Privacy Policy
AT A GLANCE
This summary is provided for clarity. It does not replace the text of the Articles below, which alone shall prevail.
Who are we?
We publish the Papa In Shape and Maman In Shape brands: a website, content, individualised sports and nutrition coaching, and the mobile application through which it is delivered. Our full identity and address are set out in Article 1.
What is the purpose of this policy?
To state, plainly, which personal data we process, why, on what legal basis, with whom and for how long, and which rights you may exercise in respect of such data.
What does it apply to?
- our website and our lead-generation pages
- our forms, our calls and our sales appointments
- our mobile application and its web interface
- the messaging service connecting you to your coach
- our communications by email, SMS or WhatsApp and by notification
- our social media accounts, to the extent of the processing we carry out ourselves
- our internal tools for follow-up, invoicing and support
It does not apply to third-party websites and services accessible from our channels, which are governed by their respective publishers (Article 10).
What we do not do
⛔ we do not sell, rent or transfer any personal data
⛔ we do not request any health data, and the coaching is not a health service
⛔ we do not collect any geolocation data
⛔ no decision producing legal effects is based solely on automated processing
⛔ data read from Apple Health and Health Connect are never used for advertising or marketing
⛔ the Application is reserved for adults
How to contact us, and how to lodge a complaint?
confidentialite@papainshape.com for any question or request relating to your personal data. We respond within one month (Article 13).
How do we update this policy?
Each version bears a number and a date, and any material change is notified to you. Where required by applicable law, new consent is obtained (Article 15).
Article 1 — Identity and contact details of the controller
The website, services and mobile application Papa In Shape and Maman In Shape (hereinafter, together, the “Services”, and, as regards the mobile application and its web interface only, the “Application”) are published by:
OUTSCALE COMPANY FZCO, registered under number DSO-FZCO27663, whose registered office is located at Dubai Silicon Oasis - DDP, Building A2, Dubai, United Arab Emirates (hereinafter “we” or the “Publisher”).
Contact address for any question or request relating to personal data: confidentialite@papainshape.com
Article 2 — Scope and data subjects
2.1 Channels covered
This policy applies to the processing carried out by the Publisher in connection with:
ⓐ the consultation of its website and its lead-generation pages; ⓑ the steps taken prior to entering into the coaching contract — forms, appointment booking, telephone and video calls, email correspondence — including with persons who are not customers; ⓒ the use of the Application by holders of a customer account, access to the Application being granted by invitation only; ⓓ the contractual and post-contractual relationship with the aforementioned persons, including coaching delivered outside the Application; ⓔ its communications, its content and its social media accounts, to the extent of the processing carried out by the Publisher itself; ⓕ its internal tools for sales follow-up, invoicing, support and service improvement.
It does not apply to third-party websites, services or channels accessible from the Services, which are governed by their respective publishers (Article 10).
2.2 Data subjects
| Category | Who | Articles primarily concerning them |
| Visitor | any person who consults the website or any public content without identifying themselves | 3.1 · 8 · 14 |
| Prospect | any person who provides their contact details, books an appointment or corresponds with us prior to any subscription | 3.1 · 3.2 · 8 · 12 |
| Customer | any account holder, during and after the coaching | 3.3 to 3.9 · 5 · 6 · 12 |
| Person mentioned by a customer | any person whose data are provided to us by a customer (Art. 3.9) | 3.9 · 13 |
| Person giving a testimonial | any customer whose image, voice or statements are published with their consent | 8.3 |
| Applicant | any person responding to a job offer or submitting an unsolicited application | 4 · 12 |
| Staff member | any member of the Publisher's team, whether employee or contractor, whose professional exchanges with a data subject are stored in the Publisher's tools | 3.7 · 3.10 · 4 · 12 |
The professional exchanges of staff members — telephone calls, short text messages and emails exchanged with a data subject — are stored in the Publisher's tools and, where they relate to an identified customer or prospect, recorded in its tracking system. Each staff member is informed individually thereof, prior to implementation.
The Application is reserved for natural persons who have reached the age of majority. No account is opened for a minor. The only data relating to minors processed by the Publisher are the first names of a client's children, where the client chooses to provide them. Any other data collected in error from a minor is erased as soon as the Publisher becomes aware of it.
