Conflicts of Interest Declaration

Effective Date: 05/05/2026

Preamble

In line with the transparency principles upheld by France's Agence du Numérique en Santé (ANS), the Haute Autorité de Santé (HAS) and the CNIL, and pursuant to Article L.1453-1 of the French Public Health Code, PROMOTAL SAS hereby discloses all elements relating to its relationships — or the absence of any — with healthcare ecosystem stakeholders. This declaration forms part of the Teleconsultation Company Approval framework (ETH.13 and ETH.14 requirements).

Publishing company

PROMOTAL SAS, publisher of the System, is an independent French company.

• SIREN : 421 156 720
• Legal form : Société par actions simplifiée (SAS)
• Registered office : 22 rue Saint-Denis-de-Gastines, 53500 Ernée, France

PROMOTAL SAS has no parent company in the healthcare sector, holds no health-related subsidiary and has no sister company operating in the medical ecosystem. No healthcare ecosystem stakeholder is a shareholder of the company.

Explicitly absent relationships

PROMOTAL SAS holds:

• no capital, commercial or funding partnership with any pharmaceutical company;
• no capital, commercial or funding partnership with any mutual insurer or supplementary health insurance organisation.

The platform:

• displays no pharmaceutical product advertising;
• contains no marketplace for health products.

PROMOTAL SAS does not operate any teleconsultation centre and employs no physician performing teleconsultations on the platform: physicians using the System practise independently, within their own practice or usual care setting.

Technology partners

In the ordinary course of business, PROMOTAL SAS contracts with technology suppliers, notably:

• AWS — HDS-certified hosting (Health Data Hosting);
• Stellair / Olaqin — electronic care sheet (FSE) billing;
• Stripe — payment processing.

PROMOTAL SAS also purchases CE-marked medical devices from manufacturers for integration into the platform.

None of these partners remunerates PROMOTAL SAS based on prescription or consultation volume by healthcare professionals. No physician is paid based on prescription volume by PROMOTAL SAS.

Information mechanisms

Before their first teleconsultation, the healthcare professional must explicitly accept the Terms of Use including this declaration.

When booking an appointment, the patient is shown a notice stating the publisher's independence and the absence of any link with a pharmaceutical lab or mutual insurer.

The full declaration is available at any time on this page and on request at [email protected].

Review and archiving

This declaration is reviewed annually and upon any material change to the company structure or partner list. Previous versions are archived within the company's ISO/IEC 27001 information security management system.

Contact

For any question regarding this declaration:

PROMOTAL SAS
22 rue Saint-Denis-de-Gastines, 53500 Ernée, France
[email protected]