In short
- We only collect what is needed to answer your requests and perform our services.
- No analytics, no advertising, no newsletter, no sale of data.
- The contact form is transmitted by FormSubmit, a service located outside the European Union; you can e-mail or call us directly to avoid it.
- You can access, correct or delete your data at any time by writing to [email protected].
- You can complain to the CNIL if you believe your rights are not respected.
Data controller
The data controller is Bertrum Nivonu SARL, private limited company (SARL, French law), 14 Rue Sébastien Gryphe, 69007 Lyon, France, RCS Lyon 915 473 268, represented by Camille Vernet, managing director (gérante). Contact: [email protected] — +33 (0)4 78 62 19 47.
Personal data contact
Given the size of the company and the nature of its processing, Bertrum Nivonu SARL has not appointed a data protection officer (DPO), as this is not mandatory in its situation (Article 37 GDPR). Questions about your data are handled by Camille Vernet, managing director, at [email protected].
Data we process
Contact form
Full name, e-mail address, phone (optional), requested service, description of your project, confirmation that you have read this policy. Required fields are marked as such; without them we cannot reply to you.
E-mail and phone exchanges
The information you choose to give us: identity, contact details, message content, links to your demos.
Clients
Identity, contact details, billing address, company name and VAT number for businesses, history of quotes, bookings, invoices and payments. We do not store card numbers: card payments are processed by our bank's payment terminal.
Recordings
Audio files made during sessions contain the voices and performances of participants and, where relevant, their names for credits. Voice is not used as biometric data: no voice identification processing is carried out.
Browsing
The site sets no analytics or advertising cookies. It only stores, in your browser's local storage, your choice about trackers (see the cookie policy). The host keeps technical logs (IP address, date and time, requested page, browser) needed for server security and operation.
Purposes, legal bases and retention periods
| Purpose | Legal basis | Retention period |
|---|---|---|
| Answering your quote requests and questions (form, e-mail, phone) | Pre-contractual steps taken at your request (Art. 6(1)(b) GDPR) | 3 years from your last contact, if no contract is concluded |
| Managing bookings and performing services | Performance of the contract (Art. 6(1)(b)) | Length of the relationship, then 5 years (limitation period, Article 2224 of the French Civil Code) |
| Issuing and keeping invoices | Legal obligation (Art. 6(1)(c); Article L.123-22 of the French Commercial Code) | 10 years from the end of the financial year |
| Keeping a backup copy of recorded files | Performance of the contract (Art. 6(1)(b)) | 6 months after the session, unless you ask for earlier deletion or a different written agreement exists |
| Remembering your choice about trackers | Legal obligation to collect and prove consent (Art. 6(1)(c); Art. 82 French Data Protection Act) | 6 months, in your browser only |
| Keeping the site secure (host's technical logs) | Legitimate interest (Art. 6(1)(f)) and the host's legal obligation | 1 year (Decree No. 2021-1362 of 20 October 2021) |
| Establishing, exercising or defending our rights in a dispute | Legitimate interest (Art. 6(1)(f)) | Length of the proceedings and appeal periods |
After these periods, data is deleted or anonymised. We send no newsletter or marketing; if that changed, your prior consent would be requested.
Recipients
Your data is only accessible to the people at Bertrum Nivonu SARL who need it, and to the following providers within the limits of their task:
- FormSubmit (formsubmit.co): forwarding by e-mail of messages sent through the contact form;
- OVH SAS, 2 rue Kellermann, 59100 Roubaix, France: hosting of the website and e-mail, in France;
- our chartered accountants, for bookkeeping and invoices;
- the file transfer service agreed with you for delivering recordings, project by project.
Your data is neither sold nor rented. It may be disclosed to authorities where required by law.
Transfers outside the European Union
The FormSubmit service, used to transmit the contact form, is operated from outside the European Union. Data entered in the form (name, e-mail, phone, service, message) may therefore be processed in a third country, including the United States, before reaching us by e-mail.
We limit the data requested to what is strictly necessary and have disabled service options that would involve additional third-party tools (captcha). You can obtain information about the safeguards covering this transfer by writing to [email protected].
If you do not want your data to pass through this service, write to us directly at [email protected] or call +33 (0)4 78 62 19 47: these channels do not use FormSubmit.
Other data (clients, invoices, recordings) is processed within the European Union.
Security
We apply measures appropriate to the risks: site served over HTTPS, access to mailboxes and files limited to authorised people and password-protected, backups of recordings on separate media, deletion at the end of the planned periods. No measure offers absolute security; in the event of a data breach posing a risk to your rights, we will notify the CNIL and, where necessary, the people concerned (Articles 33 and 34 GDPR).
Your rights
You have the following rights over your data:
- right of access (Article 15 GDPR) and rectification (Article 16);
- right to erasure (Article 17) and to restriction of processing (Article 18);
- right to portability of data you provided to us (Article 20);
- right to object to processing based on our legitimate interest (Article 21);
- right to set instructions on what happens to your data after your death (Article 85 of the French Data Protection Act).
To exercise them, write to [email protected] or by post to Bertrum Nivonu SARL, 14 Rue Sébastien Gryphe, 69007 Lyon, France. We reply within one month, which may be extended by two months for complex requests (Article 12 GDPR); we would inform you if so. We only ask for proof of identity if there is reasonable doubt about who you are.
Some data cannot be erased while a legal obligation requires us to keep it (invoices in particular).
Complaint to the CNIL
If, after contacting us, you believe your rights are not respected, you can lodge a complaint with the supervisory authority: Commission nationale de l'informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France — www.cnil.fr.
Objection to telephone canvassing
We only use your phone number to answer your request and organise your sessions. Under Article L.223-2 of the French Consumer Code, you can register free of charge on the Bloctel telephone canvassing opt-out list: www.bloctel.gouv.fr.
Minors
Our services are intended for adults. A minor may record at the studio with the consent of a holder of parental authority, who makes the booking and receives communications about the contract.
No automated decisions
We make no decision based solely on automated processing and carry out no profiling.
Changes
This policy may be updated, in particular if we add a service or provider. The update date is shown at the top of the page. We will flag any significant change on the site. In case of discrepancy, the French version prevails.