Article 3 — Which personal data do we process, and where do they come from?
3.1 Data processed when consulting the website and during the pre-contractual stage
ⓐ Browsing data: IP address, browser type and version, operating system, pages consulted, date and duration of the visit, referring page or source, identifiers placed by trackers under the conditions set out in Article 14.
ⓑ Data provided voluntarily: surname, first name, email address, telephone number, and any information provided in a form, an appointment booking or a message.
ⓒ Data relating to sales exchanges: date and purpose of appointments, notes taken by our teams, history of follow-ups, status of the process, and, where applicable, recording and transcription of telephone and video calls.
ⓓ Campaign data: advertising source, campaign and click identifiers, under the conditions set out in Article 8.2.
3.2 Data collected prior to the opening of the account
Data relating to the data subject may have been collected, with their consent, prior to the opening of their account in the Application, by means of forms, lead-generation channels or tracking tools used by or on behalf of the Publisher.
Where applicable, such data are transferred into the Application upon the opening of the account, for the purpose of ensuring continuity of the coaching. They are then subject to this policy.
The corresponding legacy channels are intended to be deleted upon completion of the migration of the services to the Application, and at the latest on 30 June 2027. Until such deletion, the rights provided for in Article 13 may be exercised in respect of such channels and of the Application alike.
3.3 Data provided by the data subject in the Application
ⓐ Identification and contact data: surname, first name, email address(es), telephone number(s), date of birth, declared gender.
ⓑ Fitness and well-being data (Article 5): weight, body measurements, progress photographs, sleep data, food and hydration data, declared alcohol consumption, physical activity and training data, perceived exertion, declared mood, declared goals, answers to intake and follow-up questionnaires.
ⓒ Exchanged content: written messages, voice messages, photographs, videos — including videos submitted for technique correction purposes — and files transmitted through the built-in messaging service.
ⓓ Answers to questionnaires and surveys: satisfaction surveys, knowledge assessments.
Answers to intake questionnaires are retained as a versioned history: a subsequent amendment does not entail the erasure of the previous version, nor does the removal of a question from the questionnaire. Such retention meets a traceability requirement and is not subject to any independent further use.
3.4 Data collected automatically in the Application
ⓐ Account and connection data: technical identifiers, login and logout timestamps, IP address — the latter being retained in particular upon acceptance of the contractual documents, for evidentiary purposes.
ⓑ Usage data: all screens viewed and all actions performed in the Application, including the consultation of educational content and video content. Such events are recorded systematically and in detail; they constitute the largest share of the data held on a data subject, and are included in full in the export provided for in Article 13.
ⓒ Technical device data: model, operating system and version thereof, installed version of the Application, system language and time zone, technical notification identifier. Such data are processed solely for the purposes of diagnostics, security, support and distribution of updates, and are automatically attached to any bug report or suggestion submitted from the Application.
ⓓ Technical logs: error and access-denial events — endpoint called, error code, timestamp, excluding any content and any directly identifying data — for the purposes of security and fixing malfunctions.
The time zone is determined from the settings of the device's operating system and, failing that, from the IP address. The Application does not collect any geolocation data.
3.5 Data from the operating system's health and fitness services (optional feature)
Where the data subject expressly activates this feature and grants the corresponding permissions at the level of their operating system, the Application accesses, on a read-only basis, the following categories of data:
On iOS, through the Apple Health (HealthKit) interface:
- daily step count
- distance travelled
- active energy expenditure
- sleep analysis (bedtime and wake-up time, duration, stages where available)
- body mass
- recorded workouts (activity type, duration, energy expenditure, distance)
On Android, through the Health Connect interface:
- Steps — daily step count
- Distance — distance travelled
- ActiveCaloriesBurned — active energy expenditure
- SleepSession — sleep sessions
- Weight — body mass
- ExerciseSession — exercise sessions (type and duration)
Purpose: such data are processed for the sole purpose of automatically populating the data subject's activity, recovery and progress tracking within the Application, and of enabling their coach to adapt the coaching programme.
