Privacy Policy

Last updated: January 15, 2025

This Privacy Policy explains how Axiom Analytics SAS ("we", "us", "our") collects, uses, and protects your personal data when you use the Axiom platform ("Service"). We process personal data in accordance with the EU General Data Protection Regulation (GDPR) (Regulation 2016/679).

1. Data Controller

The data controller responsible for your personal data is:

Company name	Axiom Analytics SAS
Legal form	Société par actions simplifiée (SAS)
Registered address	12 Rue du Faubourg Saint-Antoine, 75011 Paris, France
Email	legal@axiom-analytics.fr
EU Representative	Not applicable — data controller is established in France (EU)

For data protection enquiries or to exercise your rights, contact us at: privacy@axiom-analytics.fr

2. Personal Data We Collect

2.1 Data you provide

Access credentials — your access code and password (stored as a cryptographic hash; we cannot read your plain-text password)
Telegram handle — if you contact us via Telegram, we receive your public Telegram username

2.2 Data collected automatically

Visit data — IP address, browser type, referring URL, pages visited, timestamps
Game session data — which AI tools you used and when (for access-tier management and service improvement)
Access code linkage — your access code is associated with a referring campaign for internal analytics

2.3 Data from third parties (with your consent only)

Meta Pixel — if you consent to marketing cookies, Meta Platforms Ireland Ltd. may collect browsing behaviour for advertising purposes. See Section 6 for details.

3. Legal Basis for Processing

Processing activity	Legal basis (GDPR Art. 6)
Account authentication and game access	Performance of contract (Art. 6(1)(b))
Visit logging and security monitoring	Legitimate interest — fraud prevention and platform security (Art. 6(1)(f))
Internal campaign analytics (access code attribution)	Legitimate interest — understanding acquisition channels (Art. 6(1)(f))
Meta Pixel (marketing cookies)	Consent (Art. 6(1)(a)) — only loaded after you accept marketing cookies

4. Cookies and Tracking Technologies

We use a cookie consent banner to give you control over non-essential cookies. You can change your preferences at any time via the "Cookie Settings" link in the footer.

Category	Purpose	Consent required?	Examples
Strictly necessary	Session management, security, storing your cookie preferences	No	`axiom_cookie_consent`
Marketing	Advertising attribution, retargeting via Meta Pixel	Yes — opt-in	Meta Pixel cookies (`_fbp`, `_fbc`)

Marketing cookies are not set until you actively accept them. Rejecting them has no effect on your ability to use the Service.

5. Third-Party Data Processors

We engage the following processors under written Data Processing Agreements (DPA):

Processor	Purpose	Country
OVHcloud SAS	Website hosting and server infrastructure	France
Meta Platforms Ireland Ltd.	Marketing analytics via Meta Pixel (only with consent)	Ireland / USA
Telegram Messenger Inc.	User-initiated communication channel (we do not share data proactively)	USA

6. International Data Transfers

Some processors are located outside the EU/EEA. Transfers are protected by:

Meta Platforms (USA) — Meta is certified under the EU–U.S. Data Privacy Framework, which provides an adequacy decision under GDPR.
Telegram (USA) — transfers are covered by Standard Contractual Clauses (SCCs) as approved by the European Commission.
OVHcloud SAS — processed entirely within the EEA (OVHcloud data centres in France and Germany); no international transfer.

7. Data Retention

Data category	Retention period
Account credentials	Duration of active subscription + 30 days after termination
Visit and session logs	90 days, then automatically deleted
Cookie consent records	13 months from consent date
Campaign attribution data	12 months

8. Your Rights Under GDPR

As a data subject in the EU/EEA, you have the following rights:

Right of access (Art. 15) — obtain a copy of all personal data we hold about you
Right to rectification (Art. 16) — correct inaccurate or incomplete data
Right to erasure (Art. 17) — request deletion of your data ("right to be forgotten"), where legally permitted
Right to restriction (Art. 18) — temporarily pause processing while a dispute is resolved
Right to data portability (Art. 20) — receive your data in a structured, machine-readable format
Right to object (Art. 21) — object to processing based on legitimate interests; absolute right to object to direct marketing
Rights related to automated decision-making (Art. 22) — we do not make solely automated decisions that produce legal or similarly significant effects
Right to withdraw consent — withdraw any consent at any time (e.g., via Cookie Settings in the footer). Withdrawal does not affect the lawfulness of prior processing.

To exercise any right, send a request to privacy@axiom-analytics.fr. We will respond within 30 days (extendable to 3 months for complex requests). We may ask you to verify your identity before processing the request.

You also have the right to lodge a complaint with your national data protection supervisory authority. A list of EU supervisory authorities is available at edpb.europa.eu.

9. Security

We implement appropriate technical and organisational measures to protect your personal data, including TLS encryption for data in transit, hashed password storage, and access controls limited to authorised personnel.

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and, where required, notify affected individuals without undue delay.

10. Minors

The Service is intended for users aged 18 and over. We do not knowingly collect personal data from individuals under 18. If you believe we have inadvertently collected such data, please contact us and we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will indicate the date of the last update at the top of this page. For material changes, we will provide reasonable notice. Continued use of the Service after the effective date constitutes acceptance of the updated policy.

12. Contact Us

For any privacy-related questions or to exercise your data subject rights:

Email: privacy@axiom-analytics.fr
Postal address: 12 Rue du Faubourg Saint-Antoine, 75011 Paris, France