Privacy policy

The purpose of this document is to set out the personal data protection policy implemented by Futto, a simplified joint-stock company (société par actions simplifiée) with a share capital of €1,000, whose registered office is at 78 avenue des Champs-Élysées, Bureau 326, 75008 Paris, registered with the Paris Trade and Companies Register (R.C.S.) under number 953 111 663, hereinafter “Futto”, in compliance with the Personal Data Regulations.

Futto is the publisher of the Site and the Platform, as defined below. It designs and markets an online software solution intended for healthcare professionals, in particular podiatrists, enabling them to manage their patient records, issue digital prescriptions, invoice and transmit claims electronically.

Except in the cases described in Article 4 below, Futto collects Personal Data on its own behalf, in the course of its business, and is therefore a Data Controller within the meaning of Regulation (EU) 2016/679 of 27 April 2016 (the “GDPR”) and of French Act No. 78-17 of 6 January 1978, as amended, on information technology, data files and civil liberties (the “French Data Protection Act (Loi Informatique et Libertés)”) (together, the “Personal Data Regulations”).

Where Futto processes the data of Patients on behalf of the healthcare professionals who use the Platform, it acts as a Processor. This particular case is described in Article 4 of this policy.

Futto may amend this policy (the “Policy”) in order to reflect regulatory, case-law, editorial or technical developments relating to the protection of Personal Data. In the event of minor changes, Futto will update the “last updated” date to show the date on which the changes were made. However, in the event of a substantial change to this Policy, Futto will inform the Data Subjects of the changes directly, by email or by a notification on the Platform.

You are advised to consult this page regularly in order to take note of any changes or updates made to the Policy.

1. Definitions

“Customer” means any healthcare professional, in particular a podiatrist, whether a natural person or a legal entity, who has subscribed to the Platform, including during the free trial period;

“Cookie” means a small file stored by a server in the device (computer, phone, tablet, etc.) of a Visitor to the Site or a User of the Platform, associated with a web domain and automatically sent back during subsequent contacts with that same domain. By extension, the term also covers other trackers that make it possible to access information stored in the device or to write information to it;

“Recipient” means any natural person or legal entity that receives communication of Personal Data, whether or not it is a Third Party;

“Personal Data” means any information relating to an identified or identifiable natural person, directly (for example by their surname and first name) or indirectly (for example by a telephone number, a postal or email address, an identifier such as a social security number, a voice or an image);

“Health Data” means Personal Data relating to the physical or mental health of a natural person, past, present or future, including the provision of healthcare services, which reveal information about that person’s state of health;

“Patient” means any natural person treated by a Customer whose Personal Data, in particular Health Data, is entered into the Platform by the Customer or its Users;

“Data Subject” means any identified or identifiable natural person whose Personal Data is processed by Futto in accordance with this Policy;

“Platform” means the Futto application, a software solution accessible online, published by Futto and made available to Customers and their Users, enabling in particular the management of patient records, the issuing of digital prescriptions, invoicing and electronic claims transmission;

“Prospect” means any professional likely to be interested in Futto’s services who is not yet a Customer;

“Data Controller” means any natural person or legal entity which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data, in this case, and unless otherwise indicated, Futto;

“Site” means the online public communication service published by Futto and accessible, as at the date of the last update of this Policy, at the following address:

• www.futto.com.

This also includes its mobile versions, its online forms, newsletters and any other existing or future medium;

“Processor” means any natural person or legal entity, public authority, agency or other body which processes Personal Data on behalf of the Data Controller;

“Processing” means any operation or set of operations performed, whether or not by automated means, on personal data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“Third Party” means any natural person or legal entity, public authority, agency or body other than the Data Subject, the Data Controller, the Processor and the persons who, under the direct authority of the Data Controller or the Processor, are authorised to process the Personal Data;

“User” means any natural person authorised by the Customer to access and use the Platform (practitioner, associate, reception staff, etc.);

“Visitor” means any person who browses the Site, whether or not a Futto customer.