The Publisher expressly declares that:
ⓐ such data are not used for any advertising or marketing purpose, whether direct or indirect; ⓑ they are neither sold, transferred, rented nor shared with any data broker or any third party for such purposes; ⓒ they are not stored in any third-party backup service, in particular iCloud; ⓓ the Application never writes to Apple Health or Health Connect; access is exclusively read-only; ⓔ data entered manually by the data subject in the Application shall prevail in all cases over imported data; ⓕ such data are used neither to train any artificial intelligence model nor for research purposes.
Withdrawal: the permission may be withdrawn at any time, from the settings of the device's operating system as well as from the Application. Withdrawal ends the import for the future and does not affect the lawfulness of prior processing.
3.6 Strong authentication data and biometric data
The Application allows the activation of a lock by biometric recognition (Face ID, Touch ID, fingerprint) or by the device passcode, as well as the registration of a passkey.
Biometric verification is carried out entirely by the device's operating system. No biometric template, image or derivative is transmitted to the Publisher or stored on its systems or on those of its processors. The Publisher receives only the binary result of the verification.
The Publisher does not carry out any processing of biometric data within the meaning of Article 9(1) GDPR.
3.7 Data relating to the commercial relationship
Subscribed offer, duration and status of the programme, payment schedule and payment status, accepted contractual documents and timestamp of their acceptance, as well as the invoicing data required by accounting regulations.
Telephone, short message (SMS) and email exchanges between the data subject and the Publisher are stored within the Publisher's professional tools, and then recorded in its tracking system where they relate to an identified customer or prospect. The following are processed: the date, time, direction and duration of the exchange, the contact details used, and the content of the message or the recording of the conversation where it exists. No exchange that does not relate to an identified customer or prospect is recorded.
The Publisher does not collect or retain any payment card data: payment transactions are carried out by Whop.com, Stripe.com, Wise.com and Hotmart.com, acting as separate controllers for such transactions.
3.8 Unsolicited data
The Services include free-text fields — in particular in the messaging and support features — through which the data subject may, on their own initiative, provide information that the Publisher does not request, including information relating to their health.
The Publisher does not request any data concerning health within the meaning of Article 4(15) GDPR. Technical measures are implemented to ensure that such information, where provided spontaneously, is neither exploited, analysed, nor used to produce a response or recommendation, the data subject being then invited to consult a healthcare professional.
The message remains stored as part of the history of exchanges, under the conditions set out in Article 12, in the same manner as any other content provided by the data subject, and for the purpose of traceability of the safeguard applied. It is not used for any other purpose.
3.9 Data concerning a third party
Where the data subject provides the Publisher, in a form, a message or an exchange, with data relating to a third party — family member, relative, person they refer — they shall ensure that they are authorised to do so and that they have informed such person of this policy.
Such data are processed solely for the purposes for which they were provided and are not subject to any independent direct marketing, save with the third party's own consent.
3.10 Recording of telephone calls
Telephone calls with the Publisher may be recorded. The data subject is informed thereof at the beginning of the call, prior to any recording, by an announcement broadcast by the telephony system and/or by the Publisher's staff members.
Purpose: traceability and evidence of pre-contractual and contractual exchanges, as well as training and quality control of the coaching delivered by the Publisher's staff members.
Objection: the data subject may object to the recording. The call then continues without being recorded, and no consequence is drawn from such objection as regards the benefit of the exchange or of the service.
Access: only those of the Publisher's staff members whose duties so require — management of the sales team, management of the coaching, support, executive management — have access to the recordings, under the conditions set out in Article 9.1.
Retention periods are set out in Article 12.
Article 4 — Purposes of processing, legal bases and retention periods
One processing operation, one purpose, one legal basis. The table below is the reference table of this policy; retention periods are detailed in Article 12.
