Privacy policy

This is a courtesy translation. The French version, politique de confidentialité, is the legally binding one.

Who we are

FramIQ is an iOS bike fitting app published by Gaspard Blanc, osteopath D.O. and bike fitter. It helps you optimise your position on the bike through video analysis, frame comparison and cleat setup.

Data controller: Gaspard Blanc, sole trader, 3C chemin du Nèple, 73420 Viviers-du-Lac, France. SIRET 930 445 325 00028.
For anything concerning your data: contact@gaspardblanc.fr.

There is no data protection officer: the business meets none of the three cases that require one under article 37 of the GDPR.

Data we collect

Only what the application needs to work.

What we still need to improve. Today, your analysis results and usage events are sent automatically, and you cannot turn this off in the app. They carry neither your name nor your email, but an installation identifier that links them together and to your purchases: they are therefore pseudonymous data, not anonymous data. A future version will let you choose, will remove this identifier from the results and will let you erase everything from the app. Until then, as this data carries nothing that designates you, we can only find it if you give us this identifier (Article 11 GDPR); the app does not display it yet. If you have an account, write to contact@gaspardblanc.fr: we will search from your purchases.

Videos and images: all video analyses and photos are processed entirely on your device. No image and no video is ever sent to our servers or to any third party.

What we do not collect

• GPS location data
• Contacts and address book
• Browsing history
• Financial data: payments are handled exclusively by Apple
• HealthKit health data
• Advertising identifiers: there is no tracker and no advertising SDK in the application

Hosting and transfers

Your account and session data are stored on servers operated by Railway, in its European region, in Amsterdam, the Netherlands. Hosting does not take them outside the European Union. As Railway Corp. is a US company, its support may need to intervene from the United States for maintenance: that case is covered by the European Commission's standard contractual clauses set out in its data processing agreement.

If you use “Your analysis in brief” or “Your frame search in brief”, the settings and angles of the analysis concerned, or the frames compared, are also sent to Anthropic, in the United States (see the dedicated section).

iCloud synchronisation goes through Apple CloudKit, subject to Apple's privacy policy.

The framiq.fr website itself is hosted by Infomaniak Network SA, in Switzerland. Switzerland is covered by a European Commission adequacy decision: no additional safeguard is required for this hosting.

We do not sell or rent any personal data. We disclose it to no one other than the providers described here (Railway, Apple, Google for crash reports, Infomaniak for the website, Anthropic for the “in brief” summaries if you use them), except where the law requires it.

While you type your address in "My information", the text is sent to Apple to suggest addresses.

Crash reports, Firebase Crashlytics

FramIQ uses Firebase Crashlytics, a Google service, to detect and fix crashes. It is the only third-party service built into the app, and it serves technical stability alone: no data is used for advertising or audience measurement.

When the app crashes, Crashlytics sends Google a technical report containing the device model, the iOS version, the app version, the execution trace at the time of the crash, a Firebase installation identifier and, if you are signed in, the internal identifier of your FramIQ account (a random number, without your name or email). That report contains no body measurements, no health history and no image or video. This is pseudonymous data.

Legal basis: legitimate interests, article 6(1)(f) GDPR, namely keeping the application working and secure. Reports are kept for 90 days by Google, then deleted. Google acts as a processor. A transfer outside the European Union is possible, framed by the European Commission's standard contractual clauses. To object to these reports being sent, write to contact@gaspardblanc.fr. The app does not let you turn them off yet: a future version will add this setting.

“Your analysis in brief” and “Your frame search in brief”, written by AI

On the results screen of an analysis, a button offers you “Your analysis in brief”: a short summary, of 50 to 90 words and with no figures, that explains what changes in your settings, why, and how to get used to it on your first rides. On the frame comparison screen, a button likewise offers you “Your frame search in brief”: a short summary, with no figures other than the names and sizes of the frames, that explains which frame best matches your position and what the others give up. These features are optional. They are reserved for the one-time purchase (“Full analysis”) and the subscription (“Unlimited access”): the free version does not offer them.

