Privacy Policy

Last updated: 12 June 2026 — Version: 2026-06-12-v1

This Privacy Policy describes how personal data is processed within the Roro Vision service, in accordance with Regulation (EU) 2016/679 (GDPR) and the French Data Protection Act No. 78-17 of 6 January 1978, as amended.

1. Data controller

The data controller is Alexandre Khalifé, a sole trader operating under the trade name "Roro Vision", SIREN 989 113 352 (Créteil Trade and Companies Register), whose registered office is at 29 Boulevard Henri Ruel, 94120 Fontenay-sous-Bois, France.

For any question regarding your data or to exercise your rights: support@roro.vision — Phone: +33 7 82 03 85 21.

2. Purposes of processing

3. Lawful bases

In accordance with Article 6(1) of the GDPR, processing is based, depending on the purpose, on:

4. Data collected

5. Data that may relate to health (Article 9 of the GDPR)

The service neither solicits nor requires health data. However, as part of general-purpose use (for example reading a medication dosage), a user may voluntarily provide information that may fall within Article 9 of the GDPR (special categories of data). Such information is processed solely to answer the user's specific request.

6. Processors (Article 28 of the GDPR) and recipients

We use the following processors, which act only on our documented instructions:

ProcessorRoleLocation / transferTransfer safeguard
Google (Gemini / Cloud / Vertex AI)Generative AI (session photos and transcription)EU regions available; inference may occur outside the EUEU-US Data Privacy Framework (DPF) and Standard Contractual Clauses (SCC)
LiveKit CloudReal-time audio/video infrastructureRegional pinning possible; observability outside the EUDPF, Standard Contractual Clauses (SCC) and UK IDTA
SupabaseDatabase, storage and authenticationEU region (Frankfurt)Standard Contractual Clauses (SCC)
Fly.ioBackend and worker hostingEU region (Paris)EU-US Data Privacy Framework (DPF)
RevenueCatSubscription and purchase managementUnited States infrastructureStandard Contractual Clauses (SCC)
SentryError monitoringEU residency optionDPF and Standard Contractual Clauses (SCC)
PostHogUsage analytics (can be enabled / disabled)PostHog Cloud EU (Frankfurt)Standard Contractual Clauses (SCC)

Advertising measurement (Meta)

To measure the effectiveness of our advertising campaigns, the application embeds the SDK of Meta Platforms Ireland Limited (Merrion Road, Dublin 4, Ireland). Unlike the processors above, Meta acts as a separate data controller for this measurement. The data processed is limited:

This measurement is enabled by default and can be disabled at any time via the app's analytics setting (the same setting as usage analytics). The first technical events (install, first app launch) may however be sent before that choice is expressed. Transfers to the United States are governed by the EU-US Data Privacy Framework and Standard Contractual Clauses (SCC). More information: Meta Privacy Policy.

7. Transfers outside the European Union

Where processing involves a transfer to a third country, it is governed by the appropriate safeguards under Articles 44 to 49 of the GDPR: Standard Contractual Clauses adopted by the European Commission (Article 46) and, where applicable, a processor's participation in the EU-US Data Privacy Framework (adequacy decision).

8. Retention periods

Account deletion is preceded by a 30-day cooling-off period during which the account can be reactivated.

9. Your rights

Under Articles 15 to 21 of the GDPR, you have the following rights:

To exercise these rights, contact support@roro.vision.

10. Data Protection Officer (DPO)

The role of Data Protection Officer is held by the director of Roro Vision, who can be reached at support@roro.vision.

11. Supervisory authority

Under Article 77 of the GDPR, you have the right to lodge a complaint with a supervisory authority. In France, the competent authority is the Commission nationale de l'informatique et des libertés (CNIL)cnil.fr.

12. Minors

The service is not intended for children under 15. In France, consent to data processing in the context of online services requires a minimum age of 15 (Article 8 of the French Data Protection Act).

13. Data residency

At launch, data is hosted in the European Union (single region). Any transfers to processors located outside the EU are governed in accordance with section 7.

14. Cookies and trackers

The Roro Vision mobile application does not use cookies. Usage within the application is measured using PostHog (by means of a tracking identifier) and technical errors are collected via Sentry. Audience measurement can be disabled in the application settings.

15. Updates

This policy may be updated. Users are informed of significant changes within the application.

Notes and references

Applicable official references.

  1. GDPR, Article 6 (lawfulness), Article 9 (special categories) — CNIL, Chapter II.
  2. GDPR, Articles 12 and 13 (information); Articles 15 to 21 (rights) — CNIL, Chapter III.
  3. GDPR, Article 28 (processor), Article 37 (DPO) — CNIL, Chapter IV.
  4. GDPR, Articles 44 to 49 (international transfers) — CNIL, Chapter V.
  5. GDPR, Article 77 (right to lodge a complaint) — CNIL, Chapter VIII.
  6. French Data Protection Act No. 78-17 of 6 January 1978 — Légifrance.
  7. Processors' data processing addenda (DPA): Google Cloud, LiveKit, Supabase, Fly.io, RevenueCat, Sentry, PostHog.