# Privacy policy

Web version: https://espeir.com/en/confidentiality
Languages: [fr](https://espeir.com/md/fr/confidentiality) · [en](https://espeir.com/md/en/confidentiality) · [de](https://espeir.com/md/de/confidentiality)

Last updated: October 2026

## Preamble

This privacy policy (the “Policy”) describes the conditions under which ESPEIR (the “Company”) processes personal data in connection with:

visiting and using the ESPEIR website (the “Site”);

and, where applicable, using the CLARYS Medical Memory solution, a longitudinal clinical reading interface based on HL7 FHIR (R4), designed to provide read-only access to clinical data and documents from third-party systems (EHRs, EDMS, document repositories exposing FHIR) and to present them in a readable, chronological and contextualized form.

ESPEIR attaches particular importance to the protection of personal data and acts in accordance with the GDPR and applicable laws.

## 1. Definitions

Personal data: any information relating to an identified or identifiable natural person.

Health data: personal data concerning health (a special category within the meaning of the GDPR).

Processing: any operation performed on data (collection, consultation, use, display, etc.).

Controller / Processor / Data subject: within the meaning of the GDPR.

## 2. Our role: controller and processor

2.1 ESPEIR as controller

ESPEIR is the controller for data relating to:

browsing the Site (technical data, cookies, security);

inbound requests (contact, demo, meetings, commercial exchanges);

managing contractual relationships with its customers (business contacts, billing).

2.2 ESPEIR (and/or CLARYS Medical Memory) as processor

When CLARYS Medical Memory is used by a healthcare facility (or a software vendor / integrator), the customer is in principle the controller for health data and defines the purposes (patient care, record access, etc.).

CLARYS Medical Memory is positioned as a cross-cutting viewing component, downstream of the source systems, without replacing an EHR or a system of record. In this context:

CLARYS Medical Memory accesses FHIR servers in read-only mode;

CLARYS Medical Memory does not create, modify or validate clinical data;

CLARYS Medical Memory makes no medical decisions. When CLARYS Intelligence is enabled, it performs semantic extraction: it identifies and structures the information in documents, with a link to its source, without making any diagnosis or recommendation. Clinical interpretation remains the role of healthcare professionals;

processing is governed by a data processing agreement (DPA).

Depending on the deployment model (on-premises or managed cloud), ESPEIR may or may not have operational access to the customer’s environments. This scope is set out in the contract signed with each customer.

## 3. Principles of data processing by ESPEIR

ESPEIR applies the GDPR principles: lawfulness, fairness, transparency, data minimization, accuracy, storage limitation, security.

CLARYS Medical Memory product principle (deliberately limited scope):

CLARYS Medical Memory is designed for document visualization and navigation;

authentication is handled by the customer’s identity provider; CLARYS Medical Memory does not manage its own user accounts and only keeps identity references and display preferences;

authentication and access logging are centralized on the server side; the interface displayed in the browser does not handle authentication tokens.

## 4. Legal bases, purposes and scope of processing

4.1 Website (ESPEIR as controller)

Purposes: operation, security, fraud/incident prevention, usage statistics; responding to requests (contact/demo); B2B communication.

Legal bases (depending on the case): legitimate interest (website security, administration); pre-contractual measures (responding to a request); consent (non-essential cookies, if used).

Data categories (website): browsing data and logs (IP address, user agent, pages viewed, timestamp); data provided through forms (name, email, organization, message).

4.2 CLARYS Medical Memory (customer as controller / ESPEIR as processor)

Purposes: providing a longitudinal clinical view of data exposed by FHIR servers, presented in a contextualized and traceable way.

Scope (concrete principles):

read-only access to FHIR resources, through a server-side service;

logging/auditability of application access (in line with hospital information system requirements);

limited application storage (sessions, preferences, context settings), with no clinical repository of its own.

When CLARYS Intelligence indexes document content, this indexing constitutes processing: its duration, location and security measures are defined with the customer acting as controller and documented in the contract.

## 5. Data sources

directly from you (website/forms/exchanges);

automatically (security logs, cookies if used);

through the customer’s source systems (FHIR servers / IdP) when CLARYS Medical Memory is used in a customer environment.

