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Privacy Policy

This privacy policy was updated on 07/06/2025.

‍PREAMBLE

Ochy (as defined hereinafter) is concerned about the protection of Personal Data (as defined hereinafter) that may be collected and processed from the Website (as defined hereinafter), from its Application (as defined hereinafter) and indirectly from its application programming interfaces (hereinafter referred as the “API”).

Ochy provides digital services incorporating video technology and artificial intelligence to deliver personalised full-body movement analysis in the context of sports (hereinafter the “Services’”).

Ochy undertakes to protect Personal Data in accordance with the applicable regulations and in particular Regulation (EU) n°2016/679 of 27 April 2016 known as the “General Data Protection Regulation” or “GDPR” and Law n° 78-17 of 6 January 1978 known as the “Data Protection Act” as amended (hereinafter the “Applicable Regulations”).

This document constitutes the privacy policy implemented by Ochy and is intended to inform you of the commitments and practical measures taken to ensure that your Personal Data is respected and protected (hereinafter the “Privacy Policy”).

The Services might be used in the different following contexts, involving different obligations on our part in terms of data protection:

  • The Application is downloaded and used directly by the User (as defined hereinafter) for personal purpose (1);
  • The Services are used through one of our partners by our API (2);
  • The Application is downloaded and used by a professional customer or a healthcare professional for its own customers or patients (3).

Ochy recommends that you read this Policy carefully. When Processing your Personal Data, Ochy complies with the requirements of the Applicable Regulations. This means, among other things, that:

  • Ochy clearly indicates the purposes for which Ochy processes your Personal Data by means of this Privacy Policy and processes your Personal Data exclusively for these specified purposes.
  • In accordance with the principle of minimisation, Ochy limits the collection of Personal Data strictly to the Personal Data necessary for the purposes of Processing indicated.
  • Ochy takes appropriate technical and organisational measures to ensure the appropriate security of your Personal Data.
  • Ochy undertakes to comply with any request for access, modification, deletion, objection, withdrawal and portability. You are also entitled to bring any complaints regarding the protection of personal data before the competent national authority, the Commission Nationale de l'Informatique et des Libertés (CNIL).

If you have any questions, you can contact Ochy by e-mail at the following address: info@ochy.io

DEFINITIONS

The words and expressions used in this Privacy Policy have the meaning defined below or that given to them by the Applicable Regulations, whether used in the singular or plural:

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“Applicable Regulations”

Has the meaning set forth in the preamble.

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“Application”

Refers to the software developed and operated by Ochy.


“API”

Has the meaning set forth in the preamble.


“Controller”

Refers to the natural or legal person or other body which, alone or jointly with others, determines the purposes and means of the processing.


“Data Subject”

Refers to a natural person who is directly or indirectly identified or identifiable.

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“Ochy”

Refers to the company Ochy, a simplified joint-stock company (Société par Actions Simplifiée) with a capital of 5,000 euros, registered with the Rennes Trade and Companies Register under number 901 855 296, and having its registered office at Le Village By CA, 3 Avenue Germaine Tillon SAINT-JACQUES-DE-LA-LANDE (35136).


“Personal Data”

Refers to any information relating to a Data Subject, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.


“Privacy Policy”

Has the meaning set forth in the preamble.


“Processing”

Refers any operation or set of operations which is performed upon Personal Data or sets of Personal Data, whether or not by automatic means, 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.

In this Privacy Policy, Ochy informs you about the processing of your Personal Data that Ochy has collected from the Website and the Application.


“Processor”

Refers to the natural or legal person or any other body that processes Personal Data on behalf of the Controller.


“Services”

Has the meaning set forth in the preamble.


“User”

Refers to any individual over the age of 18 who has full legal capacity and acts for purposes that do not fall within the scope of their commercial, industrial, craft, professional, or agricultural activities.


“Website”

Refers to Ochy’s website accessible at the address www.ochy.io. The Website is available twenty-four (24) hours a day, seven (7) days a week, except in cases of force majeure or the occurrence of an event beyond Ochy’s control, and subject to any maintenance operations necessary for the proper functioning of the Website.


  1. DIRECT USE OF THE WEBSITE AND APPLICATION BY THE DATA SUBJECT

In this context, Ochy acts as a Controller and complies with the relevant obligations.

  1. Purpose, data, and retention period


Ochy may collect Personal Data for the following purposes when you browse the Website and use the Application.

