Privacy Policy
Preamble
PASOLA SAS is committed to protecting the privacy of its visitors and the security of their personal data, in compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the French "Informatique et Libertés" law of January 6, 1978, as amended.
This policy describes the conditions under which personal data is collected and processed on the website pasola.fr.
Data Controller
- PASOLA, simplified joint-stock company (SAS)
- Registered office: 60 rue François Ier, 75008 Paris, France
- SIREN: 995 071 636
- Contact: contact@pasola.fr
Data collected
Contact form (Section "Begin the conversation")
- First name and last name
- Email address
- Profile of the inquirer (private buyer, family office, press)
- Message (if provided)
Newsletter subscription form
- First name and last name
- Email address
- Explicit consent to receive communications
Language preference cookie
- The "pasola-lang" cookie stores the user's manual language choice (French or English), retained for 1 year. See Cookie Policy.
Technical data
Cloudflare, as host, processes technical data (IP address, timestamp, HTTP headers, user agent) for the purposes of website delivery and protection against attacks. This data is retained for limited durations (typically from a few hours to 30 days depending on the type of log).
Purposes and legal bases of processing
| Purpose | Legal basis |
|---|---|
| Response to a contact request | Pre-contractual measure at your request / consent |
| Newsletter delivery | Explicit consent |
| Storage of language preference | Legitimate interest (quality of user experience) |
| Website security and technical logs | Legitimate interest (information security) |
| IP-based geolocation for language routing | Legitimate interest (automatic language routing) |
Recipients and processors
The data collected may be transmitted to the following technical sub-processors, strictly to the extent necessary for their services:
| Processor | Purpose | Location |
|---|---|---|
| Cloudflare, Inc. | Website hosting and delivery, anti-DDoS protection, IP geolocation | United States and global infrastructure |
| Brevo (Sendinblue SAS) | Sending of transactional emails: address verification, acknowledgements, administrative notifications | France / European Union |
| Cloudinary | Hosting and delivery of video content | United States |
| YouTube (Google LLC) | Playback of embedded video content (Section "Friends' Voices") | United States |
| Spotify AB | Playback of embedded playlist in the footer | Sweden / United States |
| Google Fonts | Delivery of typographic fonts (Cinzel, Cormorant Garamond, Outfit) | United States |
These sub-processors are selected for their level of technical and legal guarantees. PASOLA SAS enters into agreements with its sub-processors that comply with Article 28 of the GDPR.
Transfers outside the European Union
Several of the above sub-processors are located outside the European Union, notably in the United States. These transfers are governed by the Standard Contractual Clauses (SCCs) adopted by the European Commission, or by other equivalent mechanisms provided for under the GDPR (adequacy decisions, binding corporate rules).
Retention period
| Category | Duration |
|---|---|
| Contact form data | 3 years from the last interaction |
| Newsletter data | Until unsubscription, plus 3 years from unsubscription as proof of consent |
| Language preference cookie | 1 year |
| Technical hosting logs | In accordance with applicable legal retention periods (typically 6 months to 1 year) |
Your rights
In accordance with the GDPR, you have the following rights over your personal data:
- Right of access
- Right of rectification
- Right to erasure ("right to be forgotten")
- Right to restrict processing
- Right to data portability
- Right to object
- Right to withdraw your consent at any time, without affecting the lawfulness of prior processing
- Right to define directives concerning the storage, deletion, and communication of your data after death
To exercise any of these rights, please write to: contact@pasola.fr. A response will be provided within one month of receipt of your request, this period being extendable by two months in the case of complex requests.
You also have the right to lodge a complaint with the French Data Protection Authority (CNIL), 3 place de Fontenoy, 75007 Paris — cnil.fr.
Minors
This website is not intended for minors. No data is knowingly collected from minors. If a parent or guardian discovers that data concerning a minor has been transmitted without their consent, they may request its deletion at contact@pasola.fr.
Security
PASOLA SAS implements appropriate technical and organizational measures to preserve the security, confidentiality, and integrity of personal data: encryption of communications (HTTPS / TLS), restricted access to data, careful selection of sub-processors.
Changes to this policy
This policy may be updated. Any substantive change will be signaled by updating the date at the top of the document.