Legal

Privacy policy

Last updated : 26 October 2026 · draft v1

This policy describes the processing of personal data carried out by ALL4FEED (“we”) in connection with the FeedSourcing platform, in accordance with Regulation (EU) 2016/679 (GDPR) and the French Data Protection Act of 6 January 1978 as amended. It applies to visitors, account holders, persons mentioned in the directory and contacts of listed companies. In case of discrepancy, the French version prevails.

FeedSourcing is a professional (B2B) service: the data processed concern persons acting in the course of their professional activity.

Content provided for information only. The final legal text remains to be completed and validated by counsel.

1.Controller and contact

Controller: ALL4FEED, [TO COMPLETE: legal form, registered office, SIREN].

Data Protection Officer / GDPR contact: [TO COMPLETE: name or position, dedicated e-mail]. Any question or request to exercise your rights may be sent by e-mail, via the contact form (topic “Personal data”) or by post to the registered office.

MOBYCLIC (Alistair Marca), which develops and technically operates the Platform, acts as a processor (Article 28 GDPR) under a data processing agreement setting out its obligations (confidentiality, security, assistance, deletion of data at the end of the contract, supervised sub-processing). [TO COMPLETE: date and reference of the agreement.]

3.Directory data: origin and rights of data subjects

The directory lists companies, not individuals. It is built from public sources (Sirene register, DGAL and DGCCRF official lists, Agence Bio, OQUALIM, FAMI-QS), licensed data (MovUP) and declarations by the companies themselves. It may contain personal data where the company is a sole trader (the trader’s name is then the company name) or where a public source mentions a director.

These data are processed on the basis of our legitimate interest in informing professionals of the sector and facilitating their business relations (Art. 6(1)(f) GDPR; Art. 14 for information of data subjects). Data subjects are informed through this policy and through the source shown on each record.

Any data subject may object at any time, on grounds relating to their particular situation, to the presence of their data in the directory (Art. 21 GDPR): the “Removal request” page, available from each record, allows a correction or removal to be requested. An accepted request is recorded in an opposition list that prevents the record from reappearing during automatic updates.

A company’s e-mail and phone do not appear in the public content of pages: they are only communicated to a signed-in user, at their request, and each disclosure is logged and capped.

4.Recipients

Data are accessible, within the limits of their duties, to: authorised ALL4FEED staff; MOBYCLIC (technical processor); the providers listed in section 5 for the sole operations entrusted to them; other users of the Platform for the information you choose to publish (company record, catalogue, public documents, messages sent).

Data may be disclosed to competent authorities where required by law. We do not sell or rent personal data.

5.Hosting, providers and transfers outside the European Union

We favour data locations within the European Union: the application runs in our host’s Europe-West region (Netherlands), the database is in Ireland and files are stored with an EU storage location. E-mails and AI processing involve providers established in the United States.

Point of attention: US-law providers and the CLOUD Act

Several providers (Railway, Cloudflare, Resend, Anthropic, Esri) are US companies. Even where servers are located in the European Union, these companies are subject to the CLOUD Act (18 U.S.C. § 2713), which may compel them to disclose data to US authorities in criminal proceedings, and to FISA 702 for data in transit. We draw the following consequences:

  • Framed transfers: each US provider is either certified under the EU–US Data Privacy Framework (adequacy decision of 10 July 2023) or bound by the Commission’s standard contractual clauses (Decision 2021/914) supplemented by a transfer impact assessment. [TO COMPLETE: measure selected for each provider.]
  • Minimisation: providers only receive what their task requires — Resend receives the address and content of an e-mail, Anthropic the text of a document to read, never the database as a whole.
  • Encryption: data are encrypted in transit (TLS) and at rest with the database and storage hosts; passwords are hashed; Kbis extracts are stored in a private, non-public space.
  • Reversibility: the application is containerised and the database exportable; a migration to an EU-established, EU-law host (e.g. Scaleway or OVHcloud) is technically planned and may be decided if the risk analysis so justifies. [TO COMPLETE: ALL4FEED decision after the audit.]

The United Kingdom (SurrealDB Ltd; Nominatim) benefits from a European Commission adequacy decision (28 June 2021). The database instance itself is located in Ireland.

