This Privacy Policy describes how Saneftec SAS ("Saneftec", "we", "us", "our") collects, uses, and protects personal data in connection with FootLens, a mobile application for clinicians and rehabilitation specialists.
FootLens is available on iOS and Android. It allows professionals to manage client records and conduct footprint analyses. All client data is encrypted on the user's device before any cloud synchronisation — Saneftec has no technical means to access client data in decrypted form.
This policy applies to all users of the FootLens application, regardless of location. Where applicable, we process personal data in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and applicable French data protection law administered by the CNIL. Users located outside the EU benefit from equivalent protections as described in this policy.
Data Controller and Processor
Data Controller for account data: Saneftec SAS, 93 Cours Berriat, 38000 Grenoble, France (SIRET 947 999 280 00011) is the data controller for personal data collected directly from FootLens users — specifically, authentication and subscription data.
Data Processor for client data: For data that FootLens users input about their own clients (names, dates of birth, assessment results, footprint images), Saneftec acts solely as a data processor. The FootLens user (the clinician or practitioner) is the data controller for that data and is solely responsible for ensuring their collection and use of client data complies with applicable law, including obtaining any necessary consent from their clients.
Saneftec cannot access client data in decrypted form at any point. See §4 (Zero-Knowledge Architecture) for the technical details.
Data We Collect
Saneftec collects only what is necessary for the purposes described in this policy.
| Category | Data points | Source |
|---|---|---|
| Authentication data | Authentication token | Google Sign-In or Sign in with Apple |
| Subscription data | Subscription status token and plan type. No payment card details. | Apple App Store / Google Play in-app purchase |
| Client records & footprint assessments | Client names, dates of birth, assessment results, footprint images. Encrypted on the device; Saneftec receives only an encrypted blob. | Entered by the FootLens user (see §1 and §4) |
| Aggregated usage statistics | Depersonalised, bucketed, and aggregated on the device before transmission. No identifiers. | FootLens app (if collected) |
Important: All client records and footprint assessments are encrypted on the user's device using a locally generated key before being transmitted to cloud storage. Saneftec receives only an opaque encrypted blob and has no means of decrypting it.
On analytics: Any usage data shared with Saneftec is processed locally on the device first — depersonalised, bucketed, and aggregated — before transmission. Data received by Saneftec in this form does not constitute personal data under GDPR Recital 26 and is used solely to understand aggregate usage patterns.
Legal Basis for Processing
We process personal data on the following legal bases under GDPR Article 6:
- Contract performance (Art. 6(1)(b)): Processing authentication and subscription data is necessary to provide FootLens services, including cloud backup and subscription management.
- Legitimate interests (Art. 6(1)(f)): Maintaining the security and integrity of our systems, and handling anonymised crash and usage data to improve the application. We have balanced these interests against users' privacy rights and concluded they do not override individual rights.
- Legal obligation (Art. 6(1)(c)): Retaining transaction records as required by French commercial and tax law.
Special category data (GDPR Article 9): Client records entered into FootLens may include health-related data (e.g. physical measurements, clinical assessments). This data is processed by FootLens users in their capacity as data controllers, typically on the basis of Art. 9(2)(h) (health or social care purposes by a professional) or Art. 9(2)(a) (explicit consent from the client). Saneftec, as data processor, never accesses this data in decrypted form and does not independently determine its processing purpose.
Zero-Knowledge Architecture
FootLens is designed so that Saneftec cannot access your client data. Here is how it works:
- Local encryption: All client records and footprint assessments are encrypted on your device using a locally generated encryption key before being written to the local database or transmitted to cloud storage.
- Key stays on device: The encryption key never leaves your device in a form accessible to Saneftec. It is stored locally and is not associated with your account credentials.
- Cloud backup is opaque: When you enable cloud backup, only the encrypted data blob is uploaded to our servers. Saneftec receives and stores ciphertext only — we have no means, technically or legally, to decrypt or access the content.
- Key export: You may export your encryption key as a QR code for safekeeping. This is the only copy of the key that can be used to restore your data on a new device. Saneftec does not hold a copy.
This architecture means that FootLens client data is not personally identifiable to Saneftec at any point.
How We Use Data
- Authentication data is used solely to identify your account and provide access to FootLens, including cloud backup.
- Subscription data is used to verify your active subscription and grant access to premium features.
- Client records and footprint assessments are stored and synchronised on your behalf. Saneftec does not access, analyse, or use this data for any purpose — it remains encrypted and opaque to us at all times.
- Aggregated usage statistics (if collected) are generated entirely on-device through local depersonalisation and bucketing before any data leaves your device. What reaches Saneftec's servers is not personal data under GDPR Recital 26 — it contains no identifiers and cannot be traced back to an individual. These statistics are used to understand app stability and usage patterns, with no individual profiling.
We do not use any personal data for advertising, profiling, or sale to third parties.