| # | Purpose | Data subjects | Legal basis | Retention |
| 1 | Provision of the website and its content, security of browsing | Visitor | Legitimate interests — Art. 6(1)(f) | Logs: 12 months |
| 2 | Audience measurement and improvement of the website | Visitor | Consent — Art. 82 of Law No. 78-17, save for exempted measurement | (Article 14) |
| 3 | Online advertising, targeting and campaign measurement | Visitor, prospect | Consent — Art. 6(1)(a) and Art. 82 of Law No. 78-17 | (Article 14) |
| 4 | Response to a contact request, an appointment booking or an application | Prospect, applicant | Pre-contractual steps — Art. 6(1)(b); legitimate interests — Art. 6(1)(f) | 12 months from the last contact |
| 5 | Direct marketing, follow-ups and sending of content by email | Prospect | Consent — Art. 6(1)(a); legitimate interests — Art. 6(1)(f) for direct marketing relating to a similar product already subscribed | Until withdrawal, and at the latest 12 months after the last contact |
| 6 | Performance of the coaching services: periodic follow-up, individualised sports and nutrition programmes, messaging with the coach | Customer | Performance of a contract — Art. 6(1)(b) | (Article 12) |
| 7 | Processing of fitness and well-being data for the purpose of individualising the coaching | Customer | Explicit consent — Art. 9(2)(a) | (Article 12) |
| 8 | Import of data from the operating system's health services (Art. 3.5) | Customer | Explicit consent — Art. 9(2)(a) | (Article 12) |
| 9 | Assistance to teams by means of automated processing, including through the use of artificial intelligence technologies (Article 6) | All | Performance of a contract — Art. 6(1)(b); legitimate interests — Art. 6(1)(f) outside the contract; explicit consent for data falling under Art. 9 | (Article 12) |
| 10 | Account management, authentication, prevention of unauthorised use and security of systems | Customer | Performance of a contract — Art. 6(1)(b); legitimate interests — Art. 6(1)(f) | (Article 12) |
| 11 | Sending of service-related notifications, configurable in the Application | Customer | Performance of a contract — Art. 6(1)(b); consent for notifications that are not strictly necessary | (Article 12) |
| 12 | Management of invoicing, debt collection and accounting obligations | Customer | Performance of a contract — Art. 6(1)(b); legal obligation — Art. 6(1)(c) | 10 years |
| 13 | Satisfaction measurement, usage analysis and improvement of services and content | Customer | Legitimate interests — Art. 6(1)(f) | (Article 12) |
| 14 | Publication of reviews, testimonials and content featuring a data subject | Person giving a testimonial | Consent — Art. 6(1)(a), separate and documented | Until withdrawal |
| 15 | Establishment and retention of evidence of consents and contractual acceptances | All | Legal obligation — Art. 6(1)(c); legitimate interests — Art. 6(1)(f) | 5 years |
| 16 | Handling of requests to exercise rights and of complaints | All | Legal obligation — Art. 6(1)(c) | (Article 12) |
| 17 | Establishment, exercise or defence of legal claims | All | Legitimate interests — Art. 6(1)(f); Art. 9(2)(f) for data falling under Art. 9 | Applicable limitation periods |
| 18 | Tracking and traceability of telephone, short message and email exchanges relating to an identified customer or prospect (Art. 3.7) | Prospect, customer, staff member | Performance of a contract — Art. 6(1)(b); pre-contractual steps — Art. 6(1)(b); legitimate interests — Art. 6(1)(f) | (Article 12) |
| 19 | Recording of telephone calls for the purposes of evidence, training and quality control (Art. 3.10) | Prospect, customer, staff member | Legitimate interests — Art. 6(1)(f), together with the right to object under Art. 3.10 | (Article 12) |
| 20 | Erasure of recordings and exchanges upon expiry of their retention period, including at the telephony provider | All | Legal obligation — Art. 6(1)(c) (Art. 5(1)(e) GDPR) | (Article 12) |
The legitimate interests relied upon consist of the security of systems, the continuity and improvement of the services, the development of the Publisher's business and the defence of its rights. A written balancing test is maintained for each purpose based on Article 6(1)(f) and may be provided upon request at the address set out in Article 1. The data subject may object to such processing under the conditions set out in Article 13.
Article 5 — Qualification of fitness and well-being data
The data referred to in Articles 3.3.ⓑ and 3.5 constitute fitness and well-being data, processed solely for the purpose of individualising sports and nutrition coaching.
The Publisher's services do not constitute health services. The Publisher does not collect any medical record, diagnosis, treatment data or data relating to any medical condition. The Services do not provide any diagnosis, prescription or medical advice. Coaches are not healthcare professionals.
