Privacy policy

Last updated: 12 August 2026

We take the protection of your personal data seriously and are committed to processing it transparently and in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR), the French Data Protection Act (“Loi Informatique et Libertés”) and the recommendations of the French Data Protection Authority (CNIL).

We may update this Privacy Policy from time to time. We therefore encourage you to review it regularly.

1. Data Controller

The controller responsible for the processing of personal data in connection with Fred is:

[Full legal name of the company]
[Registered address]
[Company registration number, if applicable]
Email: [privacy/contact email]

Additional information about the company can be found in our Legal Notice.

2. Personal Data We Collect

Simply visiting our website does not require you to create an account or directly provide identifying information.

However, depending on how you interact with our website and services, we may collect the following categories of personal data:

Identification data, such as your first name and last name;
Contact information, such as your email address, telephone number and postal address;
Information you provide through our contact forms;
Information relating to your account when you create or use an account;
Technical information about your device and browser;
Browsing and usage information;
Cookie and similar technology identifiers;
Information relating to communications we send to you, including, where permitted, whether an email has been opened.

We do not intentionally collect special categories of personal data such as information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sexual orientation or sex life unless such processing is specifically required and legally permitted.

3. When We Collect Your Data

We may collect personal data when:

You browse our website;
You use Fred or our related services;
You create or manage an account;
You contact us through a form or another communication channel;
You subscribe to a newsletter or request information about our products or services;
You interact with emails that we send to you;
You provide your consent to specific processing activities.

4. Purposes and Legal Bases

We process personal data only when we have an appropriate legal basis.

Depending on the circumstances, your data may be processed to:

Provide and operate our services;
Manage your account;
Respond to your enquiries and support requests;
Perform a contract or take steps at your request before entering into a contract;
Ensure the security and proper functioning of our services;
Measure and improve the performance and usability of our website;
Produce statistics regarding the use of our website and services;
Send newsletters or commercial communications where permitted;
Measure interactions with commercial communications where permitted;
Comply with our legal and regulatory obligations.

The applicable legal basis may include:

Performance of a contract;
Compliance with a legal obligation;
Our legitimate interests, where those interests do not override your rights and freedoms;
Your consent, where consent is required.

Where processing is based on your consent, you may withdraw your consent at any time, without affecting the lawfulness of processing carried out before its withdrawal.

5. Email Tracking Pixels

Some emails sent by us may contain a tracking pixel, also known as an email tracking pixel.

A tracking pixel is generally a small invisible image embedded in an email. When the email is opened and the image is loaded, information may be transmitted to us or to the service provider used to send the communication.

Where enabled, this technology may allow us to determine information such as:

Whether an email has been opened;
The date and time at which it was opened;
Technical information associated with the device or email client;
The campaign or communication concerned;
An identifier associated with the recipient.

We currently use email and CRM tools, including Zoho, which may provide email-opening and engagement tracking functionality.

Why we use email tracking

Where permitted, email tracking may be used to:

Measure the effectiveness of our communications;
Produce statistics about email campaigns;
Understand whether our communications are relevant to recipients;
Improve the content and timing of future communications.

Consent

Where tracking pixels are used for purposes requiring consent, including certain marketing, profiling or individual engagement measurement activities, the tracking pixel will not be activated unless you have given your prior consent.

Refusing tracking will not prevent you from receiving communications that you have otherwise requested or are legally entitled to receive.

You may withdraw your consent at any time.

Withdrawal must be as easy as giving consent and will apply to future tracking.

Where technically applicable, you may manage your preferences through:

[Link to communication/privacy preferences]

or by contacting us at:

[privacy/contact email]

We may retain limited information concerning your choice in order to ensure that your preferences are respected.

6. Cookies and Other Trackers

Our website may use cookies and similar technologies.

Some cookies are strictly necessary for the operation of the website and do not require consent.

Other cookies or trackers, including certain analytics, advertising or personalisation technologies, are used only after obtaining your consent when required by law.