2. When is personal data collected?

Personal Data is collected mainly from the Data Subject themselves.

The Data Subject’s Personal Data may be collected in particular in the following situations:

• When they browse the Site and use its features, some of their Personal Data may be collected as a Visitor;
• When they fill in a contact form, request a demonstration or start a free trial period, or when they communicate with Futto by chat, some of their Personal Data may be collected as a Prospect;
• When they create an account on the Platform and use it, some of their Personal Data may be collected as a User;
• In the context of managing the commercial and contractual relationship, in particular when the contract is signed, and when the subscription is taken out, paid for and invoiced, some of the Data Subject’s Personal Data may be collected as a Customer;
• When they contact Futto’s support team, some of their Personal Data may be collected;
• In the context of Futto’s sales prospecting and marketing operations, in particular at trade fairs, some of the Data Subject’s Personal Data may be collected;
• Where the Data Subject is an employee or a service provider of Futto, some of their Personal Data may be collected in the context of managing that relationship.

By exception, some Personal Data may be collected indirectly:

• For prospecting purposes, professional data relating to practitioners may be taken from the official public directory of healthcare professionals;
• Where a Customer enters the data of its Patients into the Platform, or receives data transmitted by the partners integrated into the Platform (see Article 4 below).

In any event, Futto collects only the Personal Data that is strictly necessary for the purposes of its activities.

Accordingly, only information that is relevant, adequate and limited to what is necessary in relation to the purposes for which it is processed is collected.

3. For what purposes and on what legal bases is personal data collected?

The Personal Data collected from the Data Subject and processed by Futto or by its Processors is processed for specified, explicit and legitimate purposes, which may vary depending on the context of collection:

Management of practitioner accounts

Commercial and contractual management of Customers (practices)

Sales prospecting and marketing

Website, forms and Cookies

Management of employees and service providers

Accounting and invoicing

Information systems security and access management

Protection of forms against bots (Cloudflare Turnstile)

The contact, demonstration request and quote forms are protected by Cloudflare Turnstile, a service provided by Cloudflare, Inc. (a processor within the meaning of Article 28 of the GDPR). When you start filling in a form, your browser connects to Cloudflare’s servers, which receive your IP address and technical information about your browser in order to verify that the request comes from a person. On submission, Futto sends Cloudflare only a technical token; no data entered in the form is sent to Cloudflare, which does not use it for advertising or tracking purposes.

Purpose: security of the site and prevention of spam. Legal basis: Futto’s legitimate interest in protecting its forms (Article 6(1)(f) of the GDPR). This mechanism is strictly necessary for the security of the service and does not require your consent (Article 82 of the French Data Protection Act (Loi Informatique et Libertés)). Cloudflare may process this data in the United States; this transfer is governed by the EU–US Data Privacy Framework and the European Commission’s standard contractual clauses.

Compulsory or optional nature of the data: data marked as compulsory in the forms (for example by an asterisk) is necessary for the purpose pursued. If it is not provided, Futto will not be able, as the case may be, to create the account, perform the subscription or process the request. The data necessary for the performance of the contract (identification, professional contact details, RPPS, ADELI or AM number, payment data) is a condition of creating the account and accessing the Platform. All other data is optional.

Important: the Patients’ Health Data entered into the Platform by Customers and their Users is not processed by Futto on its own behalf. It is subject to specific provisions described in Article 4 below.

4. Cases in which Futto acts as a processor: Patient data

Futto is solely responsible for the Processing of Personal Data described in Article 3 of this Policy.

By contrast, where a Customer uses the Platform to manage its Patients’ records, it is the Customer (the practitioner or their practice) that determines the purposes and means of the Processing: the Customer is the Data Controller for its Patients’ data. Futto then acts exclusively as a Processor within the meaning of Article 28 of the GDPR, on behalf of the Customer and on its documented instructions.