As a precautionary measure, and without this constituting any acknowledgement that such data qualify as data concerning health, the Publisher applies to such data the regime of Article 9 GDPR and obtains explicit consent, collected by means of a dedicated screen at the pre-contractual stage, separate from the acceptance of the terms and conditions, and revocable at any time.
The withdrawal of consent does not affect the lawfulness of prior processing. It may prevent the continuation of the coaching service, which relies on the processing of such data.
Progress photographs: by default, they are accessible only to the data subject and to their coaching team. Any other use, in particular for testimonial or communication purposes, is subject to the separate consent provided for in Article 8.3, together with an option for visual anonymisation.
Limited exception to the principle of data entry by the data subject: the coach may rectify self-reported data relating solely to the period under their review, to the exclusion of any other. Any rectification of this kind is logged and enforceable.
Article 6 — Use of artificial intelligence technologies
The Publisher uses artificial intelligence technologies, provided by specialised providers acting as processors, for the processing of all categories of data it holds — data relating to its customers, its prospects, its staff members, its sales and marketing activities, its content and its technical systems.
Such processing pursues the following purposes:
ⓐ improving its internal processes and the quality of its services; ⓑ improving its communication and its sales and marketing approaches; ⓒ designing, evaluating and improving its educational and teaching content; ⓓ improving its coaching and support methods; ⓔ assisting its teams in preparing, drafting and delivering follow-up; ⓕ making available, within the Application, a conversational feature answering the data subject's questions on the basis of the educational content of their training.
Applicable safeguards:
ⓐ No decision producing legal effects concerning a person, or similarly significantly affecting them, is based solely on automated processing, within the meaning of Article 22 GDPR. Any output resulting from such processing is intended for the Publisher's teams, who review, modify or discard it. With the exception of the answers of the conversational feature referred to in ⓕ, which are addressed directly to the data subject and produce no decision concerning them. ⓑ Data transmitted to such providers are transmitted solely for the above purposes. They are not used to train or improve the providers' models, in accordance with the contractual commitments given by the latter. ⓒ Processing relating to data falling under Article 5 is carried out solely on the basis of the explicit consent referred to in that Article. ⓓ The conversational feature referred to in ⓕ above does not answer any question relating to diagnosis, treatment or medication: it then refers the data subject to their coach or to a healthcare professional, and the question asked remains stored under the conditions set out in Article 3.8. On fitness and well-being topics, its answer is limited to the educational content of the program and comes with the same referral. ⓔ Certain outputs of such processing relate to a data subject without being displayed to them: they are intended for their coaching team. They fall within the scope of the right of access and the right to data portability provided for in Article 13 and are included in the data export. ⓕ The Publisher implements technical measures intended to exclude from the scope of such processing the unsolicited information referred to in Article 3.8.
Archives of previous conversations. The Publisher holds, on a transitional basis, archives of exchanges originating from the channels used prior to the Application, constituted solely for the purposes of internal qualitative analysis and improvement of its content and methods. Such archives are not subject to any individual use, do not serve as the basis for any decision concerning a person, and are intended to be deleted at the end of the transitional period, and at the latest on 30 June 2027. Until their deletion, they fall within the scope of the rights provided for in Article 13.
Article 7 — Coaching delivered outside the Application
Coaching may be delivered, in whole or in part, outside the Application: exchanges via external messaging services, by email, by telephone or by video call, documents and programmes transmitted as files, individual or group sessions.
The corresponding processing pursues the same purposes and relies on the same legal bases as that carried out in the Application (Article 4, purposes 6 to 9). The resulting data are, where retained, subject to the retention periods set out in Article 12 and fall within the scope of the rights set out in Article 13.
The Publisher gives preference to the Application for any exchange relating to the coaching. External channels are intended to be discontinued upon completion of the migration, under the conditions set out in Article 3.2.
Article 8 — Our marketing and sales activities
8.1 Direct marketing and communications
The Publisher sends, by email and by SMS or WhatsApp notification, content relating to its offers, its programmes and its publications:
- to a person who is not a customer: on the basis of their CONSENT, obtained by means of an unticked checkbox or an express request
- to a customer: in the context of the contractual relationship, for similar services, on the basis of legitimate interests
Each message includes a simple and free means of unsubscribing, and unsubscription is given effect without delay. It does not constitute an objection to messages strictly necessary for the performance of the contract (invoicing, security, service information).
