Privacy Policy

• Data controller: FullSignaux SASU, 1 rue Marguerin, 75014 Paris
• Contact for any GDPR request: dpo@fullsignaux.com
• General contact: contact@fullsignaux.com

As part of using the Service, FullSignaux collects the following categories of data, depending on the user's profile (Subscriber or Trader):

• Identification data: last name, first name, e-mail address, password (encrypted),
• Data required for identity verification (KYC), where required,
• Payment data: processed directly by Stripe Connect, FullSignaux having no access to any complete banking data,
• Connection and Service usage data (technical logs, usage statistics),
• For Traders: data relating to published performance and payments received under the partnership agreement,
• Correspondence exchanged with Next Generation of Traders support.

• Account management and access to the Service: performance of the contract
• Processing of subscription payments: performance of the contract
• Identity verification (KYC): legal obligation or legitimate interest
• Service improvement, audience measurement: consent (non-essential cookies)
• Fraud prevention: legitimate interest
• Promotional emails and their personalisation: consent (see sections 10 to 12)
• Origin of signups (originating campaign): legitimate interest (see section 13)

The data collected is intended for FullSignaux's authorized internal teams, as well as the following technical service providers, acting as data processors within the meaning of the GDPR: Stripe (payment processing), OVH SAS (Service hosting), Brevo (sending account-related emails and, with your agreement, promotional emails; see section 14), and any additional technical service provider whose list is kept up to date by FullSignaux. These service providers only use the data to perform the services entrusted to them by FullSignaux.

FullSignaux does not sell or transfer users' personal data to third parties for commercial purposes.

Some service providers mentioned in Article 4 may be established, or may host data, outside the European Union, in particular in the United States. In this case, FullSignaux ensures that this transfer relies on a safeguard mechanism recognized by the GDPR (European Commission standard contractual clauses, adequacy decision, or equivalent).

Data is retained for the duration of the contractual relationship, plus the applicable legal limitation periods (in particular for accounting and tax purposes). Connection data is retained in accordance with the periods provided for by applicable regulations. Upon expiry of these periods, the data is deleted or anonymized.

In accordance with the GDPR, every user has the following rights over their personal data: the right of access, rectification, erasure, restriction of processing, objection, and portability. Users also have the right to set guidelines for what happens to their data after their death.

These rights may be exercised at any time by writing to dpo@fullsignaux.com. FullSignaux undertakes to respond within one month of receiving the request, a period that may be extended by a further two months in the case of a complex request.

Users also have the right to lodge a complaint with the French data protection authority, the Commission Nationale de l'Informatique et des Libertés (CNIL), 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, www.cnil.fr.

The Service uses the following categories of cookies:

• Strictly necessary cookies: login session, authentication, subscription cart, payment security. These cookies do not require consent and cannot be disabled without preventing the Service from functioning,
• Audience measurement (analytics) cookies: subject to the user's prior consent,
• Cookies related to the Stripe payment provider, necessary to secure transactions.

On their first visit, the user is informed via a dedicated banner of the use of these cookies and can accept, refuse, or configure their preferences for non-essential cookies. This consent can be withdrawn at any time from the cookie management module accessible in the footer of the Service.

FullSignaux implements appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or disclosure, including password encryption and the use of hosting and payment providers with recognized security guarantees.

We send you two types of emails.

Emails related to your account (welcome, verification codes, payment confirmations, subscription renewal) are necessary to perform our terms of use. They contain no commercial offer.

If you start a signup without finishing it, the information entered is erased 72 hours after the last completed step. A single email tells you so, 24 hours before the erasure, with a link to finish the signup. It contains no commercial offer.

Promotional emails (subscription offers, featured traders, reminders about an unfinished payment, follow-ups after a period of inactivity) are only sent to you if you have agreed to them by ticking the box provided for that purpose. You can withdraw your agreement at any time, in one click, from the unsubscribe link included in every email or from your member area.

If you have agreed to promotional emails, we tailor them to your activity on the platform: traders and offers viewed, number of views, date of last activity, subscription status. This analysis is used only to choose the content of the emails sent to you; it has no effect on your account or on your access to the services. It is based on your consent and stops as soon as you withdraw it.

With your agreement, our emails contain an invisible image (pixel) and links that let us know whether you opened the email and which links you clicked. We use this information to improve the content and frequency of our emails. Without your agreement, we only measure the date of your last open, solely to space out or stop our emails if you no longer read them, together with aggregate and anonymous statistics on our campaigns. You can withdraw your agreement at any time from the preferences page; earlier pixels are then ignored and the data collected is deleted.

When you reach our website from a campaign (social network, partner, advertising), the link may contain parameters identifying the originating campaign. These parameters are identical for everyone who clicks the same link and are not stored in your browser. If you sign up, the originating campaign is recorded on your account in order to measure the effectiveness of our acquisition campaigns. This processing is based on our legitimate interest; you can object to it by writing to us.

Our emails are sent by Brevo (Sendinblue SAS, Paris, France), which acts as a processor, on our instructions only and under a contract compliant with Article 28 of the GDPR. Brevo receives your email address and, for account-related emails, your first and last name. If you have agreed to promotional emails, Brevo also receives your activity indicators (traders and offers viewed, date of the last payment started, date of last activity), your subscription status, your choice on open and click measurement, and a personal link to your preferences page.

• Inactive member: 3 years after signup or after their last contact with us (logging into their account or making a choice about their emails counts, merely opening an email does not),
• Signup started but not finished: 72 hours after the last completed step,
• Former subscriber, for promotional emails: 3 years after the end of the subscription,
• Open and click data: until the agreement is withdrawn, and at most for the retention period of the contact,
• Proof of consent: for as long as the consent is relied upon, then for the time needed to evidence it,
• Address on the objection list: for as long as necessary to ensure that no promotional email is sent to you again,
• Invoices: 10 years (legal obligation).

You can at any time withdraw your consent, object to direct marketing and to personalisation, and request access to, rectification or erasure of your data, by writing to dpo@fullsignaux.com. You can also lodge a complaint with the CNIL (www.cnil.fr).

FullSignaux reserves the right to change this Privacy Policy at any time, in particular to comply with any legal, regulatory, or technical developments. The version in force is the one published on the Service on the date of consultation.