When using the Application and/or browsing the Website, the following Data may be collected by Ochy:

- First name,

- Last Name

- Gender,

- Weight,

- Height,

- User's movement speed,

- e-mail address,

- The User's profile photo,

- Video of the User's stride.

  1. Subscribing and managing your User account

For this Processing, Ochy uses the following data:

  • A first name and surname
  • An email address
  • The User’s profile photo

The purpose of this Processing is to be able to create and manage your User account.

The basis on which Ochy may process Personal Data is the performance of the contract.

Retention period

The Data is kept for a period of 12 months from the deletion of the User account.

  1. Use of the Services

For this Processing, Ochy uses the following data:

  • User's movement speed
  • Video of the User's stride
  • Gender
  • Weight
  • Height

From this data, Ochy generates biomechanical metrics to provide an analysis of your stride.

The purpose of this Processing is for the User to be able to use the Services provided by Ochy.

The basis on which Ochy may process Personal Data is the performance of the contract.

Ochy and its partners may further use the anonymized biomechanical metrics for research purposes and for AI model training.

Retention period

The initial Data provided (User’s movement speed, Video of the User’s race, Gender, Weight, Height) is kept for a period of 12 months from the deletion of the User account.

The biomechanical metrics are kept for a period of 5 years from the moment of their generation unless the User requests deletion.

  1. Contact by web form

For this Processing, Ochy uses the following data:

  • A first name and surname
  • An email address
  • A telephone number
  • Your company name
  • Content of the message

The purpose of this Processing is to be able to respond to your requests for information via the contact form available on the Website, via email or telephone.

The basis on which Ochy may process Personal Data is the legitimate interest of Ochy to be able to answer to your queries.

Retention period

Ochy keeps this data for the time required to provide you with a response to your initial request.

  1. Compiling and analysing statistics to improve the Website (Cookies)

A cookie is a small file stored by a server on a user's terminal (computer, telephone, etc.) and associated with a web domain (i.e. in most cases with all the pages of a single website).

They are used when using the Application and browsing the Website, in order to collect certain information (in particular IP address, connection mode, browser type and version, etc.).

There are several types of cookies:

- Cookies which are essential for using the Application or browsing the Website and which aim to enable or facilitate the transmission of communication by electronic means.

The User may make settings to block them, but this may have negative effects on the operation of the Application or the Website.

These cookies do not require the User's prior consent.

- Cookies linked to operations relating to personalised advertising, sharing on social networks, and those whose exclusive purpose is not to enable or facilitate the transmission of communication by electronic means.

These cookies require the User's prior consent.

The information collected via cookies is kept for a maximum of thirteen (13) months.

The first time the User browses the Website, he or she will be presented with a cookie consent form. This will present the cookies used by Ochy and their respective purposes.

The User will be able to explicitly select the cookies he accepts according to their purpose, and he will be able to withdraw his consent at any time.

  1. Communications and transfers of Personal Data

Within the framework of a strict policy of access and confidentiality management, only recipients duly authorised by Ochy may access the information that you may have communicated to us.

Under no circumstances will Personal Data be passed on to third parties for advertising and promotional purposes without your prior consent.

  1. Internal recipients

The Personal Data collected may be processed within the following Ochy departments: management, IT department, sales and marketing department.

  1. External recipients

Personal Data may also be transmitted to:

  • Third parties authorised by law, such as judicial or administrative authorities.
  • Processors and external service providers of Ochy, within the limits provided by the provisions in force and in accordance with this Privacy Policy.

In the context of their contractual relationship with Ochy, these Processors undertake to comply with the Applicable Regulations.

  1. Transfer and hosting of Personal Data

The processing and hosting of Personal Data is carried out in the European Union. The Data is stored by Google Cloud in Germany.

The Personal Data collected may be transmitted or processed outside the European Union, to Ochys’s partner companies.

In this context, Ochy guarantees that these transfers are carried out within the framework of an adequacy decision taken by the European Commission, justifying an adequate level of protection, within the meaning of Article 45 of the GDPR.

In the absence of an adequacy decision, Ochy may transfer Personal Data outside the European Union by putting in place the appropriate or adapted safeguards provided for by the applicable Regulation, such as the conclusion of standard contractual clauses approved by the European Commission.

