Privacy Policy

1. Data controller

Ouchiner — a simplified joint-stock company with a sole shareholder (SASU) with share capital of €1,000, registered with the Épinal Trade and Companies Register under number 106 905 938, registered office at 39 rue Alix le Clerc, 88500 Poussay, France, represented by its president Mr Stéphane Perry.
Contact: [email protected] — Website: ouchiner.com

2. Data we collect

Data	Purpose	Legal basis	Retention
Email address	Account creation, transactional communications	Performance of the contract	Until the account is deleted (Creator Partners: see below)
Password (hashed, PBKDF2 100,000 iterations)	Authentication (professional, shop and ambassador areas)	Performance of the contract	Lifetime of the account
Phone number (Pro alerts with SMS option)	Sending alerts by SMS	Performance of the contract	Lifetime of the account; masked in logs (last 4 digits retained)
Shop / event information	Display on the map	Performance of the contract	Duration of the subscription
Uploaded photos	Illustrating the listing	Performance of the contract	Duration of the subscription; their metadata, including GPS location, is removed on upload
Messages, photos and PDFs exchanged through the messaging service	Direct communication between buyers and dealers (contacting a listing)	Performance of the contract	365 days, then automatic purge; attachments stored with Cloudflare (R2); everything erased when the account is deleted. Photos lose their metadata, including GPS location. If one of the participants reports the conversation, the person in charge of moderation may read it, solely to handle that report; every reading is logged.
“What I’m looking for” searches (text, centre and radius)	Letting you know when someone has the item; showing the search, without your name, to professionals and buyers in the area	Performance of the contract	While the search is open, then 12 months after it is closed; deleted with your account or your subscription. The messages and replies it triggers: 12 months. A phone number, email address or link written in a search is not shown to others.
Report of content (explanation; name and email optional)	Handling the report, acknowledging it and telling you our decision	Legal obligation	12 months
Payment data	Payment processing (via Stripe)	Legal obligation	10 years (accounting obligation)
GPS location (optional)	"Near me"; centre of an alert area, if you choose it that way	Consent	For an alert: stored as the centre of your area for as long as the subscription exists (and reused by your “What I’m looking for” searches), after being rounded to about one kilometre. Elsewhere: it stays on your device, or is only sent for the search you asked for; a route calculation sends a rounded value to Mapbox.
Sign-up IP address	Proof of consent, abuse prevention	Legitimate interest	13 months maximum
Data of an unsubscribed subscriber	Allow re-subscription (link valid for 30 days), then erasure	Legitimate interest	12 months after unsubscribing, then automatic and permanent deletion

3. Cookies and trackers

OuChiner uses no advertising cookies and no profiling trackers, and no consent banner is required: we only use cookies strictly necessary for the service (session, preferences) together with audience-measurement and quality tools that work without cookies and without personal data. The Mapbox mapping library tries to write a technical identifier into your browser's local storage, for its own usage measurement: we delete it and prevent it from being written.

Cookie / Tool	Type	Duration	Purpose
session, admin_session, amb_session	Necessary	Session (8h to 30 days)	Keeping the user signed in
localStorage (token, geolocation)	Necessary	Persistent	PWA authentication + cached position for the "near me" feature
Plausible Analytics	Anonymous statistics	No cookies	Visit counting, with no individual tracking or profiling. Exempt from consent (per the CNIL).
Cloudflare Web Analytics	Anonymous statistics	No cookies	Performance and traffic, with no individual tracking
Sentry	Error monitoring (cookieless)	30 days	Detection of JavaScript bugs in no-personal-data mode (no IP address, no identity, no session recording). Basis: legitimate interest.

Since no tracking cookie is set, there is no consent choice to manage. To object to audience-measurement or quality processing (legitimate interest), write to [email protected].

4. Data sharing — processors

Your data is never sold. It may be shared with the following processors, strictly as required to deliver the service:

