Legal Notice

1. App Publisher

The CortiFree mobile application is published by Solstys I.T., a simplified joint-stock company (SAS) with a share capital of €5,000.00, registered with the Trade and Companies Register of Pontoise under SIRET number 878 797 117 00024, with its registered office located at:
12 rue des Carrières, 95300 Pontoise, France.

Legal representative and publication director: Mr. Nicolas Biot
Contact: contact.cortifree@gmail.com

2. Hosting Provider

The hosting of the application, databases, and associated website is provided by:

Google Cloud Platform (Firebase)
Google Ireland Limited
Gordon House, Barrow Street, Dublin 4, Ireland

3. Intellectual Property

All content of the CortiFree application, including but not limited to texts, interfaces, graphic elements, sounds, images, videos, source code, and overall structure, is the exclusive property of Solstys I.T. or is used under specific authorization.

Icons are sourced from the SF Symbols library (Apple), and certain animations from LottieFiles, both used under free licenses in accordance with their respective terms of use.

Any reproduction, representation, modification, publication, transmission, or adaptation, in whole or in part, without prior written authorization is strictly prohibited and may result in legal action in accordance with the provisions of the Intellectual Property Code.

4. Personal Data

Data collected by the CortiFree application is processed in accordance with the General Data Protection Regulation (GDPR) and the French “Data Protection Act” (Loi Informatique et Libertés).

For any questions regarding privacy or to exercise your rights (access, rectification, deletion, objection, data portability), you may contact:
contact.cortifree@gmail.com

The full Privacy Policy is available directly within the application and on the official website.

5. Liability

Solstys I.T. makes every effort to ensure the availability, security, and accuracy of the information provided.
However, the company cannot be held liable for errors, interruptions, or service unavailability, nor for any consequences arising from improper use of the application.

CortiFree is intended to promote well-being and relaxation.
It does not provide any medical diagnosis or therapeutic treatment and does not replace consultation with a healthcare professional under any circumstances.

6. Governing Law

These legal notices are governed by French law.
In the event of a dispute, the competent courts of France shall have exclusive jurisdiction.1. App Overview

The CortiFree application is published by Solstys I.T., a company represented by Mr. Nicolas Biot, with its registered office located at 12 rue des Carrières, 95300 Pontoise, France.
Contact: contact.cortifree@gmail.com

CortiFree is a mobile well-being application designed to help users better manage stress and improve relaxation through breathing exercises, visualization, and guided meditation.

The application is available on the App Store.

2. Purpose of These Terms of Use

These General Terms of Use (GTU) define the terms and conditions under which:

• users may access and use the services offered by the CortiFree application; and

• the respective rights and obligations of the user and the publisher.

Any use of the application implies full and unconditional acceptance of these GTU.

3. Access Conditions

3.1 User Account

Access to CortiFree requires the creation of a personal account via a Firebase authentication service.
The user undertakes to provide accurate information and to keep it up to date.

Access is reserved for adults or persons aged 16 years or older.

3.2 Subscription

Use of CortiFree is subject to the purchase of a paid subscription:

• €9.99 per month, or

• €39.99 per year,

with a 3-day free trial period.

Subscriptions are managed by the App Store platform.
Payment is processed after the trial period unless the subscription is cancelled before the end of that period.

3.3 Cancellation and Refunds

The user may cancel their subscription at any time via their App Store account.
Any subscription period already started is due in full and is not eligible for partial refunds, in accordance with the terms of the payment platforms.

4. Description of the Service

CortiFree offers the following features:

• guided breathing,

• meditation,

• well-being and progress tracking,

• personalized reminder notifications.

These features are subject to change and may be modified or enhanced at any time by Solstys I.T.

5. No Medical Purpose

CortiFree is a well-being application.
It does not provide any medical diagnosis, therapeutic advice, or treatment within the meaning of public health regulations.

The exercises offered aim to improve relaxation and body awareness.
They do not replace medical consultation or follow-up under any circumstances.

