Privacy
policy

The controller of the data collected on the Site and in connection with the services is Cléo Schmitt, sole trader, 1 rue Fernand et Paul Méchin, 37550 Saint-Avertin, France, reachable at contact@frenchwithcleo.com.

For any question about your personal data, or to exercise your rights, you can write to contact@frenchwithcleo.com.

No data protection officer has been appointed, as this is not required given the nature of the activity.

The data collected is what you provide directly when booking and during the programme:

• identity and contact details: surname, first name, email address, time zone and, where applicable, telephone number;
• information about your learning: level, goals, difficulties encountered, progress and work done between sessions;
• booking data: time slots chosen, session history, cancellations and rescheduling;
• billing data: amounts, dates and payment records;
• correspondence: messages sent by email.

The information requested when booking is necessary to process your order; without it, the booking cannot proceed. Information about your level and goals is optional, but determines how far the coaching can be personalised.

No bank details are collected or stored by the controller: payment is handled by Stripe.

Data is processed for the following purposes:

• managing bookings and delivering the services purchased — legal basis: performance of the contract;
• issuing invoices and meeting accounting obligations — legal basis: a legal obligation;
• replying to enquiries sent by email — legal basis: the legitimate interest in responding to enquiries;
• making audio or video recordings of pronunciation — legal basis: your consent;

Data is neither sold nor transferred. It is accessible to the controller and, strictly as necessary, to the following technical providers:

• Cal.com, for appointment booking and time-slot management;
• Stripe, for collecting payments;
• Google Meet, for holding sessions;
• Quizlet, for the vocabulary lists made available;
• Timothée Schmitt (Hostinger infrastructure), for hosting the site;
• Outlook, for correspondence by email.

These providers act on instructions and are bound by confidentiality and security obligations.

To host the Site, manage bookings, deliver lessons by video call, correspond by email and process payments, the controller uses Hostinger, Cal.com, Google Meet, Microsoft and Stripe.

These services may involve processing some personal data outside the European Economic Area, in particular in the United States. Depending on the recipient and the transfer concerned, the applicable safeguards are an adequacy decision — notably for US organisations certified under the EU–US Data Privacy Framework — or the European Commission’s standard contractual clauses.

For information about the safeguards that apply to your data, you can write to contact@frenchwithcleo.com.

• booking and learning records: for the duration of the programme, then three years from the last contact;
• invoices and accounting records: ten years, in accordance with accounting obligations;
• contracts concluded online for €120 or more: ten years, under Article L213-1 of the French Consumer Code;
• email correspondence: three years from the last contact;
• audio and video recordings: one month, then deletion;
• data of people who only booked a discovery session without taking it further: three years from the last contact.

Pronunciation feedback may involve recording your voice, and where applicable your image.

Such recordings are made only with your prior consent, obtained separately. They are used solely to give you educational feedback and are never published or used for promotional purposes without your separate agreement.

You may withdraw your consent at any time, without affecting the lawfulness of processing already carried out. The recordings are then deleted.

The services are intended for adults only. The Site is not aimed at minors and no data is knowingly collected from them.

No decision producing legal effects or significantly affecting you is taken solely on the basis of automated processing. No profiling is carried out.

Under the conditions set out in the General Data Protection Regulation, you have the following rights:

• the right of access to your data and to obtain a copy;
• the right to rectification of inaccurate or incomplete data;
• the right to erasure, within the limits of statutory retention obligations;
• the right to restriction of processing;
• the right to object, on grounds relating to your particular situation;
• the right to portability of the data you have provided;
• the right to withdraw your consent at any time, where processing is based on it;
• the right to give directions as to what happens to your data after your death.

To exercise these rights, send your request to contact@frenchwithcleo.com, stating which right you wish to exercise.

You will receive a reply within one month of the request being received. This period may be extended by two months for complex requests; you would be informed if that were the case.

Proof of identity may be requested where there is reasonable doubt as to the identity of the person making the request.

Appropriate technical and organisational measures are in place to protect your data against loss, alteration and unauthorised access: encrypted connections, access limited to authorised people only, and the use of providers offering sufficient safeguards.

If, after contacting us, you consider that your rights are not being respected, you may lodge a complaint with the French data protection authority (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, or through its website.

If you live in another European Union member state, you may contact the supervisory authority of your country of residence.

This policy may be amended to reflect legal, technical or organisational developments. The version that applies is the one published on the Site on the date you consult it.

Where a change is substantial, the people concerned are informed by email.