FramIQ Pro privacy policy

1. Who is responsible for what

Three processing operations coexist in FramIQ Pro. They do not have the same controller.

Your patients' data

The practitioner or organisation using FramIQ Pro (the "practice") is the controller. The practice decides to open a record, collects consent, and decides what to keep or erase. FramIQ acts as a processor within the meaning of Article 28 GDPR: it processes this data on the practice's instructions, to provide the service, under the data processing agreement (DPA) signed with it.

The practitioner's account

For account, practice and contract data, FramIQ is the controller.

Research, if the practice and the patient have agreed

When a practice has subscribed to the "research" option and a patient has given separate, optional consent, FramIQ becomes the controller for reusing that patient's data for research purposes (section 8).

2. Publisher

Gaspard Blanc, sole trader (entrepreneur individuel), osteopath D.O. and bike fitter, trading as FramIQ and OBF Studio. These names do not designate separate companies.
3C chemin du Néplé, 73420 Viviers-du-Lac, France. SIRET 930 445 325 00028.
Full details in the legal notice (FR).

Contact for personal data: contact@gaspardblanc.fr. There is no data protection officer: the business falls under none of the cases where Article 37 GDPR requires one.

3. Data processed

Practitioner and practice account

• practitioner identity and contact details, practice address, SIRET and VAT number where applicable
• ADELI or RPPS number, when provided
• IBAN and BIC, solely to appear on the invoices the practitioner issues
• logo, custom wording, services and prices of the practice
• email address, password stored as a hash, first-login and reset tokens
• connected devices (device name, technical identifier)
• contract data (plan, amount, dates, payment)

Patient data, entered by the practitioner or by the patient

• identity: last name, first name, sex, date of birth
• contact details: email address, phone number, postal address
• cycling profile: discipline, level, annual distance, cadence
• body measurements: height, inseam, arm, femur, sit bone width and other protocol measurements, weight, shoe size
• health data: pain areas, medical history, prescribed exercises, practitioner's observations, pain progression after the session
• session data: joint angles computed from video (knee, hip, trunk, elbow), aerodynamic measurements, bike settings, equipment, frame geometry
• billing: patient identity and address, service, amounts, payment method and reference
• consent: date collected, method (signature or email code), version of the accepted text, integrity hash; where applicable, research consent or refusal, with its date and version
• preparation questionnaire filled in by the patient before the session (contact details, date of birth, weight, shoe size, annual distance, pain or injuries, equipment, club, remarks)
• answers to the satisfaction questionnaire (feeling, pain progression, rating, comment)

Technical data

Server connection and operation logs (IP address, date, request, browser or app).

4. What stays on the practitioner's device

Photographs taken for measurement and consent signatures stay on the practitioner's iPhone, iPad or Mac, and in that device's backups (iCloud or computer) if the practitioner has enabled them. They are never uploaded to FramIQ's servers. No video is recorded: analysis happens live, and only the computed angles are kept.

The biomechanical calculation runs entirely on the device. It does not depend on any server.

5. Hosting, service providers and transfers

• Railway Corporation (United States): hosting of the API and database, and therefore of all synchronised data. European region, Amsterdam (Netherlands): data is stored in the European Union. As Railway is subject to US law, access by its support staff from the United States is possible, and some technical operations (monitoring, logs) may take place there. Railway participates in the EU-US Data Privacy Framework (adequacy decision (EU) 2023/1795) and its processing agreement also includes the standard contractual clauses.
• Resend (United States): sending emails (consent code, research question, report sharing, satisfaction questionnaire, notifications to the practitioner). Data: recipient's email address and first name, practice name, message content and links. Resend participates in the EU-US Data Privacy Framework and its processing agreement also includes the European Commission's standard contractual clauses. Messages are kept for 30 days by Resend.
• Infomaniak Network SA (Switzerland): hosting of the framiq.fr website and questionnaire pages, publisher's mailbox. Switzerland benefits from a European Commission adequacy decision.
• Base adresse nationale (French government public service): address suggestions while typing, based only on the address text, without any name.
• Apple: app distribution, with no patient data.

6. Legal bases

• Patient data: the patient's explicit consent (Article 9.2.a GDPR), collected by the practice in the app before any data entry; for FramIQ, the processing agreement with the practice.
• Research (section 8): the patient's explicit, separate and optional consent (Articles 6.1.a and 9.2.a), and the practice's written agreement.
• Practitioner account: performance of the subscription contract; accounting obligations for subscription billing.
• Technical logs and security: FramIQ's legitimate interest in running and securing the service.

7. What FramIQ does and does not do with patient data

FramIQ processes patient data to run the service, on the practice's instructions, and for nothing else, subject to anonymisation on deletion described below and to section 8.