In the event of persistent disorders (severe anxiety, sleep disorders, depression, etc.), it is the user’s responsibility to consult a qualified healthcare professional.

6. Publisher’s Liability

Solstys I.T. makes every effort to ensure the availability, reliability, and security of the application.
However, the publisher cannot guarantee the absence of errors, interruptions, or malfunctions.

The user acknowledges that:

• they remain solely responsible for their use of the application;

• the effects of the exercises may vary from one person to another;

• CortiFree cannot be held liable for any direct or indirect damage resulting from improper use, lack of results, or misinterpretation of the guidance provided.

7. Intellectual Property

7.1 Protected Content

All elements comprising the CortiFree application (texts, design, source code, structure, visuals, sounds, logos, databases) are the exclusive property of Solstys I.T. and are protected by intellectual property laws.

Any reproduction, representation, modification, or extraction, in whole or in part, without prior written authorization is strictly prohibited.

7.2 Third-Party Elements

The icons used are sourced from the SF Symbols library (Apple).

Certain animations are provided by LottieFiles and are used under free licenses in accordance with their respective terms of use.

8. Personal Data

Data collected in connection with the use of CortiFree is processed in accordance with Regulation (EU) 2016/679 (GDPR).
Such data is handled in accordance with the Privacy Policy available within the application and on the official CortiFree website.

9. Security and Confidentiality

CortiFree implements all necessary measures to ensure data security and prevent unauthorized access.
Data exchanges are protected by HTTPS / TLS encryption, and data is pseudonymized and hosted on secure servers.

10. Notifications

CortiFree may send local notifications to remind users of a routine or to indicate a new exercise.
These notifications contain no health data and can be disabled at any time in the application settings.

No commercial communications or promotional messages are sent to the user without their prior consent.

11. Account Termination

The user may request deletion of their account at any time via the application or by email at contact@cortifree.app.
Data associated with the account is deleted within a maximum period of 30 days, except where legal retention obligations apply.

12. Support and Contact

For any questions, technical issues, or complaints, users may contact:
contact.cortifree@gmail.com

Solstys I.T. will endeavor to respond within a reasonable timeframe.

13. Governing Law and Jurisdiction

These General Terms of Use are governed by French law.
Any dispute relating to their interpretation, validity, or performance shall be submitted to the competent courts of France.

© 2025 Solstys I.T. – All rights reserved.

Terms and Conditions of Use

1. App Overview

The CortiFree application is published by Solstys I.T., a company represented by Mr. Nicolas Biot, with its registered office located at 12 rue des Carrières, 95300 Pontoise, France.
Contact: contact.cortifree@gmail.com

CortiFree is a mobile well-being application designed to help users better manage stress and improve relaxation through breathing exercises, visualization, and guided meditation.

The application is available on the App Store.

2. Purpose of These Terms of Use

These General Terms of Use (GTU) define the terms and conditions under which:

• users may access and use the services offered by the CortiFree application; and

• the respective rights and obligations of the user and the publisher.

Any use of the application implies full and unconditional acceptance of these GTU.

3. Access Conditions

3.1 User Account

Access to CortiFree requires the creation of a personal account via a Firebase authentication service.
The user undertakes to provide accurate information and to keep it up to date.

Access is reserved for adults or persons aged 16 years or older.

3.2 Subscription

Use of CortiFree is subject to the purchase of a paid subscription:

• €9.99 per month, or

• €39.99 per year,

with a 3-day free trial period.

Subscriptions are managed by the App Store platform.
Payment is processed after the trial period unless the subscription is cancelled before the end of that period.

3.3 Cancellation and Refunds

The user may cancel their subscription at any time via their App Store account.
Any subscription period already started is due in full and is not eligible for partial refunds, in accordance with the terms of the payment platforms.

4. Description of the Service

CortiFree offers the following features:

• guided breathing,

• meditation,

• well-being and progress tracking,

• personalized reminder notifications.

These features are subject to change and may be modified or enhanced at any time by Solstys I.T.

5. No Medical Purpose

CortiFree is a well-being application.
It does not provide any medical diagnosis, therapeutic advice, or treatment within the meaning of public health regulations.

