Privacy Policy

1. Who is the data controller?

The data controller is KC KOMPANION CARE, a société par actions simplifiée (simplified joint-stock company), registered with the Paris Trade and Companies Register (RCS) under number 983 608 571, whose registered office is located at 26 rue de Charonne, 75011 Paris, France ("we", "us", "our").

2. What data do we collect?

Personal data is data that can be used to identify an individual, either directly or by cross-referencing it with other data.

We collect personal data falling into the following categories:

2.1. Regarding Application users:

• Identification data (last name, first name, email address, phone number);
• Connection data (connection logs, encrypted passwords);
• If you choose to sign in using a third-party authentication service (for example, Google or Facebook), certain data such as your name and email address may be retrieved from that service. By choosing this sign-in method, you agree that the relevant service may share this data with us. We do not collect the password for your third-party account;
• Data relating to your memories (photographs, videos, stories, etc.) and content generated from them;
• Data relating to the effects of the Application on your mood and emotional well-being (feedback provided through questionnaires while using the Application, reactions to content generated by the Application via voice messages or text messages);
• Application usage data (time spent using the Application, satisfaction rate).

2.2. Regarding WhatsApp Group users:

• Identification data (last name, first name, phone number);
• Family-related data (relationship to the Application user, memories in the form of photographs, videos and stories).

Mandatory data fields are indicated when you provide us with your data. They are flagged by any appropriate means.

3. How do we collect your personal data?

We collect your personal data in two ways:

• directly, when you have provided it to us (by creating an account on our Application or by sending us memories about you through the WhatsApp Group);
• indirectly:
  • when you are an Application user: we collect data about you from your relatives through the WhatsApp Group;
  • when you are a WhatsApp Group user: we collect your contact details from your relative who is an Application user.

4. Details on the processing of your personal data

5. Who are the recipients of your data?

The following will have access to your personal data:

1. Our company's staff;
2. Our subcontractors: hosting provider, CRM tool, audience measurement and analytics provider, email service provider, transactional email provider, artificial intelligence tools;
3. Healthcare institutions offering use of the Application to their patients, acting as independent data controllers. We accept no liability for the processing of personal data carried out by our partners and invite you to consult their own privacy notices;
4. Any authority legally entitled to access it, in particular judicial, police or administrative authorities, upon their request.

6. May your data be transferred outside the European Union?

Your data is retained and stored throughout the duration of processing on the servers of Google Cloud Platform and Xano, located within the European Union.

As part of the tools we use (see the section on recipients regarding our subcontractors), your data may be transferred outside the European Union. Such transfers are secured using the following mechanisms:

• either the data is transferred to a country that is the subject of an adequacy decision by the European Commission, in accordance with Article 45 of the GDPR: in this case, that country is deemed to ensure a level of protection considered sufficient and adequate under the GDPR;
• or the data is transferred to a country whose level of data protection has not been recognised as adequate under the GDPR: in this case, such transfers are based on appropriate safeguards set out in Article 46 of the GDPR, adapted to each provider, including, without limitation, the conclusion of standard contractual clauses approved by the European Commission, the application of binding corporate rules, or under an approved certification mechanism;
• or the data is transferred on the basis of one of the appropriate safeguards described in Chapter V of the GDPR.

You may obtain a copy of the tools used to transfer your data outside the European Union by contacting us using the details indicated in the "What are your rights regarding your data?" section below.

7. What are your rights regarding your data?

You have the following rights regarding your personal data:

• Right to information: this is precisely why we have drawn up this Privacy Policy. This right is provided for in Articles 13 and 14 of the GDPR.
• Right of access: you have the right to access all of your personal data at any time, under Article 15 of the GDPR.
• Right to rectification: you have the right to rectify inaccurate, incomplete or outdated personal data at any time, in accordance with Article 16 of the GDPR.
• Right to restriction: you have the right to obtain restriction of the processing of your personal data in certain cases defined in Article 18 of the GDPR.
• Right to erasure: you have the right to require that your personal data be erased, and to prohibit any future collection, for the reasons set out in Article 17 of the GDPR.
• Right to give instructions regarding the retention, erasure and disclosure of your personal data after your death.
• Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of processing carried out before the withdrawal.
• Right to data portability: under certain conditions set out in Article 20 of the GDPR, you have the right to receive the personal data you have provided to us in a standard, machine-readable format and to have it transferred to a recipient of your choice.
• Right to object: under Article 21 of the GDPR, you have the right to object to the processing of your personal data. Please note, however, that we may continue processing your data despite this objection, for legitimate reasons or for the defence of legal claims.

You may exercise these rights by writing to us at:

We may ask you, on this occasion, to provide us with additional information in the event of reasonable doubt, or indeed any document capable of proving your identity if the doubt persists.

For any question or request that remains unresolved, you are entitled to lodge a complaint with the competent supervisory authority, in France the Commission Nationale de l'Informatique et des Libertés ("CNIL"), located at 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.

8. Changes

We may amend this Privacy Policy at any time, in particular to comply with any regulatory, case-law, editorial or technical developments. Such amendments will apply as of the effective date of the amended version. You are therefore invited to regularly check the latest version of this policy. Nevertheless, we will inform you of any significant change to this privacy policy.

Effective date: 9 July 2026