## 6. Recipients

Depending on the case, data may be accessible to:

authorized ESPEIR teams (on a need-to-know basis);

technical service providers, under contract: website hosting (Vercel Inc.), audience measurement (PostHog Inc., EU hosting), transactional email delivery (Resend), messaging (Microsoft 365), as well as hosting, managed services and support for CLARYS Medical Memory;

competent authorities where required by law.

As CLARYS Medical Memory is designed to integrate with existing information systems, most of the rules governing access to clinical data are determined by the upstream systems (FHIR server / authorization mechanisms).

## 7. Retention periods

7.1 Website data (ESPEIR as controller)

contact / demo requests: up to 36 months from the last contact; job applications: up to 24 months;

security logs: a limited and proportionate period.

7.2 CLARYS Medical Memory data (ESPEIR as processor)

sessions / preferences / context settings: the time needed to run the service, agreed with the customer at deployment;

logs/audit trails: according to the customer’s requirements and security policy;

clinical data: no primary storage by CLARYS Medical Memory; any retention/persistence only if provided for in the contract and configuration (e.g. indexes), with specified periods.

## 8. Hosting and transfers

CLARYS Medical Memory can be deployed on-premises (hospital) or in a cloud that meets applicable requirements (e.g. HDS, the French health data hosting certification, where required), at the customer’s choice.

As a principle, ESPEIR aims for EU/EEA hosting for CLARYS Medical Memory. The website is hosted by Vercel Inc. and contact form emails are delivered by Resend, both providers established in the United States: these transfers are governed by appropriate safeguards (European Commission standard contractual clauses and, where applicable, the Data Privacy Framework).

## 9. Cookies and audience measurement

The site uses PostHog (PostHog Inc., data hosted in the European Union, in Frankfurt) to measure its audience and improve its content.

Without your consent, measurement runs without cookies or storage on your device: only aggregate statistics are produced (page views, referrers, clicks), based on a temporary identifier computed server-side.

With your consent, PostHog sets cookies and uses your browser’s local storage to follow your journey on the site and record your browsing (session recording), in order to identify usability issues. Form fields are masked and never recorded.

Your choice is kept for up to 13 months. You can change it at any time via the “Manage cookies” link at the bottom of every page. Legal basis: your consent for cookies, legitimate interest for cookieless measurement.

## 10. Your rights

Where ESPEIR is the controller: rights of access, rectification, erasure (subject to conditions), restriction, objection, portability (subject to conditions), withdrawal of consent (where applicable), and the right to lodge a complaint with the CNIL.

Where ESPEIR acts as a processor for CLARYS Medical Memory: requests should in principle be addressed to the customer acting as controller, unless the contract provides for a different mechanism.

## 11. Exercising your rights / Contact

ESPEIR

contact@espeir.com

ESPEIR responds within the applicable legal time limits.

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## Site pages

- [Home](https://espeir.com/md/en)
- [CLARYS Medical Memory](https://espeir.com/md/en/clarys/medical-memory)
- [CLARYS Intelligence](https://espeir.com/md/en/clarys/intelligence)
- [IT convergence and modernization](https://espeir.com/md/en/solutions/modernisation)
- [Archives and medical heritage](https://espeir.com/md/en/solutions/archives)
- [Clinical data warehouses](https://espeir.com/md/en/solutions/clinical-data-warehouse)
- [Health and social care continuity](https://espeir.com/md/en/solutions/care-continuity)
- [Software vendors and integrators](https://espeir.com/md/en/solutions/software-vendors)
- [Trajectories and populations](https://espeir.com/md/en/solutions/trajectories-populations)
- [Technology and science](https://espeir.com/md/en/technology)
- [Partners](https://espeir.com/md/en/partners)
- [ESPEIR](https://espeir.com/md/en/espeir)
- [Contact](https://espeir.com/md/en/contact)
- [Legal notice](https://espeir.com/md/en/legals)
- [Privacy policy](https://espeir.com/md/en/confidentiality)

## Contact

ESPEIR, 66 avenue des Champs-Élysées, 75008 Paris, France
contact@espeir.com