8.2 Online advertising and campaign measurement
The Publisher promotes its offers by means of campaigns run on third-party platforms, and measures the effectiveness of such campaigns.
Such processing is based on consent, obtained by means of the mechanism provided for in Article 14, and is carried out only after such consent has been obtained.
The Publisher declares that:
ⓐ no fitness and well-being data within the meaning of Article 5, no data from Apple Health or Health Connect, and no content exchanged with a coach is transmitted to any advertising platform, in any form whatsoever, including in hashed or pseudonymised form; ⓑ the data transmitted to advertising platforms for measurement and matching purposes are limited to surname, first name, email address and telephone number, transmitted in hashed form, to advertising identifiers stored on the terminal equipment as well as click and campaign identifiers, to the IP address, browser type and pages consulted, and to the characteristics of the event measured — the page or form concerned, the date and, where applicable, the amount and currency — to the exclusion of any other data, and are transmitted only after consent; ⓒ hashing does not deprive data of their personal nature: the Publisher treats identifiers transmitted in hashed form as personal data; ⓓ no data are transferred to any third party for that third party's direct marketing (Article 9.6).
8.3 Reviews, testimonials and content featuring a person
The publication of a review, a testimonial, a progress photograph, or a voice or video recording featuring a data subject is subject to separate, specific and documented consent, specifying the channels of distribution and the duration.
- such consent may be withdrawn at any time, without giving reasons
- withdrawal entails the removal of the publication for the future, within a reasonable period, on the channels controlled by the Publisher
- an option for visual anonymisation is offered
- a review posted on a third-party platform is governed by the terms of that platform, and its removal must be requested there
A review, comment or post made public by the data subject is visible to all and may be reproduced, quoted or indexed by third parties outside the Publisher's control.
8.4 Social media
The Publisher administers accounts on social media platforms. The processing carried out by such platforms is governed by their own policies, and the Publisher controls neither its scope nor its terms; for certain audience statistics, it may act as joint controller with the platform, under the conditions set by the latter.
The processing carried out by the Publisher itself is limited to the messages, comments and contact data that the person sends to it through such channels, for the purposes set out in Article 4.
Information disclosed publicly on social media is, by its nature, accessible to all. The Publisher invites everyone never to disclose there any information relating to their health, their personal situation or their payments, and to use the Application's messaging service for that purpose.
8.5 Referral, affiliation and competitions
Where the Publisher runs a referral or affiliation scheme, a competition or a game, the participants' data are processed solely for the purposes of such operation, for the period necessary for its conduct and for the award of prizes, and the specific rules of the operation supplement this policy. The contact details of a referee provided by a referrer are governed by Article 3.9.
Article 9 — Recipients of the data
9.1 Internal recipients
The coach in charge of the coaching, as well as those members of the Publisher's teams whose duties so require — coaching management, business development, support, technical administration — within the limits of role-based access rights.