• Stripe (payments) — email address and card details transmitted when a payment is made. Policy: stripe.com/privacy
• Resend (transactional emails) — email address transmitted to send confirmations, alerts and notifications, and, for Creator Partners, the invoices issued in their name (as attachments). Resend stores messages in the United States (see below). Policy: resend.com/legal/privacy-policy
• OVH SMS (SMS delivery for Pro subscribers who have taken the SMS option) — phone number transmitted only at the moment of sending. Policy: ovhcloud.com/en/personal-data-protection
• Mapbox (mapping, geocoding and route calculation) — address search queries may include the terms you type; a route calculation sends a starting point (your position, rounded, or the address you chose) and a destination. Policy: mapbox.com/legal/privacy
• Cloudflare (hosting and database) — all service data is hosted with Cloudflare. Policy: cloudflare.com/privacypolicy
• GitHub (Microsoft — backups) — a daily copy of the database (accounts, listings, subscriptions) is stored in a private repository, so the service can be restored after an incident. Policy: docs.github.com
• Sentry (JavaScript error monitoring, in no-personal-data mode) — policy: sentry.io/privacy
• Plausible / Cloudflare Web Analytics (anonymous, cookieless statistics — see §3)
• Open-Meteo (weather forecasts for flea-market alerts) — the approximate GPS coordinates of the event are transmitted. No personal data. Policy: open-meteo.com/en/terms
• Anthropic (artificial-intelligence assistance — Claude API) — depending on the feature, the following may be transmitted: descriptions and photos of items and listings published by dealers (analysis and drafting of listings), the content of submitted event announcements, the public posts of our social-media accounts, and the messages received on those accounts (text and the sender's public handle) in order to prepare a draft reply. This data is not used to train the models. Policy: anthropic.com/legal/privacy
• OpenAI (generating the illustrations for our social-media posts) — no user data is transmitted: only scene instructions written by OuChiner. Policy: openai.com/policies/privacy-policy
• DataForSEO (keyword research for the blog) — no user data is transmitted
• French company search API (annuaire-entreprises.data.gouv.fr) — the SIRET number entered by a Creator Partner is transmitted to this public government API in order to verify that the establishment exists and is active, and to retrieve its legal name and address.
• VIES (the European Commission's VAT-number validation service) — the intra-EU VAT number of a Creator Partner who declares charging VAT is checked there. The Commission acts on behalf of the Member States' tax authorities and does not retain the data; we keep only the result of the check.
• Billit (accredited electronic-invoicing platform) — for Creator Partners only, and at the time of a payment: legal name, SIRET number, registered address, VAT number where applicable, email address and bank details, as required to issue the self-billed invoice. Billit itself also sends a copy of the invoice to that email address. Policy: billit.eu/en/privacy

Ambassador programme

If you are an ambassador, your Instagram account — username, biography text and website — is read regularly through Meta's official interface, solely to check that your OuChiner link appears there, and only if it is a public professional account. For each check, we keep its date, the username read and its result (link found, link missing or account unreadable); if we look at your profile ourselves and don't find the link, we record the date of that finding. These notes are deleted at the daily check that follows the deletion of your account. The biography text is not kept; only your account's display name, shown on your ambassador card, is cached for 24 hours. Legal basis: performance of the contract between us (Article 6(1)(b) GDPR).

Visits generated by your link are counted without cookies. For each one we store a fingerprint of the visitor's IP address (a salted hash: it does not reveal the address, but it is pseudonymised data, not anonymous data), their country, their type of device and the date; the fingerprint is used solely to avoid counting the same person twice and to exclude your own visits, never to identify them. The browser used and the referring page, which we use to filter out bots and to count arrivals from the ambassadors page, are deleted after 90 days; the rest is kept for as long as your ambassador account exists, and deleted with it.

Creator Partner programme

If you become a Creator Partner, we additionally process the following in order to carry out your orders, pay you and issue invoices in your name (Creator Partner self-billing mandate):

• Your Instagram account: username, permanent identifier, display name and profile picture, number of followers and posts, read through Meta's official interface — only for a public professional account. Your follower count is recorded every day while you are signed up: it sets the price of an order. When you declare a video, a carousel or a tag posted (“It’s posted”), the list of your latest posts is read too — their type, date and caption — to find the post there: posted after the order was accepted and with your link (or @ouchiner.official, for a tag). Until it is found, that list is read again every night; the post is read again before approval and before payment.
• The post you declare: the link to and date of the post found on your account — or of a post found there that could not be matched to your order — and, if you attach one, the screenshot, stored but never published: only the OuChiner team views it, and every viewing of a screenshot is logged.
• Opens of your download link (ouchiner.com/app?c=…): a simple monthly count, shown in your area — nothing is kept about the people who open it.
• Your SIRET number, together with the legal name and registered address of your business, retrieved automatically from the SIRENE register — mandatory details on an invoice.
• Your intra-EU VAT number, derived from your SIREN number, if you declare that you charge VAT.
• Your bank details (IBAN and account holder), encrypted at rest and decrypted only at the moment of a transfer. Every access is logged.
• Your orders (purchase orders, statuses, dates) and the invoices issued in your name.