Activities carried out by Futto on behalf of Customers:

• Hosting and storage of patient records: hosting of the database, secure storage of Health Data, prescriptions, invoices and quotes, backup and restoration of data;
• Provision of the patient record management application: provision of the data entry and consultation interface, management of User accounts and authentication, recording of the consultations, prescriptions, quotes and invoices entered by the practitioner;
• Electronic transmission of prescriptions and exchanges with partners: transmission of prescriptions to the partners integrated into the Platform, pre-filling of records from the data transmitted by those partners;
• Maintenance and technical support: corrective and evolutive maintenance of the application, technical support for practitioners (including by chat), occasional access to Patients’ data where strictly necessary for an intervention.

Data concerned: Patients’ identity data and contact details, medical history, data relating to consultations, prescriptions and orders, medical images, quotes and invoices, and any document that the Customer chooses to add to its Patient’s record.

The purposes, legal bases, retention periods and categories of data processed are the responsibility of each Customer in its capacity as Data Controller. It is for the Customer to inform its Patients of the Processing of their data.

Futto’s commitments: in this context, Futto undertakes to:

• Process Patients’ data only on the documented instructions of the Customer;
• Ensure the confidentiality of this data and not disclose it to any Third Party, except on the express instructions of the Customer;
• Never use Customers’ and Patients’ data for commercial purposes;
• Never use Patients’ data to train artificial intelligence models;
• Host this data in France (Paris region), in an environment certified for the hosting of health data (HDS);
• Access Patients’ data, for support or maintenance purposes, only by means of strong authentication and a secure, short-lived session limited to the duration of the intervention;
• Assist the Customer in responding to requests to exercise rights, in data security and in the notification of data breaches;
• Inform the Customer without delay of any data breach affecting the data of its Patients.

Sub-processors and location: to carry out these activities, Futto uses sub-processors (hosting, authentication, transmission of prescriptions, electronic claims transmission, medicines database, chat support, technical monitoring), whose categories are set out in Article 6 below and whose detailed list is set out in the appendix to this Policy. No Patient data is transferred outside the European Union.

Fate of data at the end of the contract: patient records are kept for the entire duration of the Customer’s subscription. From termination, the Customer has thirty (30) days to retrieve its data using the export feature. After that period, the data is permanently deleted. Technical backups are kept for ninety (90) rolling days.

Patients of a practitioner using Futto: for any question about the Processing of their data or to exercise their rights, the Patient must contact their practitioner directly, who is their point of contact as Data Controller. Any request sent to Futto is forwarded to the practitioner concerned, whom Futto assists in responding.

5. How long is personal data kept?

In accordance with the Personal Data Regulations, Futto keeps Personal Data for the period strictly necessary to achieve the purposes of the Processing it carries out.

The retention period may depend on circumstances specific to the Processing, on regulations requiring information to be kept for a set period, or on statutory limitation periods relating to disputes. Where a limitation period is provided for by law, the retention period may not be shorter than it.

Acting as Data Controller, Futto undertakes to comply with the retention periods required by the regulations in force.

• Practitioner accounts and the contractual relationship with Customers: Personal Data is kept for the entire duration of the subscription. It is then archived for five (5) years from the end of the contractual relationship, for evidentiary purposes;
• Sales prospecting: Personal Data is kept for three (3) years from the end of the commercial relationship for Customers, or from the last contact initiated by them for Prospects;
• Contact, demonstration and free trial requests, and chat exchanges: Futto keeps Personal Data for up to three (3) years after the last contact initiated by the Data Subject;
• All accounting and tax information, including in particular invoices, is kept for ten (10) years, in accordance with the legal obligations incumbent on Futto;
• Security and connection logs are kept for one (1) year;
• Technical backups are kept for ninety (90) rolling days;
• Cookies: Cookies and the choices expressed by the Data Subject are kept for a maximum of thirteen (13) months, and audience measurement data for a maximum of twenty-five (25) months;
• Employees and service providers: their Personal Data is kept for the duration of the contractual relationship, then for five (5) years from its end.

