Updated on June 13, 2023
1. Identity and WISTIM’s contact details
The WiStim Service is published by WiStim, Société par actions simplifiée (a simplified Joint-Stock company), with a share capital of 120,990 Euros having its registered office located: 62 rue de Prony – 75017 Paris, FRANCE application@wistim.fr ; Tel: +336.11.38.44.83, registered with the Register of Commerce and Companies of Nanterre under the No. 815 293 329, (hereinafter « WISTIM »)
2. Non-disclosure Policy for the patients
2.1 When you use the WiStim Service without your gynecologist being registered
WISTIM collects and processes your personal data as part of the provision of the WiStim Service and its associated features.
2.1.1. Purposes of processing the patients' personal data and legal grounds
WISTIM processes your personal data for the following purposes:
- Enable you to register on the WiStim Service by creating a profile/user account;
- Enable you to subscribe to the newsletters published by WISTIM or its partners according to your preferences;
- Guarantee the storage, archiving and security of your personal data;
- Manage the WiStim Service, understand the usage trends and improve its operation.
When you consent that your doctor provides your personal data, WISTIM processes these data to enable you to:
- Receive and consult your personalized treatment;
- Set reminders for the injections;
- Manage your stimulation appointments via an interactive calendar;
- Access your biological and ultrasound results of the day;
- Receive messages from your gynecologist;
- Store your results/exams;
- Archive and classify your results.
In addition to the hypotheticals where your consent has been collected, processing your data for the various purposes mentioned hereinabove is necessary in particular for:
- The enforcement of the contract pursuant to which WISTIM makes the WiStim Service available to you through the app;
- For the legitimate interests pursued by WISTIM (in particular to develop new services and offers).
2.1.2. Mandatory or optional nature of the data provision
Some personal data collected by WISTIM are essential (such as your last name, first name, email address), especially to enable the WiStim Service to function properly, whereas others are optional.
The data needed by WISTIM to achieve the purposes described hereinabove are marked with an asterisk.
The data relating to your health and about your sex life are optional; they enable to achieve the purposes described in paragraph 1.2.
2.1.3. Recipients of your personal data
In connection with the provision of our services, we may transfer or give access to your data to the following subcontractors:
- Open Group, i.e., the subcontractor managing the WiStim app and the back-office,
- ITS Integra, i.e., the subcontractor hosting the app, who has the approval issued by the Minister in charge of Health pursuant to the provisions of Article L. 1111-8 of the Public Health Code.
WISTIM may be required to disclose your data to third parties, in cases when such communication is authorized and required by law or a court order, or if this is required to ensure the protection and defense of its rights.
Besides from these hypotheticals, your data will not be assigned or made available to any third party without your prior consent.
WISTIM does not transfer your data to a country outside the European Union.
2.1.4. Retention period of your personal data
WISTIM undertakes to keep your personal data for a period of time which does not exceed what is necessary for the purposes for which they are processed.
If you are not connected to a doctor, your personal data are kept in an active database until you delete your profile or they are deleted after a period of five years of an ongoing inactivity of your account (legal prescription period).
If you are connected to a doctor for the purpose of communicating with him through the app, these data will be considered as part of your medical record. In this case, the retention period of your data will be 20 years pursuant to Article R1112-7 of the Public Health Code amended by Decree No. 2018-137 of February 26, 2018.
2.1.5. Your rights of access, rectification, deletion, opposition, portability and limitation
Pursuant to the governing personal data protection legislation, you have the right to access, rectify and delete any personal information relating to you, as well as to oppose, for legitimate reasons, the processing of your personal data. You can exercise any of these rights at any time by sending an email to the following address: application@wistim.fr.
You may request to receive your personal data that you have provided to WISTIM in a structured, commonly used, machine readable format, and you have the right to transfer your data to another manager of the data processing.
You also have the right to file a complaint with a supervisory authority.
The French supervisory authority is the Commission Nationale Informatique et Libertés (CNIL), 3 Place Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.
2.2. When you use the WiStim Service and your gynecologist is registered
WISTIM collects and processes your personal data in the name and on behalf of your gynecologist as part of the provision of the WiStim Service and its associated features.
