Privacy Policy

1. Introduction

FRUTEAU ("we," "our," or "us") is committed to protecting the privacy and personal data of individuals who visit our website and use our coaching education services. This Privacy Policy explains how we collect, use, store, share, and protect your personal information in compliance with the General Data Protection Regulation (GDPR — Regulation (EU) 2016/679), the French Data Protection Act (Loi Informatique et Libertés), and other applicable data protection legislation in France.

By accessing or using our website, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, please do not use our website or submit any personal information.

2. Data Controller

The data controller responsible for the processing of your personal data is:

3. Personal Data We Collect

We may collect and process the following categories of personal data when you interact with our website and services:

3.1 Information You Provide Directly

• Contact Information: Full name, email address, phone number.
• Program Preferences: Selected program of interest and preferred learning format.
• Communications: Messages, comments, or inquiries submitted through our contact form.
• Consent Records: Records of consent provided through forms, including the date and time of consent.

3.2 Information Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device type, screen resolution.
• Usage Data: Pages visited, time spent on pages, referring website, navigation paths.
• Cookie Data: Information collected through cookies and similar tracking technologies as described in our Cookie Policy.

4. Legal Basis for Processing

Under the GDPR, we process your personal data based on the following legal grounds:

• Consent (Article 6(1)(a) GDPR): When you voluntarily submit a contact form or subscribe to communications, we process your data based on your explicit consent. You may withdraw your consent at any time.
• Legitimate Interest (Article 6(1)(f) GDPR): We may process certain data to maintain the security and functionality of our website, analyze aggregated usage trends, and improve our educational services. This processing is balanced against your rights and freedoms.
• Legal Obligation (Article 6(1)(c) GDPR): We may process data when required to comply with applicable French or European Union laws and regulations.

5. How We Use Your Personal Data

We use the personal data we collect for the following purposes:

• To respond to your inquiries and provide information about our coaching education programs.
• To process and manage contact form submissions.
• To communicate with you regarding programs, resources, or updates you have expressed interest in.
• To maintain, protect, and improve the functionality and security of our website.
• To analyze aggregated, anonymized website usage data to improve user experience.
• To comply with legal and regulatory obligations under French law.

6. Data Sharing and Disclosure

We do not sell, rent, or trade your personal data to third parties for marketing purposes. We may share your personal data only in the following limited circumstances:

• Service Providers: We may share data with trusted third-party service providers who assist us with website hosting, form processing, email delivery, and analytics. These providers are contractually obligated to process data only on our behalf and in compliance with GDPR requirements.
• Legal Requirements: We may disclose personal data when required by law, regulation, legal process, or enforceable governmental request under the jurisdiction of France or the European Union.
• Protection of Rights: We may disclose data to protect our rights, safety, or property, or that of our users or the public, as required or permitted by applicable law.

7. International Data Transfers

As our educational services are offered to participants in Canada, certain data may be transferred to or processed in countries outside the European Economic Area (EEA). When such transfers occur, we ensure that appropriate safeguards are in place in accordance with GDPR requirements, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission.
• Adequacy decisions by the European Commission where applicable.
• Other legally recognized mechanisms ensuring an adequate level of data protection.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Specific retention periods include:

• Contact form submissions: Retained for a maximum of 24 months from the date of submission, unless you request earlier deletion.
• Website analytics data: Aggregated and anonymized data may be retained indefinitely. Identifiable analytics data is retained for no more than 13 months in compliance with CNIL guidelines.
• Consent records: Retained for the duration required to demonstrate compliance with GDPR obligations.

Once the retention period expires, personal data is securely deleted or irreversibly anonymized.

9. Your Rights Under the GDPR

Under the GDPR and applicable French data protection law, you have the following rights regarding your personal data:

• Right of Access (Article 15): You have the right to request a copy of the personal data we hold about you.
• Right to Rectification (Article 16): You have the right to request correction of inaccurate or incomplete personal data.
• Right to Erasure (Article 17): You have the right to request deletion of your personal data, subject to certain legal exceptions.
• Right to Restriction of Processing (Article 18): You have the right to request that we restrict the processing of your personal data under certain circumstances.
• Right to Data Portability (Article 20): You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object (Article 21): You have the right to object to the processing of your personal data based on legitimate interests.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days in accordance with GDPR requirements.

10. Right to Lodge a Complaint

If you believe that our processing of your personal data infringes the GDPR or applicable French data protection law, you have the right to lodge a complaint with the French data protection authority:

11. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance functionality and analyze usage patterns. For detailed information about the types of cookies we use, how they are managed, and your choices regarding cookies, please refer to our Cookie Policy.

12. Security Measures

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• HTTPS encryption across all pages of the website.
• Secure server environments with restricted access controls.
• Regular security assessments and updates.
• Secure form processing with server-side validation and spam protection.

While we strive to protect your personal data, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security but are committed to maintaining industry-standard protections.

13. Third-Party Links

Our website does not contain links to third-party websites. If any external links are added in the future, please be aware that we are not responsible for the privacy practices or content of third-party websites. We encourage you to read the privacy policies of any external websites you visit.

14. Children's Privacy

Our website and coaching education services are intended for adults only. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have collected personal data from a minor, we will take steps to delete such data promptly. If you believe a minor has provided us with personal data, please contact us at [email protected].

15. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. Any changes will be posted on this page with an updated "Last updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data. Continued use of our website after changes are posted constitutes your acceptance of the updated Privacy Policy.

16. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of France and the applicable regulations of the European Union, including the General Data Protection Regulation (GDPR). Any disputes arising from or related to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of France.

17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us: