Privacy Policy

Last updated: 21-10-2026

Courtesy translation – working draft – the French version prevails

Preamble

This Privacy Policy is addressed to the Users of the platform distributed as SaaS "DataXtrak" (hereinafter the "Platform") and of the VISIONARY TECH website accessible at the following URL: https://visionary-tech.fr/ (hereinafter the "Site"), published by Cristella HARSINGH (VISIONARY TECH). The purpose of this document is to inform you of how we collect and process your personal information.

Respect for privacy and for personal data is a priority for VISIONARY TECH, which is why we undertake to Process such data in the strictest compliance with the French Data Protection Act (Loi Informatique et Libertés) of 6 January 1978, as amended (hereinafter the "Loi IEL"), and with Regulation (EU) 2016/679, the General Data Protection Regulation of 27 April 2016 (hereinafter the "GDPR").

In any event, we undertake to respect the following two essential principles:

Each User remains in control of their personal data;
Personal data is Processed in a transparent, confidential and secure manner.

Article 1. Definitions

For the purposes of this Privacy Policy, the following terms, in the singular as in the plural, shall have the following meanings:

"Customer": any natural or legal person who has subscribed to one of the paid subscriptions offered by VISIONARY TECH under the Contract, in order to benefit from the features of the Platform;
"Contract": all of the contractual terms governing the relationship between the Customer and VISIONARY TECH, intended to govern the use of the Platform by Users and Customers.
"Account": the interface hosted on the Platform in which all the data provided by the Customer and the User is brought together, and which allows them to access the Platform. The Account is accessed by means of credentials of which the Customer has custody.
"Personal data" or "Personal Data": any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to their physical, economic, cultural or social identity.
"Processing/Process": any of the operations referred to in Article 4(2) of the GDPR, carried out on Personal data in the context of the performance of this Privacy Policy.
"User": any person who accesses and browses the Platform, whether a Customer or a user authorised by the Customer, and/or any person who accesses the Site, whether a Customer, a user authorised by the Customer or a mere internet user.

Article 2. Identity of the controller

In connection with the provision of the Platform and the Site, VISIONARY TECH, as identified below, will act towards you as the "Controller" within the meaning of the GDPR.

HARSINGH CRISTELLA (VISIONARYTECH), sole trader (Entrepreneur individuel), registered under SIREN number 943 216 465, having its registered office at 1050 Avenue du Mondial 98 – 34000 MONTPELLIER.

contact@visionary-tech.fr
https://visionary-tech.fr/

Legal reminder:

The controller is, within the meaning of the French Data Protection Act and the GDPR, the person who determines the means and purposes of the processing. Where two or more controllers jointly determine the purposes and means of the processing, they are joint controllers (or co-controllers).

The processor is a person who processes personal data on behalf of the controller; it acts under the authority of the controller and on its instructions.

Article 3. How do we collect your data?

As a matter of principle, all Personal data concerning you is collected directly from you.

For example, when you register, when you create an Account, when you log in and during our various exchanges (online requests, letters, telephone calls, etc.).

In all cases, you are informed of the purposes for which your Personal data is collected by us.

Article 4. What are the purposes and legal bases of the processing we rely on?

We only collect the Personal data necessary for the explicit and specified purposes set out below:

Purposes	Details of the purposes pursued	Legal bases
Administration of the Platform and the Site	General administration of the Platform and the Site; Carrying out corrective and evolutive maintenance operations; General management of the security of the Platform and the Site; Placing of cookies and other trackers necessary for the proper functioning of the Platform and the Site.	Our legitimate interest in providing a functional Platform and Site.
Provision and performance of the features of the Platform	Receipt and storage of documents; Automatic extraction of their content; Structuring and consultation of databases; Export and sending of results.	Performance of the contract, the Processing being necessary for the performance of the contract where the Customer is a natural person acting as a consumer and carrying out processing falling within the household exemption.
Creation and management of Accounts and workspaces	Management of requests to create, modify, suspend and delete an Account; Management of roles and access.	Performance of the contract, the Processing being necessary for the performance of a contract or for pre-contractual measures.
Customer relationship follow-up	Handling of information requests; Management of pre-litigation and litigation; Follow-up of requests.	Our legitimate interest in responding to your requests and in defending the interests of VISIONARY TECH.
Commercial prospecting actions	Prospecting aimed at professionals and consumers; Animation of the Platform, the Site and social networks (community management); Organisation of events; Production of statistics on marketing operations.	Our legitimate interest in offering you deals as part of our commercial development. You may object at any time to such mailings via the dedicated unsubscribe links. Consent where the commercial prospecting actions are aimed at consumers.
Invoicing management	Payment follow-up; Management of unpaid amounts.	Performance of the contract, the Processing being necessary for the performance of a contract.
Keeping of accounts	Keeping of accounting records and legal supporting documents	Our legal obligations to retain accounting and tax data
Personalisation of the User experience	Placing of cookies and other trackers in order to analyse your use of the Platform and the Site; Statistical analyses of your use.	Your consent.
Management of requests to exercise rights	Follow-up of the processing of requests; Carrying out operations on your data in connection with the requests addressed to us	Our legal obligations arising from Articles 15 et seq. of the GDPR and the Loi IEL.

