Privacy Policy

1. Who is responsible for your data

The data controller is SECUNARY, a French single-shareholder simplified joint-stock company (SASU) with a share capital of €100, registered with the Paris Trade and Companies Register under number 942 117 771, with its registered office at 102 avenue des Champs-Élysées, 75008 Paris, France.

For any question about your data: support@secunary.fr.

2. What we collect

Identity and contact details: first name, last name, date of birth, company name where relevant, e-mail address and phone number. Your e-mail may be an Apple private relay address if you chose to hide it.

Sign in with Apple identifier: the anonymous user identifier Apple provides. We never see your Apple ID password.

Your requests: destinations, dates, number of guests, preferences, budgets, and any detail you give your concierge, including addresses for pickups and deliveries.

Location: only when you choose “use my current position” to fill in an address. We do not track your location in the background.

Messages and attachments exchanged with your concierge in the app, including photos you attach to a request.

Payment confirmations: amount, date, method and status of each payment. Card details are handled by our payment provider Revolut; we never receive your full card number.

Technical data: device identifiers, push notification token, app version, crash reports, performance measurements and anonymous usage statistics.

Calendar: if you allow it, the app adds your confirmed bookings to your calendar on your device. We do not read your other calendar events.

3. Why we use it and on what legal basis

To perform the concierge service you request (contract): identifying you, handling your requests, preparing proposals, booking with suppliers, invoicing and keeping you informed.

To comply with the law (legal obligation): accounting and invoicing records, anti-fraud checks, and the identity retention required of online service providers in France.

To keep the service secure and reliable (legitimate interest): authentication, abuse prevention, crash and performance diagnostics, aggregated usage statistics.

With your consent, which you can withdraw at any time in the iOS Settings: push notifications, calendar access, photo library access and location.

4. Who receives your data

Our concierge team, bound by confidentiality.

The suppliers of the services you book (hotels, airlines and operators, yacht charters, chauffeur companies, restaurants, boutiques), who receive only what the booking requires.

Our technical providers, acting on our instructions: Apple (Sign in with Apple, iCloud and push notifications), Google Firebase (database, authentication, notifications, crash and performance reports, usage analytics), Revolut (card and Apple Pay payments), Whop (payment pages), Vercel (website hosting), AviationStack (airport search, receiving only the city you type), and Meta / WhatsApp when you choose to contact us through WhatsApp.

Public authorities when the law requires it.

5. Transfers outside the European Union

Some providers process data in the United States. These transfers rely on the European Commission’s adequacy decision for the EU-US Data Privacy Framework or on Standard Contractual Clauses, together with additional safeguards.

6. How long we keep it

Account and request data: for as long as your account is open, then deleted or anonymised when you delete your account.

Identity data after account deletion: 1 year, as required of online service providers in France (Decree 2021-1362), accessible only on judicial request.

Invoices and transaction records: 10 years (French Commercial Code, art. L123-22), in anonymised form after account deletion.

Messages with your concierge: anonymised when you delete your account.

Crash and performance diagnostics: up to 90 days.

7. Your rights

You can access, correct, delete and receive a copy of your data, object to or restrict certain processing, and withdraw your consent at any time.

You can delete your account yourself in the app: Settings › Delete my account. Your personal data is erased immediately; only the records the law requires us to keep are retained, anonymised.

To exercise any right, write to support@secunary.fr. You may also lodge a complaint with the CNIL (www.cnil.fr).

8. Security

All exchanges between the app and our servers are encrypted. Access to your data is restricted to the people and systems that need it, and every request from the app is checked for authenticity (Apple App Attest).

9. Age

Secunary is intended for adults. We do not knowingly collect data from anyone under 18.

10. Changes

We may update this policy. The version and date at the top tell you which version applies; significant changes are announced in the app.