The exercises offered aim to improve relaxation and body awareness.
They do not replace medical consultation or follow-up under any circumstances.

In the event of persistent disorders (severe anxiety, sleep disorders, depression, etc.), it is the user’s responsibility to consult a qualified healthcare professional.

6. Publisher’s Liability

Solstys I.T. makes every effort to ensure the availability, reliability, and security of the application.
However, the publisher cannot guarantee the absence of errors, interruptions, or malfunctions.

The user acknowledges that:

• they remain solely responsible for their use of the application;

• the effects of the exercises may vary from one person to another;

• CortiFree cannot be held liable for any direct or indirect damage resulting from improper use, lack of results, or misinterpretation of the guidance provided.

7. Intellectual Property

7.1 Protected Content

All elements comprising the CortiFree application (texts, design, source code, structure, visuals, sounds, logos, databases) are the exclusive property of Solstys I.T. and are protected by intellectual property laws.

Any reproduction, representation, modification, or extraction, in whole or in part, without prior written authorization is strictly prohibited.

7.2 Third-Party Elements

The icons used are sourced from the SF Symbols library (Apple).

Certain animations are provided by LottieFiles and are used under free licenses in accordance with their respective terms of use.

8. Personal Data

Data collected in connection with the use of CortiFree is processed in accordance with Regulation (EU) 2016/679 (GDPR).
Such data is handled in accordance with the Privacy Policy available within the application and on the official CortiFree website.

9. Security and Confidentiality

CortiFree implements all necessary measures to ensure data security and prevent unauthorized access.
Data exchanges are protected by HTTPS / TLS encryption, and data is pseudonymized and hosted on secure servers.

10. Notifications

CortiFree may send local notifications to remind users of a routine or to indicate a new exercise.
These notifications contain no health data and can be disabled at any time in the application settings.

No commercial communications or promotional messages are sent to the user without their prior consent.

11. Account Termination

The user may request deletion of their account at any time via the application or by email at contact@cortifree.app.
Data associated with the account is deleted within a maximum period of 30 days, except where legal retention obligations apply.

12. Support and Contact

For any questions, technical issues, or complaints, users may contact:
contact.cortifree@gmail.com

Solstys I.T. will endeavor to respond within a reasonable timeframe.

13. Governing Law and Jurisdiction

These General Terms of Use are governed by French law.
Any dispute relating to their interpretation, validity, or performance shall be submitted to the competent courts of France.

© 2025 Solstys I.T. – All rights reserved.

Privacy policy

1. Publisher and Data Controller

The CortiFree application is published by Solstys I.T., represented by Mr. Nicolas Biot,
with its registered office located at 12 rue des Carrières, 95300 Pontoise, France.

CortiFree acts as the data controller for the personal data collected in connection with the use of the application.
For any questions relating to data protection, you may contact:
📩 contact.cortifree@gmail.com

2. Data Collected

CortiFree collects and processes only the data necessary for the proper functioning of the application and for improving the user experience.
Data is pseudonymized or anonymized whenever possible.

Categories of data processed:

• Identification data: email address, first name (where applicable, during account creation).

• Well-being data: stress level, mood, onboarding quiz responses, personal goals (sleep, anxiety, focus, etc.), exercise and routine history.

• Technical data: Firebase identifier, device model, operating system, error logs.

• Analytics data: navigation and usage events collected via Mixpanel (EU project).

• Subscription data: managed exclusively by the App Store.

• Local notifications: used solely to remind users of routines or to signal new exercises.

No bank card data and no sensitive data (within the meaning of Article 9 of the GDPR) is collected by CortiFree.

HealthKit data (if enabled by the user):
CortiFree may access certain data from Apple’s Health app only if the user provides explicit authorization. Depending on the user’s choices, this data may include information related to sleep, physical activity, or mindfulness. It is used solely for personalization of the experience, progress tracking, or display within the application.

No HealthKit data is shared with third parties, used for advertising purposes, sold, or transferred off the device without the user’s explicit consent. Such data is never stored on our servers and remains strictly confined to the secure environment provided by Apple.