Where the legal basis relied upon is the pursuit of a legitimate interest, you may, on simple request, obtain additional information relating to the balancing of interests.

Article 5. What types of data are collected?

The mandatory or optional nature of the Personal data collected and the possible consequences of a failure to reply are indicated during the various contacts with Users.

You can consult below the details of the Personal data that we are likely to collect:

Processing	Types of personal data collected
Administration of the Platform and the Site	Information associated with the Account; Connection logs, device identification data, data on use of the Platform and API and history of actions on the Platform and the Site; Data collected via cookies and other "technical" trackers; Statistics.
Provision and performance of the features of the Platform	Imported content: documents and spreadsheets imported by the Customer, and the data they contain, whether concerning the Customer or third parties; Generated data: information extracted from documents, databases, records, summaries and exports produced by means of the Platform; Sending data: e-mail address of the recipients of exports and content of the items sent from the Platform; Associated technical data: account identifier, date and time of imports, extractions and exports, operation logs.
Creation and management of Accounts and workspaces	Identity (surname, first name), professional e-mail address, login credentials, assigned role, names of workspaces, account settings; Connection logs, device identification data, data on use of the Platform, the Site and API and history of actions on the Platform and the Site; Data collected via cookies and other "technical" trackers; Statistics.
Customer relationship follow-up	Information associated with the data subject (title, surname, first name, e-mail, postal address, customer number, telephone number); Data necessary for carrying out loyalty, prospecting, study, survey, product testing and promotion actions; Information relating to the request; Statistics.
Commercial prospecting actions	Data relating to the identity of the User; Postal contact details of the User; Information relating to the organisation of events; Statistics.
Invoicing management	Financial information related to the subscription to the Platform; Payment data, namely data relating to the means of payment used in the event of a subscription (RIP or RIB [bank details], information on transfers, information on payments by bank card, etc.) In the event of a one-off payment by bank card, the cryptogram is deleted as soon as the transaction is completed. Data relating to discounts, receipts, balances, etc. Data relating to the issuing and settlement of invoices: payment terms, discounts granted, receipts, balances and unpaid amounts.
Keeping of accounts	Accounting information and legal supporting documents;
Personalisation of the User experience	Connection logs; Data relating to the use of the Site and the Platform.
Management of requests to exercise rights	Data relating to the identity of the User: title, surname, first names, address, telephone number, e-mail addresses, customer number, date of birth. Proof of identity may be retained for the purpose of evidencing the exercise of a right of access, rectification or objection or to meet a legal obligation Data relating to your request to exercise your rights

The details of the information provided below are not intended to be exhaustive and are primarily intended to inform you of the categories of Personal data that VISIONARY TECH is likely to Process. In any event, VISIONARY TECH undertakes to Process all Personal data collected in accordance with the GDPR and the Loi IEL.

Where the collection of this information is regulatory or contractual in nature, where it is a condition of entering into a contract or where there is an obligation to provide the information, we will indicate this by a mention such as "*" at the time of collection.

Failure to provide this information could lead VISIONARY TECH to terminate or to refuse you access to the Site and the Platform, and, where applicable, to hold you liable.

Article 6. Who can access your Personal Data?

