Data controller
FRADECO SAS
50, rue Chapon, 75003 Paris, France
Telephone: +33 1 40 09 13 77
Email: contact@fradeco.fr
Represented by Susanne Wiener, présidente.
Scope of processing
FRADECO provides its services to businesses. This site is addressed neither to private individuals nor to minors. Only the data required for the purpose stated in each case is collected. No personal data is sold. Data is passed on for advertising purposes only with your consent, as described below.
Visiting the site
Each page request is logged with the following data: IP address, date and time, page requested, referring page, browser type and operating system.
Purpose: operation and security of the site.
Legal basis: legitimate interest, Article 6(1)(f) GDPR.
Retention: seven days. The logs are then deleted automatically by the host.
Contact form
The data transmitted comprises name, email address, company, telephone number (optional), subject and message. The consent given is stored together with the enquiry. The form data is also kept in the website’s database, together with the page visited.
Purpose: handling and answering your enquiry.
Legal basis: pre-contractual steps, Article 6(1)(b) GDPR. For enquiries that do not lead to a contract, legitimate interest under Article 6(1)(f) GDPR.
Retention: three years from the last contact. If the enquiry leads to an engagement, the data becomes part of the client file and is subject to the retention periods applicable to it.
Without this data the enquiry cannot be processed.
Needs check
The needs check on the home page records the situation and the topics you select and transmits both with the form. The form data is also stored in the website’s database, together with the page visited. A selection that is not submitted does not leave your browser.
The purpose, legal basis and retention period correspond to those of the contact form.
Booking an appointment
When you book a call, the name, email address, company, telephone number, language, subject and page visited are transmitted and stored in the website’s database. The call takes place as a video conference through Microsoft Teams. Confirmation is sent by email.
Purpose: arranging and holding the call.
Legal basis: pre-contractual steps, Article 6(1)(b) GDPR.
Retention: three years from the last contact. If the call leads to an engagement, the data becomes part of the client file.
Without a name and an email address the appointment cannot be booked.
Applications
The application form transmits name, email address, telephone number, earliest starting date, area of interest and message, together with the documents attached. These documents are sent with the email and then deleted from the site server. The other form data is also kept in the website’s database, together with the page visited.
Purpose: assessment of your application.
Legal basis: pre-contractual steps, Article 6(1)(b) GDPR.
Retention: three years from the last contact. Retention beyond that period takes place only with your express consent, which you may withdraw at any time.
Cookies and trackers
Trackers strictly necessary for the operation of the site are set without consent. All other trackers are set only after your consent has been obtained for the purpose concerned. Consent is obtained through the site’s own consent window, without a third-party provider. It may be withdrawn at any time with effect for the future.
Further detail is set out on the cookie settings page.
Storage of your choice
Your choice is stored on your device in the cookie fdc_einwilligung for six months. A refusal is stored without an identifier. If you give consent, the cookie also receives a random identifier, and the site stores in its database that identifier, the date and time, the version of the text displayed, the purposes accepted, the language and the page visited. Any later change or withdrawal is stored in the same way. Neither the IP address nor browser characteristics are stored.
Purpose: proof of consent.
Legal basis: legal obligation, Article 6(1)(c) GDPR in conjunction with Article 7(1) GDPR.
Retention: three years, followed by automatic deletion.
Audience measurement and advertising
This site uses Google Analytics to analyse how its pages are used, and Google Ads to measure the performance of advertising and to show personalised ads on other websites to people who have already visited the site. Each of these three purposes is pursued only after your consent to that purpose has been obtained.
The exemption from the consent requirement under article 82 de la loi n° 78-17 du 6 janvier 1978 applies, under the CNIL position, only where the provider processes the data solely on behalf of the site operator and produces nothing but anonymous statistics from it. That condition is not met here, as Google also processes the data for its own purposes.
The data processed comprises an identifier for your device, your IP address, the pages requested, the origin and duration of the visit and events triggered, such as the submission of a form.
When you send an enquiry or book a call, the email address and, if provided, the telephone number entered are also transmitted to Google in hashed, that is pseudonymised, form, so that Google can attribute the enquiry to an ad. This takes place only with your consent to ad measurement.
Purpose: improvement of the site, assessment of advertising performance and personalised advertising.
Legal basis: consent, Article 6(1)(a) GDPR and article 82 de la loi n° 78-17 du 6 janvier 1978.
Retention: the lifetime of the trackers is limited to thirteen months and is not extended by a further visit. The analysis data collected is retained for no more than twenty-five months. Both periods correspond to the CNIL recommendation.
Recipient: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
For Google Analytics and the hashed transmission of enquiries (enhanced conversions), Google acts as a processor under the Google Ads Data Processing Terms. For ad measurement and personalised advertising in Google Ads, Google acts as an independent controller, subject to Google’s privacy policy.
Consent may be withdrawn at any time through the “Cookie settings” link at the bottom of every page. The lawfulness of the processing carried out up to the withdrawal remains unaffected.
Google tag
Google Analytics and Google Ads are integrated by means of the Google tag (gtag.js), likewise a service of Google Ireland Limited. It is loaded only after your consent has been obtained and sets only the trackers of the purposes you have accepted. No data is transmitted to Google before that point.
Legal basis: consent, Article 6(1)(a) GDPR. The consent covers the Google tag and the service it loads and may be withdrawn for both together.
Recipients and processors
The data is accessible to those members of the firm who handle your enquiry. The following processors are also involved:
- ALL-INKL.COM – Neue Medien Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany, for hosting the site and delivering its email
- Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland, for the email mailbox and Microsoft Teams
- Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, for audience measurement and enhanced conversions
Each processor is bound by a contract under Article 28 GDPR. For ad measurement and personalised advertising, Google Ireland Limited acts as an independent controller (see “Audience measurement and advertising”).
Transfers outside the European Union
Hosting, including the storage of consent records, and email delivery take place in Germany. To that extent no data is processed outside the European Union.
Google may transfer the data collected through the services named above to Google LLC in the United States. The transfer is based on the European Commission’s adequacy decision of 10 July 2023 on the EU-US Data Privacy Framework, to the extent that the recipient is certified under it, and additionally on the European Commission’s standard contractual clauses. Without your consent, no such transfer takes place.
Microsoft may transfer data to group companies in the United States. The basis is the adequacy decision of 10 July 2023 on the EU-US Data Privacy Framework, to the extent that the recipient is certified, and additionally the standard contractual clauses.
Location of backups: Germany, and therefore within the European Union.
Your rights
In respect of your personal data you have the following rights: access, rectification, erasure, restriction of processing, objection, data portability. Where processing is based on your consent, you may withdraw it at any time with effect for the future. The lawfulness of the processing carried out up to that point remains unaffected.
French law further allows you to issue directions as to the treatment of your data after your death, under article 85 de la loi n° 78-17 du 6 janvier 1978.
Requests should be addressed to contact@fradeco.fr. A reply will be provided within one month.
Right to lodge a complaint
If you consider that your data is not being processed lawfully, you have the right to lodge a complaint with the French supervisory authority, the Commission nationale de l’informatique et des libertés:
CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France
www.cnil.fr
Security of processing
The site is served exclusively over HTTPS. Data transmitted through the forms is encrypted in transit. Access to the data is restricted to those persons who require it in order to perform their tasks.
Version and amendments
This privacy policy is amended whenever the site or the processing described above changes. Version of 11 October 2026.