3. Purposes of Processing

The collected data is used for the following purposes:

• Providing breathing, meditation, and well-being tracking services;

• Adapting exercises and routines based on stated preferences and goals;

• Visualizing personal progress through anonymized statistics;

• Improving the operation, stability, and relevance of application content;

• Managing subscriptions and paid access via the App Store;

• Sending non-commercial and non-medical local notifications.

4. Legal Basis for Processing

Processing is based on:

• the user’s explicit consent (Article 6(1)(a) GDPR) for well-being, mood, and progress data;

• the performance of a contract (Article 6(1)(b) GDPR) for providing the CortiFree service;

• the legitimate interest of Solstys I.T. in analyzing usage and continuously improving the application.

5. Hosting and Subprocessors

Application data is processed exclusively by specialized third-party service providers, each acting within a specific scope.

Firebase (Google Cloud) provides user authentication, account management, storage of quiz-related information, and processing of anonymized statistics. Associated data is hosted within Google’s European infrastructure, mainly in Belgium and the Netherlands.

Superwall handles subscription and paywall management. This solution, used to display and orchestrate premium offers, relies on infrastructure located in the United States.

Mixpanel is used to analyze application usage and understand key interactions in order to improve the user experience. The project is hosted within the provider’s European infrastructure.

Firebase Crashlytics collects technical information required for error diagnostics and application stability improvements. Data is processed on Google’s European servers.
Finally, Firebase Storage is used for secure hosting of media and animations, also within European infrastructure.

6. Data Transfers Outside the European Union

Some of our subprocessors (notably Google Firebase, Mixpanel, and Superwall) may process data in the United States.

These providers are certified under the EU–U.S. Data Privacy Framework, ensuring a level of personal data protection recognized by the European Commission.
Where data is transferred to a country not covered by an adequacy decision, Standard Contractual Clauses (SCCs) approved by the European Commission are implemented to ensure an adequate level of protection.

7. Data Retention Periods

Account data is retained for as long as the user keeps their account active. It may be deleted manually at any time or automatically after twelve months of inactivity.

Well-being data is retained for twelve months after the last use of the application and is then anonymized to allow statistical analysis without any personal link.

Technical data, used solely for error diagnosis and resolution, is retained for a maximum of three months.

Subscription-related information is not stored by CortiFree and is entirely managed by Apple or Google depending on the purchase platform.

Finally, anonymized analytics data used to measure overall application usage and improve features is retained for twenty-four months in aggregated form, without any personal identifiers.

8. Security and Confidentiality

CortiFree implements all appropriate technical and organizational measures to ensure the security of personal data, including:

• encryption of communications via HTTPS / TLS;

• restricted and secured access to Firebase databases;

• pseudonymization and anonymization of data from the point of collection;

• confidentiality commitments from employees and service providers.

9. User Rights

In accordance with the General Data Protection Regulation (GDPR), each user has the following rights:

• right of access, rectification, and erasure of their data;

• right to withdraw consent at any time;

• right to object to processing and to data portability;

• right to lodge a complaint with the French data protection authority (CNIL – www.cnil.fr).

To exercise these rights, simply write to:
📩 contact.cortifree@gmail.com

10. Notifications

CortiFree may send local notifications to remind users of certain routines or to signal new content.
These notifications contain no health data and can be disabled at any time in the application settings.
No commercial or marketing messages are sent.

11. Target Audience and Health Disclaimer

CortiFree is intended for the general public aged 16 and over.
The application aims to promote relaxation, mindful breathing, and stress reduction.

It does not provide any medical diagnosis or therapeutic treatment and does not replace consultation with a healthcare professional under any circumstances.

In cases of significant stress, persistent anxiety, or sleep disorders, users are encouraged to consult a qualified professional.

12. Governing Law

This Privacy Policy is governed by French law.
Any dispute relating to its interpretation or execution falls under the jurisdiction of the French courts.

© 2025 Solstys I.T. – All rights reserved.