Preamble

FixScan places the utmost importance on protecting its users' personal data. This Privacy Policy

describes the data collected, how it is processed, retained, and protected, in accordance with the

General Data Protection Regulation (GDPR – EU Regulation 2016/679) and applicable national

data protection law.

Article 1 – Data Controller

The data controller is FixScan, the publisher of the Application.

Data Protection contact: privacy@fixscan.app

Article 2 – Data Collected

2.1 – Account Data

• Email address

• Username / first name (optional)

• Password (stored in hashed and salted form, never in plain text)

2.2 – Usage Data

• Images or photos submitted for analysis (deleted after processing, within 24 hours)

• Diagnosis history (if enabled by the user)

• Interactions with the Application (features used, frequency of use)

• Technical data (device model, OS version, Application version)

2.3 – Payment Data

FixScan does not collect or store any banking or payment card data. Transactions are handled

entirely by the Apple App Store or Google Play Store.

2.4 – Location Data

The Application does not collect precise geolocation data. An approximate location (country/region)

may be inferred from the IP address for aggregated statistical purposes only.

Article 3 – Purposes and Legal Bases for Processing

• Provision of the AI diagnostic service – Performance of a contract

• User account management – Performance of a contract

• Application improvement and AI model training (anonymised data only) – Legitimate interest

• Communications about updates and new features – Consent

• Fraud prevention and security – Legitimate interest

• Compliance with legal obligations – Legal obligation

Article 4 – Data Retention Periods

• Active account data: duration of account activity + 3 years after deletion

• Images submitted for analysis: immediate deletion after processing (within 24 hours)

• Diagnosis history: retained while the account is active, deleted upon request

• Billing data: 10 years (statutory accounting obligations)

• Connection logs: 12 months

Article 5 – Data Sharing

FixScan never sells its users' personal data. Data may be shared with:

• Cloud infrastructure and AI service providers (subcontractors bound by GDPR-compliant

agreements)

• Distribution platforms Apple / Google in the context of in-app purchases

• Competent authorities upon lawful judicial request

Any transfer of data outside the European Union is governed by appropriate safeguards (European

Commission standard contractual clauses or an adequacy decision).

Article 6 – Data Security

• Encryption of data in transit (TLS 1.2+) and at rest (AES-256)

• Password hashing (bcrypt)

• Strict access control and enhanced authentication for internal teams

• Regular security audits

Article 7 – Your Rights (GDPR)

In accordance with the GDPR, you have the following rights regarding your personal data:

• Right of access: obtain a copy of the data we hold about you

• Right to rectification: correct inaccurate or incomplete data

• Right to erasure: request the deletion of your data ("right to be forgotten")

• Right to restriction: limit certain processing operations

• Right to data portability: receive your data in a machine-readable format

• Right to object: object to processing based on legitimate interest

• Right to withdraw consent at any time, without affecting the lawfulness of prior processing

To exercise your rights: privacy@fixscan.app — We will respond within one month of receiving

your request.

You also have the right to lodge a complaint with your local supervisory authority. In France: CNIL –

www.cnil.fr

Article 8 – Cookies and Trackers

The FixScan mobile application does not use cookies in the traditional sense. Technical identifiers

(device ID, session token) are used to ensure the Application functions correctly and to maintain

user sessions. These trackers are strictly necessary for the service to operate and do not require

prior consent.

Article 9 – Artificial Intelligence and Images

Images you submit are transmitted to our AI analysis engine solely for the purpose of providing a

diagnosis. They are not used to train our models without prior anonymisation and removal of any

information that could identify a natural person.

FixScan commits to never using your images for commercial or advertising purposes.

Article 10 – Minors

The Application is not intended for children under the age of 13. FixScan does not knowingly collect

personal data from children under 13. If we become aware that an account belongs to a user under

the age of 13, we will immediately delete all associated data.

Article 11 – Policy Updates

This Privacy Policy may be updated at any time to reflect legal developments or changes in our

practices. Any material modification will be notified to the user via the Application or by email. The

date of the last update is indicated below.