Depending on their purpose, cookies may be used to:

Enable essential website functionality;
Remember your preferences;
Maintain sessions and authentication;
Measure website traffic and performance;
Understand how visitors use our website;
Personalise content;
Measure advertising effectiveness.

Where consent is required, you can accept or refuse cookies through our cookie management interface.

Refusing non-essential cookies must not prevent access to the essential features of our website.

You can change or withdraw your choices at any time through:

[Cookie preferences link/button]

7. Commercial Communications

Where required by law, we send newsletters and marketing communications only after obtaining your consent.

You may unsubscribe at any time by:

Clicking the unsubscribe link included in our commercial emails;
Changing your communication preferences;
Contacting us at [privacy/contact email].

Unsubscribing from marketing communications does not prevent us from sending service-related, contractual, security or administrative communications where these communications are necessary.

8. Recipients of Personal Data

Your personal data may be accessed, where necessary, by:

Authorised personnel within our organisation;
Hosting and IT service providers;
CRM and email service providers, including Zoho where applicable;
Analytics providers;
Technical support providers;
Professional advisers;
Public authorities where disclosure is required by law.

Our service providers process personal data only for the purposes necessary to provide their services and in accordance with applicable contractual and data protection requirements.

We do not sell your personal data.

9. International Data Transfers

Some of our service providers may process personal data outside the European Economic Area.

Where such transfers take place, we implement appropriate safeguards required by applicable data protection legislation, which may include:

An adequacy decision adopted by the European Commission;
Standard Contractual Clauses approved by the European Commission;
Additional technical and organisational safeguards where necessary.

You may contact us for further information regarding the safeguards applicable to international transfers.

10. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected and in accordance with applicable legal requirements.

In particular:

Account-related data may be retained for the duration of the contractual relationship and, where appropriate, for the applicable statutory limitation periods;
Contact requests are retained for the time necessary to process the request and, where necessary, for evidentiary or litigation purposes;
Data concerning prospects used for commercial prospecting may generally be retained for up to 3 years from collection or from the last meaningful contact initiated by the prospect;
Customer data used for commercial prospecting may generally be retained during the commercial relationship and for up to 3 years after the end of that relationship;
Information relating to consent or objection may be retained for the period necessary to demonstrate compliance and respect your preferences;
Cookie and tracking data are retained in accordance with applicable legal requirements and the retention periods communicated through our cookie management interface.

At the end of the applicable retention period, personal data is deleted or anonymised unless further retention is required by law or necessary for the establishment, exercise or defence of legal claims.

11. Your Rights

Under the GDPR and French data protection legislation, depending on the processing concerned, you may have the right to:

Access your personal data;
Rectify inaccurate or incomplete personal data;
Request deletion of your personal data;
Request restriction of processing;
Object to certain processing;
Withdraw your consent at any time;
Request portability of your personal data where applicable;
Define instructions concerning the use of your personal data after your death, under the conditions provided by French law.

You may exercise your rights by contacting:

[privacy/contact email]

or:

[Postal address]

We may request reasonable information necessary to verify your identity where appropriate.

We will respond to requests within the time limits required by applicable law.

12. Right to Lodge a Complaint

If you believe that your personal data is being processed in violation of applicable data protection legislation, you have the right to lodge a complaint with the French supervisory authority:

Commission Nationale de l’Informatique et des Libertés (CNIL)

You may consult the CNIL website for further information regarding your rights and how to submit a complaint.

13. Security

We implement appropriate technical and organisational measures designed to protect personal data against:

Unauthorised access;
Accidental or unlawful destruction;
Loss;
Alteration;
Disclosure;
Other unlawful processing.

Access to personal data is restricted to persons who need it to perform their duties.

14. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to our services, technologies, legal requirements or data processing practices.

The date of the latest version is displayed at the top of this page.

Where a change materially affects how we process your personal data, we may provide additional information or request a new consent where required by law.