At the end of these periods, the Personal Data will be destroyed or irreversibly anonymised so that the Data Subject can no longer be identified by any means.

The retention periods for Patients’ data are set out in Article 4 above.

For any question about the retention period of certain types of Personal Data that Futto processes, please contact the Data Protection Officer at the following address: [email protected].

6. Who are the recipients of personal data?

As Personal Data is confidential, only persons duly authorised by Futto may access it, where necessary in the course of its activities.

In providing its services, Futto uses service providers who act as Processors. In any event, the sharing of Personal Data is carried out in accordance with the legislation in force and is limited to what is strictly necessary.

The Personal Data collected by Futto may be intended for the following categories of persons and/or entities:

• Futto’s teams authorised to carry out Processing of Personal Data, each as far as it is concerned (general management, sales, marketing, technical, finance and support teams);
• Futto’s Processors and service providers, whose categories are set out below and whose detailed list is set out in the appendix;
• Futto’s banking institutions, which act as independent data controllers for their own obligations;
• Legally authorised authorities, under the conditions described below.

Categories of Futto’s Processors and service providers

The detailed and up-to-date list of Futto’s Processors is set out in the appendix to this Policy.

All persons or entities with access to Personal Data are bound by an obligation of confidentiality and security.

Futto has carefully selected these Processors and continuously ensures that they comply with its instructions. These persons and entities are not authorised to use the Personal Data for purposes other than those set out in this Policy.

Futto does not sell or rent Personal Data to Third Parties.

Disclosure of Personal Data to authorities: some Personal Data may also be disclosed to legally authorised authorities in order to comply with the legal, regulatory or contractual obligations to which Futto may be subject.

7. Is data transferred outside the European Union?

Data processed by means of the Platform is hosted in France (Paris region). The other providers used by Futto host Personal Data within the European Union, with the exception of the payment provider and the appointment-booking provider, which also process it in the United States.

Certain providers, or their own processors, may nevertheless process certain Personal Data or access it from the United States or other countries outside the European Union, in particular for the purposes of payment, authentication, audience measurement, technical monitoring, support, appointment booking, protection of the Site and analysis of subscriptions. These transfers are governed by the European Commission’s adequacy decision on the EU–US Data Privacy Framework, where the recipient is certified under it, and/or by the European Commission’s standard contractual clauses.

No Patient data is transferred outside the European Union.

Concerned to protect privacy and Personal Data, Futto uses its best efforts to select partners offering security and confidentiality guarantees and to put in place contractual relationships that meet regulatory standards, in particular at European level.

Unless the country to which the Personal Data is transferred has been recognised by the European Commission as providing an adequate level of protection of Personal Data, Futto requires these Recipients to comply with the data protection measures contained in the applicable regulations. Any transfer that proves necessary will be governed by the standard contractual clauses issued by the European Commission and currently in force, as well as by the implementation of additional technical and organisational measures to guarantee the protection of this Data.

The Data Subject may request a copy of these clauses from the Data Protection Officer at the following address: [email protected].

8. Profiling and automated decisions

Profiling means any form of automated Processing of Personal Data consisting of using it to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning their personal preferences, interests or behaviour.

Futto does not take any decision based solely on automated Processing, including profiling, which produces legal effects concerning the Data Subject or similarly significantly affects them, within the meaning of Article 22 of the GDPR.

Futto does, however, segment its contacts for marketing communication purposes. Data relating to the opening of emails and clicks on the links they contain, collected by means of tracking pixels embedded in emails, is used to adapt the sending and content of Futto’s communications to the Data Subject’s interests. This segmentation is based on the Data Subject’s consent, which they may withdraw at any time by means of the unsubscribe link in each email or by writing to [email protected]. It produces no legal effect concerning them and does not significantly affect them.

Usage data from the Platform and the Site is used in the form of statistics, for the sole purpose of improving their operation and features.

Should Futto carry out other profiling operations, the Data Subject would be informed beforehand and Futto would seek their consent where necessary.

