Privacy notice

1. Operator and distinct processing roles

Myriam Pontiac, individual entrepreneur (micro-entreprise), trading as MP Développement Digital, is the operator identified in the publisher notice. She acts as controller for her own agency/account administration, support correspondence, security administration and legally required commercial records.

For end-customer enquiries, conversations, quotes and outcome evidence processed on instructions, MP Développement Digital acts as processor for a business controller, or as subprocessor where the agency is itself that business's processor. An agency determining purposes independently may be a controller for those purposes. The approved DPA identifies the actual chain per customer; white-label branding does not determine legal roles.

2. Categories, sources and purposes

Operator data may include professional contact and account identifiers, role/access information, subscription references/status, support messages and limited security records. It is received from account users, the purchasing Marketplace and interactions with the service. Payment-card credentials are not requested by ordinary email or through a separate MP Développement Digital checkout.

Instructed customer data can include names and contact details, CRM identifiers, communications, consent/preferences/exclusions, appointments, quotes, opportunity records and sourced payment/outcome information. Sources are the authorised agency/business, its connected CRM and the configured transport. Processing supports configured follow-up, human handoff, evidence reporting and requested export/deletion.

Do not import health data, biometric identification, criminal records or other special-category data into ordinary recovery workflows. The product is not designed for emergency decisions or solely automated decisions producing legal or similarly significant effects. Optional AI cannot override contact controls.

3. Legal bases and recipients

For MP Développement Digital's own administration, the bases are performance of its business contract where the data subject is a contracting party; legitimate interests in managing professional relationships, support, preventing abuse and securing the service; and legal obligations for records actually required by law. A documented balancing assessment is required where legitimate interests are relied on. No unrelated advertising consent is assumed.

For customer processing, the business controller determines and documents the applicable basis and channel consent requirements, informs individuals and issues lawful instructions. MP Développement Digital's processor relationship is not a substitute for that basis.

Access is limited to authorised agency/business users, personnel who need it and the providers described below for their specified tasks. MP Développement Digital does not sell customer personal data. A lawful authority may receive information where legally required; requests are assessed and the customer is informed where permitted.

4. Rights and privacy contact

Send operator-data enquiries to support@mpddrecover.com with subject Privacy. For business customer data, contact the relevant business or agency controller; MP Développement Digital will route and assist with the request without taking over its decisions. Only necessary identity checks will be requested through an appropriate secure channel.

Where applicable, rights include access, correction, erasure, restriction, portability, objection and withdrawal of consent without affecting prior lawful processing. Legal grounds for limited preservation may prevent immediate deletion of specific records. A STOP or channel opt-out stops eligible automated contact; it is distinct from an erasure request.

For requests where MP Développement Digital is controller and GDPR applies, the response period is normally one month; any permitted extension and reasons are communicated within that period. An individual may complain to the competent authority, including the CNIL in France. No contractual term removes that right.

5. Security, cookies and optional features

The platform uses tenant-scoped access controls, protected server-side credentials, access checks, audit records and controlled communication workflows. These measures do not constitute a certification or absolute-security guarantee. Customers must protect their accounts and avoid sending secrets or complete CRM exports by email.

The application uses session/authentication and security mechanisms necessary for account access. This notice does not authorise advertising trackers. Any future non-essential tracking must be disclosed and use an appropriate consent mechanism before activation.

OpenAI and Sentry integrations remain disabled in this preview. Their activation would require an updated notice and approved processor/transfer arrangements before customer data is shared.

Retention and exit schedule

These operator-approved periods are the retention policy, not evidence that every deletion is automated. Conversations: 730 days; attachments: 365 days; audit records: 2,555 days; maintenance-run history: seven days. Conversation, attachment and audit periods are measured from the relevant record's creation unless lawful customer instructions specify a necessary earlier deletion; retention is not restarted by unrelated activity.

The existing application holds conversation/attachment/audit duration parameters but has no verified comprehensive age-based purge for those records. The seven-day maintenance-history purge is scheduled. The operator must track and execute the other approved periods through a controlled procedure; the document does not certify that such a procedure is already operational.

Support correspondence: 24 months after ticket closure. Account administration: during the contract, then five years after its end in restricted archives for claims. Required accounting records: ten years from the relevant financial-year close. Preserve only records necessary for the stated purpose; lawful holds record scope, grounds and review date.

For opt-outs, keep only the minimum identifier or suppression evidence necessary to honour the objection; exclude it from campaigns. Contacts, quotes, opportunities and sourced outcome records follow necessary documented customer instructions, without overriding erasure duties or using account/accounting periods to retain full CRM content.

