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Privacy Policy

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At DataGem Consulting, we are committed to protecting your privacy and ensuring transparency in how your data is collected and used. This Privacy Policy explains what information we collect, how we use it, and your rights regarding your personal data. The data controller is Pierre Denig, entrepreneur individuel trading as DataGem Consulting (see the Legal Notice).

  1. 1. Information We Collect

    We may collect and process the following types of personal information:

    • Name, email address, and contact information
    • Business information you provide when contacting us
    • Website usage data (via cookies and analytics tools)
    • Your IP address and the technical data of your requests (see "Hosting and Server Logs")
  2. 2. How We Use Your Information

    We use the information we collect for the following purposes:

    • To provide and improve our data consulting services
    • To respond to inquiries or support requests
    • To analyze website performance and user behavior
    • To comply with legal obligations

    Each use rests on a legal basis under the General Data Protection Regulation (GDPR, Article 6):

    • Messages you send us, through the contact form or by email: steps taken at your request before entering into a contract or, for any other question, our legitimate interest in answering the messages we receive
    • Providing our services to our clients: the performance of our contract
    • Improving our services and the website: our legitimate interest
    • Google Analytics: your consent (see "Cookies & Analytics")
    • The dg-lang cookie and the language chosen from your location: our legitimate interest in showing you the website in your language; the cookie is strictly necessary to remember the choice you made, so it needs no consent
    • Hosting logs: our legitimate interest in running and securing the website
    • Compliance with our legal obligations: the legal obligation concerned
  3. 3. Cookies & Analytics

    With your consent, our website uses Google Analytics 4 to measure its audience and how it is used. Google Analytics loads only after you click "Accept" in our cookie banner. It then sets two cookies, _ga and _ga_JWZQJ9NE3L, which expire after 13 months and are not extended. Closing the banner without choosing counts as a refusal: nothing is stored, and the banner appears again the next time you open our website or reload a page. Your choice is stored in your browser for 6 months. You can change or withdraw it at any time through "Cookie settings" in the footer. If you refuse, the website works exactly the same.

    Our website also sets one functional cookie, dg-lang, when you use the language switch (EN / FR) in the navigation bar. It stores your choice, "en" or "fr", so that the website opens in that language on your next visits, and it expires 1 year after you last use the switch. It is not used for analytics or advertising, and it needs no consent because it only remembers a choice you made. You can delete it at any time in your browser settings.

  4. 4. Language Based on Your Location

    To show you our website in the right language, our web server reads the IP address of each request and looks up its country in a database stored with the website: DB-IP's free IP to Country Lite database. We use the result only to choose between English and French. If you open an English page from France (including its overseas departments and territories), you are taken to its French version; elsewhere, the page you asked for opens as it is. If you have chosen a language with the language switch, that choice applies instead.

    Your IP address is not sent to DB-IP or to anyone else for this lookup, and the country found is not recorded. Your IP address is not stored by our website beyond the standard request logs of our hosting (see "Hosting and Server Logs" below). We do this on the basis of our legitimate interest in showing you our website in your language.

    IP geolocation by DB-IP (database licensed under CC BY 4.0).

  5. 5. Hosting and Server Logs

    Our website is hosted on Google Cloud Run, a Google Cloud service, in Google's us-central1 region (United States). Like most websites, it keeps standard request logs, which we use only to run the website, keep it secure and fix errors. Two logs record the requests made to it:

    • Google Cloud Run's request log, for every request: the date and time, the method and full address requested (query string included), the response status, the request and response sizes, the response time, the protocol, your IP address, your browser's user agent and, if any, the referring page
    • Our web server's (nginx) access log, for every request except the website's build files (scripts, stylesheets and images under /assets/): the date and time, the request line (method, address requested and protocol), the response status and size, the referring page, your browser's user agent and your IP address

    These logs contain no cookies. They are stored by Google Cloud Logging and deleted automatically after 30 days. We keep them on the basis of our legitimate interest in running and securing our website.

    Google acts as our processor under the Google Cloud Data Processing Addendum. As the website and its logs may be processed outside the European Union, including in the United States, these transfers are covered by the safeguards of that addendum (the European Commission's standard contractual clauses or another transfer mechanism recognized under European law).

  6. 6. Third-Party Services

    We do not sell your data. We may share your information with trusted partners solely for service delivery (e.g. hosting providers or analytics tools), always in compliance with privacy regulations.

    These partners are:

    • Google Cloud (Google Cloud France SARL), which hosts the website: see "Hosting and Server Logs"
    • Google (Google Ireland Limited), which provides Google Analytics, if you accept it: see "Cookies & Analytics"
    • EmailJS Pte. Ltd. (Singapore), which delivers the contact form's messages to us: when you send the form, your browser sends your name, email address, subject and message (and, as with any request, your IP address) to EmailJS, which emails them to us. EmailJS states that it keeps this data for 30 days
    • Google (Google Workspace), which hosts our email

    Transfers outside the European Union: some of these partners process data in the United States.

    • Google: data from Google Analytics, Google Cloud and Google Workspace may be processed by Google LLC in the United States. Google LLC is certified under the EU-U.S. Data Privacy Framework, which the European Commission has recognized as providing an adequate level of protection (adequacy decision of 10 July 2023), and Google's data processing terms provide for the European Commission's standard contractual clauses where needed
    • EmailJS: its servers are in the United States (Amazon Web Services), and EmailJS covers these transfers with the European Commission's standard contractual clauses
  7. 7. Data Retention

    We keep your data only as long as the purposes above require:

    • Messages from contacts and prospects: 3 years after our last exchange
    • Client data: the duration of the contract, plus 5 years
    • Invoices and accounting records: 10 years (legal obligation)
    • Hosting logs: 30 days (see "Hosting and Server Logs")
    • The dg-lang cookie: 1 year after you last use the language switch (see "Cookies & Analytics")
    • Google Analytics: your choice is stored for 6 months, and the Google Analytics cookies expire after 13 months (see "Cookies & Analytics")

    At the end of these periods, the data is deleted.

  8. 8. Your Rights

    You have the right to:

    • Access, update, or delete your personal data
    • Withdraw consent at any time
    • Request a copy of your data
    • Contact us regarding any privacy concerns
    • Restrict the processing of your data
    • Object at any time to processing based on our legitimate interest
    • Receive the data you gave us in a structured, commonly used and machine-readable format, and have it transmitted to another controller (data portability)
    • Give instructions on the storage, erasure and communication of your data after your death

    To exercise these rights, contact us using the details under "Contact Us". We will reply within one month. Withdrawing your consent does not affect the lawfulness of the processing carried out before you withdrew it.

    If you believe your rights are not respected, you may lodge a complaint with the French data protection authority, the CNIL (Commission nationale de l'informatique et des libertés), 3 place de Fontenoy, 75007 Paris, France, www.cnil.fr, or with the supervisory authority of the EU country where you live or work.

  9. 9. Data Security

    We implement appropriate technical and organizational measures to protect your data from unauthorized access or disclosure.

  10. 10. Changes to This Policy

    We may update this Privacy Policy from time to time. We encourage you to review it periodically.

  11. 11. Contact Us

    If you have any questions or concerns about this Privacy Policy, please contact us at:

    Address
    4 Rue Principale, Linstroff, 57660 Grostenquin, France