Controller
Taner OKUR, sole trader under French law (entrepreneur individuel, EI), trading as OLHYN. SIRET 793 428 715 000 31, RCS Pontoise 793 428 715, Villiers-le-Bel (95400), France. You can reach us through our contact page.
OLHYN is established in France and applies the EU General Data Protection Regulation (GDPR), which protects you in Ireland as it does in France. In Ireland, the GDPR is supplemented by the Data Protection Act 2018.
Data we collect
The website collects data in the following cases:
Cookie-free visit measurement (Cloudflare Web Analytics): number of visits and page views, page viewed, referring page, country, browser type and page load times, combined into anonymous statistics. No cookie or identifier is placed on your device, and your browsing is not tracked from one website to another: this measurement therefore does not require your consent.
Audience measurement (Google Analytics through Google Tag Manager): pseudonymised browsing data (pages viewed, session length, device type, traffic source). Enabled only after your explicit consent through the cookie banner.
Behavioural analytics (Microsoft Clarity through Google Tag Manager): pseudonymised session recordings and heatmaps to understand how the site is used (movements, clicks, scrolling). Enabled only after your explicit consent through the cookie banner.
Error monitoring (Sentry): when a technical error occurs on the site, a report containing the error message, the page concerned and the browser type is sent to Sentry so that we can fix the problem. Your IP address is never sent, and no video or recording of your browsing is made.
Push notifications: if you agree to receive notifications, a technical subscription identifier is kept by our hosting provider. No personal data (name, email) is linked to it.
Booking (cal.eu): when you book a call, your name, email address and any message are processed by the booking tool cal.eu, published by Cal.com, under its own privacy policy.
Contact by email: the data you choose to send us by email (name, email address, message) is processed to answer your request.
Article comments: if you post a comment, your name and message are kept; the email address is optional and never displayed. A non-reversible technical fingerprint of your IP address is computed to limit abuse, together with an anti-bot check. Every comment is reviewed by hand before publication.
Likes on articles: no personal data is collected; only a non-reversible technical fingerprint of your IP address is kept, so that the same visitor is not counted twice.
Maps (Google Maps): pages presenting an area we serve in France offer a map provided by Google Maps. It loads only after you accept cookies in the banner, or if you click the button that shows the map. Google then receives your IP address and sets its own cookies in your browser. Until the map is shown, no request is sent to Google.
Customer relationship management: when you contact us or become a customer, your contact details and the history of our exchanges are kept in a customer relationship tool that we host ourselves, on a server located in France. It holds your business contact details, the follow-up of our exchanges, your quotes and invoices, and the emails we exchange, automatically linked to your record. This data does not come from your browsing on this site: it is what you give us in the course of our business relationship.
Legal basis for processing
Consent: audience measurement (Google Analytics and Microsoft Clarity cookies), map display (Google Maps), push notifications, posting a comment.
Legitimate interest: website security, anonymous visit measurement (Cloudflare Web Analytics), error monitoring (Sentry), prevention of abuse on comments and likes (IP fingerprint, anti-bot check), and follow-up of our relationship with prospects and customers in our management tool.
Performance of a contract: booking calls, answering contact requests.
Cookies
This website uses the following cookies:
Strictly necessary cookies: storing your cookie choice. No consent is required.
Analytics cookies (Google Analytics, Microsoft Clarity): set only after your consent through the cookie banner. You can withdraw your consent at any time by deleting your cookies or through the banner.
Google Maps cookies: set by Google only when a map is shown, that is after you accept cookies in the banner or click the map button. You can delete them at any time in your browser settings.
Error monitoring (Sentry) and visit measurement (Cloudflare Web Analytics) set no cookie and work regardless of your cookie choice. Apart from the cookies listed above, no other tracker is placed in your browser.
Retention periods
Analytics data: 14 months (Google Analytics setting).