  1. Security

Ochy is committed to ensuring the security of your Personal Data in order to guarantee an appropriate level of security as required by Article 32 of the GDPR. In particular, Ochy takes appropriate security measures to limit misuse and unauthorised access to your Personal Data. This ensures that only the necessary people have access to your data, that access to the data is protected.

These measures also aim to:

- Protect your Personal Data against destruction, loss, alteration and disclosure to unauthorised third parties,

- Ensure that the availability of your Personal Data is restored and that it can be accessed within an appropriate timeframe in the event of a physical or technical incident.

Our security measures are regularly checked and updated.

  1. Third party websites

This Privacy Policy does not apply to third party websites connected by links on our Website. Ochy cannot guarantee that these third parties manage your Personal Data in a reliable or secure manner when you browse these third-party websites. Ochy recommends that you read the privacy policies of these websites before browsing them.

  1. Changes to this Privacy Policy

Ochy reserves the right to modify this Privacy Policy. You are advised to consult this Privacy Policy regularly in order to take note of any changes. In addition, Ochy will actively inform you as far as possible of any changes that have an impact on the Processing of your Personal Data. The current version of the Privacy Policy is the one available at the time of your navigation on the Website.

  1. Your rights

If you have any questions or would like to know what Personal Data Ochy has collected about you, please contact Ochy. You can contact Ochy using the contact details below. You have the following rights:

  • Right of information: You have the right to know the purposes for which your Personal Data is collected, how it is processed and how long it is kept.


  • Right of access: you have the right to obtain confirmation as to whether or not your Personal Data is being processed by Ochy and, if so, to access your Personal Data.


  • Right of rectification and deletion: you have the right at any time to complete, correct or delete your Personal Data.


  • Right to Withdraw Consent: If the Processing of your Personal Data is based on the legal basis of consent, you have the right to revoke this consent and to have your Personal Data deleted. The exercise of this right will not affect the Processing carried out prior to the date of the request.


  • Right to transfer your data (portability): where Processing is based on your consent or on the performance of a contract on the one hand and is carried out using automated processes on the other, you have the right to request all your Personal Data from Ochy in a structured, commonly used and machine-readable format, and to transfer them in their entirety to another Data Controller.


  • Right to object: you may object to the processing of your Personal Data where this is based on consent or on grounds relating to your particular situation in the case of processing based on Ochy's legitimate interest. Ochy will comply unless there are compelling legitimate grounds for doing so.

When requesting rights, please ensure that you always clearly identify yourself so that Ochy can be sure that Ochy is not altering or deleting the Personal Data of the wrong person.

  1. Lodge a complaint

If you are not satisfied with the way Ochy process your Personal Data, you have the right to lodge a complaint with the French competent authority, which is the Commission Nationale de l'Informatique et des Libertés (CNIL).

  1. Contact details

Ochy :

Registered office: Le village by CA, 3 avenue Germaine Tillion 35136 Saint-Jacques-de-la-Lande, France

Phone: +33 6 22 89 50 28

E-mail: info@ochy.io

  1. INDIRECT USE OF SERVICES BY OUR API

When Ochy's Services are used indirectly via our partners through our API, Ochy acts only as a Processor and complies with the corresponding obligations, in particular in terms of security and cooperation with the Controller.

The partner who collects the Personal Data and provides the User with the biomechanical analysis generated by Ochy’s software acts as the Controller and complies with the obligations incumbent upon it in this capacity, in particular that of informing you of the conditions under which it processes your Data in this context by means of its own privacy policy. Please refer to this policy for further information.

  1. USE OF SERVICES BY PROFESSIONALS

When the Application is downloaded and used by a professional customer or a healthcare professional for its own customers or patients, Ochy acts only as a Processor and complies with the corresponding obligations, in particular in terms of security and cooperation with the Controller.

The Controller is the professional using the Services for its clients or patients and must respect the Applicable regulations in this capacity, in particular that of informing you of the conditions under which it processes your Data in this context by means of its own privacy policy. Please refer to this policy for further information.

Health Data

In the context of the collection and use of your Personal Data by healthcare professionals, this Data may be qualified by destination as health data, which is subject to stricter protection by the Applicable Regulations (in particular by article 9 of the GDPR).

This Processing is allowed under the exception of article 9.2(h) of GDPR for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional.

Ochy also complies with the specific obligations applicable to the hosting of such Data, in accordance with the provisions of the French Public Health Code. In this context, the Data is hosted by Google Cloud, an HDS-certified host.

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