Exit: authenticated return/deletion requests are scoped and a feasible completion timetable is documented, with secure delivery and completion evidence. The current implementation does not substantiate fixed 30-day export or 60-day active-data deletion after termination. Those deadlines are not contractual guarantees in this version. Mandatory rights and applicable deadlines remain unaffected.

Residual copies: restrict access, prohibit campaign reuse, request deletion where provider controls permit, and track expiry. If a backup is restored, reapply the recorded deletion instructions before returning data to normal use. No claim of immediate deletion of every physical copy or a universal expiry is made.

Supabase: the current account is Free and the primary database is in Ireland. No managed restoration entitlement or account-specific residual-backup expiry is verified. Database backups do not include the stored attachment files; those require separate Storage API deletion. No seven-day Supabase expiry is promised.

Vercel documents infrastructure backups retained for 30 days. That is a published vendor cycle, not proof of an individual deletion date or the retention of every request log, cache or deployment. Resend documents standard-plan email/log retention of 30 days, backups of seven days, and deletion of remaining data within 90 days after account termination; these are different triggers, and account applicability must be confirmed. Outlook is used only for support: the 24-month support policy does not establish automatic mailbox/archive purge or the expiry of Microsoft's residual copies.

Vendor references: Supabase backups · Vercel backup cycle · Resend retention.

Providers, processing locations and transfer safeguards

This inventory distinguishes operator vendors from the customer's own providers. Public vendor documents establish available terms, not proof that every required account agreement and transfer assessment has been completed. The operator has accepted the verified Vercel, Supabase and Resend disclosures as sufficient documentation for V1; missing account-by-account documents are not a separate launch condition. No unverified signature or account-specific exception is claimed.

• Vercel — application hosting and request processing. The current deployment reports iad1, United States; its delivery network and support can involve other countries. The published DPA identifies Vercel Inc. and contains transfer provisions. Confirm the applicable account agreement. Vercel DPA.
• Supabase — database, authentication, private storage and worker infrastructure. The project's database region is eu-west-1, Ireland; this does not establish exclusive EEA processing for support, logs, backups or Edge Functions. The current public DPA names Supabase Pte. Ltd.; confirm whether that entity or an earlier contracted entity applies to this account. Supabase DPA and subprocessor list.
• Resend / Plus Five Five, Inc. — email transport when enabled. Public documentation states US storage, standard-plan email/log retention of 30 days, backups of seven days and remaining-data deletion within 90 days after account termination; the account plan and applicable contract must be confirmed. Sending-region selection does not move storage to Europe. Its DPA includes standard contractual clauses; do not infer adequacy from an EU sending region. Customer sends remain disabled. Resend DPA, subprocessors and locations and retention.
• The connected CRM and business communications transport are contracted/configured by the agency or business, not supplied as an operator telecom subscription. Their own contractual entities, locations, retention and transfer terms must be recorded by that customer. They are not automatically treated as operator-appointed subprocessors.
• The operator's support mailbox receives correspondence through Microsoft Outlook. No exclusively European storage or unverified vendor retention period is promised. Account-specific Microsoft terms and residual-copy expiry remain to be confirmed. It is a support-data recipient, not a destination for importing whole customer datasets.
• Marketplace payment services receive subscription/account data under their own applicable terms. Developer payout services process the operator's payout identity and banking data. These financial relationships do not authorise disclosure of end-customer CRM records to payout providers.
• Optional OpenAI assistance and Sentry monitoring are disabled in the current preview and are not authorised for live customer data by this document. Any activation requires an updated inventory, data-minimisation review and applicable agreements and transfer safeguards.

For an EEA transfer, the exporter must document the receiving entity and country and a valid Chapter V basis. Where standard contractual clauses are used, record the relevant controller-to-processor or processor-to-processor module, complete annexes and assess whether supplementary measures are required. A UK transfer needs the applicable UK mechanism; Swiss transfers need the applicable adaptations. An adequacy decision may be used only after its applicability to the actual recipient and processing has been verified. No agreement signature, DPF certification or completed transfer assessment is claimed here.

Contact and operator identification

Myriam Pontiac — entreprise individuelle / micro-entreprise, trading as MP Développement Digital. SIREN 107 090 268; SIRET 107 090 268 00015. Business address: 141 rue Peton Gaudet, 42400 Saint-Chamond, France. Publication director: Myriam Pontiac. TVA non applicable, art. 293 B du CGI.

Email support and privacy/DPA contact: support@mpddrecover.com. First support response within 24 hours of receipt, including weekends and public holidays. This is an initial response commitment, not a resolution deadline or continuous live support. Use subject Privacy or DPA. Do not send passwords, API keys or full customer files by ordinary email. Necessary identity checks use a suitable secure channel.