In Brazil: LGPD and ECA Digital
For organisations in Brazil, the LGPD annex completes the DPA (roles, transfers, incidents reported to the ANPD), and a note explains how Buddy protects children under the ECA Digital. Documents in Portuguese.
If a data breach occurs
We notify the organisation concerned by email within 48 hours: what happened, the data and people affected, the likely consequences and the measures taken. For accounts we are responsible for, we notify the CNIL (the French data protection authority) within 72 hours and inform the people concerned if the risk is high.
Last updated: 3 November 2026
Pictalk Buddy is developed by Pictalk Speech Made Easy, a French non-profit association. This page explains where the app runs, where data is stored, how it is protected and which providers receive any of it.
Hosting
- The web app, sign-in, the API and app updates run on a Kubernetes cluster at OVHcloud, in France (Paris and Gravelines).
- The PostgreSQL database is in Gravelines and can only be reached from the cluster's private network.
- Files (images, vocabularies, language files) are stored at OVHcloud, in Gravelines and Paris.
- The database is backed up every day to another data centre (Strasbourg). Backups are kept for 2 days.
- Hosting is HDS-certified (the French certification for hosting health data).
Security measures
- Encryption in transit: all communication between the apps and our servers uses HTTPS (TLS).
- Isolated database: never exposed to the internet.
- Central sign-in: accounts are managed by Keycloak, which we host ourselves. Professionals share access through groups and roles, without sharing passwords.
- Data minimisation: no advertising, no data resale, no ad trackers in the app.
- Restricted access: only authorised Pictalk staff can access production data.
Data retention
- An account is deleted automatically after 1 year without sign-in, or at any time on request.
- Communication logs (AAC) are collected only with consent and are kept for 3 months.
- When a Pro membership ends, the organisation can ask for its data to be returned and deleted within 30 days.
Service providers
All account data and all content stay in France. The providers below receive only the data listed.
| Service | Purpose | Data shared | Location |
|---|---|---|---|
| PostHog | Usage statistics, no screen recording | Usage events | EU |
| Sentry | Crash and error reports | Error traces, device, user ID | Germany |
| OneSignal | Push notifications, delivered to devices by Apple (APNs) and Google (FCM) | Push token, user ID | EU |
| RevenueCat | Subscriptions and in-app purchases | User ID, purchases | United States (standard contractual clauses) |
| Stripe | Payment of memberships and donations | Name, email address, amount (never card numbers) | Ireland and United States (Data Privacy Framework) |
| SendGrid (Twilio) | Account emails and donation receipts | Email address, name | United States (Data Privacy Framework) |
| App Store, Google Play | Distribution and payment | Handled by Apple and Google | Apple, Google |
| Hugging Face | Download of the on-device voice model | None (file download) | CDN |
| OpenStreetMap | Maps and address search | Address entered, IP address | EU / United Kingdom |
| YouTube | Videos added to boards by the user | IP address, video watched | United States (Data Privacy Framework) |
| ipify | Country detection to show the local price | IP address | United States |
| ElevenLabs | Premium voice, optional, with the user's own key | Text to be spoken | United States |
Organisations and public bodies
Our data processing agreement (DPA), which you can download at the top of this page, governs the processing we carry out on your behalf (Article 28 of the GDPR). For any question, or to report a security issue: alex@pictalk.org.
See also the privacy policy and the legal notice.