Privacy Policy
This policy explains what personal data Foot Camera handles, why, and on whose behalf — for practitioners who use the app, for the clinics and laboratories that hold accounts, and for the patients whose feet are scanned.
Last updated 26 July 2026
1. Who we are
Foot Camera is operated by Novansa OÜ, a company registered in Estonia under registry code 17445226, with its registered address at Sepapaja tn 6, 15551 Tallinn, Harju maakond, Estonia. In this policy “we”, “us” and “our” mean Novansa OÜ.
Foot Camera consists of an iOS app used by clinicians to capture 3D scans of patients’ feet, a web application used by clinics and laboratories to manage orders, and the backend service that connects them.
For any privacy question, or to exercise your rights, contact us at privacy@foot.camera. We have not appointed a Data Protection Officer; privacy enquiries are handled by our management.
2. Two roles: controller and processor
We handle personal data in two distinct capacities, and it matters which one applies to you.
We are the controller
For the data we decide the purposes of ourselves: the accounts of the practitioners, clinic staff and laboratory staff who use the service, our correspondence with them, technical diagnostics, security logging, and visitors to this website. Section 5 sets out our legal bases for that processing.
We are a processor
For patient data — including the foot scans themselves — the clinic is the controller. The clinic decides which patients are scanned, what is recorded about them, which laboratory receives the order, and how long the record is kept. We process that data only on the clinic’s documented instructions, as set out in our data processing terms. A data processing agreement is available to account holders on request from privacy@foot.camera.
3. What data we handle
Account data (we are the controller)
- Name and work email address.
- Role within the service (practitioner, clinic staff or laboratory staff) and the clinic or laboratory the account belongs to.
- Sign-in codes sent by email, session tokens, and the timestamps of account activity.
- Any correspondence you send us — by email, or through the contact form on this website. The form collects your name, email address, optionally your clinic or laboratory, and your message; it is delivered to us as an email and is not stored in a database.
Patient and order data (we are a processor)
- Patient identity and contact details entered by the clinic: first and last name, date of birth and sex where recorded, phone number, email address, and the clinic’s own patient reference.
- Order details: which feet are being scanned, the ordering practitioner, the selected laboratory, order dates and status, and any clinical notes the practitioner adds to the order.
Scan data (we are a processor)
- The 3D geometry of the foot — roughly 100,000 measured surface points, expressed in metres — together with the colour of the foot surface, which includes any marks a clinician has drawn on the skin.
- A rendered image of the finished 3D model, used as a quick reference by the laboratory.
- Scan measurements: which foot, capture duration, point count, working distance and bounding dimensions.
Technical and diagnostic data (we are the controller)
- A diagnostic record saved with each scan: device model, operating system build, app version, capture settings in force, frame and tracking counts, timings and thermal state. It contains no patient identifiers.
- Crash reports and performance traces from the app and web application, generated when something goes wrong. These are intended to contain technical information only.
- Server access logs from our hosting, which include IP addresses and request metadata, kept for security and troubleshooting.
This website
This website sets no advertising or analytics cookies and runs no tracking of any kind. If you choose a light or dark appearance, that preference is saved in your browser’s local storage on your own device; nothing is sent to us. Our hosting provider records standard server access logs.
4. Health data and special categories
A foot scan captured in a clinical setting is data concerning health under Article 9 of the GDPR. We process it solely as the clinic’s processor. The clinic is responsible for establishing the Article 9 condition it relies on — typically the provision of health care under Article 9(2)(h), or the patient’s explicit consent — and for informing the patient before the scan is taken.
The 3D geometry we capture is not used, and cannot be used by us, to identify a person by their physical characteristics. We therefore do not treat it as biometric data for the purpose of uniquely identifying a natural person within the meaning of Article 9(1).
5. Why we process data, and our legal bases
Where we act as controller, we rely on the following bases.
| Purpose | Legal basis |
|---|---|
| Creating and running user accounts, authenticating sign-in, and providing the service to the account holder | Performance of a contract (Art. 6(1)(b)), or our legitimate interests where the contract is with the account holder’s organisation (Art. 6(1)(f)) |
| Responding to support requests and other correspondence | Legitimate interests in supporting our users (Art. 6(1)(f)) |
| Keeping the service secure, investigating faults, and diagnosing scan quality problems | Legitimate interests in a secure and reliable service (Art. 6(1)(f)) |
| Improving capture quality and the reliability of the scanning engine using diagnostic records | Legitimate interests in improving our product (Art. 6(1)(f)) — this uses technical measurements, not patient data |
| Meeting accounting, tax and other legal obligations | Legal obligation (Art. 6(1)(c)) |
Where we act as processor — all patient and scan data — the legal basis is the clinic’s, and our processing is governed by our agreement with the clinic. We do not use patient data or scans for our own purposes, we do not use them to train machine-learning models, and we do not sell data to anyone. There is no automated decision-making producing legal or similarly significant effects.
7. International transfers
Foot Camera is built to keep clinical data in the European Union. The application, database and scan files are hosted in the EU, and crash reporting uses an EU-region service.
Two exceptions apply. Transactional email, which carries only a recipient address and the message itself, is delivered by a provider in the United States under the European Commission’s Standard Contractual Clauses. And if a clinic chooses a laboratory outside the EEA, the resulting transfer is one the clinic directs and is responsible for; we will act on that instruction.
8. How long we keep data
- Patient and scan data is kept for as long as the clinic’s account is active, or until the clinic instructs us to delete it. On a documented deletion instruction we delete the records and the underlying files within 30 days, backups included in the normal backup rotation.
- Account data is kept while the account is active and for up to 12 months after it is closed, so that access can be restored and questions answered.
- Scan diagnostics are retained with the scan record; the technical fields may be kept in aggregate after the scan itself is deleted.
- Crash reports and server logs are kept for up to 90 days.
- Data we must keep for accounting or legal reasons is kept for the period the law requires.
Scans also exist temporarily on the capturing device until they have uploaded successfully, and are removed from the device thereafter.
9. Security
- All traffic between the app, the web application and our servers is encrypted in transit (TLS).
- Scan files and database contents are encrypted at rest by our hosting and storage providers.
- Access is enforced by the backend, not just the interface: clinic accounts can reach only their own clinic’s patients and orders, and a laboratory can reach only the orders sent to it.
- Sign-in uses a one-time code sent to a work email address — there are no shared passwords. On the device, session tokens are held in the iOS Keychain.
- Administrative access to production systems is limited to the people who need it to operate the service.
No system is perfectly secure. If we become aware of a personal data breach affecting patient data, we will notify the affected clinics without undue delay so they can meet their own obligations, and we will notify the supervisory authority where the law requires it.
10. Your rights
Under the GDPR you have the right to access your personal data, to have inaccurate data corrected, to have data erased, to restrict or object to processing, to data portability, and to withdraw consent where processing rests on consent. Withdrawing consent does not affect processing already carried out.
To exercise these rights over an account with us, write to privacy@foot.camera. We respond within one month, and will tell you if we need longer. For a patient record, contact the clinic that holds it — we will pass on requests we receive and support the clinic in answering them.
You also have the right to complain to a supervisory authority. Ours is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, aki.ee), and you may instead complain to the authority in your own country of residence.
11. Children
Foot Camera is a professional tool and is not directed at children. Accounts are held by clinicians and by clinic and laboratory staff. A clinic may of course treat and scan a child patient; where it does, the clinic is responsible for consent and for informing the child’s parent or guardian under its own clinical framework.
12. Changes to this policy
We will update this policy as the service changes. The date at the top always reflects the current version. Where a change materially affects account holders, we will tell them by email or in the application before it takes effect.
13. Contact us
Novansa OÜ, Sepapaja tn 6, 15551 Tallinn, Harju maakond, Estonia. Registry code 17445226.
Privacy enquiries: privacy@foot.camera · General support: support@foot.camera
See also our Terms of Use.