MediCoach™ Privacy Policy

Last updated: June 12, 2026

MediCoach™, developed by Flomut SRL, processes your personal data in compliance with the General Data Protection Regulation (GDPR) (EU 2016/679), the applicable Belgian legislation, and the applicable requirements of Google Play and the App Store (Apple).

This policy applies to our mobile application designed to assist in organizing medication intakes and related reminders. MediCoach™ is a Class I Medical Device within the meaning of Regulation (EU) 2017/745 on medical devices. The application is not intended to provide a medical diagnosis or a therapeutic decision.

1. Data Controller

Flomut SRL VAT: BE 0787.787.478 Avenue Chantecler 39, 1420 Braine-l’Alleud, Belgium Contact: support@medi-coach.be Responsible Pharmacist: Florien Munezero Twahirwa

2. Collected Data

We only collect data necessary for the operation of the application, the personalization of the experience, and access management:

• Firebase UID: necessary for the secure authentication of your account.

• First name: used to personalize the interface and certain messages from the assistant.

• Date of birth: information required during registration. It is used to calculate your age, adapt certain presentations in the application, and produce aggregated usage statistics.

• Gender: information required during registration, used for interface personalization and, where applicable, aggregated usage analysis.

• Profile picture: optional, used exclusively to personalize your interface.

• Country of residence: used to adapt certain information, the framework of use, and the application settings according to the relevant region.

• Professional profile and registration number: if you create a "Healthcare Professional" profile, your registration number may be requested to verify your professional status and activate the features reserved for professionals.

• Lifestyle and organization habits: information provided voluntarily to personalize your reminders and the assistance offered by the application.

• List of personal products: name, form, frequency, and times, solely for programming reminders and displaying your schedule.

• Validation history: information indicating whether an intake has been marked as completed or not, in order to display your organization tracking.

• "Duo Mode" link data: if you activate this optional feature, the application generates a link token to associate your account with that of a caregiver.

3. Data Not Collected

We never collect:

• NISS number or other national identifiers,

• medical diagnoses,

• laboratory test results,

• detailed medical history,

• geolocation data,

• biometric data,

• facial or voice recognition data.

4. Purposes of Processing

Your data is used to:

• schedule and display your intake reminders;

• organize your intake schedule and your daily tracking;

• personalize the interface and certain interactions with the assistant;

• verify the status of healthcare professionals when this feature is used;

• allow, solely with your explicit consent, the sharing of your schedule with a caregiver via Duo Mode;

• produce aggregated or pseudonymized usage statistics to improve the application, its performance, and its ergonomics.

We do not use your data for:

• targeted advertising,

• commercial behavioral profiling,

• resale to third parties,

• sharing with partners not necessary for the operation of the application.

5. Retention Periods

• Active reminders and schedule: kept as long as your account is active or until the application is uninstalled.

• Validation history: kept for a rolling period of 30 days to display organization tracking and generate reports in the application.

• Deleted account: in the event of account deletion by the user, the associated data is deleted or anonymized within a maximum of 30 days, subject to legal, technical, or security obligations that may justify a limited retention of certain traces.

6. Technical Security

MediCoach™ implements appropriate protection measures, including secure authentication, encryption of data in transit via HTTPS/TLS 1.3, and protection mechanisms for the data stored on the infrastructure used by the application. On the device, the application may use secure local databases to restrict unauthorized access. When certain export functions are used, appropriate encryption mechanisms may be applied to the generated files.

7. Data Sharing

• With your caregiver (Duo Mode): only if you explicitly authorize it via the dedicated feature, your caregiver can access the information necessary for shared support. Depending on the rights you grant them, they can view certain organizational data and, if you allow it, add or modify your reminders and product sheets.

• Technical providers: certain data may be processed by our technical service providers, only to the extent necessary for the operation, security, and maintenance of the application.

• Conversational assistant: requests sent to the integrated assistant may be processed via an artificial intelligence service provided within a developer/API framework. In this context, the transmitted data is processed in accordance with the conditions applicable to this service and is not intended for training the public models of the service used.

8. Your Rights

From the application settings or by contacting us by email at support@medi-coach.be, you can exercise your rights of access, rectification, erasure, objection, and restriction, under the conditions provided for by the GDPR. You may also lodge a complaint with the Data Protection Authority (DPA) in Belgium.

9. Consent

When creating an account or upon first use, the user is informed of this policy. When required by regulations, specific consent is obtained for the respective processing activities, particularly for Duo Mode or certain optional features.

10. Nature of the Application and Materiovigilance

MediCoach™ is a tool designed to assist in organizing medication intakes. The application and the integrated assistant do not make diagnoses, prescribe treatments, modify your dosages, or perform personalized clinical analysis. For any medical questions, please consult your doctor or pharmacist. In accordance with the regulations applicable to medical devices, any serious incident occurring in connection with the use of the application must be reported to the manufacturer and the competent authority of your country.

11. International Transfers

Data is primarily hosted within the European Union. In the event of a technical transfer outside the EU, this is governed by the mechanisms provided for by the applicable regulations, including, where necessary, the Standard Contractual Clauses of the European Commission.

12. Cookies and Trackers

The application does not display any advertising. Technical measurement or usage analysis tools may be used to understand the overall use of the application and improve its performance. If acquisition tools are activated, they must not have access to your health data, intake history, or personal content within the application.

13. Changes to the Policy

In the event of a significant change to this policy, you will be informed via the application and/or by email to the address associated with your account, within a reasonable time before the changes take effect.

14. Contact

Flomut SRL – MediCoach™ Avenue Chantecler 39, 1420 Braine-l’Alleud, Belgium Email: support@medi-coach.be Data Protection Authority (Belgium): https://www.dataprotectionauthority.be/citizenuthority: https://www.dataprotectionauthority.be