Controller
Taner OKUR, individual entrepreneur (entrepreneur individuel, EI) established in France, trading as OLHYN. SIRET 793 428 715 000 31, RCS Pontoise 793 428 715. Contact: through our contact page.
OLHYN is established in France: its processing is governed by the General Data Protection Regulation (GDPR), which applies in Germany in the same way, and by the French Data Protection Act.
Data collected
The website collects data in the following cases:
Cookie-free visit measurement (Cloudflare Web Analytics): number of visits and page views, page viewed, referring page, country, browser type and page load times, combined into anonymous statistics. No cookie or identifier is placed on your device, and your browsing is not tracked from one website to another: this measurement therefore does not require your consent.
Audience measurement (Google Analytics through Google Tag Manager): pseudonymised browsing data (pages viewed, session length, device type, traffic source), only after your explicit consent through the cookie banner.
Behaviour analysis (Microsoft Clarity through Google Tag Manager): pseudonymised session recordings and heat maps to understand how the site is used (movements, clicks, scrolling), only after your explicit consent through the cookie banner.
Technical error monitoring (Sentry): when a technical error occurs, a report with the error message, the page concerned and the browser type is sent to Sentry so that we can fix it. Your IP address is never sent, and no video or recording of your browsing is made.
Push notifications: if you agree to receive notifications, a technical subscription identifier is stored with our hosting provider, with no name or email attached.
Booking (cal.eu): when you book a call, your name, email and any message are processed by the booking tool cal.eu, published by Cal.com, under its own privacy policy.
Contact by email: the data you choose to send us by email (name, email address, message) is processed to answer your request.
Article comments: if you post a comment, your name and message are kept; your email is optional and never shown. A non-reversible technical fingerprint of your IP address is computed to limit abuse, together with an anti-bot check. Every comment is reviewed by hand before publication.
Likes on articles: no personal data is collected; only a non-reversible fingerprint of your IP address is kept so that the same visitor is not counted twice.
Maps (Google Maps): pages showing a service area in France offer a Google Maps map. It loads only after you accept cookies in the banner, or if you click the button that shows the map. Google then receives your IP address and sets its own cookies in your browser. Until the map is shown, no request is sent to Google.
Business relationship management: when you contact us or become a client, your details and the history of our exchanges are kept in a customer relationship tool that we host ourselves on a server located in France. It holds your business contact details, the follow-up of our exchanges, your quotes and invoices, and the emails we exchange, attached automatically to your record. This data does not come from your browsing: it is what you give us in the course of our business relationship.
Legal bases
Consent (article 6(1)(a) GDPR): audience measurement (Google Analytics and Microsoft Clarity cookies), map display (Google Maps), push notifications, posting a comment.
Legitimate interest (article 6(1)(f) GDPR): website security, anonymous visit measurement (Cloudflare Web Analytics), technical error monitoring (Sentry), preventing abuse of comments and likes (IP fingerprint, anti-bot check), and following up the business relationship with prospects and clients in our management tool.
Performance of a contract or pre-contractual steps (article 6(1)(b) GDPR): booking a call, answering contact requests.
Cookies and similar technologies
Storing information on your device, or reading it, requires your consent unless it is strictly necessary for the service you asked for. This is the rule of the ePrivacy Directive, which section 25 of the German TDDDG and French law both transpose. This website uses the following cookies:
Strictly necessary cookies: remembering your cookie choice. No consent required.
Analytics cookies (Google Analytics, Microsoft Clarity): set only after your consent through the cookie banner. You can withdraw consent at any time by deleting your cookies or using the banner.
Google Maps cookies: set by Google only when a map is shown, that is after you accept cookies in the banner or click the map button. You can delete them at any time in your browser settings. Maps appear only on pages about service areas in France, not on the pages for Germany.
Technical error monitoring (Sentry) and visit measurement (Cloudflare Web Analytics) set no cookie and work independently of cookie consent. Apart from the cookies listed above, no other tracker is placed in your browser.
