Sémio — LA TOUR DE BABEL CORPORATION (LTB SARL)
PRIVACY POLICY OF THE SÉMIO APPLICATION
Version: 2.0.0 — Last updated: 2026-07-08.
1. DATA CONTROLLER
The Sémio application is published by LA TOUR DE BABEL CORPORATION ("LTB SARL"), a limited liability company governed by Cameroonian law (the "Publisher"), controller of the processing of personal data.
Contact and exercise of rights: semio.ltdb@gmail.com. Further company identification details are provided on request.
2. NATURE OF THE APPLICATION
Sémio is an educational training tool, including a medical observation simulator for clinical-reasoning practice. It is neither a medical device, nor an electronic health record, nor a care tool. The User undertakes to enter only training, fictitious, or duly anonymized data, and never data identifying a real patient.
3. DATA PROCESSED
3.1. User data. Email address and account identifier required for authentication; where provided, given or usual name, sex, professional role, specialty, and affiliated institution. This data identifies the User, not a patient.
3.2. Observation content. The content of training cases entered by the User: complaint, history, background, examination, additional tests, hypotheses, treatments, and monitoring parameters, including images. Such content may constitute health data, a special category within the meaning of Article 9 of Regulation (EU) 2016/679 ("GDPR"), and is treated as such. Before any transmission to a server, an AI service, or remote storage, this content is anonymized on the User's device, an application check blocking transmission where an identifying field is present.
3.3. AI-generated outputs. Summaries, hypotheses, and suggestions produced for learning purposes, with no diagnostic or prescription value.
3.4. Voice recordings. When the User uses dictation, an audio recording is captured and then transcribed into text by a voice-recognition provider, for the sole purpose of that transcription.
3.5. Technical and device data. User identifier, notification token, timestamps, synchronization status, and technical error logs free of clinical content.
3.6. Biometric unlock data. Biometric unlocking is handled by the device operating system. No biometric data is transmitted to the Publisher or stored on its servers; it remains on the device.
3.7. Permissions. The Application may request access to the camera and gallery, microphone, notifications, and biometrics. These permissions are optional and enabled on the User's request.
4. PURPOSES AND LEGAL BASES
4.1. Operation of the Application and account management: performance of the contract with the User (Article 6.1.b GDPR).
4.2. Processing of content constituting health data: the User's explicit consent (Articles 6.1.a and 9.2.a GDPR), obtained separately and revocable at any time. The Publisher does not rely on the "health care" basis of Article 9.2.h, the Application being an educational tool.
4.3. Improvement and security of the Service, abuse prevention: the Publisher's legitimate interest (Article 6.1.f GDPR), respecting the User's rights.
Data is used neither for advertising, commercial profiling, resale to third parties, nor for training artificial intelligence models absent a separate, revocable consent.
5. STORAGE AND SECURITY
5.1. Local storage. Data is stored primarily on the User's device. Sensitive observation content is encrypted there using an AES-256-GCM algorithm, the key being kept in the device's hardware secure component.
5.2. Optional remote storage. Where the User enables synchronization, anonymized data is transmitted to the host's infrastructure, whose region is configured within the European Union. Transmissions are encrypted in transit using TLS and data is encrypted at rest.
5.3. Security measures. The Publisher implements appropriate technical and organizational measures: encryption in transit and at rest, mandatory authentication, per-user data partitioning, access logging, and regular updates.
6. SUB-PROCESSORS AND INTERNATIONAL TRANSFERS
6.1. The Publisher uses technical service providers acting on its instructions, bound by a processing agreement compliant with Article 28 GDPR, falling within the following categories: a hosting, authentication, and storage provider; artificial intelligence model providers (processing anonymized content only, see Article 8); document-recognition providers; a subscription-management provider; a technical-monitoring provider, to which no clinical data is transmitted. The detailed named list of sub-processors is kept up to date by the Publisher and provided on request.
6.2. Some sub-processors are established outside the European Union, in particular in the United States and, for one AI model provider, in the People's Republic of China. Such transfers are framed by the European Commission's standard contractual clauses, supplemented where appropriate by additional measures. Only anonymized content is transmitted to these sub-processors. The detailed register of sub-processors is maintained by the Publisher and provided on request.
7. DATA RESIDENCY AND REGULATED REGIONS
Remote storage and synchronization may be disabled for Users located in certain strict-framework jurisdictions, in particular the European Union, the United Kingdom, and the United States. In that case, the Application operates in local mode, data remaining encrypted on the device, and the User is informed.
8. AUTOMATED PROCESSING AND ARTIFICIAL INTELLIGENCE
Content submitted to the assistant is anonymized on the device before any transmission to AI model providers (Google Gemini, DeepSeek, Mistral), for the sole purpose of generating an educational response. This content is not used to train the models absent a separate, revocable consent. The suggestions produced have no legal or similarly significant effect on the User, who retains the decision.
9. SDKS AND ABSENCE OF ADVERTISING TRACKERS
The Application integrates third-party services for its operation: authentication and database, subscription management, and technical monitoring (with personal data filtered). The Application integrates no advertising network and no advertising tracker, and performs no tracking of the User's activity across applications or websites. Non-essential trackers, if any, are placed only with the User's prior consent.
10. RETENTION PERIODS
Account data is retained for the duration of account use. Locally stored data is retained until deleted by the User. Upon an account-deletion request, data is permanently erased after a thirty-day grace period. Voice recordings are not retained beyond transcription, save specific consent. Technical logs are retained for a limited period for security and diagnostic purposes.
11. RIGHTS OF DATA SUBJECTS
The User has the rights of access, rectification, erasure, restriction, objection, and portability, as well as the right to withdraw consent at any time without retroactive effect. These rights are exercised with the Publisher at semio.ltdb@gmail.com. The User also has the right to lodge a complaint with the competent supervisory authority.
12. CALIFORNIA USERS
For Users residing in California, the Publisher collects identifiers, user content, any health data qualifying as sensitive personal information, and technical data, for the purpose of operating the Application and excluding any advertising purpose. The Publisher does not sell or share personal data within the meaning of the California Consumer Privacy Act as amended. Concerned Users have the rights to know, access, delete, correct their data, opt out of its sale or sharing, limit the use of sensitive information, and to non-discrimination. These rights are exercised at the address in Article 11.
13. MINORS
The Application is reserved for adults practising or training for a healthcare profession. It is not intended for children. The Publisher does not knowingly collect data concerning minors within the meaning of the Children's Online Privacy Protection Act and Article 8 GDPR. Any data relating to a minor brought to its attention is deleted.
14. DATA BREACH
In the event of a data breach likely to result in a risk to the rights and freedoms of individuals, the Publisher notifies the competent supervisory authority as soon as possible, and at the latest within seventy-two hours of becoming aware of it, and informs the concerned individuals where the risk is high.
15. CHANGES TO THIS POLICY
The Publisher may amend this policy. In the event of a material change, the User is informed at the next login and, where required, invited to renew their consent.
16. CONTACT
For any question regarding this policy or to exercise rights, the User may contact the Publisher, LA TOUR DE BABEL CORPORATION ("LTB SARL"), at semio.ltdb@gmail.com.