• Who writes it: Claude, the artificial intelligence model of Anthropic PBC, a company established in the United States. The app never contacts Anthropic directly: the FramIQ server, hosted by Railway in its European region, sends it the request and returns the text to you.
• What is sent to Anthropic: the language, your discipline and your riding level, then, for an analysis, its type (position analysis or post-adjustment check), the recommended and current settings (saddle height and setback, drop, stem, crank, handlebar or armrest width, saddle width) and the measured angles (knee, hip, shoulder, elbow, torso) with their target range; for a frame search, each frame compared (four at most) with its brand, model and size, its compatibility with your target position, its difference in length and height from that position, and whether it is a recent generation; if you fine-tune this advice (“Fine-tune for you”), your position preference: your goal (racing, all-round or comfort) and, where applicable, the wish for a higher front end or a less stretched position. If you mention a discomfort (lower back, neck and shoulders, hands, knees, saddle), it stays on your iPhone: the app turns it into a position preference before sending, and neither the discomfort nor its area is sent.
• What is never sent to Anthropic: your name, your email, any identifier, your body measurements (height, inseam and the others), your pain, your medical history, your video.
• Checking your purchase: the app sends the FramIQ server the proof of purchase signed by Apple, to check that your access is valid. This proof is not sent to Anthropic. To limit use to 10 summaries per day and per purchase (analyses and frame searches combined), the server keeps a SHA-256 fingerprint of your original transaction identifier, not the identifier itself, for 2 days at most, then erases it.
• What FramIQ keeps: no content, neither the data sent nor the text written. The server keeps only a counter, without content (volume of text processed, cost, status of the request), to track spending. The text written is kept on your iPhone, so that you find it again when you reopen your results; it is not sent to FramIQ.
• Anthropic's role: processor acting for FramIQ. Under the commercial terms of its API, Anthropic does not use this data to train its models and erases it within 30 days.
• Transfer outside the European Union: as Anthropic is established in the United States, this data leaves the European Union for the writing. This transfer is governed by the European Commission's standard contractual clauses, provided for in Anthropic's data processing agreement.
• Legal basis: your consent, Article 6(1)(a) GDPR. The first time you use it, the app shows you what is sent, what is never sent and to whom, and asks for your agreement. If you choose “Not now”, nothing is sent.
• Refusing or withdrawing your agreement: simply do not use the button, or stop using it. Nothing is sent without an action on your part.

Legal bases

• Performance of the contract: data needed for the application to work
• Consent: health history, collected optionally; “in brief” summaries, optional
• Legitimate interests: account security and fraud prevention

Retention periods

• Account data: for as long as the account is active
• Analysis sessions: until manually deleted, or until the account is deleted
• Data held locally on the device: until the app is uninstalled
• After deleting your account from the app: your account and its data are erased from our servers immediately, then from our backups as they are renewed, within 89 days at most. Analysis results and usage events linked to the installation identifier are not erased automatically (see above)
• Analysis results and usage events: until you ask for erasure; a maximum period will be applied by a future version
• Web server logs: 6 months at most
• Crash reports: 90 days
• “In brief” summaries: no content kept by FramIQ (neither the data sent nor the text written); purchase fingerprint erased after 2 days at most; counter without content (volume of text processed, cost, status); at Anthropic, erased within 30 days

Your rights

• Access: see the data we hold about you
• Rectification: correct inaccurate data
• Erasure: delete your account from the app, under Account then Delete my account (if you are signed in). Data on your iPhone and in your iCloud is erased by deleting the app and, in Settings, iCloud, Manage Storage, FramIQ. For data linked to your iPhone on our server, see above
• Portability: obtain your data in a structured format
• Objection: object to certain processing
• Restriction of processing
• Withdraw your consent at any time where consent is the basis, without affecting what was done before

To exercise these rights, write to contact@gaspardblanc.fr. You will get an answer within one month. If it does not satisfy you, you may lodge a complaint with the French data protection authority, the CNIL: 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France. If you live in another EU country, you may also lodge it with your own supervisory authority.

Security

• Sign in with Apple, no password stored
• Authentication tokens kept in the encrypted iOS Keychain
• Communications encrypted over HTTPS/TLS
• Video and photo analysis processed locally on the device

Purchases and quotas

One-time purchase, €29

• 1 complete postural video analysis, permanent, with no expiry
• 1 frame comparison across 3 models, permanent
• Free, unlimited cleat setup
• “In brief” summaries of the analysis and the frame search, written by AI, optional: 10 per day at most

The one-time purchase is for personal use. Access is personal, non-transferable and tied to the Apple account used for the purchase.

Annual subscription, €89 per year

• 5 postural analysis credits included on activation
• 1 extra credit added each month, on the anniversary date of activation
• Maximum balance of 8 credits
• Unrestricted frame comparisons and cleat setup
• “In brief” summaries of the analysis and the frame search, written by AI, optional: 10 per day at most

The phrase unlimited analyses means there is no permanent limit, not an infinite quota. If your balance runs out, you get new credits from the following month. Credits are personal, non-transferable and may not be used for commercial purposes.

Minors

FramIQ is intended for people aged 16 and over. We do not knowingly collect data about children under 16.

The website: cookies, logs and audience measurement

framiq.fr sets no cookie and uses no tracker: no audience measurement script, no advertising, no social media button. Nothing is written to or read from your device while you browse. That is why no consent banner is shown to you: there is nothing to consent to.