9. Cookies and other trackers

When browsing the Site and using the Platform, Cookies may be placed on the Data Subject’s device:

• Functional Cookies: they enable the Site and the Platform to operate and the service to be improved (authentication, session maintenance, security, remembering Cookie choices). They do not require consent;
• Non-essential Cookies: these include in particular audience measurement and analytics Cookies, which enable Futto to know how the Site is visited and used in order to improve its content and usability. They are placed only with the Data Subject’s consent;
• Tracking pixels in emails: emails sent by Futto may contain pixels that make it possible to know whether they have been opened and whether their links have been clicked. Those used for audience measurement or segmentation purposes are used only with the Data Subject’s consent. Those strictly necessary for deliverability, transactional emails or security do not require consent.

The Data Subject may accept or refuse the placing of non-essential Cookies by means of the consent banner on the Site. Refusing these Cookies has no effect on their access to the Site and the Platform.

10. What are the Data Subject’s rights?

The Data Subject whose Personal Data is processed has various rights.

These rights are nevertheless not absolute and are subject to certain conditions, in accordance with the Personal Data Regulations.

• Right to be informed

Futto undertakes to inform the Data Subject of the collection and use of their Personal Data and thus undertakes to provide concise, transparent and accessible information on the conditions and arrangements for the collection and Processing of Personal Data.

• Right of access

The Data Subject has a right of access to the Personal Data concerning them, enabling them to obtain information on the existence of Processing and on its arrangements.

They also have the right to obtain a copy of their Personal Data as kept by Futto.

• Right to rectification

The Data Subject may ask Futto to rectify their Data, in particular where it is no longer up to date.

• Right to object

The Data Subject has the right to object at any time, on grounds relating to their particular situation, to Processing of Personal Data concerning them that is based on Futto’s legitimate interest.

They may object at any time, without having to give reasons, to the Processing of their Personal Data for sales prospecting purposes, by writing to [email protected] or by clicking on the unsubscribe link in each of Futto’s communications.

• Right to erasure of Personal Data (or “right to be forgotten”)

Subject to the regulations in force, and in particular to the exceptions (for example, where retention is necessary to comply with a legal obligation), the Data Subject may request the erasure of the Personal Data concerning them:

• • Where the Data is no longer necessary, or never was, in relation to the purposes for which it was collected or otherwise processed;
  • Where they withdraw the consent on which the Processing is based and there is no other legal ground for the Processing;
  • Where they consider that the Processing of their Data is unlawful;
  • Where the Data must be erased under a legal obligation provided for by Union law or by the law of the Member State to which Futto is subject, namely France;
  • Where they have objected to the Processing of the Data and Futto has no compelling legitimate grounds for refusing the request.
• Right to restriction of Processing

The Data Subject may obtain from Futto the restriction of Processing where one of the following applies:

• • Where the accuracy of the Data is contested, for a period enabling Futto to verify the accuracy of the Data;
  • Where the Processing is unlawful and they oppose the erasure of their Data and instead request the restriction of the Processing;
  • Where the Data is no longer necessary in relation to the purposes for which it was collected but they need it for the establishment, exercise or defence of legal claims;
  • Where they object to Processing that is based on Futto’s legitimate interest, pending verification of whether the legitimate grounds pursued by Futto override their own.
• Right to data portability

The Data Subject may obtain from Futto the Personal Data that they have previously provided to it, in a structured, commonly used and machine-readable format.

They may also transmit this Data to another data controller, or request that the Personal Data concerning them be transmitted directly by Futto to another data controller where technically feasible.

• Right to withdraw consent

The Data Subject may, using the means put in place by Futto for this purpose, withdraw their consent at any time where their Personal Data is processed on the basis of that consent.

The withdrawal of consent applies only for the future, and therefore cannot call into question the lawfulness of Processing carried out before the withdrawal.

