MediCoach™ Privacy Policy

Last updated: March 3, 2026

MediCoach, developed by Flomut SRL, avenue Chantecler 39, 1420 Braine-l'Alleud, Belgium, and Florien Munezero Twahirwa, founding pharmacist of « MediCoach™ », is committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR) (EU 2016/679), the Belgian Law of July 30, 2018, and Google Play program rules.

This policy applies to our mobile application for medication intake organization and reminders, classified in the Health & Fitness category of the Play Store. MediCoach is not intended for diagnosing or providing therapeutic decisions.

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 (Minimization Principle)

We collect only the data necessary for the operation of the application and the organization of your reminders:

• Firebase UID: Required for secure authentication of your account.

• First Name: Used for interface personalization and assistant messages (organizational purpose, non-medical).

• Profile Photo (optional): If you import a photo, it is used to personalize your interface. You can modify or delete it at any time via your profile settings.

• Age Range: Data used to generate anonymous usage statistics and optimize the display of your adherence tracking.

• Personal Goals (e.g., habit tracking, life routine): Information voluntarily provided by the user to guide the motivational support of the IA assistant.

• Personal Product List: Name, form, frequency, and times, solely for programming reminders and displaying your daily schedule.

• Validation Status: Marking intakes (validated / not validated) for calculating your personal adherence score.

MediCoach implements double data protection:

• Standard AES-256 encryption for data in transit (HTTPS/TLS 1.3) and server storage (Firebase).

• Use of isolated and encrypted storage compartments on the Android system (EncryptedSharedPreferences and Room/SQLCipher database), ensuring your product list and times remain inaccessible to other apps on your device.

• Use of bank-grade AES-GCM protocol for encrypting exported reports (PDF/QR Code).

Searches in our product database are processed locally or via anonymized requests, preventing any link between your searches and your civil identity.

3. Non-Collected Data

We never collect:

• NISS number or other national identifiers.

• Diagnoses, laboratory results, or detailed medical history.

• Geolocation data.

• Biometric data.

• Facial or voice recognition data.

4. Processing Purposes

Your data is used exclusively for:

• Programming and displaying your medication intake reminders.

• Organizing your daily schedule and intake habits.

• Generating anonymous usage statistics to improve the application (ergonomics, frequency of use).

We do not use your data for:

• targeted advertising,

• sale or rental of data to third parties,

• behavioral profiling for commercial purposes,

• sharing data with partners without your explicit consent.

Adherence data (e.g., percentage of completed intakes) is processed as global statistics, completely dissociated from your civil identity, to improve our support tools.

5. Retention Periods

• Active reminders and schedule: retained as long as your account is active or until app uninstallation.

• Intake history (taken / missed): 30 days, then automatic deletion or anonymization.

• Deleted account: definitive erasure of your data from Firebase servers within a maximum of 30 days. Deleted account: the deletion commitment is total. The user can trigger this action autonomously via the app Settings. The definitive erasure of all data from Firebase servers occurs within a maximum of 30 days, with no residual retention.

6. Technical Security

We apply the following measures:

• Secure authentication via Firebase (servers located in the EU, via Google Ireland Ltd).

• AES-256 encryption of data at rest.

• Secure transmission via HTTPS/TLS 1.3.

• Encrypted backups and access restricted to authorized persons only within Flomut SRL.

• Isolated local storage (EncryptedSharedPreferences/Room) to prevent access by other apps.

7. Data Sharing

• Technical providers (Firebase/Google): limited access, governed by EU Standard Contractual Clauses.

• No sharing with laboratories, pharmacies, or commercial partners without your explicit prior consent.

• Any pharmacy partnerships are based solely on anonymized and aggregated data (e.g., global adherence indicators).

8. Your Rights (GDPR)

From the Settings of the application or by contacting us by email, you can:

• Right of access: view or download your data in readable format (JSON).

• Right to rectification: modify your profile information.

• Right to erasure: use the « Delete my account » function or write to us at support@medi-coach.be; your data will be deleted within 30 days.

• Right to object and limitation: disable certain tracking features in Settings.

You may also file a complaint with the Belgian Data Protection Authority (DPA).

9. Consent

• Upon first use, an explicit checkbox allows you to accept this privacy policy.

• Some optional features may be subject to specific consent (e.g., notifications).

• You may withdraw your consent at any time via the app Settings; certain features may then be limited.

10. Non-Medical Nature of the Application

MediCoach is a personal organization and reminder tool.
The application and integrated IA coach:

• do not diagnose,

• do not prescribe treatment,

• do not modify dosages or intake times,

• do not perform personalized medication interaction analysis.

For any medical question (symptoms, side effects, interactions, treatment adjustment), consult your doctor or pharmacist.

11. International Transfers

Data is primarily hosted in the europe-west1 region (Ireland) via Firebase infrastructure (Google Cloud).
In case of transfer to servers located outside the EU (e.g., Google services), these are governed by the Standard Contractual Clauses adopted by the European Commission to ensure adequate protection.

12. Cookies and Trackers

No advertising cookies are used in the app.
We may use Firebase Analytics in anonymized form, without personal identifiers, solely for global usage statistics.

13. Policy Changes

In case of significant changes to this policy, you will be informed via the application (notification or in-app message).
In case of substantial changes to the purposes, new consent may be required.

14. Contact

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