Article 1, Preamble
The purpose of this privacy policy is to inform users of the dafolle.io website (hereinafter the « Users ») about how VERITY STUDIO, operating under the Dafolle brand, collects, uses, stores and protects their personal data, in compliance with Regulation (EU) 2016/679 of 27 April 2016 (« GDPR ») and the amended French Data Protection Act of 6 January 1978.
Article 2, Data Controller
The controller of the personal data collected on the dafolle.io website is VERITY STUDIO, a simplified joint-stock company registered with the Paris Trade and Companies Register under number B 900 453 333, with its registered office at 37 rue du Ranelagh, 75016 Paris, France.
Contact: clara@dafolle.io
Article 3, Data Collected
VERITY STUDIO collects the following categories of data:
3.1 Data provided directly by the User
Identification data: surname, first name, position, company name.
Contact data: professional email address, telephone number (optional).
Content of messages, briefs and documents submitted via the website forms (in particular the contact form, meta-brief, resource-sharing form).
3.2 Data collected automatically
Connection and browsing data: IP address, browser type, operating system, pages viewed, visit duration, traffic source.
Data collected via cookies and trackers (see Article 7).
3.3 Data collected in connection with services
For Users who have subscribed to a Dafolle service, additional data may be collected in the course of performing the contract (detailed briefs, project exchanges, meeting recordings). The processing of this data is governed by the applicable services contract and Dafolle's terms and conditions.
Article 4, Purposes and legal bases for processing
Personal data are collected and processed for the following purposes:
To respond to contact and quote requests (legal basis: pre-contractual measures at the request of the data subject).
To perform services subscribed to by Clients (legal basis: performance of the contract).
To manage invoicing and maintain accounting records (legal basis: legal obligation).
To improve the website, measure audience and analyse Users' behaviour (legal basis: legitimate interest, subject to consent to non-essential cookies).
To send commercial and marketing communications (legal basis: the User's consent or legitimate interest for existing Clients).
To capitalise on internal knowledge via Dafolle's Context Intelligence tools (legal basis: legitimate interest, as part of service performance).
Article 5, Recipients of the data
The personal data collected are intended for VERITY STUDIO's internal departments authorised to process them (sales team, production team, management).
They may also be transmitted to VERITY STUDIO's technical subcontractors, strictly within the scope of their assignments and under a contractual obligation of confidentiality, in particular:
Hosting providers and infrastructure service providers (Framer, Cloudflare, AWS).
Customer relationship management and productivity tools (including Airtable, HubSpot, Slack, Notion, Google Workspace).
Audience analytics tools (Google Analytics, Microsoft Clarity).
Artificial intelligence tools used in connection with the services (including Anthropic, OpenAI, and any equivalent tool).
Meeting recording and transcription tools (including Claap).
No personal data is sold, rented or exchanged with third parties for commercial purposes.
Article 6, Transfers of data outside the European Union
VERITY STUDIO gives priority to tools and services hosted within the European Union. However, some subcontractors may be established in, or host data outside, the European Union, in particular in the United States.
In such cases, VERITY STUDIO ensures that appropriate safeguards are in place to protect personal data, in particular:
The recipient's adherence to the EU-US Data Privacy Framework (European Commission adequacy decision of 10 July 2023).
The signing of Standard Contractual Clauses approved by the European Commission (SCCs).
The implementation of additional technical and organisational security measures where necessary.
Article 7, Cookies and trackers
The dafolle.io website uses the following categories of cookies:
7.1 Strictly necessary cookies
These cookies are essential for the functioning of the website and do not require consent (Article 82 of the French Data Protection Act). Retention period: duration of the session or a maximum of 13 months.
7.2 Audience measurement cookies
VERITY STUDIO uses Google Analytics (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) and Microsoft Clarity (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052, United States) to measure the website's audience and analyse Users' behaviour.
These cookies are placed subject to the User's consent, collected via the consent banner on first visit. The User may withdraw consent at any time.
Retention period: 13 months maximum.
7.3 Cookie management
The User may set their preferences via the consent banner displayed on the website, or disable cookies through their browser settings. Disabling cookies may affect the website's functionality.
Article 8, Data retention period
Data from the contact form (prospects): 3 years from the last contact.
Client data (contract files, invoices): 10 years (accounting and tax obligation).
Browsing data and cookies: 13 months maximum.
Data used for commercial prospecting: 3 years from the last contact or until the data subject objects.
Meeting recordings and transcriptions: 24 months from the end of the project, unless the Client requests earlier deletion.
Article 9, Users' rights
In accordance with the GDPR, the User has the following rights regarding their personal data:
Right of access to their data.
Right to rectification of inaccurate or incomplete data.
Right to erasure (« right to be forgotten »).
Right to restriction of processing.
Right to data portability.
Right to object to processing, in particular for commercial prospecting purposes.
Right to withdraw consent at any time, where processing is based on consent.
Right to set out instructions regarding the fate of their data after death.
To exercise these rights, the User may send a request to clara@dafolle.io, accompanied by a copy of an identity document in the event of reasonable doubt as to the requester's identity.
The User also has the right to 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.
Article 10, Data security
VERITY STUDIO implements appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, disclosure, alteration or destruction. These measures include, in particular, encryption of connections (HTTPS), access controls to data, regular backups and periodic security audits.
Article 11, Changes to the privacy policy
This privacy policy may be amended at any time by VERITY STUDIO to reflect changes in regulations, activities or tools used. Any amendment will result in an update of the date shown at the top of this document. Users are advised to consult this page regularly.
Article 12, Contact
For any questions relating to this privacy policy or the processing of your personal data, you may contact VERITY STUDIO at the following address: clara@dafolle.io.