DIGICAL PRIVACY POLICY

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Effective Date: 01/09/2026

Last Updated: 01/09/2026 — Supersedes version dated 06/06/2023

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This privacy policy describes how Digical ("Digical," "we," "us," "our") collects, uses, and discloses personal information when you visit digical.fr (the "Site"), engage us for consulting services, or otherwise interact with us. It describes our practices as a data controller of website, marketing, and business-contact information. Where Digical processes personal data on behalf of a client during a consulting engagement, we act as a data processor under a separate Data Processing Addendum, governed by our Terms & Conditions §12 and the DPA itself, not by this policy.

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1. Personal Information We Collect

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Device and site-usage information. Web browser version, IP address, time zone, cookie data, pages and content you view, search terms, and how you interact with the Site. Collected automatically via cookies, log files, and pixels when you access the Site. Used to load the Site correctly and to analyze and improve it. Shared with our hosting subprocessor, Wix.com.

Business contact and engagement information. Name, company, billing address, email address, phone number, and payment details (processed via Stripe or bank transfer; see our Terms §4.3). Collected directly from you when you request a proposal, sign an Order Form/SOW, or are invoiced. Used to deliver the services you've contracted for, process payment, issue invoices, communicate about the engagement, screen for fraud, and, where consistent with your preferences, share relevant product or service updates. Shared with Wix (billing/checkout infrastructure) and, for payment processing, Stripe.

Customer support information. Name, contact details, and engagement/account details. Collected directly from you when you contact us for support. Used to respond to your request. Shared with Wix.

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2. Minors

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The Site and our services are intended for business use by adults acting on behalf of an organization. We do not knowingly collect personal information from anyone under 18. If you believe a child has provided us personal information, contact us at the address below to request deletion.

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3. Our Role: Controller vs. Processor

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For website, marketing, and business-contact data described above, Digical is the data controller. Separately, where our consulting engagements involve us processing a client's own customer or business data (for example, implementing a client's CRM or automation workflows), Digical acts as a data processor on that client's documented instructions, under the Data Processing Addendum referenced in our Terms & Conditions §12.2. That processing is governed by the DPA and the client's own privacy commitments to their customers, not by this policy.

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4. Sharing of Personal Information

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We share personal information with service providers who help us run the Site and deliver our services, including: Wix (site hosting and infrastructure), Stripe (payment processing), and Google, LinkedIn, and Facebook/Meta (analytics and advertising, see §6). Our current subprocessor list is maintained at digical.fr/subprocessors. We may also disclose personal information to comply with law, respond to a subpoena or legal request, or protect our rights.

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5. Use of Personal Information

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We use personal information to deliver our consulting services, process payments and invoicing, respond to inquiries, maintain the security of the Site, and, where consistent with your preferences, share relevant updates about our services.

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6. Behavioral Advertising and Analytics

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We use Google Analytics to understand how visitors use the Site. Learn more or opt out at https://policies.google.com/privacy and https://tools.google.com/dlpage/gaoptout. We share information about your Site use and interaction with our ads with advertising partners including Google, LinkedIn, and Facebook/Meta, directly and via cookies. Learn more about how online advertising works at the Network Advertising Initiative: http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising directly: Facebook (https://www.facebook.com/settings/?tab=ads), Google (https://www.google.com/settings/ads/anonymous), Bing (https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads), or via the Digital Advertising Alliance portal (http://optout.aboutads.info/).

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7. Sale of Personal Information

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We do not sell personal information as defined by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act ("CCPA/CPRA").

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8. Legal Basis for Processing (GDPR)

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For residents of the European Economic Area, we process personal information under one or more of the following legal bases: your consent; performance of a contract with you; compliance with our legal obligations; protection of vital interests; performance of a task in the public interest; or our legitimate interests, where these do not override your rights and freedoms.

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9. Retention

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We retain personal information for as long as necessary to provide our services and for our legitimate business records, unless you request deletion (see §11). Invoices and accounting records are retained for 10 years as required under French law. Client data processed under a DPA is retained and deleted per that DPA and our Terms §12.5.

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10. Automated Decision-Making

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We do not engage in fully automated decision-making that produces a legal or similarly significant effect on you. Our hosting/payments provider Wix applies limited automated fraud-prevention measures (for example, temporary blocklisting of IP addresses or cards associated with repeated failed transactions, lasting hours to a few days) that do not have a legal or similarly significant effect on you.

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11. Your Rights

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GDPR (EEA residents): You have the right to access, correct, update, delete, or receive a portable copy of your personal information. Contact us at the address below to exercise these rights. Where personal information is transferred outside the EEA (including to the US or Canada via our subprocessors), such transfers are made under Standard Contractual Clauses or, where applicable, the EU-US Data Privacy Framework. See Wix's GDPR documentation at https://help.wix.com/en/manual/your-account/privacy/GDPR.

CCPA/CPRA (California residents): You have the right to know what personal information we hold, and to request access, correction, deletion, or to designate an authorized agent to act on your behalf. Contact us at the address below.

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12. Cookies

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We use functional, performance, advertising, and social-media/content cookies to operate the Site, remember your preferences, and understand how the Site is used. You can manage cookie preferences through your browser or, where offered, the Site's cookie banner.

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13. Do Not Track

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Because there is no consistent industry standard for responding to "Do Not Track" browser signals, we do not currently alter our data practices in response to them.

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14. Changes to This Policy

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We may update this policy from time to time to reflect changes in our practices or for legal, regulatory, or operational reasons. Material changes will be posted here with an updated effective date.

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15. Contact

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Digical, 141 avenue Félix Faure, 75015 Paris, France
Email: hello@digical.fr

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If you are not satisfied with our response to a complaint, you have the right to lodge a complaint with your local data protection authority (in France, the CNIL).