Data Storage and Retention
All server-side data is stored within the European Economic Area (EEA) on EU-based cloud infrastructure.
| Data category | Retention period |
|---|---|
| Authentication data | For the duration of your account. Deleted immediately upon account deletion. |
| Subscription data | For the duration of your subscription plus the period required by French tax law (10 years, Art. L.123-22 Code de commerce). |
| Encrypted cloud backup | For the duration of your account. Deleted immediately upon account deletion, or when you generate a new encryption key (which triggers a full wipe of prior cloud data). |
| Local database | Stored on your device only. Removing the app deletes all local data. Saneftec has no control over local device data. |
Account deletion: You may delete your account at any time directly from within the FootLens app. Deletion is immediate and permanent — your authentication data and encrypted cloud backup are deleted from our servers at the moment of deletion. This action is irreversible and the deleted data is irrecoverable.
Data Sharing and Sub-processors
Saneftec does not sell, rent, or trade personal data. We share data only with the following categories of third parties, to the extent strictly necessary:
| Category | Role | Data shared | Location |
|---|---|---|---|
| EU-based cloud infrastructure provider | Backend infrastructure, authentication, cloud storage | Authentication data, subscription status, encrypted backup blob | EU / EEA |
| Google LLC | Authentication provider (Google Sign-In), app distribution (Google Play), in-app purchases | Authentication token, subscription purchase data | USA (EU-US Data Privacy Framework) |
| Apple Inc. | Authentication provider (Sign in with Apple), app distribution (App Store), in-app purchases | Authentication token, subscription purchase data | USA (EU-US Data Privacy Framework) |
Saneftec may also disclose cloud data to law enforcement or regulatory authorities where required to do so by applicable law. We have no discretion in such cases and do not proactively share data with any authority.
No personal data is transferred outside the EEA except where the recipient provides adequate protections under GDPR Chapter V, including Standard Contractual Clauses or the EU-US Data Privacy Framework as applicable.
Encryption Key Management and Data Loss
You are solely responsible for your encryption key.
Your encryption key is generated on your device and stored locally. Saneftec does not hold a copy of your key and cannot recover it on your behalf under any circumstances.
If you lose your encryption key:
- Your cloud backup data is permanently inaccessible. Saneftec cannot decrypt it, retrieve it, or provide any form of recovery.
- Your only option is to generate a new encryption key within the app. Generating a new key permanently and irrecoverably deletes all previously encrypted cloud data associated with your account.
- Local data on your device remains accessible as long as the app and device are intact.
We strongly recommend exporting your encryption key as a QR code and storing it securely (for example, in a password manager or printed and stored offline). This is the only mechanism available to restore your cloud data on a new or replacement device.
Saneftec accepts no liability for data loss resulting from loss of the encryption key.
Subscriptions and In-App Purchases
FootLens is available on a subscription basis, with a 3-day free trial. Subscriptions are managed entirely through Apple App Store (iOS) and Google Play (Android) in-app purchase systems.
- Saneftec does not receive or store your payment card details. Payment processing is handled exclusively by Apple or Google.
- Saneftec receives only a subscription status token and plan type from Apple or Google, sufficient to verify your entitlement to use FootLens features.
- Subscription renewal, cancellation, and refund requests are governed by Apple's or Google's own terms and must be managed through your App Store or Google Play account settings.
For Apple: support.apple.com/billing
For Google: support.google.com/googleplay/answer/7018481
Your Rights
EU / EEA users (GDPR): Under the General Data Protection Regulation, you have the following rights regarding personal data held by Saneftec:
- Access (Art. 15): Request a copy of the personal data we hold about you.
- Rectification (Art. 16): Request correction of inaccurate or incomplete data.
- Erasure (Art. 17): Request deletion of your personal data, subject to legal retention obligations.
- Restriction (Art. 18): Request that we restrict processing in certain circumstances.
- Portability (Art. 20): Request your data in a structured, machine-readable format where technically feasible.
- Objection (Art. 21): Object to processing based on legitimate interests.
- Withdrawal of consent (Art. 7(3)): Where processing is based on consent, withdraw at any time without affecting prior processing.
Note: Because client data is encrypted and inaccessible to Saneftec, we are unable to fulfil access, rectification, erasure or portability requests with respect to that data. Those requests should be directed to the FootLens user (your clinician) who entered the data.
To exercise your rights regarding account data, please use the contact form on our website. We will respond within one month (extendable by two months for complex requests, with notification).
You also have the right to lodge a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés), the French data protection supervisory authority: www.cnil.fr.
International users: Where local law provides equivalent or additional rights, Saneftec will endeavour to honour those rights to the extent technically possible. This includes, where applicable, rights under the California Consumer Privacy Act (CCPA) and similar legislation. Saneftec does not sell personal data.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in the app, our practices, or applicable law. Any changes will be indicated on this page with an updated date. For material changes, we will notify users via the app or by email where possible. Continued use of FootLens after a change constitutes acceptance of the revised policy.
Contact
For any questions about this policy, your personal data, or to exercise your rights, please use the contact form on our website.
Postal address: Saneftec SAS, 93 Cours Berriat, 38000 Grenoble, France
We will acknowledge data protection requests promptly and respond within one month of receipt. You also have the right to lodge a complaint with the CNIL at www.cnil.fr.