Within the limits of their respective duties and for the purposes set out above, the main persons likely to have access to your Personal data are as follows:

Authorised personnel of VISIONARY TECH;
Where applicable, authorised personnel of VISIONARY TECH's processors: the hosting provider of the Platform and the Site, the PVC card provider, the provider of the general-purpose AI model, etc.;
Where applicable, third parties involved in invoicing operations: banks, Payment Service Provider, Approved Platform (Plateforme Agréée);
Where applicable, the relevant courts, mediators, chartered accountants, statutory auditors, lawyers, bailiffs (huissiers), debt collection companies, police or gendarmerie authorities in the event of theft or judicial requisition, as well as in the context of searching for the perpetrators of offences committed on the internet;
Where applicable, third parties likely to place "commercial" cookies on your devices when you consent to this.

Your Personal data is not communicated, exchanged, sold or rented to any person other than those mentioned above without your express and prior consent and in accordance with the applicable legal and regulatory provisions.

Article 7. How long do we keep your personal data?

We keep your Personal data only for the time necessary for the purposes pursued, as summarised in the table below:

Processing	Retention period
Administration of the Platform and the Site	Throughout the duration of the contractual relationship, then storage as intermediate archive for the limitation period in force, i.e. five (5) years for evidentiary purposes. Retention of connection logs and history of actions for a period not exceeding twelve (12) months.
Provision and performance of the features of the Platform	The data is retained until it is deleted by the Customer and at the latest until the end of the contractual relationship. For extracted data, databases, records and summaries, at the end of the contractual relationship, they are retained for the transitional period (30 days) and the recovery period (30 days) provided for reversibility, then deleted. Data transmitted to the provider of the general-purpose AI model is deleted as soon as the extraction is completed. At the end of the contract, the history of operations carried out on the Platform and the technical logs necessary to prove its performance are retained as intermediate archive for five (5) years, the general-law limitation period (Article 2224 of the French Civil Code).
Creation and management of Accounts and workspaces	Throughout the duration of the Account or on expiry of a period of two (2) years) during which the Account has remained inactive. On closure of a workspace, the related data is permanently and irreversibly deleted within a period of thirty (30) days.
Customer relationship follow-up	Throughout the duration of the contractual relationship, then storage as intermediate archive for the limitation period in force, five (5) years for evidentiary purposes.
Commercial prospecting actions	Until the right to object is exercised or for a period not exceeding three (3) years from your last contact with VISIONARY TECH.
Invoicing management	Deletion of payment information once the transaction is completed. Retention of information relating to payment (payment, subscription, etc.) throughout the duration of the contractual relationship, then storage as intermediate archive for a period of five (5) years for evidentiary purposes.
Keeping of accounts	In the form of intermediate archive: legal retention period (e.g. accounting obligation of 10 years). The identity document is retained for the time necessary to verify the identity of the data subject. A copy of an identity document may be retained for a period of six (6) years if this is necessary for evidentiary purposes or to meet a legal obligation
Personalisation of the User experience	For a maximum period of twelve (12) months.
Management of requests to exercise rights	Personal data relating to the management of rights requests is retained for as long as necessary to Process the request, then stored as intermediate archive for the applicable criminal limitation period, namely six (6) years (Art. 8 of the French Code of Criminal Procedure).

Article 8. What are your rights?

In accordance with the Loi IEL and the GDPR, you have several rights relating to your Personal data:

Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the Processing carried out prior to the withdrawal (Article 13-2c of the GDPR);
Right to define what happens to your Personal data after your death and to choose whether or not we communicate your Personal data to a third party that you have previously designated (Article 85 of the Loi IEL).
Right of access: you have the right to access all of your Personal data at any time, pursuant to Article 15 of the GDPR;
Right of rectification: you have the right to rectify at any time your inaccurate, incomplete or obsolete Personal data in accordance with Article 16 of the GDPR;
Right to erasure: you have the right to require that your Personal data be erased and to prohibit any future collection for the grounds set out in Article 17 of the GDPR, namely where it is inaccurate, incomplete, equivocal, outdated, or where its collection, use, communication or retention is prohibited (find out more);
Right to restriction of processing: you have the right to ask us to temporarily freeze the use of some of your Personal data, under the conditions provided for (Article 18 of the GDPR);
Right to object: under Article 21 of the GDPR, you have the right to object to the Processing of your Personal data. Please note, however, that we may maintain their Processing despite this objection, for legitimate grounds or for the defence of legal claims.
Right to portability: subject to certain conditions specified in Article 20 of the GDPR, you have the right to receive the Personal data that you have provided to us in a standard, machine-readable format and to require its transfer to the recipient of your choice.

