Privacy policy
Last updated:
This site creates no account, sells nothing, has no form and sets no cookies of its own. It asks you for no data and uses no analytics and no social media button. To send you the pages, its host processes your IP address: this page explains what happens there, and when you write to me or call me.
Who is responsible for your data
THG CONSEIL, 95-97 boulevard Suchet, 75016 Paris, France, represented by Tudor Hilcu, managing director (gérant). Contact: contact@thgconseil.fr.
In this policy, “I” means Tudor Hilcu, managing director, who answers on behalf of THG CONSEIL.
What this site collects
The site asks you for nothing. The pages are static files: it has no database, no account, no form and no analytics. The only data processed during your visit is the technical data received by the host (next section).
- Reading the pages: no data is requested or recorded by the site.
- Downloading the documents: one click is enough, with no sign-up and no email address. The site does not ask who you are.
- Online checklist and self-assessment: your answers are processed in your browser. They are neither sent to a server nor recorded. If you choose to write with your result, it is placed in an email prepared in your own mail application, or copied to your clipboard at your request: nothing leaves until you send it.
- Fonts, images and videos: they are all served by this site. No resource is loaded from another service: no remote font, no external video player, no advertising network.
- Links to other websites: LinkedIn, WhatsApp and the sources cited in the articles and on the “Method and gains” page are plain links. Those sites receive nothing until you click; after that, their own rules apply.
What the host records
To send you a page, the host (Cloudflare, Inc.) necessarily receives your IP address and technical data: page requested, date and time, type of browser. It processes them on behalf of THG CONSEIL, under a data processing agreement (Article 28 GDPR), to deliver the pages and protect the site against attacks. It also uses some of this data to secure its own network, as a separate controller, under its privacy policy.
THG CONSEIL only draws overall statistics from it, supplied by the host, such as the number of requests and their country of origin, with no cookie and no script in your pages. I do not try to identify a visitor. Legal basis: the legitimate interest of THG CONSEIL in running the site and protecting it.
When you write to me or call me
- By email: I receive your address, your name and what you write. The contact@thgconseil.fr mailbox is hosted by OVHcloud, in France.
- By phone: I see your number and keep the notes taken during our conversation.
- By WhatsApp or LinkedIn: your message reaches me through those services, which apply their own privacy rules.
I use it to answer you and, if you ask, to prepare a proposal and then carry out the assignment. Legal bases: the legitimate interest of THG CONSEIL in answering those who contact it; performance of the contract when you are yourself the client; the legal obligation to keep accounting records. You are under no obligation to give me this data; without it, I cannot answer you.
This site has no newsletter and no mailing list. Your address is only used to correspond with you about your request and, if an assignment follows, about that assignment: I add it to no list.
How long
| Data | Period |
|---|---|
| Technical data held by the host | The time needed to deliver the pages and secure the site, according to the host’s log retention period. The overall statistics I consult identify no visitor. |
| Messages and calls that go no further | 3 years after your last message or call. |
| Exchanges with a client | The length of the assignment, then 5 years as evidence of the contract (Article L110-4 of the French Commercial Code); 10 years for accounting records (Article L123-22 of the French Commercial Code). |
| Answers to the online checklist and the self-assessment | Never kept. They disappear when you leave the page. |
Who has access
I alone read your messages. Two technical providers act on behalf of THG CONSEIL: Cloudflare, Inc., which hosts the site, and OVHcloud, which hosts the mailbox in France. Your data is never sold, rented or passed on.
Transfers outside the EU
Cloudflare, Inc. is a US company: its network serves each page from the data centre closest to you, and this technical data may be processed in the United States. The transfer relies on the European Commission’s adequacy decision of 10 July 2023 (EU-US Data Privacy Framework); Cloudflare is certified under that framework. Should that basis cease to apply, the standard contractual clauses in Cloudflare’s agreement would take over. Copy of these safeguards on request: contact@thgconseil.fr. The mailbox is hosted in France.
Your rights
Access, rectification, erasure, restriction, objection, portability, instructions on what happens to your data after your death. To exercise them, write to contact@thgconseil.fr; I reply within one month.
You may object at any time, on grounds relating to your particular situation, to processing based on legitimate interest. The one-month period may be extended by two months for a complex request; I will tell you if so. No automated decision is taken about you.
You may also complain to the CNIL, the French data protection authority (www.cnil.fr), or to the data protection authority of the EU country where you live or work.
Cookies and trackers
This site sets no cookies of its own: no advertising, no analytics, no social network. This is why it shows no cookie banner. Nor does it write anything to your browser’s storage.
One exception is possible: if the host submits a suspicious connection to a security check, it sets a cookie named cf_clearance, which proves the check was passed. It serves no other purpose and expires after the period set at the host (30 minutes by default). Being strictly necessary to protect the site, it does not require your consent (Article 82 of the French Data Protection Act).
Security
Encrypted connection (HTTPS). A security policy prevents the pages from loading content from another website. The site stores no personal data. Messages received are read only by Tudor Hilcu.
If the site changes
If a feature that processes data is ever added, this page is updated, with its date.
Contact
For any question about your data: contact@thgconseil.fr, or by post: THG CONSEIL, 95-97 boulevard Suchet, 75016 Paris, France.