Privacy Policy
Last updated: 6 October 2026
Your health data is used only to care for and support you. It is hosted in France by a certified health-data host (HDS). It is never sold, never used for advertising and never shared with your employer or an insurer.
1. Who processes your data
Flora Ventures S.L. ("Days of Confidence", "we"), Calle de la Hiedra, 74, 28109 Alcobendas (Madrid), Spain, tax ID B88362926, is the controller for processing related to daysofconfidence.co.uk and daysofconfidence.com, the ReConnect by Days of Confidence app (the "App"), ReConnect plans, coaching, care coordination, the symptom quiz and product sales.
The Doctors. Each independent doctor who sees you by teleconsultation is the controller of the medical record she creates (diagnosis, reports, prescriptions, treatment plan). For this data, Days of Confidence acts as the Doctor's processor: we host it and make it available to you in the App, on her instructions.
Contact. For any question or request about your data: privacy@daysofconfidence.com or by post to the address above. Data Protection Officer (DPO): [TO COMPLETE: name or organisation, email]. UK representative (Article 27 UK GDPR): [TO COMPLETE: name and address of the UK representative].
2. The data we collect
| Source | Data |
|---|---|
| Browsing the Site | IP address, device and browser type, pages viewed, cookies (according to your choices) |
| Symptom quiz | Quiz answers (health data), email address if you ask for your results |
| Welcome call | Name, email, phone, chosen slot, reason for the call |
| Account and App | First name, last name, date of birth, email, phone, address, language, login credentials, plan subscribed |
| Medical questionnaire and follow-up | Medical history, symptoms, cycles, current treatments, weight and height, test results you upload, symptom-tracking entries, messages with the team |
| Teleconsultations | Date, Doctor, reports, prescriptions, treatment plan. Videos are not recorded. |
| Coaching | Goals, session notes (diet, sleep, physical activity, stress) and, if you agree, the main points of your treatment plan |
| Orders and payments | Delivery address, order history, invoices. Your card details are processed by our payment provider; we never store the full number. |
| Contact with us | Messages to customer service, complaints, published reviews, newsletter sign-up |
Access through your employer (ReConnect Entreprise). If you use the App through your employer, we only know that your access is funded by them. Your employer never receives individual data: only anonymised statistics, never calculated on a group of fewer than 30 people.
3. Why we use it and on what legal basis
| Purpose | Legal basis (UK GDPR) |
|---|---|
| Creating and managing your Account, providing the App and your ReConnect plan | Performance of a contract (Art. 6.1.b) |
| Organising your teleconsultations and sharing your questionnaire and documents with your Doctor | Performance of a contract (Art. 6.1.b) and explicit consent for health data (Art. 9.2.a) |
| Symptom tracking, messaging, care coordination, coaching | Performance of a contract and explicit consent (Art. 9.2.a) |
| Symptom quiz and sending results | Explicit consent (Art. 9.2.a) |
| Product orders, delivery, customer service | Performance of a contract (Art. 6.1.b) |
| Invoicing, accounting, contract archiving | Legal obligation (Art. 6.1.c) |
| Newsletter and marketing offers | Consent (Art. 6.1.a), which you can withdraw at any time |
| Service security, fraud prevention, usage statistics without health data | Legitimate interest (Art. 6.1.f) |
| Anonymised statistics for ReConnect Entreprise employer clients | Legitimate interest; only anonymised data leaves our systems |
| Handling complaints and defending our rights | Legitimate interest (Art. 6.1.f) and, for health data, Art. 9.2.f |
No decision about you is made solely by automated means. The App calculates no diagnosis or therapeutic recommendation: only your Doctor interprets your data.
4. Your health data
Consent. We obtain your explicit consent, through a separate tick box, before processing any health data. You may withdraw it at any time from your Account or by writing to us. Withdrawal does not affect processing already carried out. It prevents us from providing the services that depend on it. It does not remove your Doctor's obligation to keep your medical record.
Certified hosting. Your health data is hosted in France by [TO COMPLETE: host name], certified as a health-data host (Hébergeur de Données de Santé, HDS) under Article L.1111-8 of the French Public Health Code. The United Kingdom recognises the European Economic Area as providing an adequate level of protection for personal data sent from the UK.
Who can access it.
- Your Doctor: your full record, subject to medical confidentiality.
- Another Days of Confidence Doctor: only if you change Doctor or a replacement is needed, and with your agreement.
- Your Care Coordinator: the information needed to organise your appointments and what you write to her in messaging. She has no access to reports or prescriptions.
