Privacy Policy
Last updated: March 2026
This privacy policy explains how felipetroy.pro collects and uses your data. Felipe Díaz Marín is the data controller.
Data we collect
Analytics: if you consent, Google Analytics 4 collects anonymised browsing data (pages visited, session duration, device type). No personally identifiable information is sent to Google. Contact form: your name, email, and message are processed by Formspree to deliver them to us. Functional data: a language-preference cookie (NEXT_LOCALE) and a theme preference in localStorage are stored locally to remember your settings.
Legal basis
We process your personal data on the following legal bases (GDPR Art.6): Analytics (GA4): your explicit consent — Art.6(1)(a). You may withdraw consent at any time via the cookie banner or by emailing hello@felipetroy.pro. Contact form: legitimate interest in responding to your enquiry — Art.6(1)(f). Functional cookies (language, theme): strictly necessary for the service you requested — Art.6(1)(b). Website hosting and infrastructure (Vercel): necessary to provide the service — Art.6(1)(b). App user data (CitoyenApp, PermisB — learning progress, subscription, email): performance of a contract — Art.6(1)(b). KOL Publisher API data (TikTok account info, video metadata): performance of a contract — Art.6(1)(b).
Third-party processors
Google Analytics (Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4). Formspree Inc. (contact form submissions). Data may be transferred to the United States under the EU–US Data Privacy Framework.
Data retention
Analytics data: 14 months (Google Analytics default). Contact form submissions: retained only as long as needed to reply, then deleted. Functional cookies: 12 months. App user data (CitoyenApp, PermisB — learning progress, quiz answers, session data, subscription status): retained for the lifetime of your account plus 30 days after deletion. Email address (app accounts): retained for the lifetime of your account plus 30 days after deletion. KOL Publisher data (TikTok account info, video metadata): deleted within 30 days of revoking authorization or account termination. Server logs (Vercel): up to 90 days.
Children's privacy
Our services are not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13. Our applications (CitoyenApp, PermisB) are designed exclusively for adults aged 18+ preparing for official examinations. If you believe we have inadvertently collected information from a child under 13, please contact us at hello@felipetroy.pro and we will delete it promptly.
Your rights
Under GDPR you have the right to access, rectify, erase, restrict, and port your data, and to object to processing. To exercise these rights, use the contact form on this site. You may also lodge a complaint with your national supervisory authority (for France: CNIL, www.cnil.fr).
Contact
For any privacy-related question, contact Felipe Díaz Marín via the contact form on this site.
Sub-processors and data locations
Vercel Inc. (San Francisco, USA) — website hosting and all web traffic. Google Analytics 4 (Google Ireland Ltd, Dublin) — anonymised analytics, loaded only with your consent. Formspree Inc. (USA) — contact form submissions. Supabase (EU infrastructure, AWS eu-west-1) — app user data for CitoyenApp and PermisB. TikTok Inc. (global) — KOL Publisher API data. Transfers to the United States are governed by Standard Contractual Clauses (GDPR Art. 46).
Data deletion
You may request deletion of all your personal data at any time by emailing hello@felipetroy.pro with the subject 'Data Deletion Request'. We will process your request within 30 days. Accounts inactive for 36 months will be notified and scheduled for deletion with 30 days notice.
TikTok API data use
KOL Publisher accesses TikTok API data (account information and video metadata) solely to execute publishing actions you have authorized. This data is never sold to third parties, never used to build competing products, and never used for advertising or profiling. This disclosure satisfies TikTok Developer Terms of Service §4 (Restrictions on Use of TikTok Data). To revoke KOL Publisher's access to your TikTok account: Settings → Security → Authorized Apps. Upon revocation, all TikTok API data held by KOL Publisher will be deleted within 30 days.