Visit statistics (Cloudflare Web Analytics): kept by Cloudflare in aggregated, anonymous form, with no data that could identify a visitor.
Behavioural analysis (Microsoft Clarity): session recordings kept for 30 days by Microsoft, except a random sample and recordings marked as favourites, kept for up to 9 months; heatmaps available for up to 9 months.
Error reports (Sentry): kept for 30 days, then deleted automatically.
Push subscriptions: kept until you unsubscribe or the subscription expires technically.
Booking data: kept by cal.eu (Cal.com, Inc.) under its own policy, and by OLHYN for the duration of the business relationship, then 3 years for prospecting purposes.
Contact emails: kept as long as needed to handle the request, then 3 years at most.
Comments: published comments are kept as editorial content of the site; rejected or unmoderated comments may be deleted during moderation.
Likes: the IP fingerprint is kept as long as the like remains active, with no retention period separate from the content concerned.
Business management data: kept for the duration of the business relationship, then 3 years from the last contact for a prospect. Accounting records follow their own statutory periods.
Emails linked to your record: kept on the same terms as the record they relate to.
Transfers outside the European Union
Some data may be transferred outside the European Union through the following providers:
Cloudflare, Inc. (United States): hosting of the website, anonymous visit measurement, storage of push subscriptions and comments in databases created in Europe, and anti-bot checks. Cloudflare participates in the EU-US Data Privacy Framework.
Google LLC (United States): audience measurement through Google Analytics and display of maps through Google Maps. Google participates in the EU-US Data Privacy Framework.
Microsoft Corporation (United States): behavioural analytics through Microsoft Clarity. Microsoft participates in the EU-US Data Privacy Framework.
Cal.com, Inc. (United States), publisher of the booking tool cal.eu: management of call bookings.
Stripe Payments Europe, Limited (Ireland): online payment of a paid consultation booked through cal.eu, under Stripe’s privacy policy. Stripe may transfer this data to Stripe, Inc. (United States), which participates in the EU-US Data Privacy Framework.
Dropbox, Inc. (United States): archiving of the accounting records (quotes, invoices, receipts) of our clients and suppliers. Dropbox participates in the EU-US Data Privacy Framework.
Infomaniak Network SA (Switzerland): hosting of our mailbox; the emails you send us are received and stored there. Switzerland benefits from an adequacy decision of the European Commission.
SMTP2GO Ltd (New Zealand): delivery of the emails we send you from our customer relationship management tool (follow-up of your requests). The service does not keep the content of emails, apart from occasional anti-abuse checks. New Zealand benefits from an adequacy decision of the European Commission.
Our internal management tools are hosted by Oracle Corporation on a server located in Paris: the business data they hold does not leave the European Union. These transfers are covered by appropriate safeguards (Data Privacy Framework, standard contractual clauses) in accordance with the GDPR. Error reports (Sentry) are not transferred outside the European Union: the account we use is hosted in the European region (Frankfurt).
Your rights
You have the following rights:
Right of access: to obtain confirmation that data about you is processed and to receive a copy.
Right to rectification: to have inaccurate or incomplete data corrected.
Right to erasure: to ask for your data to be deleted, under the conditions set by law.
Right to object: to object to the processing of your data on legitimate grounds.
Right to restriction: to ask for processing to be restricted in the cases provided for by the GDPR.
Right to data portability: to receive your data in a structured, commonly used and machine-readable format.
Right to withdraw consent: at any time (cookies, push notifications).
To exercise your rights, write to us through our contact page. We answer within the time the GDPR sets: one month from receipt of the request, which may be extended by two months given its complexity or the number of requests, in which case we tell you so within the first month.
If you are not satisfied with our answer, you can lodge a complaint with the Data Protection Commission (DPC), the supervisory authority in Ireland: dataprotection.ie. As our business is established in France, our lead supervisory authority is the CNIL: cnil.fr.
Updates
This privacy policy may be changed at any time. The date of the latest update is shown at the top of this page.