Privacy policy
Last updated: November 2026. This is a translation; in the event of any discrepancy, the French version prevails.
This policy explains what personal data we collect on this website, why, who has access to it and how to exercise your rights, in accordance with the General Data Protection Regulation (GDPR) and the French Data Protection Act. This is a translation; in the event of any discrepancy, the French version prevails.
Data controller
Qréactive, a simplified joint-stock company (SAS) with share capital of €5,000, RCS Nice 842 402 539, with its registered office at c/o Fiduciaire On Line, 22 boulevard Dubouchage, 06000 Nice, France, trading as Académie de la Qualité efficace (A-QE). For any question about your data: contact@a-qe.eu.
The data we collect and why
| Situation | Data | Purpose | Legal basis |
|---|---|---|---|
| Contact form | First name, last name, work email, company, topic and message; phone and job title if you provide them | To respond to your request and discuss your situation | Pre-contractual measures taken at your request, and your consent |
| FOCUS and BOOSTER assessments | First name, last name, work email, company; job title if you provide it | To give you access to the analysis tool and contact you about your assessment | Your consent |
| Polton webinar replay | Work email | To give you access to the replay; to contact you by email about Polton, only if you ticked the box provided | Your consent, which can be withdrawn at any time |
| Online purchases (training, Memory Box…) | Identity, contact details, billing data | To process the order, invoice and provide follow-up | Performance of the contract and legal obligations |
| Browsing the website | Technical data (IP address, browser type, pages viewed) | To ensure the website works and is secure | Our legitimate interest |
The FOCUS and BOOSTER analysis tools run directly in your browser: the file you upload isn’t sent to any server and nothing is kept when you close the page. Only the summary of your indicators reaches us, if you choose to send it to us by email. We neither see nor store your bank details, which are entered directly with our payment provider.
Who has access to your data
Your data is managed by the Académie de la Qualité efficace and its partner Sinfony: the website’s forms feed the Sinfony group’s HubSpot contact management tool, where the data is hosted. It is neither sold nor rented. It may be passed on to our partner Bio15Pharma, strictly for the purposes of your request, when your project directly concerns them.
We also use the following service providers, which process data on our behalf:
- HubSpot, for forms and contact management (Sinfony group account, hosted in the European Union);
- Stripe, for online payments;
- o2switch, for website hosting, in France.
Some links on the website lead to third-party services that apply their own privacy policies: the online training platform, the newsletter (Substack), the WhatsApp community and the Polton demo request form, managed by our partner Gordios.
Transfers outside the European Union
The website is hosted in France. Some of our service providers (HubSpot, Stripe) are based in the United States or may process data there. These transfers are governed by the EU–US Data Privacy Framework and, where applicable, by the European Commission’s standard contractual clauses.
Retention periods
- Contact requests and prospects: 3 years from our last exchange;
- Clients: for the duration of the business relationship, then 3 years;
- Invoices and accounting records: 10 years, as required by the French Commercial Code;
- Technical browsing data: 12 months maximum.
Cookies
This website uses neither advertising cookies nor audience measurement cookies, and loads no tracking scripts. That’s why no consent banner is displayed.
Only one strictly necessary cookie may be set: when you fill in the access form for the Polton webinar replay or an assessment tool, a technical cookie (“aqe_acces”) remembers for 180 days that you have access, so you don’t have to fill in the form on every visit. It contains no personal data and serves no other purpose.
Your rights
You can at any time access your data, have it rectified or erased, object to its use, restrict its processing, request its portability and withdraw your consent. Every email we send contains an unsubscribe link.
To exercise your rights, write to us at contact@a-qe.eu. We reply within one month.
If you believe your rights are not being respected, you can lodge a complaint with the CNIL, the French data protection authority (www.cnil.fr).
Security
We implement appropriate technical and organisational measures to protect your data: encrypted connection (HTTPS), access limited to authorised people only, service providers selected for their level of security.
Changes
This policy may change. The date of the last update is shown at the top of this page.