Data controller
The controller is Halcyon Enterprise, 24 rue de Clichy, 75009 Paris, France. For any question about this policy or about your data, contact contact@halcyon.paris or call +33 7 80 90 87 37.
No data protection officer has been appointed. Requests are handled by the director of publication.
What we collect
We only collect what you give us and what the site technically needs to run. Specifically:
- Contact form: your name, your email address and the content of your message.
- Technical data: IP address, browser type and pages requested, recorded in server logs by our host for security and troubleshooting.
- Cookie preference: your consent choice, stored locally in your browser.
Why we process it, and on what basis
- Answering your enquiry
- Legal basis: our legitimate interest in responding to someone who has contacted us (GDPR Art. 6(1)(f)), and the performance of a contract or pre-contractual steps where relevant (Art. 6(1)(b)).
- Site security and stability
- Legal basis: legitimate interest in keeping the service available and protecting it from abuse (Art. 6(1)(f)).
- Audience measurement
- Legal basis: your consent (Art. 6(1)(a)). Refusing costs you no functionality, and measurement is not active unless you accept it.
Who has access
Your data is accessible to the group’s staff who need it to reply to you. We also use the following processors:
- Railway Corporation: hosting and server logs. Data may be processed outside the European Union.
- Resend, Inc.: transactional email delivery for messages sent through the contact form.
Transfers outside the EU
Some of our processors are established in the United States. Such transfers are covered by the European Commission’s Standard Contractual Clauses and, where applicable, the processor’s certification under the EU-US Data Privacy Framework. You may request a copy of the safeguards in place.
How long we keep it
- Contact form messages
- Up to 3 years from our last exchange with you, then deleted.
- Server logs
- Up to 12 months, in line with our host’s retention.
- Cookie preference
- Up to 6 months, in line with the CNIL recommendation, after which you are asked again.
Your rights
Under the GDPR you have the right of access, rectification, erasure, restriction of processing, objection, and data portability, as well as the right to withdraw consent at any time where processing is based on consent.
To exercise any of these, write to contact@halcyon.paris. We reply within one month. You may be asked to confirm your identity if there is reasonable doubt about it.
If you consider that your rights are not respected, you may lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, or at cnil.fr.
Automated decisions
We do not carry out automated decision-making or profiling that produces legal effects concerning you.
Children
This site is aimed at professionals. We do not knowingly collect data from anyone under 15.
Changes
We may update this policy. The date below records the current version, and any substantial change will be reflected here.