1. Data Controller
The controller responsible for the processing of personal data through the website www.myradar.bio is:
ECOMSOFT
2 rue des Frères Perret
87280 Limoges – France
Telephone: +33 9 72 17 03 10
Email: contact@ecomsoft.fr
2. Data Collected Through the Contact Form
Fields marked as mandatory are required to enable ECOMSOFT to receive and process the request. Failure to complete these fields may prevent the form from being submitted or an appropriate response from being provided. Optional fields may help facilitate communication.
Users are advised not to provide sensitive data or information about third parties in free-text fields unless it is necessary for their request. Technical information relating to the use of the website may also be processed for security and operational purposes.
When a user completes the contact or demonstration request form, ECOMSOFT may collect, in particular:
- First and last name;
- Company or organisation name;
- Professional email address;
- Telephone number;
- Message content;
- Any information voluntarily provided in the free-text field.
The data is sent directly to ECOMSOFT by email and, to the website publisher’s knowledge, is not automatically transferred to a CRM.
3. Purposes and Legal Basis
Processing is limited to data relevant to the stated purposes. The applicable legal basis depends on the nature of the request and the capacity in which the person submits it. Where a request is made on behalf of an organisation, ECOMSOFT’s legitimate interest in managing its business relationships may be relevant. Where an individual requests a service on their own behalf, steps taken prior to entering into a contract may apply.
Submitting a request through the form does not automatically subscribe the user to a newsletter or marketing campaign. Any subsequent use of contact details for marketing purposes must be assessed separately under the GDPR and the rules applicable to electronic direct marketing.
Information collected through the form is used to:
- Respond to requests sent to ECOMSOFT;
- Provide information about the MyRadar solution;
- Arrange a presentation or demonstration, where appropriate;
- Establish and continue pre-contractual discussions requested by the individual.
Where the request concerns a service, demonstration or project, processing is based on taking steps at the data subject’s request prior to entering into a contract.
Where the request is of a general nature, processing may be based on ECOMSOFT’s legitimate interest in responding to enquiries.
A checkbox requesting consent to the processing of personal data is therefore not required to submit the form. A separate checkbox would, however, be necessary if ECOMSOFT wished to obtain consent for a different purpose, such as subscribing to electronic marketing communications where consent is required.
4. Retention Periods
Retention periods are determined according to the purpose of the processing and any applicable legal obligations. At the end of the relevant period, data is deleted or, where legally justified, retained in restricted-access intermediate archives.
The three-year period specified for prospective customers is a maximum reference period and does not relieve ECOMSOFT of its obligation to delete data sooner when it is no longer needed. Data contained in contact emails must also be included in data review and deletion procedures.
Data submitted as part of a simple contact enquiry is retained for the time necessary to process the request.
Where business discussions continue, data may be retained for the management of the prospective customer relationship. Prospective customer data may be retained for three years from the last contact initiated by that prospective customer.
Where the person becomes a customer, information necessary to manage the contractual relationship is retained throughout that relationship and subsequently archived for the periods necessary to comply with legal obligations and defend ECOMSOFT’s rights.
5. Recipients
Access to data is organised on a need-to-know basis. Service providers acting on behalf of ECOMSOFT must only access information necessary to perform their duties, in accordance with applicable contractual and confidentiality obligations.
Where service providers act as processors within the meaning of Article 28 of the GDPR, their activities must be governed by appropriate contractual provisions covering, in particular, instructions, security, confidentiality, and the return or deletion of data.
Data is accessible only to authorised personnel within ECOMSOFT and to technical service providers acting on its behalf where access is necessary for their work.
Data may, in particular, be processed in connection with the hosting, maintenance and security of the website.
6. Hosting
The fact that the hosting infrastructure is located in France does not, in itself, rule out the disclosure of data to service providers located outside the European Economic Area. Any data flows associated with third-party services integrated into the website must be assessed separately.