Fonts are served from our own servers, so no request is made to any third-party service while you read these pages. Only three pages query our own server. The shared report page, at framiq.fr/share/…, displays the report your practitioner prepared for you: that link is single-use and expires after 24 hours. The preparation questionnaire, at framiq.fr/preparation/…, sends your answers to your practitioner (see the dedicated section). The satisfaction questionnaire, at framiq.fr/avis/…, sends your feedback after a session to the practice that emailed it to you (see its section). None of these three pages can be indexed by search engines.

Server logs

Like any web server, the one hosting framiq.fr keeps a technical access log: IP address, date and time, page requested, response code, declared browser, referring page. That log is kept by our hosting provider, Infomaniak Network SA, in Switzerland.

• Purpose: keeping the site running and secure, and detecting abuse.
• Legal basis: legitimate interests, article 6(1)(f) GDPR.
• Retention: 6 months at most, then automatic deletion.
• Recipient: the hosting provider, acting as a processor. No third party.

Audience measurement

Site traffic statistics are produced from those server logs alone, by our hosting provider's statistics tool. No cookie is set, no measurement script is loaded in your browser, no data is passed to a third party, and the results only tell us which pages were read and how often. This falls within the exemption from consent that the CNIL provides for strictly necessary audience measurement, which is why you are not asked to choose.

Pre-appointment questionnaire

Practitioners who use FramIQ Pro may ask you to fill in a questionnaire before your appointment, at framiq.fr/preparation/…: contact details, date of birth, weight, shoe size, kilometres ridden per year, pain or injuries, equipment, club and comments.

• Data controller: the practice or practitioner named at the top of the questionnaire. They decide how your answers are used: preparing your session and completing your file.
• FramIQ's role: processor. FramIQ hosts your answers on behalf of the practice and makes them available to it in the FramIQ Pro app. It uses them for no other purpose and shares them with no one else.
• Legal basis: your explicit consent, given by ticking the box before sending (Article 9(2)(a) GDPR, as pain and injuries are health data). You can withdraw it at any time by contacting the practice.
• Hosting: Railway servers, European region (Amsterdam), as described above. Answers are sent encrypted over HTTPS.
• Retention: once the practitioner links your answers to your file, they follow that file's retention period, set by the practice. If they are never linked to a file, they are deleted automatically after 6 months.
• What is not kept with your answers: neither your IP address nor your browser. The page sets no cookie and stores nothing on your device, not even a draft. Like any server, the one that receives your answers keeps a technical log of its accesses (IP address, date, page address), kept for its security.
• Practitioner notification: each time you send the questionnaire, the practitioner receives an email showing only your first name, the initial of your last name and the appointment date, without any of your answers.
• Your rights: to access, correct or delete your answers, or to withdraw your consent, contact the practice, whose details appear on the questionnaire. You can also write to contact@gaspardblanc.fr: we will pass your request on to the practice concerned.

Post-session satisfaction questionnaire

About two weeks after a session, a practice that uses FramIQ Pro may email you a personal link to a short questionnaire, at framiq.fr/avis/…: how you feel on the bike, how your pain has changed, your rating of the bike fit, whether you would recommend the practice, and an optional comment.

• Data controller: the practice named on the questionnaire. It uses your answers to follow up on its adjustments and improve its sessions.
• FramIQ's role: processor. FramIQ sends the email, hosts your answers on behalf of the practice and makes them available to it in the FramIQ Pro app. It uses them for no other purpose and shares them with no one else.
• Legal basis: your explicit consent, given to the practice during your session (Article 9(2)(a) GDPR, as changes in your pain are health data). Without that consent, no questionnaire is sent to you.
• Hosting: Railway servers, European region (Amsterdam), as described above. Answers are sent encrypted over HTTPS.
• Retention: for as long as the practice follows you up with FramIQ Pro. Your answers are deleted when its contract ends, or sooner at your request.
• What is not kept with your answers: neither your IP address nor your browser. The page sets no cookie and stores nothing on your device. Like any server, the one that receives your answers keeps a technical log of its accesses (IP address, date, page address), kept for its security.
• Google reviews: if the practice has a Google review page, a link to it is offered after you send your answers, whatever your rating. Nothing is posted on your behalf.
• Unsubscribing: every email contains an unsubscribe link. Once you confirm, you no longer receive any satisfaction questionnaire, whichever the practice.
• Your rights: to access, correct or delete your answers, or withdraw your consent, contact the practice. You can also write to contact@gaspardblanc.fr: we will pass your request on to the practice concerned.

Changes

This policy may change. Where a change is significant, you will be told through the application. The last updated date appears at the top of this page.

Contact

About the service: hello@framiq.fr
About your personal data or to exercise your rights: contact@gaspardblanc.fr