FrenchEdtech.com – TROËL Operations & Consulting
Last updated: [DD Month YYYY]
1) Overview
This Privacy Policy explains how TROËL Operations & Consulting (“we”, “us”, “our”) collects, uses, discloses, and protects your personal data when you visit FrenchEdtech.com (the “Website”), contact us, book lessons, purchase services, or use any associated learning tools/platform features.
We process personal data in accordance with the GDPR and applicable French data-protection rules.
2) Who is responsible for your data? (Data Controller)
Data Controller: TROËL Operations & Consulting
Business address: [TO COMPLETE – full address, Paris, France]
Email: [TO COMPLETE – e.g., contact@frenchedtech.com]
Business registration (SIRET): [TO COMPLETE]
VAT number (if applicable): [TO COMPLETE / “Not applicable”]
If you have any questions about this policy or your data, you can contact us at the email above.
3) What data we collect
Depending on how you interact with us, we may collect:
3.1 Data you provide directly
- Identity & contact: name, email, phone number (optional), country/time zone
- Booking & service details: lesson type, level, goals, availability, notes you share
- Billing: invoicing details, transaction references (we do not store full card numbers)
- Communications: messages sent via forms, email, chat, or messaging channels
- Learning-related information: homework submissions, progress notes, feedback, course history
- Audio/video (only if applicable): if lessons are recorded with your consent and/or you send voice recordings for practice
3.2 Data collected automatically (technical data)
- IP address, device type, browser type, pages viewed, approximate location (country/city), referral source
- Log data for security and troubleshooting
- Cookie identifiers and preferences (see Section 11)
3.3 Sensitive data
We do not intentionally collect “special category” data (health, religion, political opinions, etc.). Please do not share such data in forms or messages unless strictly necessary.
4) Why we use your data (Purposes)
We use your data to:
- Provide and manage services (lessons, scheduling, learning follow-up, support)
- Process payments and issue invoices/receipts
- Communicate with you about bookings, changes, and service information
- Improve our content and user experience (service quality, troubleshooting, analytics)
- Send optional updates/marketing (newsletter, offers) only when lawful and with appropriate opt-out options
- Ensure security (fraud prevention, abuse prevention, technical security)
5) Legal bases for processing (GDPR)
Depending on the situation, processing is based on one or more of the following:
- Contract performance (to deliver lessons/services you requested)
- Legal obligations (accounting, invoicing, compliance)
- Legitimate interests (service improvement, security, responding to requests)
- Consent (newsletter/marketing in certain cases; non-essential cookies; recordings; optional AI features where required)
You may withdraw consent at any time (see Section 9).
6) Who we share data with (Processors / Third parties)
We only share data when necessary to operate the Website and deliver services. We may use service providers (acting as “processors”) such as:
- Website hosting & infrastructure: [TO COMPLETE – host name]
- Email and communications (support, newsletters): [TO COMPLETE – provider(s)]
- Scheduling/booking (if used): [TO COMPLETE – e.g., Calendly / booking tool]
- Video conferencing (if used): [TO COMPLETE – e.g., Zoom / Google Meet]
- Payments (if used): [TO COMPLETE – e.g., Stripe / PayPal]
- Analytics (if used): [TO COMPLETE – e.g., Google Analytics / Matomo]
- Video hosting (if used): [TO COMPLETE – e.g., YouTube / Vimeo]
- Automation / integrations (if used): [TO COMPLETE – e.g., Zapier / Make]
- AI-enabled practice tools (only if you choose such features and if applicable): [TO COMPLETE – provider(s) / platform(s)]
These providers are contractually bound to process data only on our instructions and for the purposes described above.
We may also disclose data if required by law (legal requests, regulatory obligations) or to protect our rights and safety.
7) International data transfers
Some providers may be located outside the European Economic Area (EEA). Where this is the case, transfers are safeguarded through appropriate legal mechanisms (e.g., Standard Contractual Clauses or other valid transfer tools), and we take steps to ensure an adequate level of protection.
8) How long we keep your data (Retention)
We keep personal data only as long as necessary for the purposes described:
- Client/service data (lesson follow-up, account/admin): for the duration of the relationship, then archived as needed for legal defense
- Prospect data (no purchase): typically up to 3 years from the last contact
- Marketing data: until you unsubscribe, or up to 3 years from last interaction (as applicable)
- Invoices/accounting records: typically 10 years (legal/accounting obligations)
- Technical logs/security: limited duration (e.g., a few months) unless needed for security incidents
- Lesson recordings (if any): [TO COMPLETE – your retention rule] and only when consented
Exact durations may vary depending on legal requirements and operational needs.
9) Your rights (GDPR) and how to exercise them
You have rights regarding your personal data, including:
- Right of access
- Right to rectification
- Right to erasure (“right to be forgotten”)
- Right to restriction of processing
- Right to objection (in certain cases, including marketing)
- Right to data portability (where applicable)
- Right to withdraw consent at any time (where processing is based on consent)
To exercise your rights, contact: [TO COMPLETE – privacy email].
We may ask for proof of identity if needed to protect your data.
Complaints
If you believe your rights have not been respected, you can lodge a complaint with the French supervisory authority: CNIL (Commission Nationale de l’Informatique et des Libertés).
10) Security
We implement reasonable technical and organizational safeguards to protect your data (access controls, limited access on a need-to-know basis, security updates, and secure providers). No system is 100% secure, but we work to reduce risks and respond promptly to incidents.
11) Cookies & similar technologies
Cookies are small files stored on your device that help a website function and/or collect information about usage.
11.1 Types of cookies we may use
- Strictly necessary cookies: required for core site functions (security, page navigation, preferences you request)
- Functional cookies: improve usability (language, saved settings)
- Analytics cookies: measure audience and website performance
- Advertising / social media cookies (if used): enable marketing measurement and targeted advertising
11.2 Consent
- Non-essential cookies (analytics, marketing, social media) are used only if you consent, unless an exemption applies under applicable rules.
- You can refuse cookies as easily as you can accept them, and you can change your choice at any time.
12) How to manage cookies
You can manage cookies in two ways:
- Cookie banner / Cookie settings on the Website: accept, refuse, or customize by category.
- Browser settings: you can block or delete cookies in your browser. Note that blocking some cookies may affect site functionality.
Cookie Settings link: [TO COMPLETE – add a visible “Cookie Settings / Manage Cookies” link in the footer]
13) Children / Minors
Our services are primarily intended for adults. If a user is under 15, consent-based processing (such as certain cookies or optional features) may require parental involvement under applicable French rules. If you believe a minor has provided data without appropriate authorization, please contact us.
14) Third-party links and embedded content
The Website may contain links or embedded content (videos, social media). These third parties may collect data according to their own policies. We encourage you to review their privacy notices.
15) Changes to this policy
We may update this Privacy Policy from time to time. The latest version will always be published on the Website with the updated “Last updated” date.
ANNEX (Recommended) — Cookie List Table
(To keep the policy complete, add a small table once you confirm which tools are actually installed.)
Example format:
Cookie name | Provider | Purpose | Category | Duration
[TO COMPLETE with your real cookies]