Kia Privacy Policy

Who is responsible for what

• NOVIAMIND, a French société par actions simplifiée (SAS) with a share capital of EUR 1,000, 18 rue Masséna, Bureau 3, 06000 Nice, France, registered with the Nice Trade and Companies Register (RCS) under number 989 166 848, represented by its President, Elio D’Agostino. Contact: privacy@ciaoalfred.com.
• For patient data, the physician or the practice is the data controller; NOVIAMIND acts as processor (GDPR art. 28), on the practice’s instructions and under the contract approved in the application for the practice’s country. For the physician’s account data (identity, sign-in, billing), NOVIAMIND is the controller.
• Kia makes no diagnosis, suggests no treatment and takes no clinical decision: the physician decides.

Data processed

• Physician account: email, verified phone number, name, country, specialty, form of practice, health-insurance agreement, professional register number, language, preferences.
• Practice: legal identity of the practice, approved contractual documents and their receipts.
• Patient data, only once the feature is opened for the practice: identity, contact details, date of birth, reports and appointments entered by the physician. This is health data (GDPR art. 9) processed on the physician’s instructions.
• Journal: sign-ins, administrative actions and, once clinical features open, every consultation, creation, modification, export and deletion of a record.
• Technical data: security and operational logs, without clinical content.

Hosting and security

• Kia is hosted on Google Cloud in Belgium (europe-west1 region): application on Cloud Run, medical database on Cloud SQL, encrypted backups on Cloud Storage, all within the European Union. The services used are listed in Google’s HDS v2.0 certificate (no. 2022-013, activities 1 to 5); NOVIAMIND’s own HDS certification is in progress. Kia does not claim to be compliant or certified until these steps are achieved.
• The physician’s identity (email, phone, sign-in factors) is managed by Supabase in Ireland; no patient data is stored there.
• Encryption in transit and at rest, per-practice isolation in the database, mandatory email-then-SMS sign-in, daily encrypted backup with tested restoration. No one at NOVIAMIND accesses clinical content except for a documented and logged technical necessity.

Artificial intelligence

• Updated 12 October 2026. Purpose: Kia’s only AI feature formats a report already written or dictated by the physician, at their request. It adds no information, makes no diagnosis, proposes no treatment or coding, and neither summarises nor interprets; a request outside this purpose is refused before anything is sent to the model.
• Provider and location: Vertex AI (Google), European Union multi-region endpoint (“eu”), with no caching of requests, no grounding or web search and no tools. Only the text of the selected report is sent, without the patient’s name or record; requests are not used to train models.
• Traceability and review: every proposal is a draft marked “generated by AI” with the model, the version served, the fingerprint of the instruction and the date. A check flags to the physician any number, date or medicine added or missing. Nothing is saved without the physician’s review and validation; the saved report keeps the AI mark, the model and the validation date. The clinical decision remains the physician’s.
• Italy: Law no. 132/2025 (art. 7) provides that in healthcare AI remains a support to the physician’s decision and that the patient is informed of its use; Kia gives the practice the corresponding patient information text.
• This feature is closed until qualified.
• Searches in official sources (CIMA, PubMed) leave only with generic keywords: Kia refuses any query that appears to contain a patient’s name, date of birth or identification number.

Sub-processors and transfers

Retention

• Patient data is retained according to the practice’s country and the rule set by the physician; Kia never deletes automatically: France, 20 years after the last care episode (extended for minors, 5 years in the active database then archived); Italy, no expiry by default, at least 10 years after the last service if the physician sets a period; Spain, 15 years by default depending on the autonomous community, never less than 5 years, with blocking before any destruction.
• The record-access journal is kept for 24 months. The platform journal (sign-in and administration metadata) is kept for 90 days. Encrypted backups are kept for 30 days.
• The physician’s account is kept while active; at the end of the contract the practice exports its data and chooses return or deletion, subject to legal retention obligations.

Patients’ rights

• Patients exercise their rights (access, rectification, erasure within mandatory retention limits, restriction, objection, portability) with their physician, the data controller. Kia gives the physician a per-patient export, rectification by dated addendum and the view of accesses to the record. NOVIAMIND assists the physician and does not answer patients directly unless instructed by the physician.
• Complaints: CNIL (France), Garante per la protezione dei dati personali (Italy), Agencia Española de Protección de Datos (Spain).

Physician’s rights

Incidents

Countries and opening

Changes