Privacy policy

Clery Ads takes the protection of your personal data seriously. This policy explains what data is collected on aclery.com, why it is collected, how long it is kept and how to exercise your rights. It is an English translation of the French policy, provided for convenience. The site is operated from France and French law applies.

1. Data controller

2. Data collected and purposes

2.1 Audience measurement

If you consent to it, audience measurement is carried out with Google Analytics 4, deployed through Google Tag Manager. The data concerned is technical and browsing data: pages viewed, time spent, device and browser type, the source that brought you to the site, the measurement identifier assigned by the tool, and approximate location data derived from the IP address.

Purpose: understanding how the site is used, measuring how effective the content is, and improving the pages. No automated decision is made from this data, and no named commercial profile is built from browsing alone.

Legal basis: your consent, collected through the banner described in section 5. You can withdraw it at any time, with no effect on how the site works.

2.2 Booking a call

Calls are booked through an external scheduling service, Calendly. The information you enter there, in particular your name, email address and chosen time slot, is collected and processed by Calendly on its own platform, then passed to Clery Ads in order to arrange the conversation.

Purpose: arranging and confirming the requested meeting, then communicating with you about it.

Legal basis: steps taken at your request prior to entering into a contract.

The processing carried out by Calendly is governed by its own privacy policy, which we invite you to read: calendly.com/privacy.

2.3 Contact by email

If you write to hello@aclery.com, your email address, the content of your message and any information you choose to include are processed in order to answer your request and, where relevant, to follow up on the business relationship that follows.

Legal basis: the legitimate interest of Clery Ads in answering the enquiries it receives, then performance of the contract if a collaboration begins.

There is no contact form and no newsletter sign up on this site.

3. Who receives the data

Your data is never sold, rented or passed to third parties for advertising purposes. It is accessible to Anthony Cléry and to the technical providers strictly needed to run the site and the business:

• Hostinger International Ltd, website hosting.
• Google Ireland Limited, audience measurement through Google Analytics 4 and Google Tag Manager, only after consent.
• Cybot A/S, collection and record of consent through the Cookiebot solution.
• Calendly LLC, online scheduling.
• The professional email provider used for email exchanges.

Some of these providers may process data outside the European Union. Where that happens, transfers are covered by the mechanisms set out in the GDPR, in particular the standard contractual clauses of the European Commission or an adequacy decision.

4. Retention periods

• Audience measurement data: 14 months at most from collection.
• Record of cookie consent: 12 months, matching the validity period of the choice expressed.
• Data linked to a booking request or an email exchange with no follow up: 3 years from the last contact.
• Data linked to a contractual relationship: the duration of the contract, then the statutory retention period applicable to accounting and commercial records.

5. Cookies and trackers

On your first visit, a consent banner managed by the Cookiebot solution lets you accept or refuse the cookies that are not strictly necessary to run the site, in particular audience measurement cookies.

Until you give your consent, no measurement cookie is set and the corresponding tags do not fire. Refusing has no downside: the whole site remains accessible and works normally.

Only strictly necessary trackers remain, in particular the one that stores your choice so that you are not asked again on every page. You can change or withdraw your consent at any time by reopening the banner from the cookie settings link displayed by the consent solution, or by deleting cookies in your browser settings.

6. Security

The site is served over HTTPS, and access to the tools used is protected by strong passwords and two factor authentication wherever the service allows it. Clery Ads implements reasonable measures to preserve the confidentiality and the integrity of the data processed.

7. Your rights

Under the General Data Protection Regulation and the French Data Protection Act, you have the following rights over your data:

• right of access, and to obtain a copy of the data concerning you,
• right to rectification of inaccurate or incomplete data,
• right to erasure, within the limits allowed by law,
• right to restriction of processing,
• right to object, in particular to processing based on legitimate interest,
• right to portability of the data you have provided,
• right to withdraw your consent at any time, where processing relies on it,
• right to set instructions on what happens to your data after your death.

To exercise these rights, write to hello@aclery.com. You will receive an answer within one month of the request being received. Proof of identity may be requested where there is reasonable doubt about the identity of the person making the request.

If, after contacting us, you believe your rights are not being respected, you can lodge a complaint with the French data protection authority: www.cnil.fr.

8. Changes to this policy

This policy may be updated to reflect changes to the site, to the tools used or to the applicable regulation. The date it was last updated is shown at the top of this page.