Legal basis: performance of the contract between us (Article 6(1)(b) GDPR) and compliance with our accounting and tax obligations (Article 6(1)(c)). Retention: follower records, 180 days; refused, expired or cancelled requests, and orders not delivered or not compliant, 12 months; paid orders — purchase order, post verification records and invoice — 10 years (Article L123-22 of the French Commercial Code). If you delete your account, your pending requests are cancelled, and your bank details are kept only as long as needed to pay for a post already declared (“It’s posted”), then erased. Your email address, for its part, is kept long enough to send you the approval, the payment and the invoice for your last posts, then erased once the last invoice has been sent, 120 days at most after the last payment. Your billing identity is then erased too if no payout has taken place, as are your username and profile name. If your requests were suspended, your SIRET number and your Instagram account identifier are kept for 12 months after the suspension (and as long as your last orders are kept), so that a suspension cannot be circumvented by creating a new account, then erased. If you leave the programme without deleting your account, your bank details are erased as soon as nothing is owed to you, and so is your billing identity, unless a payout has taken place (it then appears on your invoices); if your requests are suspended, your SIRET number and your Instagram account identifier remain for as long as your account exists.

If you choose to, your profile is featured among the ambassadors with the label “Collaboration”.

Transfers outside the European Union

Some of these processors are established in the United States or may transfer data there — in particular Cloudflare, GitHub, Stripe, Sentry, Mapbox, Resend, Anthropic and OpenAI. Depending on the provider, these transfers are governed by the European Commission adequacy decision of 10 July 2023 on the EU—US Data Privacy Framework, where the provider is certified under it, and/or by the European Commission's standard contractual clauses incorporated into its data-processing agreement. You can obtain a copy of the safeguards applicable to a given provider by writing to [email protected].

The other providers mentioned — OVH, Plausible Analytics and Open-Meteo — are established in the European Union.

5. Your rights

Under the GDPR, you have the following rights:

• Right of access — obtain a copy of your data
• Right to rectification — correct inaccurate data
• Right to erasure — request deletion of your account and data
• Right to data portability — receive your data in a structured format
• Right to object — object to certain processing
• Right to restriction of processing — request that use of your data be temporarily frozen, for example while we verify its accuracy (Article 18 GDPR)
• Right to withdraw your consent — at any time, for processing based on consent. This applies to GPS location: simply withdraw the location permission in your browser or device. Withdrawal does not affect the lawfulness of processing carried out beforehand.

You can also act yourself: “Delete my account” in your area (buyer, shop, organiser); and, from “My alerts”, “Download my data” and “Permanently delete my data”.

Our services are not intended for people under 18. If you think a minor has sent us data, write to us: we will delete it.

One thing survives erasure, and it is there to protect you. If you have asked us to stop writing to you — unsubscribing, marking us as spam, or an unreachable address — your email address stays on a do-not-contact list. Without it, nothing would stop us writing to you again the day your address reappeared in a data source. That list holds only the address, the reason and the date; its only purpose is to send you NOTHING. If you would still rather be removed from it, write to us: we will do it — knowing that nothing will then stop us writing to you again.

To exercise these rights: [email protected]
We undertake to respond to any request within a maximum of 1 month of receiving it.
You may also lodge a complaint with the French supervisory authority, the CNIL, or with the supervisory authority of the Member State of your habitual residence, your place of work, or the place of the alleged infringement (Article 77 GDPR).

6. Security

Passwords are stored in hashed form using PBKDF2-SHA256 with 100,000 iterations and a unique salt. One-time codes (SMS, email) are generated by a CSPRNG (crypto.getRandomValues), limited to 3 attempts, and expire after 10 minutes. Data is hosted on Cloudflare infrastructure with TLS encryption. Access to the data is restricted to the data controller alone.

Backups. So that the service can be restored after an incident, our data is copied every day: the database to a private repository at GitHub (Microsoft), kept for 30 days (14 weeks for accounts and listings); photos and attachments to a copy at Cloudflare. Data deleted from the service disappears from these copies within 100 days at the latest.

7. Contacting us about your data

OuChiner has not appointed a data protection officer, as this is not required for its activity. For any question or request: Stéphane Perry, president — [email protected] — Ouchiner, 39 rue Alix le Clerc, 88500 Poussay, France.