Where personal data is transferred internationally, ECOMSOFT must verify that a mechanism compliant with Chapter V of the GDPR is in place and provide data subjects with the required information about the applicable safeguards.
The website is hosted by OVHcloud. According to information provided by the service provider responsible for the website, the relevant hosting infrastructure is located in France.
7. Protecting the Form Against Unwanted Submissions – Turnstile
This protection mechanism is used to preserve the availability and integrity of the form, reduce automated submissions and limit the risk of abuse. Any technical data disclosed to the provider must remain proportionate to this purpose.
The respective roles of ECOMSOFT and Cloudflare, the retention conditions for technical signals and any international transfers must be assessed in light of the contractual documentation and the settings actually enabled.
The contact form uses Turnstile, provided by Cloudflare, to protect the website against automated submissions, bots and unwanted messages.
To distinguish human users from automated behaviour, Turnstile may process various technical signals relating to the device and connection, including the IP address, certain browser characteristics, the User-Agent header, a TLS fingerprint, the site key and the associated origin. Cloudflare states that this data is used to detect and block bots, rather than to identify, profile or target internet users.
This processing serves ECOMSOFT’s legitimate interest in ensuring the security of the website and protecting its form against automated and abusive use.
Users can consult Cloudflare’s specific privacy policy for Turnstile:
Cloudflare Turnstile Privacy Policy
8. YouTube Videos
Where videos are embedded using a third-party service that may read or place non-essential trackers, they must only load after prior consent has been obtained. A placeholder may be displayed before consent to inform users and allow them to activate the content voluntarily.
Refusing these trackers must not prevent access to other website content. Using a privacy-enhanced mode or a particular embedding component does not remove the need to check which requests are actually triggered before the user gives consent.
Some pages of the website may include videos hosted by YouTube, a service provided by Google.
Loading a YouTube video may result in cookies or other storage items being accessed or placed on the user’s device and certain information being transmitted to Google/YouTube.
The relevant YouTube content must therefore remain blocked until the user has accepted the corresponding trackers. The French data protection authority, the CNIL, confirms that where embedded external content places trackers requiring consent, that consent must be obtained before the content is activated. CNIL guidance, in French
9. Google Tag Manager and Marketing Tools
Using a tag management system does not necessarily mean that all analytics or advertising services that could technically be configured within it are enabled. Only tags actually deployed must be described in the information provided to visitors.
For each tool actually used, the information to be documented includes its provider, purpose, categories of data processed, associated trackers, their retention periods and any international transfers. The Complianz configuration must reflect how the tags actually operate.
The website may use Google Tag Manager to deploy and manage technical, analytics or marketing tags.
Google Tag Manager is a tag management tool. The processing activities and trackers to which users may be exposed depend on the services actually triggered through that tool.
Tags that are not strictly necessary must only be activated after the user’s consent has been obtained.
10. Data Subject Rights
Requests may be submitted without any particular formalities. ECOMSOFT may request clarification necessary to process them and may only request proof of identity where there is reasonable doubt about the requester’s identity.
A response is normally provided within one month of receipt of the request. This period may be extended by a further two months where justified by the complexity or number of requests, provided that the individual is informed within the first month. Under the conditions laid down by French law, individuals may also give instructions concerning what happens to their personal data after their death.
In accordance with the General Data Protection Regulation and the French Data Protection Act, individuals have the following rights, subject to the conditions set out in the applicable legislation:
- Access to their data;
- Rectification;
- Erasure;
- Restriction of processing;
- Objection;
- Data portability, where applicable;
- Withdrawal of consent where processing is based on consent.
Requests may be sent to:
ECOMSOFT
2 rue des Frères Perret
87280 Limoges – France
Email: contact@ecomsoft.fr
If an issue remains unresolved, individuals also have the right to lodge a complaint with the French data protection authority, the Commission nationale de l’informatique et des libertés (CNIL).