Yourdata.Strictlynecessary.
GDPR-compliant privacy policy. We collect what's useful to deliver the cycle. Nothing more. No reselling. No advertising tracking.
§ 01Data controller
The data controller for personal data collected via 21day.io is 21Day Studio [TO COMPLETE before publication: legal form + full address of registered office]. The studio is represented by Maxence Foulon, founder.
For any question about your data: contact@21day.io
§ 02Data collected
- 01Identification information (first name, last name, work email, company) entered in the brief.
- 02Project details (description, sector, scope, budget, timeline) entered in the brief.
- 03Client reference generated upon brief validation.
- 04Ephemeral authentication tokens (15 minutes max) for sending magic links by email.
- 05Minimal technical logs (IP address, browser, timestamp) for security and abuse prevention.
§ 03Purposes
- 01Review your brief and prepare a fixed-price quote.
- 02Create and manage your client portal after validation.
- 03Communicate on cycle progress (update emails, notifications).
- 04Fulfil our contractual, accounting and tax obligations.
- 05Ensure site and data security and integrity.
§ 04Legal basis
- 01Performance of pre-contractual measures or contract (brief submission, quote, cycle execution).
- 02Consent, when you write to us or tick an optional box.
- 03Legitimate interest, for site security and defence of our rights.
- 04Legal obligation, for accounting and tax requirements.
§ 05Retention period
- 01Brief without follow-up: 12 months after last exchange, then deletion.
- 02Validated brief / delivered cycle: 5 years after end of contract (accounting and warranty).
- 03Authentication tokens: 15 minutes maximum.
- 04Technical logs: 12 months maximum.
§ 06Subprocessors
To run the site and honour our commitments, we use the following subprocessors. All are bound by a GDPR-compliant subprocessing contract.
- 01Vercel Inc. (USA)Front-end hosting (EU-US Standard Contractual Clauses)
- 02Hetzner Online GmbH (Germany, EU)Self-hosted Twenty CRM hosting (Person, Cycle, events, encrypted vault)
- 03Twenty CRM (self-hosted)Internal database (briefs, opportunities, cycle events, vault requests) — OSS code, data resides at Hetzner EU
- 04Stripe Payments Europe Ltd. (Ireland, EU)Online payments (deposit + balance Checkout Sessions)
- 05Resend (USA)Transactional emails (confirmation, magic link, cycle notifications)
- 06Mistral AI (France, EU)Sovereign FR AI models — only for cycles including AI, never on brief data without explicit consent
§ 07Your rights
- 01Right of access: obtain a copy of your data.
- 02Right to rectification: correct inaccurate data.
- 03Right to erasure: delete your data, subject to legal obligations.
- 04Right to portability: retrieve your data in a reusable format.
- 05Right to object: contest processing based on legitimate interest.
- 06Right to withdraw consent at any time, when processing relies on it.
To exercise these rights, write to contact@21day.io. You also have the right to lodge a complaint with the CNIL (cnil.fr).
§ 08Cookies
The site only uses strictly necessary cookies (session, authentication, security). No advertising cookies, no third-party tracking, no fingerprinting without explicit consent.
§ 09Updates to this policy
In case of substantial modification, we notify active clients by email and publish the new version here. The last-updated date appears at the top of this page.