Privacy policy

§7.1

Data Controller

Forms

Data collected through the forms

This site does not open any personal account and does not write any data to a database. The only personal data processed is what you enter into one of the site's six forms: contact, study, demonstration, quote, trial kit and assess my project. Every accepted submission is recorded in an application log named leads as thirteen pieces of information: first name, last name, company, e-mail address, phone number, subject, message, consent checkbox, originating form, timestamp, page address, language and professional profile. The professional profile is an activity category you declare yourself; it is present and empty on the five forms that do not offer it. It is not sensitive data, but combined with the company name and phone number it makes a record more easily linkable to an identified person. The same log receives two other types of records. Submissions discarded by the anti-bot honeypot appear there with exactly the same set of personal information, plus the note discarded: honeypot; this log therefore also contains submissions the site has deliberately not processed, so that a wrongly discarded request remains traceable. Submissions rejected for excessive frequency appear there with no entered value at all: only the form, the page address, the language, a client fingerprint, the applied limit and the wait time. The consent checkbox you tick is recorded as-is in this record, which is its only trace; this record retains the value submitted, and on its own it does not prove that consent was given. No profiling and no automated decision-making are carried out.

Recipients

Data recipients

Every accepted submission is sent by e-mail to a single inbox, contact@ecofass.fr by default, which the site's configuration allows to be set form by form. If mail delivery fails, the entire set of entered information is sent in JSON format to a technical alert inbox: this inbox is therefore also a recipient of personal data, not merely an operational channel. In production, the leads log record is written to standard error output, and therefore collected by the hosting platform's log aggregator, which acts in that capacity as a processor. There is no other recipient: no CRM tool, no advertising network, no audience-measurement provider, no third party. The data is neither sold nor exchanged.

Retention

Retention and rate limiting

No purge rule for the leads log exists in this site's code: nothing runs it and nothing erases it. The period for which it is retained remains to be specified and appears as such in the table below. To limit how often submissions can be made, the site separately retains a fingerprint of your IP address: an HMAC-SHA256 digest computed with the application's secret key and truncated to 128 bits, i.e. 32 hexadecimal characters, stored in a file cache under var/cache. This fingerprint does not make your address anonymous and does not remove its identifying character: the number of possible IPv4 addresses is finite, 2 to the power of 32, and anyone holding the secret key can iterate through them one by one to recover the original address. This is data minimisation at rest, nothing more. This fingerprint is retained for up to twice the configured interval, and this period is extended with each new window: for a one-hour interval, the measured figure is 7,199 seconds, not one hour. As the site has six forms, the same person may leave six fingerprints simultaneously, each extended independently. Nothing on this site purges this cache: an entry disappears only when its own sliding window expires. In addition, the path that discards submissions caught by the anti-bot honeypot is neither rate-limited nor size-bounded: the honeypot check runs before form validation, so the fields' maximum lengths do not apply, and no valid token is required. A single log line of 6,000,344 bytes was measured, and twelve submissions carrying an invalid token produced twelve records with no rejection for excessive frequency. The growth of this log is therefore determined by automated traffic, not by the actual volume of requests. Finally, when a text field contains an invalid byte sequence, the site replaces the entire value with an empty string: a submission may therefore be recorded with the first name, last name or company fields silently emptied, with no error message and without you being informed, across all six forms.

Cookies

Cookies and trackers

No audience-measurement, tracking, session or language cookie is set. The only cookie that can exist is a CSRF token strictly necessary for form security: it is set only when a form is submitted, it expires when the browser is closed, it is deleted from the very next request, and it is absent if JavaScript is disabled — the form then works without it. A strictly necessary cookie does not require a consent banner. On this site, served over HTTPS, this token carries a name beginning with __Host-csrf-token_ and the secure attribute. The script that manages the profile choice in the forms writes nothing: no local storage, no session storage, no browser database, no cookie, no call to any other server.

§7.3

Right of access, rectification and objection

In accordance with applicable European regulations, Users of the Site have the following rights: the right of access (Article 15 GDPR) and rectification (Article 16 GDPR), updating, and completeness of Users' data; the right to restrict or erase Users' personal data (Article 17 GDPR), where it is inaccurate, incomplete, ambiguous, out of date, or where its collection, use, disclosure or retention is prohibited; the right to withdraw consent at any time (Article 13-2c GDPR); the right to restriction of processing of Users' data (Article 18 GDPR); the right to object to the processing of Users' data (Article 21 GDPR); the right to portability of data Users have provided, where that data is subject to automated processing based on their consent or on a contract (Article 20 GDPR); the right to determine the fate of Users' data after their death and to choose to whom ECOFASS must (or must not) communicate their data, to a third party they will have previously designated. If a User wishes to know how ECOFASS uses their Personal Data, to request that it be rectified, or to object to its processing, the User may contact ECOFASS in writing at the following address: CG INDUSTRY – DPO, SAS CG INDUSTRY, 17 rue Charles Favre 39260 Moirans-en-montagne. In that case, the User must indicate the Personal Data they would like ECOFASS to correct, update or delete, identifying themselves precisely with a copy of an identity document (identity card or passport). Finally, Users of the Site may lodge a complaint with the supervisory authorities, in particular the CNIL (https://www.cnil.fr/fr/plaintes).

§7.4

Non-disclosure of personal data

ECOFASS undertakes not to process, host or transfer Information collected about its Clients to a country located outside the European Union or recognised as "not adequate" by the European Commission without first informing the client. The Site is hosted by a provider within the territory of the European Union in accordance with the provisions of the General Data Protection Regulation (GDPR: No. 2016-679).