Privacy policy

1Data controller

Company

FIRST AGENCY LTD

Address

167–169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom

Company Number

05260548

VAT

GB 850 234 845

2Data that may be collected

• Account data: company name, type of structure, VAT number, login email.
• Member file data: name of the manager, address, telephone, site URL, information useful for processing the order.
• Order data: chosen analysis, purchased tier, invoice, amount, history.
• Analysis data: submitted URL, public pages analysed, signals observed, generated report.
• Technical data: IP address, browser, security logs, login events, abuse prevention.

3Purposes

• Creation and management of the member account.
• Order processing, invoicing and sales follow-up.
• Generation and delivery of the analyses.
• Securing the service, fraud prevention and referral management.
• Service improvement and administrative or legal obligations.

4AI-assisted processing

Arkhoni analyses rely on automated mechanisms and may use artificial intelligence tools to analyse certain public content and produce recommendations. Reports resulting from this processing may contain errors, approximations or omissions. They must not be interpreted as absolute certainties.

5Legal basis

Processing is based, depending on the case, on the performance of the ordered service, the publisher's legitimate interest in operating and securing the platform, compliance with legal obligations and, where necessary, consent.

6Recipients

Data may be accessible to the service publisher and to its technical providers acting for hosting, security, emailing, payment, authentication, document generation or certain AI-assisted automated processing.

7Designated representative in the European Union

As the publisher First Agency Ltd is established in the United Kingdom (a third country since 1 January 2021), a designated representative within the meaning of Article 27 of the General Data Protection Regulation (GDPR) is in place to respond to requests from persons residing in the European Economic Area. Their contact details are published in the legal notice and can be reached via the contact form by specifying "GDPR, EU representative" in the subject line.

8Retention periods

The retention periods applied by Arkhoni are as follows:

• Active member account: for the entire duration of the contractual relationship, then 3 years from the account's last activity for commercial prospecting purposes (Article L34-5 of the French CPCE and CNIL guidelines).
• Invoices, quotes and accounting records: 10 years from the close of the financial year (Article L123-22 of the French Commercial Code).
• Technical and security logs: a maximum of 13 months from their recording (CNIL recommendation).
• Analysis reports and generated documents: for the duration of the account, then kept for 12 months after deletion as a limited archive to allow exceptional restoration on request.
• Correspondence, support exchanges and tickets: 3 years from the last interaction.

9Your rights

You may request access to, rectification or erasure of your data, as well as restriction of or objection to certain processing where applicable. You may also request further information about the general logic of the automated processing implemented.

10Exercising your rights

For any request relating to your personal data, the official channel is the contact form available at the bottom of the home page. Specify "GDPR" in the subject line for priority handling by the designated person. A response is provided within a maximum of one month, extendable by two months for complex requests.

11Complaints to the competent authority

If you believe your rights are not being respected, you may lodge a complaint with:

• Residents of France: the Commission nationale de l'informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07.
• Residents of another EU/EEA state: the data protection authority of your country of residence (list available on the European Data Protection Board website).
• Residents of the United Kingdom: the Information Commissioner's Office (ICO).