List of sub-processors

ProviderProcessingData locationTransfer safeguard
Railway Corporation (USA)Application hostingEuropean Union (Netherlands)[TO COMPLETE: SCCs]
SurrealDB Ltd (UK)Database hostingEuropean Union (Ireland, AWS)UK adequacy decision
Cloudflare, Inc. (USA)File storage (R2), anti-bot protection (Turnstile)European Union (R2); global network (protection)[TO COMPLETE: DPF / SCCs]
Resend, Inc. (USA)E-mail sendingUSA[TO COMPLETE: SCCs]
Stripe Payments Europe, Ltd (Ireland)Payment, invoicingEuropean UnionN/A
Anthropic, PBC (USA)Assisted reading of documents, writing and translationUSA; data not used to train models (commercial terms)[TO COMPLETE: DPF / SCCs]
Mistral AI (France)OCR of Kbis extractsEuropean UnionN/A
Esri (USA)Base maps (tile requests: IP address)USA[TO COMPLETE]
OpenStreetMap Foundation (UK)Geocoding of company addresses (no visitor data)UKAdequacy decision

This list is kept up to date; any substantial change is announced to account holders by e-mail or by a message in the professional area.

6.Retention periods

DataPeriod
Account and profileLifetime of the account, then 3 years after the last sign-in; deletion on request
Session tokens, one-time codes, magic linksSession: 30 days of inactivity; codes and links: 10 minutes to 1 hour, then purged
Kbis extract uploaded for a claimDuration of the accepted claim, then [TO COMPLETE: 12 months]; a refused document is not kept
Documents uploaded by companiesAs long as the company keeps them online, then 1 year in archive
Contact messages, reports, removal requests3 years from closure of the request; the opposition list is kept without limitation to guarantee its effect
Invoicing10 years (Art. L. 123-22 French Commercial Code)
Security log (IP addresses, rate limiting)In-memory counters: 1 minute to 24 hours; bans: until expiry (24 h by default), at most 1 year
Log of revealed contact details and usage measurement90 days, then automatic deletion
E-mail sending log12 months
NewsletterUntil unsubscription, then 3 years on a suppression list
Pilot programme questionnaire answersDuration of the programme, then 3 years in aggregated form in the report

7.Your rights

You have the rights of access, rectification, erasure, restriction, portability (for data you provided) and objection, as well as the right to set directives on the fate of your data after death. You may withdraw consent at any time (newsletter, pilot programme) without affecting the lawfulness of prior processing.

From your account: “My account” lets you edit your information, change your password, manage your alerts and the newsletter, and delete your account. Claimed companies may correct their record and choose whether their e-mail and phone are disclosed.

By request: to the DPO / GDPR contact (section 1). We reply within one month, extendable by two months for complex requests. Proof of identity may be requested in case of reasonable doubt.

Complaint: you may lodge a complaint with the French supervisory authority, CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07 — www.cnil.fr.

8.Cookies and trackers

The Platform only sets strictly necessary cookies, exempt from consent:

NamePurposeDuration
fs_sessionKeeps a signed-in user’s session30 days
fs_langChosen display language12 months

Browser local storage may remember display preferences (tab, filter, panel state); this information never leaves your browser. No advertising cookie, third-party tracker or third-party audience measurement is used. Should audience measurement be added, it would be configured according to CNIL recommendations (exemption) or subject to consent.

When Cloudflare Turnstile is enabled on a form, Cloudflare processes technical browser signals to distinguish a human from a bot, without identifying the person.

9.Security

  • Encryption in transit (HTTPS/TLS) across the Platform; encryption at rest with the database and file hosts.
  • Passwords hashed with a cost-based algorithm (never stored in clear); passwordless sign-in available by one-time code or magic link; codes limited in time and attempts.
  • Segregation of rights: public area, professional area (company membership verified by Kbis), back-office restricted to authorised staff.
  • Protection against data scraping: per-address rate limiting, temporary banning of abusive addresses, contact details revealed on click and capped, bounded pagination, no indexing of private areas.
  • Form protection against bots (honeypot field, minimum delay, rate limiting, Turnstile).
  • Kbis extracts stored in a private space with no public address.
  • Regular database backups by the host; logging of administration access.
  • Notification to the CNIL within 72 hours and information of data subjects in the event of a data breach presenting a risk (Arts. 33 and 34 GDPR).

10.Minors

The Platform is intended exclusively for professionals. It is not aimed at persons under 18 and we do not knowingly collect data about them.

11.Changes

This policy may be amended to reflect changes to the Platform, its providers or regulations. The date of the last revision appears at the top of the document; in the event of a substantial change, account holders are informed by e-mail or by a message in the professional area.