1. Data controller

The data controller is OrChair SAS (SIRET: 821 473 436), headquartered at 1 Passage des Acacias, 75017 Paris, France. Publication director: Antoine Cazals. Contact: theodore@orchair.com.

2. Data collected

OrChair collects the following data:

• Browsing data: IP address, browser type, pages visited, visit duration, via analytical cookies (with consent).
• Newsletter data: email address, preferred language.
• Advertiser data: name, email, phone, company name, website, via the advertising form.
• Chatbot data: messages exchanged with the AI assistant (not linked to personal identifiers).

3. Processing purposes

• Provision and improvement of editorial services
• Sending newsletters (with explicit consent)
• Managing advertising requests
• Anonymized statistical audience analysis
• Compliance with legal obligations

4. Legal basis

Processing is based on: user consent (newsletter, analytical cookies), contract performance (advertisers), legitimate interest (service improvement, security), and legal obligations (billing data retention).

5. Retention period

• Browsing data: 13 months maximum
• Newsletter data: until unsubscription + 3 years
• Advertiser data: duration of business relationship + 5 years (accounting obligations)
• Cookies: 13 months maximum per CNIL recommendations

6. User rights (GDPR)

Under GDPR (EU 2016/679), you have the following rights:

• Right of access: obtain a copy of your personal data
• Right of rectification: correct inaccurate data
• Right to erasure: request deletion of your data ("right to be forgotten")
• Right to restriction: limit the processing of your data
• Right to portability: receive your data in a structured format
• Right to object: object to the processing of your data
• Right to withdraw consent: withdraw your consent at any time

To exercise these rights, contact us at theodore@orchair.com with a copy of your ID.

7. Cookies

OrChair uses:

• Essential cookies: necessary for site operation (language preference, cookie consent). Exempt from consent.
• Analytical cookies: anonymized audience measurement (subject to consent via cookie banner).

OrChair does NOT use third-party advertising cookies, social media trackers, or behavioral profiling cookies.

8. Data transfers

Data is hosted within the European Union. In case of transfer outside the EU (cloud hosting), standard contractual clauses approved by the European Commission govern these transfers in accordance with GDPR.

9. Security

OrChair implements appropriate technical and organizational measures to protect your data: TLS/SSL encryption, strict access control, regular backups, penetration testing, and continuous system monitoring.

10. Complaints

For complaints, contact our Data Protection Officer at theodore@orchair.com. You also have the right to file a complaint with the French data protection authority (CNIL).

11. Legal notices

Publisher: OrChair SAS (SIRET: 821 473 436) Headquarters: 1 Passage des Acacias, 75017 Paris, France Publication director: Antoine Cazals Host: GDPR-compliant European cloud services Contact: theodore@orchair.com