Retention periods
Analytics data: 14 months (Google Analytics setting).
Visit statistics (Cloudflare Web Analytics): kept by Cloudflare in aggregated, anonymous form, with no data that could identify a visitor.
Behavioural analysis (Microsoft Clarity): session recordings kept for 30 days by Microsoft, except a random sample and recordings marked as favourites, kept for up to 9 months; heatmaps available for up to 9 months.
Technical error reports (Sentry): 30 days, then deleted automatically.
Push subscriptions: until you unsubscribe or the subscription expires technically.
Booking data: kept by cal.eu (Cal.com, Inc.) under its policy, and by OLHYN for the length of the business relationship, then 3 years for prospecting.
Contact emails: for as long as needed to handle the request, then 3 years at most.
Comments: published comments are kept as editorial content; rejected or unmoderated comments may be deleted during moderation.
Likes: the technical fingerprint of the IP address is kept while the like remains active, with no time limit separate from the content concerned.
Business management data: for the length of the business relationship, then 3 years from the last contact for a prospect. Accounting records follow their own legal retention periods.
Emails attached to your record: on the same terms as the record they relate to.
Transfers outside the European Union
Some data may be transferred outside the EU through the following providers:
Cloudflare, Inc. (United States): website hosting, anonymous visit measurement, storage of push subscriptions and comments in databases created in Europe, and anti-bot checks. Cloudflare participates in the EU-US Data Privacy Framework.
Google LLC (United States): audience measurement through Google Analytics and map display through Google Maps. Google participates in the EU-US Data Privacy Framework.
Microsoft Corporation (United States): behaviour analysis through Microsoft Clarity. Microsoft participates in the EU-US Data Privacy Framework.
Cal.com, Inc. (United States), publisher of the booking tool cal.eu: management of call bookings.
Stripe Payments Europe, Limited (Ireland): online payment of a paid consultation booked through cal.eu, under Stripe's privacy policy. Stripe may transfer this data to Stripe, Inc. (United States), which participates in the EU-US Data Privacy Framework.
Dropbox, Inc. (United States): archiving of the accounting records (quotes, invoices, receipts) of our clients and suppliers. Dropbox participates in the EU-US Data Privacy Framework.
Infomaniak Network SA (Switzerland): hosting of our mailbox; the emails you send us are received and stored there. Switzerland benefits from an adequacy decision of the European Commission.
SMTP2GO Ltd (New Zealand): delivery of the emails we send you from our customer relationship management tool (follow-up of your requests). The service does not keep the content of emails, apart from occasional anti-abuse checks. New Zealand benefits from an adequacy decision of the European Commission.
Our internal management tools are hosted by Oracle Corporation on a server located in Paris: the business data they hold does not leave the European Union. These transfers are covered by appropriate safeguards (Data Privacy Framework, standard contractual clauses) under the GDPR. Technical error reports (Sentry) are not transferred outside the European Union: the account used is hosted in the European region (Frankfurt).
Your rights
Under the GDPR, you have the following rights:
Access: confirmation of whether data about you is processed, and a copy of it.
Rectification: having inaccurate or incomplete data corrected.
Erasure: having your data erased under the conditions set by law.
Objection: objecting to processing on grounds relating to your situation.
Restriction: asking for processing to be restricted in the cases provided for by the GDPR.
Portability: receiving your data in a structured, commonly used and machine-readable format.
Withdrawal of consent: at any time (cookies, push notifications), without affecting processing carried out before.
To exercise them, write to us through our contact page. We answer within the time the GDPR sets: one month from receipt of the request, which may be extended by two months given its complexity or the number of requests, in which case we tell you so within the first month.
You may lodge a complaint with a supervisory authority, in particular in the Member State where you live or work. Our lead authority is the French CNIL. In Germany, data protection in the private sector is supervised by the data protection authority of each federal state; the Federal Commissioner for Data Protection and Freedom of Information lists them on its page of state authorities.
Updates
This privacy policy may change at any time. The date of the last update is shown at the top of this page.