1. Data controller
The data controller is Cédric Leblond, sole proprietor (SIREN 943 404 400), 4 rue Éric Tabarly, 35240 Retiers, France, publisher of the site https://dynamidoxa.com.
Any request relating to your personal data can be sent via the contact form: https://dynamidoxa.com/contact.
2. General principles
The processing of personal data on this site respects the following principles:
- Minimization: only data strictly necessary for the service provided is collected.
- Purpose: data is collected for explicit and legitimate purposes.
- Transparency: each user is informed of the collection and of their rights.
- Security: data is stored securely and is not resold.
3. Data collected and purposes
Personal data is collected only in the following contexts:
3.1. Contact form
- Data collected: name, email address, project type, message.
- Purpose: respond to your request and set up a quote or commercial exchange.
- Legal basis: explicit consent (form submission) and legitimate interest in responding to prospects.
- Retention period: 3 years from the last contact, unless early deletion is requested.
3.2. Purchase via Whop
- Data collected (transmitted by Whop): first name, last name, email address, country, NinjaTrader Machine ID.
- Purpose: license key delivery, support management, invoicing and compliance with accounting obligations.
- Legal basis: performance of the sales contract, and legal obligations (invoicing, accounting).
- Retention period: 10 years for invoices (French accounting obligation); the license lifetime for the Machine ID.
Payments are processed exclusively by Whop Inc. DynamiDoxa never has access to Customers' banking data. Whop's privacy policy is available at https://whop.com/privacy.
3.3. Hosting technical logs
- Data collected automatically by the host OVHcloud: IP address, user-agent, timestamp, requested URL.
- Purpose: service security, abuse detection, technical diagnostics.
- Legal basis: legitimate interest (site security), and legal obligations applicable to the host.
- Retention period: limited periods set by OVHcloud, in accordance with its own contractual commitments.
3.4. Analytics — Google Analytics 4
The site uses Google Analytics 4 (GA4) — a service provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) — to measure audience and improve the user experience.
Data collected: pages visited, time on site, traffic source (organic search, direct link, social network), device type, browser, language, approximate country. The IP address is anonymized (`anonymize_ip: true` parameter) before any recording by Google: only a prefix is retained, which prevents precise identification of the visitor.
Purpose: anonymized audience measurement, identification of the most-visited pages, optimization of site performance and ergonomics. No data is used for advertising purposes or shared with third-party advertisers.
Cookies placed: GA4 places a technical cookie `_ga` (anonymous client ID, 13-month duration) and a session cookie `_ga_<ID>` (13-month duration). These cookies contain no personally identifiable information.
Retention period: 14 months maximum (GA4 default setting), after which the data is automatically deleted by Google.
Transfers outside the EU: Google Analytics is administered from Google Ireland (EU), but the infrastructure may involve transfers to Google LLC servers in the United States. These transfers are governed by the standard contractual clauses of the European Commission and the EU-US Data Privacy Framework adopted in 2023.
4. Cookies
The site does not use advertising tracking cookies. Cookies placed are limited to: (a) cookies strictly necessary for the operation of the site (e.g. language preference), which do not require prior consent in accordance with CNIL recommendations, and (b) Google Analytics 4 audience-measurement cookies described in section 3.4 above, configured in anonymized mode.
You can at any time refuse the placement of analytics cookies via your browser settings, by installing the Google Analytics Opt-Out add-on, or by using a private browsing mode. No loss of functionality results.
5. Data recipients
Personal data is only shared with third parties strictly necessary for the performance of the service:
- Whop Inc.: payment and license distribution platform.
- Google Ireland Limited: anonymized audience measurement (Google Analytics 4), datacenters primarily in the EU with regulated transfers to the United States (EU-US Data Privacy Framework).
- OVH SAS (OVHcloud): technical hosting of the site, with datacenters located in France.
- Professional email provider: receiving and sending emails related to contact requests and support.
No personal data is resold or transferred to third parties for commercial or advertising purposes.
6. Transfers outside the European Union
The site is hosted by OVH SAS, a French company whose datacenters are located within the European Union; no transfer outside the EU occurs in connection with hosting. However, as the payment service provider Whop Inc. is established in the United States, certain transaction-related data may be transferred outside the European Union. These transfers are carried out within the framework of the guarantees provided by the GDPR (standard contractual clauses of the European Commission or equivalent mechanisms).
7. Your rights
In accordance with the General Data Protection Regulation (GDPR) and the French Data Protection Act, you have the following rights:
- Right of access: obtain confirmation of whether your data is being processed and receive a copy.
- Right of rectification: correct inaccurate or incomplete data.
- Right to erasure: request the deletion of your data, subject to legal retention obligations.
- Right to object: object to the processing of your data on legitimate grounds.
- Right to restriction: request temporary suspension of processing.
- Right to portability: receive your data in a structured and reusable format.
- Right to withdraw consent at any time, where processing is based on consent.
These rights can be exercised by contacting the publisher via the contact form. A response will be provided within a maximum of one month.
In case of a response deemed unsatisfactory, you may lodge a complaint with the French data protection authority (CNIL): https://www.cnil.fr.
8. Security
The publisher implements appropriate technical and organizational measures to protect personal data against unauthorized access, loss or disclosure. The site is delivered exclusively over HTTPS, and emails are exchanged via professional providers using encrypted protocols.
9. Minors
The products and services marketed are intended for adult traders. The publisher does not knowingly collect data concerning minors. If a parent or legal guardian finds that a minor has provided us with data, they may request its deletion via the contact form.
10. Policy modification
This policy may be modified at any time to reflect regulatory or technical developments on the site (in particular when deploying the analytics tool). The date of the last update appears at the top of the document. Customers with an active license will be informed of any substantial modification.