Controller
Taner OKUR, sole trader under French law (entrepreneur individuel, EI)
Trading name: OLHYN
SIRET: 793 428 715 000 31
RCS Pontoise 793 428 715
Registered office: Villiers-le-Bel (95400), France
Contact: through our contact page
As a business established in France, we are subject to the EU General Data Protection Regulation (GDPR) and the French Data Protection Act (loi Informatique et Libertés), which applies in Germany as in every EU member state, and our lead supervisory authority is the French CNIL.
Data collected
The website collects information 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). Activated only after your explicit consent through the cookie banner.
Behavioural analysis (Microsoft Clarity through Google Tag Manager): pseudonymised session recordings and heatmaps to understand how the site is used (movements, clicks, scrolling). Activated only after your explicit consent through the cookie banner.
Technical 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 stored with our hosting provider. No personal data (name, email) is associated with this identifier.
Booking a call (cal.eu): when you book, your name, email address and any message are processed by the cal.eu booking tool, published by Cal.com, under its own privacy policy.
Contact by email: the information you choose to send us by email (name, email address, content of the message) is used 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 calculated to limit abuse, together with an anti-bot check. Every comment is reviewed manually 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.
Map (Google Maps): the French pages presenting a local service area 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. The pages for Germany show no map.
Business relationship management: when you contact us or become a client, your contact details and the history of our exchanges are kept in a customer relationship management 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 attached to your record. This information does not come from your browsing on this site: it is what you give us in the course of our business relationship.
Audience measurement of our site builder: our free French-language site builder uses Cloudflare Web Analytics, which counts page views without cookies, without advertising identifiers and without cross-site tracking. No data there is linked to a person.
Why we use it, and on what basis
Consent: audience measurement (Google Analytics and Microsoft Clarity cookies), map display (Google Maps), push notifications, posting a comment. These tools stay off until you switch them on, and you can withdraw your consent at any time.
Legitimate interest: website security, anonymous visit measurement (Cloudflare Web Analytics), technical error monitoring (Sentry), prevention of abuse on comments and likes (IP fingerprint, anti-bot check), and follow-up of the business relationship with our prospects and clients in our management tool.
Performance of a contract: booking a call, answering contact requests.
We use your information only for the purposes stated here.
Cookies
This website uses the following cookies:
Strictly necessary cookies: storing your cookie consent choice. No consent 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.
Technical error monitoring (Sentry) and visit measurement (Cloudflare Web Analytics) set no cookie and work independently of cookie consent. Apart from the cookies listed above, no other tracker is placed in your browser. This is the approach required by the ePrivacy Directive, transposed in Germany by section 25 of the TDDDG: storing or reading information on your device requires your consent unless it is strictly necessary for the service you asked for.
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.
Technical 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 for 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 technical 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 legal retention periods.
Emails attached to your record: kept under the same conditions as the record they relate to.
Where your data goes
Your data is processed in the European Union: our business is in France, and our internal management tools are hosted by Oracle Corporation on a server located in Paris.
Some data may be transferred to the United States through the following providers:
Cloudflare, Inc.: website hosting, 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: audience measurement through Google Analytics and maps through Google Maps. Google participates in the EU-US Data Privacy Framework.
Microsoft Corporation: behavioural analysis through Microsoft Clarity. Microsoft participates in the EU-US Data Privacy Framework.
Cal.com, Inc., publisher of the cal.eu booking tool: 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.
These transfers are covered by appropriate safeguards (Data Privacy Framework, standard contractual clauses) in accordance with the GDPR. Technical error reports (Sentry) are not transferred outside the European Union: the account used is hosted in the European region (Frankfurt).
Your rights and recourse
Under the GDPR and the French Data Protection Act, you have the following rights:
Right of access: obtain confirmation that data concerning you is processed and receive a copy.
Right to rectification: have inaccurate or incomplete data corrected.
Right to erasure: request the deletion of your data under the conditions provided by law.
Right to object: object to the processing of your data on grounds relating to your situation.
Right to data portability: receive your data in a structured, machine-readable format.
Right to withdraw consent: withdraw your consent at any time (cookies, push notifications).
To exercise your rights, write to us through our contact page: we answer within the time limit set by the applicable law.
If you believe your rights have not been respected, you may lodge a complaint with a supervisory authority, in particular in the EU member state where you live or work, as provided by Article 77 of the GDPR. In Germany, that is the data protection authority of your federal state (Land); the Federal Commissioner for Data Protection and Freedom of Information (bfdi.bund.de) can direct you to it. You may also contact the CNIL (cnil.fr), the supervisory authority in France where we are established.
Updates
This privacy policy may be amended at any time. The date of the last update is shown at the top of this page.