This policy describes how Prevox collects, processes and protects your personal data, including your health data (GDPR article 9). It is intended to be read together with the Terms of Service.
1. Who is responsible for your data?
Prevox SAS (registration pending), registered office to be confirmed, France. Data controller within the meaning of GDPR article 4. DPO reachable at dpo@prevox.health.
2. What data do we collect?
- Identity: last name, first name, email, date of birth, administrative gender.
- Health data (GDPR art. 9): medical history, allergies, treatments, vaccinations, medical documents, Ophamir score, MindWatch sessions.
- Connected data: wearables (heart rate, sleep, HRV) if you enable Apple Health / Health Connect sync.
- Technical data: IP address, device type, connection logs (article 6.1.f, legitimate security interest).
- Sharing data: grants you have granted to your doctors (who, what, for how long), immutable audit log.
3. On what legal basis?
- Explicit consent (GDPR art. 9.2.a) for health data.
- Performance of the service contract (art. 6.1.b) to deliver Prevox.
- Legitimate interest (art. 6.1.f) for security and fraud prevention.
- Legal obligation (art. 6.1.c) to retain health access logs for 10 years (French decree 2016-994).
4. What is your data used for?
- Providing you with an end-to-end encrypted medical record, accessible from your devices.
- Computing your Ophamir preventive score on data that you keep.
- Allowing you to share part of your record with doctors, for a limited duration and with a precise scope.
- Notifying you of appointments, medication reminders, and the signal of the day (notifications chosen by you).
- Anonymised scientific research, only if you have explicitly accepted, never by default.
5. How long do we keep your data?
- Active data: as long as your account is active.
- Health data after account deletion: 30 days in a recovery holding period, then definitive cryptographic erasure.
- Health data access logs: 10 years (French decree no. 2016-994).
- Encrypted backups: 90 days maximum.
6. Who can access your data?
Prevox applies a zero-trust model: even our teams cannot decrypt your record. The only possible accesses are:
- Yourself, from your devices.
- Doctors to whom YOU have granted access, within the scope and duration you defined.
- The 5 Shamir holders of the Prevox escrow, and only if you enable recovery and at least 3 of them reconstitute the key (documented procedure).
- Our technical hosts, Supabase (database) and Vercel (website), which only ever see ciphertext. They are not HDS-certified. Data is hosted in the person's region: in Dublin for Europe, in Canada for Canada.
7. Security
- AES-256-GCM encryption for your data at rest.
- Argon2id key derivation from your password.
- RSA-OAEP-2048 keys per user, private key never in clear on the server.
- RSA-OAEP wrap per grant (workstream K) for sharing: revoking a grant cryptographically destroys the doctor's access.
- Shamir 3-of-5 for recovery, 5 independent holders.
- SHA-256 hash chain on the audit log (each access verifiable).
- Hosting in the person's region: in Dublin for Europe, in Canada for Canada. Each new country gets its own database, announced when it opens.
- Annual penetration tests (to be scheduled once funded).
8. Your rights
- Access: download all of your data at any time.
- Rectification: correct any erroneous data.
- Erasure: delete your account. Note that for your encrypted data, erasure is cryptographic (definitive loss).
- Objection: revoke a grant in 1 click (the doctor's access disappears, including cryptographically).
- Portability: export in standard format (FHIR roadmap).
- Complaint with the CNIL: www.cnil.fr/fr/plaintes.
9. Minors
Prevox is reserved for people aged 16 and over. For minors between 16 and 18, parental consent may be required depending on use (sharing with a doctor, research).
10. Cookies
The Prevox website only uses cookies that are strictly necessary for operation (session). No third-party trackers, no marketing cookies.
11. Policy updates
Any substantial modification will be notified to you by email plus an in-app banner, 30 days before entry into force.
12. Contact
DPO: dpo@prevox.health. Support: support@prevox.health. Postal address: to be confirmed.