, your personal data may be transferred. We will inform you before your personal data is transferred. We will inform you before your personal data is transferred and becomes subject to a different privacy policy.

2.6.2. Law enforcement agencies

In certain circumstances, the Company may be obliged to disclose your personal data if required to do so by law or in response to valid requests from public authorities.

2.6.3. Other legal requirements

The Company may disclose your personal data in the good faith belief that such action is necessary to:

• Complying with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in relation to the Service
• Protect the personal safety of Users of the Service or members of the public
• Protecting yourself against legal liability

2.7. Security of your personal data

The security of your personal data is important to us, but please remember that no method of transmission over the Internet or method of electronic storage is 100 % secure. Although we endeavour to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

3. Children's privacy

Our service is not intended for persons under the age of 18. We do not knowingly collect any personally identifiable information from anyone under the age of 18.

4. Changes to this privacy policy

We may update our privacy policy from time to time. We will notify you of any changes by posting the new privacy policy on this page.

We will notify you by e-mail and/or by means of a prominent notice on our service before the change takes effect and will update the «Last updated» date at the top of this privacy policy.

You are advised to consult this confidentiality policy periodically for any changes. Changes to this confidentiality policy come into force as soon as they are published on this page.

5. Contact the CNIL

You may at any time contact the «Commission nationale de l'informatique et des libertés» or «CNIL» at the following address:

CNIL Complaints Department
3 place de Fontenoy - TSA 80751
75334 Paris Cédex 07
Telephone: 01.53.73.22.22

6. Contact us

If you have any legal questions or would like further information about our Privacy Policy, please contact us:

By e-mail : dpo@solsius.fr

By post:
Solsius SAS
12 bis rue des Tours
59800 Lille, France

By indicating :

• Your contact details (surname, first name, address)
• A specific reason linked to your situation, when required by law
• The legal basis for exercising your right to erasure