• Right to lodge a complaint with a supervisory authority

If the Data Subject considers that their rights are not being respected, they may lodge a complaint with a supervisory authority, such as the French data protection authority (Commission Nationale de l’Informatique et des Libertés, CNIL) in France, in particular via its website www.cnil.fr.

• Right to decide what happens to Data after death

The Data Subject has the right to determine what happens to their Data after death by laying down general or specific directives, by sending their written instructions to the address of the Data Protection Officer.

• Right not to be subject to an automated decision

The Data Subject has the right not to be subject to a decision based solely on automated Processing, including profiling, which produces legal effects concerning them or similarly significantly affects them. As stated in Article 8, Futto carries out no Processing of this nature.

11. How to exercise these rights

The Data Subject may exercise their rights or submit any complaint concerning the Processing of their Personal Data by writing to the following address: [email protected]; or by post: Futto, Data Protection Officer, 7 rue Gustave Flaubert, 75017 Paris.

Futto may request a copy of proof of identity if necessary. The level of verification carried out by Futto when processing requests to exercise rights will vary depending on the nature of the requests, the sensitivity of the information disclosed and the context in which the request is made.

Futto undertakes to respond to any request as soon as possible, and in any event within one (1) month of receipt of the complete request. This period may nevertheless be extended by two (2) months, taking into account the complexity and/or the number of requests received.

Particular case of Patients: the Patient of a practitioner using the Platform must send their requests to that practitioner, under the conditions described in Article 4 of this Policy.

12. How is personal data protected?

Futto uses its best efforts to implement technical and organisational measures that are appropriate and adapted to the degree of sensitivity of the Personal Data collected, in order to ensure confidentiality and prevent unauthorised or unlawful access to the Personal Data provided to Futto.

These measures include in particular:

• Encryption of data in transit (TLS 1.3) and at rest (AES-256);
• Hosting of data in France (Paris region), in an environment certified for the hosting of health data (HDS) in accordance with the French Public Health Code (Code de la santé publique);
• Automatic daily backups, kept for ninety (90) days;
• Access control for Users, relying on a specialist authentication provider, and management of permissions limiting access to what is strictly necessary;
• Logging of connections and data changes;
• Software protection (security updates and patches) and technical monitoring of the Platform;
• Exchanges with partners carried out through secure interfaces (APIs).

Where the disclosure of Personal Data to third parties is necessary and authorised, Futto ensures that those third parties guarantee the Data concerned the same level of protection as that offered by Futto, and requires contractual guarantees so that, in particular, the Personal Data is processed exclusively for the intended purposes, with the required level of confidentiality and security.

As all Personal Data is confidential, access to it is limited to authorised persons or to service providers acting on behalf of Futto who need it in order to perform their duties. All persons with access to Personal Data are bound by an obligation of confidentiality and are liable to sanctions if they fail to comply with these obligations.

In the event of a Personal Data breach likely to result in a risk to the rights and freedoms of Data Subjects, Futto undertakes to notify the breach to the CNIL within seventy-two (72) hours and, where required by the Personal Data Regulations, to inform the Data Subjects. Where the breach concerns data processed on behalf of a Customer, Futto informs the Customer without delay.

13. Browsing third-party websites

The Site and the Platform may contain links, including hyperlinks, to third-party websites or services (for example Futto’s pages on social networks or the services of its partners).

Futto exercises no control over the content of third-party websites or over those third parties’ practices regarding the protection of any Personal Data they may collect, and disclaims all liability relating to such content and practices. It is for the Data Subject to find out about those third parties’ personal data protection policies.

14. Contacting Futto’s DPO

Futto has appointed a Data Protection Officer (“DPO”) with the CNIL (registration no. 173393). For any question relating to Futto’s commitments concerning the protection of Personal Data, or for any complaint, the Data Subject may contact Futto’s Data Protection Officer:

Maëva Gomez

7 rue Gustave Flaubert, 75017 Paris

[email protected]

Appendix: List of Futto’s processors

List up to date as at 10 November 2026.