- Your Health Coach: your coaching notes and, only if you agree, the main points of your treatment plan.
- Our technical teams: only for maintenance and security, under a confidentiality obligation, with logged access.
What we never do. We do not sell your data. We do not use it for advertising. We do not share it with your employer, an insurer or a laboratory.
5. Recipients, providers and transfers
Your data is accessible only to those who need it: the Doctors, the Coach and the Care Coordinator within the limits of section 4, our authorised teams and our providers (processors). Each provider is bound by a contract compliant with Article 28 UK GDPR.
| Service | Provider | Location and safeguards |
|---|---|---|
| Health-data hosting | [TO COMPLETE] | France, HDS-certified |
| Video consultation | [TO COMPLETE] | [TO COMPLETE] |
| Website and online shop | Shopify | Ireland; possible transfers to Canada (adequacy decision) and the United States (Data Privacy Framework or standard contractual clauses) |
| Transactional emails | Resend | Servers in the EU (Ireland); US company (Data Privacy Framework or standard contractual clauses) |
| Welcome call booking | Calendly | United States (Data Privacy Framework or standard contractual clauses) |
| Symptom quiz | [TO COMPLETE] | [TO COMPLETE] |
| Payment | [TO COMPLETE: card provider], PayPal | EU; PCI-DSS certified providers |
| Instalment payment | [TO CONFIRM: Klarna or another provider available in the UK] | Independent controllers, under their own policies |
| Order preparation and delivery | [TO COMPLETE: logistics provider], carriers | EU and UK |
We may also share data with our advisers (lawyers, accountant), who are bound by professional secrecy, or with authorities where required by law. No provider outside the care teams has access to your health data in readable form, except the HDS host, the video-consultation tool and the symptom-quiz host, the latter for quiz answers only.
Any transfer outside the UK and the European Economic Area is covered by UK adequacy regulations, the UK Extension to the EU-US Data Privacy Framework, or the UK International Data Transfer Addendum to the European Commission's standard contractual clauses. You may request a copy.
6. How long we keep it
| Data | Retention period |
|---|---|
| Medical record (questionnaire, reports, prescriptions, treatment plan, messages with medical content) | [TO CONFIRM: retention period for UK patients' records, e.g. 8 years after the last Consultation (NHS Records Management Code) or a longer period], on behalf of your Doctor |
| Symptom tracking | As long as your Account exists, then added to the medical record if your Doctor used it |
| Account, organisational messages, coaching notes | Duration of the relationship, then 3 years after your last activity |
| Quiz answers without an Account | 12 months [TO CONFIRM] |
| Prospects (welcome call, newsletter without purchase) | 3 years after your last contact with us |
| Invoices and accounting records | 6 years (Article 30 of the Spanish Commercial Code) [TO CONFIRM: accountant] |
| Contracts | 6 years after the end of the contract (limitation period for claims) |
| Cookies and trackers | According to the Cookie Policy; your choices are requested again at least every 13 months |
| Records of rights requests | 1 year after our reply |
At the end of these periods, data is deleted or irreversibly anonymised. You can download your medical documents at any time, including after your plan ends.
7. Security, rights and practical information
Security. We encrypt data in transit and at rest. Access is individual, limited to what is strictly necessary and logged. We apply a backup and incident-management policy. If a data breach poses a high risk to you, we will inform you without undue delay.
Your rights. You have the following rights over your data:
- access and copy;
- rectification;
- erasure, except where the law requires us to keep it (in particular the medical record);
- restriction of processing;
- portability, in a machine-readable format;
- objection to processing based on our legitimate interest and, at any time, to direct marketing;
- withdrawal of your consent at any time.
To exercise them, write to privacy@daysofconfidence.com. We reply within one month. We may ask you to prove your identity if there is reasonable doubt. For medical-record data, we forward your request to your Doctor or answer it on her behalf.
Complaints. You may complain to the Information Commissioner's Office (ico.org.uk), the UK supervisory authority. You may also contact the Spanish Data Protection Agency (aepd.es), lead authority for Flora Ventures S.L. in the European Union.
Cookies. In line with the Privacy and Electronic Communications Regulations (PECR), non-essential cookies (analytics, advertising) are only set with your consent, through the banner shown on your first visit. You can change your choices at any time from the "Cookie settings" link at the bottom of the page.
Minors. Our services are reserved for adults. We do not knowingly collect data about anyone under 18.
Changes. We may update this policy. The date of the last update appears at the top of the page. Any significant change is notified to you by email or in the App.