These rights may be exercised by contacting us:

By e-mail at: contact@visionary-tech.fr;
By post at: VISIONARY TECH, 1050 Avenue du Mondial 98 – 34000 MONTPELLIER.

You also have the possibility of lodging a complaint with a competent supervisory authority.

To date, VISIONARY TECH does not carry out any automated decision-making that may produce legal effects concerning you or similarly significantly affect you.

In the event of death and in the absence of instructions from you, we undertake to destroy your Personal data, unless its retention proves necessary for evidentiary purposes or to meet a legal obligation.

Article 9. What about cookies and other "trackers"?

VISIONARY TECH makes use, on its Site and the Platform, of connection data (date, time, Internet address, protocol of the visitor's computer, page consulted) and of cookies (small files saved on your computer) enabling it to identify you, to remember your browsing, and to benefit from audience measurements and statistics for the Platform and the Site, in particular relating to the pages consulted.

The cookies used by VISIONARY TECH can be grouped into several categories:

Strictly necessary cookies (technical cookies)
These cookies are essential for the proper functioning of the Site and the Platform and cannot be deactivated. They allow in particular:
- access to secure areas;
- management of User sessions;
- securing of connections;
- retention of the choice expressed by Users on the placing of cookies;
- the proper technical functioning of the services.
In accordance with Article 82 of the Loi IEL, these cookies do not require your consent because they are necessary for the provision of the Site and the Platform. In the event of objection, the User is exposed to total or partial unavailability of certain features of the Site and/or the Platform.
Audience measurement and performance cookies
These cookies make it possible to compile statistics on the traffic to and use of the Site and the Platform (pages consulted, browsing time, origin of connections, etc.) in order to improve the performance and ergonomics of the services offered.
In accordance with Article 82 of the Loi IEL, these cookies are necessary for the operation and administration of the Site and the Platform. In the event of objection, the User is exposed to total or partial unavailability of certain features of the Site and/or the Platform.
Personalisation cookies
These cookies make it possible to adapt the display and operation of the Site or the Platform to the User's preferences (language, settings, etc.).
In accordance with Article 82 of the Loi IEL, these cookies do not require your consent because they are necessary for the provision of the Site and the Platform. In the event of objection, the User is exposed to total or partial unavailability of certain features of the Site and/or the Platform.
Prospecting or marketing cookies (where applicable)
These cookies make it possible to measure the effectiveness of communication campaigns and to offer content adapted to the User's interests, where the User has consented to this.

By way of indication, the categories of cookies likely to be placed are as follows:

Cookie name	Purpose of the cookie	Legal basis	Retention period
Technical cookies	Functioning and security of the Site and the Platform	Legitimate interest of VISIONARY TECH in providing you with the Platform and the Site	Session or up to 12 months As regards the collection of consent, the retention period is 6 months.
Audience measurement cookies	Statistical analysis and improvement of the services	Legitimate interest of VISIONARY TECH in providing you with the Platform and the Site	Up to 13 months
Personalisation cookies	Adaptation of the display and of the User experience	Legitimate interest of VISIONARY TECH in providing you with the Platform and the Site	Up to 12 months
Marketing cookies	Prospecting and analysis of campaigns	Consent	Up to 13 months

Depending on the purposes, the User may consent to, refuse or choose the placing of certain types of cookies on their devices. The User may withdraw their consent at any time.

Furthermore, if the User does not wish cookies to be installed on their device, they may change their browser preferences to refuse them in whole or in part. Such refusal may, however, affect the use of the Site or the Platform.

The User may also configure their browser so that it indicates to the sites visited their wish not to be tracked ("Do Not Track").

Article 10. Is your Personal Data transferred outside the European Union?

As a matter of principle, we process your Personal data within the European Union.

In view of the evolution of our activity, we may be led to transfer your Personal data outside the European Economic Area. In that event, we will keep you informed of this development.

Article 11. What security measures are implemented?

We implement all the technical and organisational measures necessary to ensure the security of our Processing of Personal data and the confidentiality of the Personal data that we collect.

To this end, we take all useful precautions, having regard to the nature of the Personal data and the risks presented by the Processing, to preserve its security and, in particular, to prevent the Personal data from being distorted or damaged, or unauthorised third parties from having access to it (physical protection of premises, authentication procedures for persons accessing the Personal data with personal and secure access via confidential credentials and passwords, logging and traceability of connections, etc.).

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