1. Who is responsible for your data
The data controller is Naoufal EL BEKKALI, an independent affiliate and email marketing
business operating as a sole trader in France.
- Controller
- Naoufal EL BEKKALI
- Country
- France
2. What data I collect
- Subscription data — the email address you submit, and optionally a first name, together with the date, time, IP address and page of your opt-in, which I keep as proof of consent.
- Campaign engagement data — whether an email was delivered, opened or clicked, and which link was clicked.
- Conversion data — the fact that a click resulted in a qualifying action, reported back to me by the affiliate network in aggregate against my publisher ID.
- Enquiry data — the name, email address, phone number and message content you send me when you contact me directly.
I do not collect or store payment card details, bank details or government identification
numbers from subscribers, and I do not knowingly collect data from anyone under 16.
3. Why I process it, and on what legal basis
- To send you the marketing email you subscribed to — on the basis of your consent (GDPR Article 6(1)(a)).
- To measure and improve campaign performance — on the basis of my legitimate interest in understanding which offers and messages are relevant (Article 6(1)(f)).
- To answer your enquiries — on the basis of your consent or my legitimate interest in responding.
- To keep records of consent, unsubscribes and complaints — to comply with my legal obligations under data protection and anti-spam law (Article 6(1)(c)).
4. Who your data is shared with
I do not sell your personal data. I share it only with service providers who process it on
my behalf and under contract, and with partners where strictly necessary:
- Email service providers who deliver my campaigns and host my lists;
- Landing page and web hosting providers who host my subscription forms;
- Affiliate networks — when you click a tracking link in one of my emails you are taken to the network's or advertiser's own page, and from that point their privacy policy governs what they collect. I pass them click identifiers, not your email address;
- Advertisers' suppression systems — in the form of irreversibly hashed addresses, so their opt-out lists can be respected without disclosing the address itself;
- Professional advisers and authorities — where I am legally required to disclose data.
5. International transfers
Some of my service providers and network partners are based outside the European Economic
Area, including in the United States. Where data is transferred outside the EEA I rely on an
adequacy decision of the European Commission or on the Standard Contractual Clauses, together
with appropriate additional safeguards.
6. How long I keep it
- Subscription and engagement data: for as long as you remain subscribed, and for 12 months after your last interaction, after which inactive records are deleted.
- Unsubscribe and suppression records: indefinitely, because this is the only way to guarantee you are never contacted again.
- Consent records: for the duration of the subscription plus three years, as evidence of lawful processing.
- Enquiry correspondence: up to 24 months after the matter is closed.
7. Your rights
Under the GDPR you have the right to:
- withdraw your consent at any time, and unsubscribe from any email with one click;
- request a copy of the personal data I hold about you;
- have inaccurate data corrected;
- have your data erased;
- restrict or object to processing, including profiling for marketing purposes;
- receive your data in a portable, machine-readable format;
- lodge a complaint with a supervisory authority — in France this is the CNIL (www.cnil.fr).
To exercise any of these rights, email me at naoufal14777@gmail.com from or
quoting the address concerned. I respond within one month.
8. Cookies and tracking
This website itself does not set advertising or analytics cookies. My campaign tracking links
and landing pages may use cookies or URL parameters to attribute a click to my publisher
account; where consent is required for these, it is requested at the point of use. Networks
and advertisers you reach by clicking a link operate their own cookies under their own
policies.
9. Security
I use access controls, strong authentication and encryption in transit to protect the data I
hold, and I limit the number of systems that store subscriber data. No system is completely
secure, but if a breach occurs that is likely to put your rights at risk I will notify the
CNIL within 72 hours and inform you without undue delay.
10. Changes to this policy
If this policy changes materially I will update the date above and, where the change affects
how your data is used, notify subscribers by email.