Privacy Policy
1. Controller and scope
Publisher / Licensor / Provider: Emmanuel Revy, sole trader (entrepreneur individuel, EI), trading under the commercial name ProxCenter. Business establishment: 173 rue de Courcelles, 75017 Paris, France. Registered with the French National Business Register (RNE) under SIREN 885 316 455 and SIRET 885 316 455 00017. Contact: [email protected]. For Site, commercial contact, account, order, invoicing and ordinary support data, Emmanuel Revy (EI) is the controller. Privacy contact: [email protected]. This Policy does not itself govern Customer data in a self-hosted deployment. Where the Provider processes personal data on Customer instructions, the DPA applies.
2. Data
Depending on the interaction, the Provider may process identity and contact data; account identifiers, hashed credentials and access history; orders, invoices, licence keys, Node count and payment status; technical and security data such as IP address, browser and device details, timestamps and logs; and support communications and attachments. Payment-card data should be processed by the payment provider, not stored by the Provider. The Software is designed to be self-hosted. The Provider does not intentionally collect Customer infrastructure data or credentials merely because the Software is installed. Any licence-validation telemetry must be necessary for entitlement validation and match the technical implementation.
3. Purposes and legal bases
Purposes include providing the Site and accounts, taking pre-contractual steps and performing contracts, licensing, support, security and fraud prevention, legal and accounting compliance and, where validly consented or permitted, marketing. Legal bases are contract, legitimate interests, legal obligations and consent, as applicable.
4. Recipients, transfers and security
Recipients are limited to the Provider and the actual service providers needed for hosting, CDN, security, payment, transactional email, support, accounting, backup, analytics, or electronic signature (for partner/reseller contract signing). Data are not sold or shared for third-party direct marketing. Transfers outside the EEA use an appropriate legal mechanism, such as an adequacy decision or standard contractual clauses, where required. Appropriate measures include access controls, transport encryption where available, password hashing where accounts are operated, and least-privilege access.
5. Retention
Indicative periods: prospect data, up to 3 years after the last meaningful contact; account and support data, for the account duration then up to 3 years after closure, subject to disputes or legal needs; invoices and accounting records, 10 years where French law requires; security logs, a proportionate period; backups, the normal rotation cycle.
6. Your rights
Subject to legal conditions, you may request access, rectification, erasure, restriction or portability, or object to legitimate-interest processing; consent may be withdrawn at any time. Write to [email protected]. Identity verification may be requested. You may lodge a complaint with the CNIL (www.cnil.fr).
7. Cookies
Strictly necessary technologies for security, session or language functions may be used without consent where the law permits. No non-essential audience, advertising, social-media or similar technology is deployed unless the required information and consent have first been implemented.
8. Changes
Updates will be posted with an effective date; material changes will be notified where appropriate.