Privacy Policy — Sayna
⚠️ LEGAL DISCLAIMER. Professional draft to save drafting time. Must be reviewed by a qualified lawyer / DPO before publication, especially because Sayna processes health data (special category, Art. 9 GDPR). Replace all
[BRACKETED]fields. This English version is required for App Store / Google Play submission and must be kept consistent with the FrenchPOLITIQUE_CONFIDENTIALITE.md.
Last updated: [DATE] — Version: 1.0 (draft)
1. Who we are
This Privacy Policy explains how [LEGAL COMPANY NAME] ("Sayna", "we", "us") collects, uses, and protects your personal data.
- Data controller: [LEGAL COMPANY NAME], [legal form], registered office at [ADDRESS].
- Data Protection contact: [privacy@sayna.app]
- Registration: [Trade register / SIREN number]
Sayna provides a SaaS platform for aesthetic clinics ("Clinics") and a mobile app for their patients ("Users").
2. Controller vs processor
Under the GDPR, our role differs by data type:
- For patient account data (phone, name, email): Sayna is the controller.
- For health data entered by a Clinic about its patients: the Clinic is the controller and Sayna acts as a processor under a data processing agreement.
3. Data we collect
Provided by you: phone number (required, used for OTP login), first/last name, email (optional), date of birth (optional).
Health data (special category, Art. 9 GDPR): when a Clinic uses Sayna to manage your care, treatment-related data may be processed. This data is entered by the Clinic, processed by Sayna only as a processor, stored in the European Union, encrypted, strictly access-controlled, and never sold or used for advertising.
Collected automatically: device identifiers, technical logs, usage data (screens visited, QR scans), loyalty points, transaction history, approximate location (only if you enable it).
Clinic staff data: professional email, hashed password, role.
4. Why we process your data
- Provide the service (account, clinic linking, booking, payment).
- Loyalty program (points, memberships, rewards).
- Payments via Stripe.
- Security and fraud prevention (OTP authentication).
- Communications (appointment confirmations, reminders, receipts).
- Service improvement (aggregated analytics).
- Legal obligations (accounting, regulatory).
Legal bases: performance of a contract, consent, legitimate interest, legal obligation, and — for health data — explicit consent and/or Art. 9.2(h) GDPR under the Clinic's responsibility.
5. Data retention
| Category | Retention |
|---|---|
| Active patient account | Relationship + [3 years] after last activity |
| Health data (as processor) | As instructed by the controlling Clinic |
| Transaction / billing data | [10 years] (legal accounting obligation) |
| Technical / security logs | [6–12 months] |
| OTP codes | Validity period only (minutes) |
6. Who we share data with
We never sell your data. We share it only with service providers acting on our behalf:
| Provider | Purpose | Location | Safeguards |
|---|---|---|---|
| Supabase | Database, auth, storage | EU ([eu-west-1]) | GDPR DPA |
| Stripe | Payments | EU + USA | SCCs, DPF |
| Twilio | SMS / OTP | EU + USA | SCCs |
| Vercel | Web hosting | EU / global | SCCs |
| [Apple / Google] | Push notifications, distribution | Global | Their policies |
The Clinic you are linked to accesses data needed for your care. Authorities only upon lawful request.
International transfers: some providers (Stripe, Twilio) may process data in the USA under Standard Contractual Clauses and the Data Privacy Framework. Health data is hosted in the EU.
7. Payment data
Payments are processed by Stripe (PCI-DSS Level 1 certified) using Stripe Connect. Sayna never stores full card numbers. See https://stripe.com/privacy.
8. Security
Encryption in transit and at rest; strict multi-tenant isolation (PostgreSQL Row-Level Security) so one clinic can never access another's data; strong authentication; least-privilege access; logging of sensitive operations. In case of a data breach posing a risk, we notify the supervisory authority within 72 hours and affected users where required.
9. Your rights
You have the right to: access, rectification, erasure, restriction, data portability, object to processing based on legitimate interest, and withdraw consent at any time.
For health data entered by a Clinic, we will direct your request to the relevant Clinic (the controller) and assist them.
To exercise your rights: [privacy@sayna.app]. We respond within one month. You may lodge a complaint with your supervisory authority (in France: CNIL, www.cnil.fr).
10. Children
The service is not intended for users under [15 / 18] without parental consent. We do not knowingly collect data from children under 15.
11. Cookies and tracking
The mobile app uses secure local storage (session token, preferences) and does not embed third-party advertising trackers. The web dashboard uses strictly necessary cookies only.
12. Changes
We may update this policy. The "Last updated" date reflects the latest revision. Material changes will be communicated.
13. Contact
[LEGAL COMPANY NAME] — [ADDRESS] — [privacy@sayna.app]
App Store / Play Store mapping helper (for submission)
When filling Apple's App Privacy ("Privacy Nutrition Labels") and Google Play's Data Safety form, declare consistently with this policy:
Data type Collected Linked to user Used for tracking Purpose Phone number Yes Yes No App functionality, account Name Yes Yes No App functionality Email (optional) Yes Yes No App functionality, comms Health data Yes (as processor) Yes No App functionality (care) Purchase history Yes Yes No App functionality, loyalty Approximate location Optional Yes No App functionality Identifiers / device Yes Yes No Security, app functionality Usage data Yes Maybe No Analytics, app functionality Tracking declared: No. No third-party advertising SDKs as of this version. If you add analytics or ad SDKs later, update both this policy and the store declarations.
Working draft. Legal review required before publication.