PRIVACY POLICY

Article 1 : Introduction

This privacy policy applies to the website : www.tournaye-consulting.com.

Its purpose is to inform users about :

• How their personal data is collected and processed;
• The rights they have regarding their personal data;
• The identity of the data controller;
• The potential recipients of the data;
• The use of cookies.

This policy supplements the legal notices available on the website.

Article 2 : Data Controller

The controller of personal data is : Ms Cécile Tournaye
Contact : contact@tournaye.eu

The data controller determines the purposes and means of processing personal data.

Article 3 : Data Collected and Purposes

A. Data Collected

When using the website, the following data may be collected :

• Last name
• First name
• Email address
• Content of the message sent via the contact form
• Technical browsing data (anonymised IP address, browser type, pages visited)

No sensitive data is collected.

B. Data Collection Methods

This data is collected when the user :

• Uses the website contact form
• Browses the website (via audience measurement tools)

C. Purposes of Processing

Data is collected for the following purposes :

• Responding to requests sent via the contact form
• Ensuring the proper functioning and security of the website
• Measuring and analysing website traffic in order to improve content and user experience

Article 4 : Legal Basis for Processing

The processing carried out is based on :

• The legitimate interest of the data controller in responding to user requests
• The user’s consent for the use of audience measurement cookies

The processing is also based on the user’s consent when submitting the contact form.

Article 5 : Data Retention Period 

Data collected via the contact form is retained for a maximum of 36 months from the date of the last exchange. 

Browsing data (Google Analytics) is retained according to the settings defined by the tool, with IP address anonymisation. 

Article 6 : Data Recipients

Personal data is neither sold nor transferred.

It may be processed by technical service providers acting as data processors, including :

• The website hosting provider
• The audience measurement provider (Google Analytics)

Google Analytics may involve data transfers outside the European Union. These transfers are governed by standard contractual clauses approved by the European Commission.

These service providers are bound by contractual obligations of confidentiality and security in compliance with the GDPR.

Article 7 : Data Hosting

The website is hosted by:

OVH
2 rue Kellermann
59100 Roubaix – France
Tel: 1007

Data is hosted within the European Union.

Article 8 : Data Security

The data controller implements appropriate technical and organisational measures to ensure the security, integrity and confidentiality of personal data.

The website uses an SSL certificate to secure data exchanges between the user and the website.

Article 9 : Users’ Rights

In accordance with Regulation (EU) 2016/679, users have the following rights :

• Right of access
• Right to rectification
• Right to erasure 
• Right to restriction of processing
• Right to object
• Right to data portability
• Right to lodge a complaint with the French Data Protection Authority (CNIL – www.cnil.fr )

Users may exercise their rights by sending a request to : contact@tournaye.eu

A response will be provided within a maximum of 30 days. This period may be extended by two months in the case of complex requests, in accordance with the GDPR.

Article 10 : Data Relating to Minors

The website is not specifically intended for minors. If a user is under the age of 15, prior consent from a legal representative is required. The website does not intentionally collect data from minors.

Article 11 : Cookies

The website uses cookies that are strictly necessary for its operation, as well as audience measurement cookies (Google Analytics).

Audience measurement cookies are only placed after the user’s consent has been obtained via the cookie banner.

Users may at any time :

• Accept or refuse cookies
• Modify their preferences

Cookie preferences are managed via a dedicated consent management tool. Refusing cookies does not prevent access to the website.

Article 12 : Changes to the Privacy Policy

This privacy policy may be modified at any time in order to remain compliant with legal and regulatory developments.

Last updated: 15/12/2025