As such, WISTIM only acts on instruction from your gynecologist and undertakes to take all necessary precautions to preserve the security of the information and in particular to prevent data from being distorted, damaged or communicated to unauthorized parties.
3. Non-disclosure Policy for the doctors
WISTIM collects and processes the doctor’s personal data, as part of the provision of the WiStim Service and its associated features.
3.1. Purposes of processing personal data and legal grounds
WISTIM processes the doctor’s personal data for the following purposes:
- Enable the doctor to register on the WiStim Service, by creating a user account and benefit from the features of the WiStim Service (communication with patients, deliver their results and personalized treatments, deliver the prescriptions, and soon, the use of secured messaging);
- The RPPS number (i.e. a shared directory for health professionals), is requested to identify the doctor;
- Administer the WiStim Service, understand the usage trends and improve its operation;
- Guarantee the storage, archiving and security of your personal data.
Processing your data for the various purposes mentioned hereinabove is necessary in particular for:
3.2. Mandatory or optional nature of the data provision
Some personal data collected by WISTIM are essential to enable the WiStim Service to function properly, whereas others are optional.
The data needed by WISTIM to achieve the purposes described hereinabove are listed on our Homepage. The other ones are optional; they enable you to benefit from all the features of the Wistime Service.
3.3. Recipients of the personal data
As part of the services we provide, we may transmit or give access to the doctor’s data, to the following subcontractors:
- Open Group, i.e., the subcontractor managing the WiStim app and the back-office,
- ITS Integra, i.e., the subcontractor hosting the app, who has the approval issued by the Minister in charge of Health pursuant to the provisions of Article L. 1111-8 of the Public Health Code.
WISTIM may be required to disclose the doctor’s data to third parties, in cases when such communication is authorized and required by law or a court order, or if it is required to ensure the protection and defense of its rights.
Besides from these hypotheticals, the doctor’s data will not be assigned or made available to any third party without the doctor’s prior consent.
WISTIM does not transfer the doctor’s data to a country outside the European Union.
3.4. Retention period of your personal data
WISTIM undertakes to keep the doctor’s personal data for a period of time which does not exceed what is necessary for the purposes for which they are processed.
The doctor’s personal data are kept in an active database until he deletes his profile or they are deleted after an ongoing inactivity of his account. We then archive them for a period of 5 years (legal prescription period).
3.5. Rights of access, rectification, deletion, opposition and portability
Pursuant to the governing personal data protection legislation, the doctor has the right to access, rectify and delete any personal information relating to him, as well as to oppose, for legitimate reasons, the processing of his personal data. The doctor exercises any of these rights at any time by sending an email to the following address: application@wistim.fr.
The doctor may request to receive his personal data that he has provided to WISTIM in a structured, commonly used, machine readable format, and the doctor has the right to transfer his data to another manager of the data processing.
The doctor also has the right to file a complaint with a supervisory authority.
The French supervisory authority is the Commission Nationale Informatique et Libertés (CNIL), 3 Place Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.
3.6. Protection of the patients and their partners’ personal data
Pursuant to the (French) Data Protection Act and the General Data Protection Regulation (GDPR), WISTIM acts as the doctor’s subcontractor. As such, WISTIM only acts as instructed by the doctor and undertakes to take all necessary precautions to preserve the security of the information, and in particular to prevent data from being distorted, damaged or communicated to unauthorized parties.
The doctor, as the manager of the data processing, undertakes to comply with the requirements of the (French) Data Protection Act and the General Data Protection Regulation (GDPR), and in particular collect the consent of the patients and their partners for the collection and treatment of their health data, inform the patients and their partners about the data processing.
The doctor is informed and agrees that WISTIM uses anonymized patient data for statistical and study purposes.
4. Amending the Non-disclosure Policy
WISTIM reserves the right to adapt the Non-disclosure Policy and undertakes to inform you via its app of any amendments or supplements.
5. Contact
For any additional questions about this Policy or how WISTIM processes your personal data, please contact us at the following address: 9 rue Perronet 92200 Neuilly sur Seine, or by email at the following address: application@wistim.fr.