The Tongue Teacher SAS
Version 1.0 dated 13/11/2025
Article 1 – Purpose of the Policy
1.1 Purpose
This Privacy Policy aims to explain clearly and transparently how The Tongue Teacher SAS collects, uses, and protects your personal data when you use its mobile application.
1.2 Scope
It applies to all patients using the mobile application, whether adults or minors (in the latter case, under the responsibility of their parents or legal representatives).
Article 2 – Data Controller
2.1 Identification
The controller of your data is your practitioner (orthodontist or healthcare professional), who decided to register you on the platform.
2.2 Role of The Tongue Teacher SAS
The Tongue Teacher SAS acts as a data processor on behalf of the practitioner, meaning it hosts and processes your data for them.
2.3 Contact details
For any questions regarding your data, you may contact:
- your practitioner directly;
- or the Data Protection Officer (DPO) of The Tongue Teacher SAS: dpo@tongueteacher.com.
Article 3 – Data Collected
3.1 Identification data
Last name, first name, age, contact details of the legal guardian if you are a minor.
3.2 Monitoring and usage data
- Attendance: number of completed sessions, frequency of application use.
- Progress: progress status within the programs.
- Responses to self-assessments.
- Exercises performed.
- Photos et videos : the application may ask you to take photos or videos as part of your rehabilitation (exercises, postures, self-assessments). These recordings are made directly via your mobile device’s camera. You are always free to accept or refuse to transmit these files to your practitioner. The photos and videos taken within the application constitute facial data. They show your face (front or profile view) during exercises and self-assessments. Your facial data is used exclusively within the framework of your therapeutic follow-up: during your self-assessments and while performing your exercises.
3.3 Technical data
IP address, connection logs, information related to the device used.
Article 4 – Purposes and Legal Bases
4.1 Monitoring your rehabilitation
Your data is used to allow your practitioner to monitor your rehabilitation programs.
Legal basis: performance of the healthcare contract entered into with your practitioner.
4.2 Communication with your practitioner
Your data may be transmitted to your practitioner to inform them of your progress, results, or any refusals (e.g., if you refuse to send a video).
Legal basis: performance of the healthcare contract.
4.3 Aggregated statistics
Some of your data (e.g., attendance, progress) may be used in a strictly aggregated and anonymized form to produce global statistics (for example: average attendance level, program performance). These statistics never allow identification of you individually or your practitioner. Legal basis: legitimate interest of The Tongue Teacher SAS.
4.4 Security and maintenance
Technical data (IP, logs) is used solely to ensure the security and proper functioning of the application. Legal basis: legitimate interest.
4.5 No automated decision-making
Your data is not subject to any automated processing producing legal effects concerning you, nor to any automatic diagnosis.
Article 5 – Consent
5.1 Collection of consent
Certain data (such as videos and photos) requires your explicit consent.
This consent is collected through the application by means of checkboxes or clear messages.
5.2 Consentement des mineurs
For minors under 15 years of age, consent must be given by the parent or legal representative. For minors aged 15 or over, consent is obtained from the minor and confirmed by their parent or legal representative.
5.3 Withdrawal of consent
You may withdraw your consent at any time in the application settings. Withdrawal of consent does not affect the lawfulness of processing already carried out.
5.4 Operation of photos and videos
- Recording: when you take a photo or video in the application, a confirmation screen indicates whether the file will be transmitted to your practitioner or kept only on your device.
- Transmission: transmission occurs only after your explicit validation.
- Refusal: if you refuse, the photo/video is not sent and remains only on your device (then automatically deleted when the application is closed). Your practitioner is informed of your refusal.
- Subsequent deletion: you may delete a photo/video already transmitted via the privacy settings. Deletion results in its removal on the practitioner’s side, with notification.
- Retention periods: transmitted photos and videos are accessible during the program and for twelve (12) months after its end, then securely archived and frozen for ten (10) years.
Article 6 – Retention Periods
6.1 Identification and monitoring data
Retained for the entire duration of your active follow-up, then archived for a maximum period of ten (10) years, in accordance with obligations applicable to health data.
6.2 Videos et photos
Accessible during the program and twelve (12) months after its end, then archived in frozen form for a maximum period of ten (10) years.
6.3 Technical data (logs, IP)
Retained for a maximum period of twelve (12) months.
Article 7 – Data Recipients
7.1 Your practitioner
Your practitioner is the primary recipient of your data. They may also grant access to their staff (assistants, secretaries) under their responsibility.
7.2 The Tongue Teacher SAS
Limited access to authorized personnel only, solely to host and ensure the proper functioning of the service.
7.3 Technical processors
Your data is hosted and managed by trusted technical service providers, including:
- HDS hosting: OVH and Amazon AWS;
- Email services: Brevo (Sendinblue).
Article 8 – Transfers Outside the European Union
8.1 Location
Your data is hosted within the European Union
8.2 Occasional transfers
Certain service providers (e.g., AWS or Brevo technical support) may occasionally process data from a third country. In such cases, safeguards compliant with the GDPR (standard contractual clauses) are implemented.
Article 9 – Your Rights
9.1 Available rights
You have the right of access, rectification, erasure, restriction, objection, and portability of your data.
9.2 Exercising your rights
You may exercise your rights:
- by contacting your practitioner directly;
- or by contacting the DPO of The Tongue Teacher SAS: dpo@tongueteacher.com.
9.3 Rights of minors
Parents or legal representatives may exercise the rights of their minor children (access, rectification, deletion, objection).
9.4 Right to erasure
You may request the deletion of your personal data. However, certain data must be retained for ten (10) years in accordance with legal obligations applicable to health data.
9.5 Portability
You may request to receive your data in a structured, commonly used, and machine-readable format (e.g., CSV, PDF) in order to transmit it to another practitioner or service of your choice.
9.6 Right to lodge a complaint
You may lodge a complaint with the CNIL if you believe your rights are not respected.
Article 10 – Security and Confidentiality
10.1 Measures implemented
The Tongue Teacher SAS implements all necessary technical and organizational measures to protect your data.
10.2 HDS hosting
Your data is hosted on HDS-certified servers, in accordance with French and European requirements regarding health data.
10.3 Notification in case of breach
In the event of a data breach, your practitioner and/or you will be informed, in accordance with legal obligations.
Article 11 – Policy Updates
11.1 Right to modification
The Tongue Teacher SAS may modify this Policy at any time, particularly to comply with legal or technical developments.
11.2 Notification
Any substantial modification will be communicated via the application or by any other appropriate means.
11.3 Entry into force
This Policy enters into force on the date of its publication and remains applicable until replaced by a new version.
11.4 Independence of this Policy
This Privacy Policy applies exclusively to patients using The Tongue Teacher mobile application. It is independent from the contractual documents applicable to practitioners (Terms and Conditions of Sale and Terms of Use).