Data controller

The site comnonpareil.fr is published by: Ilana Stevens, entreprise individuelle (French sole trader) | SIRET: 95112216700012 | APE code: 7410Z | Intra-community VAT number: FR60951122167 | Telephone: +33 (0)6 08 83 10 12 | Email: contact@ultrapanache.com

No data protection officer has been appointed: the activity does not fall within the cases of mandatory appointment set out in article 37 of the GDPR. Any question relating to this policy may be addressed directly to the address above.

Data collected and purposes

Contact form and appointment booking

Data: surname, first name, email address, telephone number where applicable, organisation name, message content. Purpose: to respond to your enquiry and, if it proceeds, to prepare a commercial proposal. Legal basis: pre-contractual measures taken at your request (article 6.1.b of the GDPR). Retention: three years from the last contact, unless a contractual relationship is entered into — in which case the data is retained for the duration of the relationship and then archived in accordance with accounting and tax obligations (ten years).

Email correspondence

Data: email address, content of exchanges. Purpose: to follow up on exchanges. Legal basis: legitimate interest in handling enquiries received (article 6.1.f of the GDPR). Retention: three years from the last exchange.

Site audience measurement

Data: IP address (truncated), pages viewed, time spent, referral source, device and browser type, approximate location data. Purpose: to understand site traffic and improve its content. Legal basis: your consent (article 6.1.a of the GDPR), obtained via the banner displayed on your arrival at the site. Retention: fourteen months maximum.

Server connection logs

Data: IP address, date and time of the request, pages requested. Purpose: site security and technical diagnostics. Legal basis: legitimate interest in ensuring the security of the service and legal retention obligation (articles 6.1.f and 6.1.c of the GDPR). Retention: twelve months.

No data is collected without your knowledge, nor sold, rented or exchanged. No automated decision-making or profiling is carried out.

Recipients and processors

Your data is processed by the data controller. It may be disclosed to the following providers, acting as processors and bound by a contract compliant with article 28 of the GDPR:

Transfers outside the European Union

The use of Google Analytics 4 and Google Tag Manager may involve a transfer of data to the United States. These transfers are governed by the European Commission’s adequacy decision of 10 July 2023 on the EU–US Data Privacy Framework, Google LLC being certified under that framework, as well as by the standard contractual clauses adopted by the Commission.

Data sharing with other Google services and advertising signals features are disabled. Your IP address is anonymised before any recording.

Security

The site is accessible over HTTPS. Access to data is restricted to the data controller and protected by authentication. Security updates to the content management system and its extensions are applied regularly. As no measure can guarantee absolute security, these provisions constitute a reasonable effort in light of the risks and the nature of the data processed.

Cookies and trackers

A cookie is a file placed on your device when you visit a site. Some are essential to the operation of the site; others require your prior agreement.

Cookies exempt from consent

These are strictly necessary for the provision of the service and are placed without your agreement: recording your cookie preferences, administration session, protection against automated form submissions. Duration: twelve months maximum.

Cookies subject to your consent

Google Analytics 4, via Google Tag Manager, measures site traffic. These trackers are placed only after your explicit acceptance. Refusal has no effect on your browsing.

Withdrawing your consent

You may change your choice at any time via [the cookie management link in the footer / the banner accessible from this link]. You may also configure your browser to refuse cookies, or install the opt-out add-on offered by Google at tools.google.com/dlpage/gaoptout.

Your rights

You have, in respect of data concerning you, a right of access, rectification, erasure, restriction of processing, objection, and a right to portability. Where processing is based on your consent, you may withdraw it at any time, without this withdrawal affecting the lawfulness of processing carried out beforehand. You may also issue directives regarding the fate of your data after your death.

These rights may be exercised by email to contact@ultrapanache.com or by post to the address given at the top of this page. A response will be sent to you within one month. Proof of identity may be requested in the event of reasonable doubt as to the identity of the requester.

If, after contacting us, you consider that your rights are not being respected, you may lodge a complaint with the Commission nationale de l’informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07 — www.cnil.fr.

Changes

This policy may be amended to reflect legal or technical developments. The date of last update appears at the top of the page.