Data Processing Agreement – Tournée facile
Last updated: 12/08/2026
1. Purpose
This agreement (the "Agreement") governs the processing of personal data carried out by Hakimon Solutions on behalf of the professional user, pursuant to Article 28 of Regulation (EU) 2016/679 ("GDPR").
It supplements the Terms of Use, of which it forms an integral part. In the event of any conflict regarding the processing of personal data, this Agreement prevails.
2. Roles of the parties
2.1 The healthcare professional is the controller
The nurse or practice using Tournée facile (the "Controller") determines the purposes and means of processing their patients' data: which patients to follow, which care to record, which handover notes to write, which rounds to organise.
That processing falls under their professional practice and their own obligations, in particular medical confidentiality (Article L1110-4 of the French Public Health Code) and the keeping of the care record.
2.2 Hakimon Solutions is the processor
Hakimon Solutions, a French SAS with share capital of €1,000, 200 rue de la Croix Nivert, 75015 Paris, Paris Trade and Companies Register 992 080 192 00014 (the "Processor") processes that data solely on the Controller's documented instructions, in order to provide the service.
The Processor determines neither the purposes nor the means of processing patient data.
Two distinct processing activities. The Processor is, by contrast, the controller for its own data: user account, billing, technical logs, support. Those activities are described in the Privacy Policy and fall outside the scope of this Agreement.
3. Description of the processing
- Nature: hosting, storage, organisation, consultation, structuring and erasure.
- Purpose: to provide the features of Tournée facile — patient record, round planning, handover notes, pill organisers, visit reports.
- Duration: the term of the contract, plus the erasure periods set out in Article 9.
3.1 Categories of data subjects
- The patients followed by the Controller;
- the patients' reference contacts (relative, carer, treating physician);
- the practice members invited by the Controller.
3.2 Categories of data
- Identification data: surname, first name, date of birth, sex;
- Contact details: postal address, telephone, email;
- Health data (Article 9 GDPR): care provided, NGAP procedure codes, written handover notes, photographs and voice recordings added by the caregiver, vital signs, treatments and pill organisers, documents added to the record;
- Health identity data: French social security number (NIR) or national health identifier (INS), where the Controller enters them.
4. The Controller's instructions
The Processor processes the data only on documented instructions. This Agreement constitutes the initial instruction; any further instruction is to be sent in writing to simon@hakimon.com.
The Processor immediately informs the Controller if it considers that an instruction infringes the GDPR.
What the Processor does not do. Without the Controller's written instruction, it refrains from:
- accessing the content of patient records, save for a documented technical necessity (incident, support request);
- using the data for its own purposes, including statistics or service improvement, except after irreversible anonymisation;
- training an artificial intelligence system on that data;
- selling, renting or disclosing that data to a third party.
5. Confidentiality and authorised persons
The Processor warrants that persons authorised to process the data are bound by a contractual duty of confidentiality and access the data only as far as their duties require.
Technical access to production data is individually named, logged, and limited to the persons responsible for operations.
6. Security (Article 32 GDPR)
The measures in place as at the date of this Agreement:
- HDS-certified hosting — the application and the data are hosted by AZNETWORK, an approved French health-data host, on servers located in France;
- Encryption in transit — TLS on all communications;
- Encryption of media at rest — photographs and voice recordings are encrypted (AES-256-GCM, envelope encryption);
- Authentication — OpenID Connect, with tokens held in the operating system's secure store;
- Practice isolation — every resource belongs to a practice, and data belonging to another practice is unreachable;
- Role-based permissions — owner, associate, nurse, locum, assistant, read-only;
- Logging — access to health data is logged;
- Backups — regular, encrypted backups.
The Processor may change these measures provided it does not lower the level of security.
7. Sub-processors
The Controller authorises the use of the following sub-processors:
- AZNETWORK — HDS hosting of the application and the data. France.
- OVHcloud — hosting of the marketing website, no patient data. France.
- Apple and Google — processing of subscriptions purchased from the app stores, no patient data. Ireland and United States.
- Google Maps (Google LLC) — turning an address into coordinates and computing round itineraries. Only the postal address is sent, with no name, no identifier and no health data whatsoever. United States. This transfer relies on the European Commission's Standard Contractual Clauses and on the EU–US Data Privacy Framework, to which Google LLC adheres.
The Processor imposes on each of them the same obligations as those set out in this Agreement, and remains fully liable for their performance.
Any addition or replacement is notified at least thirty (30) days in advance. The Controller may object on legitimate data-protection grounds; failing agreement, they may terminate at no cost and obtain a pro rata refund of any period paid in advance.
8. Assistance from the Processor
The Processor assists the Controller with:
8.1 Data subject rights
The application's features allow the Controller to consult, rectify, export and erase a patient's data themselves. Where that is not sufficient, the Processor assists within a reasonable time.
A request addressed directly to the Processor by a patient is forwarded to the Controller without being answered on the merits: it is for the Controller to answer it.
8.2 Personal data breaches
The Processor notifies the Controller of any personal data breach without undue delay and at the latest within seventy-two (72) hours of becoming aware of it, by email to the owner account's address.
The notification describes the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences and the measures taken.
Notification to the CNIL (Article 33) and, where applicable, to the data subjects (Article 34) is the Controller's responsibility.
8.3 Data protection impact assessment
On request, the Processor provides the information needed for a data protection impact assessment.
9. Fate of the data at the end of the contract
At the end of the contract, the Controller may export their data from the application.
Thirty (30) days after the end of the contract, the Processor erases the patient data from its active systems. Backups are purged by rotation, at the latest six (6) months after the end of the contract.
This period is not a retention period. The care record is subject to the healthcare professional's own retention obligations. It is for the Controller to export whatever they must retain before the contract ends.
10. Audit
The Processor makes available the information needed to demonstrate compliance with Article 28, in particular its host's HDS certificate and the description of its security measures.
The Controller may request an audit, at most once a year, on thirty (30) days' notice, at the requester's expense, under conditions preserving the confidentiality of other practices.
11. Transfers outside the European Union
Patient data is hosted in France and is not transferred outside the European Union.
Data relating to subscriptions purchased from an app store is processed by Apple or Google under their own terms; it contains no patient data.
12. Liability
Each party is liable for damage caused by processing which infringes the GDPR, under the conditions of its Article 82.
13. Term and acceptance
This Agreement takes effect upon acceptance of the Terms of Use and runs for the duration of the use of the service.
Acceptance is obtained electronically when the account is created, in accordance with Articles 1127-1 and 1127-2 of the French Civil Code. The version accepted and the date of acceptance are retained by the Processor.
Any substantial change is notified at least thirty (30) days in advance.
14. Contact
Data Protection Officer: Simon Defretin Email: simon@hakimon.com Address: Hakimon Solutions, 200 rue de la Croix Nivert, 75015 Paris