Anonymisation on deletion. When a record is deleted (end of the practice's contract, request of the patient or of the practice), FramIQ may, if the practice's contract allows it, keep an irreversibly anonymised version of it to improve the tool: no name, no contact details, no free text, no exact date, age in bands. Anonymised data no longer identifies anyone and is no longer personal data.

FramIQ never sells data that identifies a patient, does not use it for advertising and does not disclose it to any third party, except to the providers in section 5, to the patient at the practice's request (report sharing), or when required by an authority.

8. Research and improvement (optional)

This section only applies to patients of a practice that has subscribed to the "research" option, and only if they agreed by ticking a separate box, never pre-ticked, or by answering "Yes" to the question received by email. Refusing changes nothing about the postural assessment.

• What is reused: measurements, settings, session results and health data (pain, types of medical history), after pseudonymisation. Name, contact details, practitioner's notes, free-text fields, photographs, videos and signature are never included. Data of minor patients is excluded.
• For what purpose: research and improvement of bike fitting methods, in particular training artificial intelligence models by FramIQ.
• Where: only on a computer of the publisher, located in France, in an encrypted space, outside any online storage service. The data is extracted there from the service database; models are trained on this computer and nowhere else, without sending this data to any third-party service.
• Sharing: only anonymised data and the results of this work, in particular trained models, which identify neither a patient nor a practice, may be made available to partners, for example cycling companies, including under commercial agreements. The pseudonymised data itself is never disclosed.
• Retention: in pseudonymised form, as long as the patient's record is kept by the practice; when the record is deleted, the data is anonymised.
• Withdrawal: at any time, with the practice or with FramIQ (contact@gaspardblanc.fr). The data leaves the research set within 30 days of the request. Data already anonymised and models already trained cannot be changed afterwards. A request to erase the record counts as withdrawal.
• Start date: no data is reused for research before 28 September 2026, nor without the patient's consent given after that date.

9. Retention periods

Data	Period
Patient record (file, sessions, questionnaires, satisfaction)	as long as the practice follows the patient with FramIQ Pro, as stated in the consent; deleted at the end of the practice's contract (row below) or earlier at the request of the patient or the practice (section 11)
Preparation questionnaire not linked to a record	6 months
Report sharing link	until it expires or is retrieved by the patient
Link to answer the research question	30 days
Invoices issued by the practice to its patients	during the contract; their legal retention is the practice's responsibility, which exports them before the contract ends
Practice data after the contract ends	deleted 30 days after the end of the contract, after an export period; a deletion certificate is sent to the practice
Practitioner account	term of the contract, then 12 months
Invoices issued by FramIQ	10 years (accounting obligations)
Pseudonymised research set	as long as the patient's record is kept by the practice, then anonymised
Anonymised data	no time limit: it no longer identifies anyone and is no longer personal data
Server technical logs	30 days, then automatically erased by the host
Database backups	daily (kept 6 days), weekly (27 days) and monthly (89 days); deleted data therefore disappears from all backups no later than 89 days after its deletion

10. FramIQ's access to practice data

The publisher technically has access to the database. It only consults a practice's data for three reasons: to answer a request from the practice (support, rectification, deletion, extraction), to ensure the security and continuity of the service, or to meet a legal obligation. It is bound to secrecy about what it sees.

11. Your rights

Patients: rights of access, rectification, erasure, restriction, objection and portability, and withdrawal of consent at any time, with the practice that saw you. FramIQ assists it: on its written request, FramIQ extracts or deletes a record within 7 days. Withdrawal of research consent can also be sent to FramIQ.

Practitioners: the same rights over your account data, with FramIQ, at contact@gaspardblanc.fr. A full export of your data is available in the app (Account, Export my data).

Answer within one month. You may lodge a complaint with the French data protection authority, cnil.fr. If you live in another European Union country, you may also contact the data protection authority of your own country.

12. Security

• encryption of exchanges between the app and the server (HTTPS)
• passwords stored as hashes, never in clear text; consent codes and answer links stored as hashes
• session bound to each device, revocable remotely; token stored in the system keychain
• biometric app lock, which the practitioner can enable
• data partitioned per practitioner account
• sessions and invoices sealed by a chained integrity hash on the server
• photographs and signatures never sent to the server

13. Data breach

In the event of a personal data breach, FramIQ informs the practices concerned without undue delay, and no later than 24 hours after becoming aware of it, with the information they need for their own notification to the CNIL and, where applicable, to their patients.

14. Minors

A minor patient's data is only entered with the consent of a holder of parental authority. It never enters the research set.

15. Changes

This document may change. The last updated date appears at the top. Any substantial change is notified to practitioners by email and in the app at least 30 days before it takes effect. A change concerning the use of patient data requires the practice's express agreement.

16. Contact

Personal data: contact@gaspardblanc.fr · Service: hello@framiq.fr

See also: FramIQ Pro · Terms of use · Legal notice (FR)