9.2 Categories of third parties — what we collect from them, what we share with them
| Type of third party | Description | We collect | We share |
| Group brands and entities | Papa In Shape and Maman In Shape and, where applicable, the entities related to them | ✓ | ✓ |
| Hosting and infrastructure | hosting of the application, the database, media and the application programming interface | ✕ | ✓ |
| Authentication | management of accounts, sessions and authentication factors | ✓ | ✓ |
| Messaging and notifications | messaging infrastructure, sending of emails and notifications | ✕ | ✓ |
| Artificial intelligence technologies | providers referred to in Article 6 | ✕ | ✓ |
| Payment and invoicing | execution of payments, invoicing, debt collection | ✓ | ✓ |
| Sales support tools | relationship tracking, appointment booking, task automation, office tools | ✓ | ✓ |
| Advertising platforms | running of campaigns and conversion measurement (Article 8.2), after consent only | ✓ | ✓ |
| Audience measurement | statistics on the consultation of the website | ✕ | ✓ |
| Review platforms | collection and display of public reviews | ✓ | ✓ |
| Video content hosting | distribution of videos published on the website and in the Application | ✕ | ✓ |
| Application distribution | app stores and distribution of updates | ✕ | ✓ |
| Publisher's advisers | lawyers, chartered accountants, statutory auditors | ✕ | ✓ |
| Authorities | administrative or judicial, upon lawful request | ✕ | ✓ |
| Reorganisation | in the event of a sale, merger or contribution of all or part of the business, the acquirer, bound by this policy | ✕ | ✓ |
9.3 Processors within the meaning of Article 28 GDPR
| Processor | Subject matter of the processing | Location |
| Cookiebot | Collection and retention of consent to trackers | Denmark |
| Clerk | Authentication and account management | United States |
| PlanetScale | Database hosting | United States |
| Render | Hosting of the application programming interface | United States |
| Cloudflare (including R2) | Hosting of the web application, content delivery network, storage of media and photographs | United States |
| Stream | Messaging infrastructure | United States |
| Anthropic | Artificial intelligence technologies (Article 6) | United States |
| OneSignal | Push notifications | United States |
| Amazon Web Services (SES) | Delivery of transactional emails | United States |
| Expo / EAS | Distribution of Application updates | United States |
| Webflow | Hosting and publication of the website | United States |
| Close.com | Customer relationship and direct marketing management | United States |
| Calendly · Google Calendar | Scheduling of sales appointments | United States · United States |
| Make | Data synchronisation between internal tools | United States |
| Google Workspace | Staff members' professional email and calendar, working documents — exchanges relating to an identified customer or prospect are recorded in the Publisher's tracking system (Art. 3.7) | United States |
| Claap | Telephony, short messages and call recording (Art. 3.10) | European Union |
| Wistia · YouTube | Video hosting providers | United States · United States |
| Google Tag Manager | Triggering of trackers (Article 14) | United States |
| Google Analytics | Audience measurement | United States |
| Stape | Server-side tag container (Article 14) | European Union |
| Xano · Weweb · System IO · Typeform · ActiveCampaign | Lead-generation channels and legacy database (Article 3.2) | United States · United States · United States · United States · United States |
Each processor is bound by a contract compliant with Article 28 GDPR.
9.4 Recipients acting as separate controllers
Advertising platforms, review platforms, social media, app stores and the payment providers determine, for all or part of the processing they carry out, their own purposes and means. They then act as separate controllers, and their respective policies apply to such processing.
9.5 Services queried without transmission of identifying data
When searching for foods, the Application queries the public Open Food Facts database; only the search term or the barcode is transmitted, to the exclusion of any identifying data.
9.6 No transfer of data
The Publisher does not sell, rent or transfer any personal data, and does not share any personal data for advertising or direct marketing purposes on behalf of third parties.
Article 10 — Third-party links and services
The Services may contain links to websites, applications or content published by third parties. The Publisher exercises no control over such channels and is not responsible for their data practices. The consultation of any such channel is governed by the policy of its publisher.
Article 11 — Transfers outside the European Union
The Publisher is established outside the European Union (Article 1). Where a provider established in the European Union makes available to it data that it processes on the Publisher's behalf, such communication is governed by the standard contractual clauses adopted by the European Commission.
Certain recipients referred to in Article 9 are established outside the European Union, in particular in the United States. The corresponding transfers are governed by the mechanisms provided for in Chapter V GDPR: certification under the EU–U.S. Data Privacy Framework, and/or standard contractual clauses adopted by the European Commission, supplemented where appropriate by supplementary measures.
Article 12 — Retention periods
| Category | Retention period |
| Account and tracking data, during the period of activity | Retained without time limit for as long as the account is active |
| Account and tracking data, after becoming inactive | 18 months from the date on which the account became inactive |
| Content exchanged via messaging | Duration of the relationship, then aligned with the period above |
| Usage data and navigation events in the Application | Aligned with the period above |
| Archives of previous conversations (Article 6) | Until the end of the transitional period, and at the latest 30 June 2027 |
| Legacy lead-generation channels (Article 3.2) | Until the end of the migration, and at the latest 30 June 2027 |
| Data of persons who are not customers | 12 months from the last contact |
| Data relating to sales appointments and exchanges | 12 months from the last contact |
| Evidence of consents given by a person who is not a customer (direct marketing, trackers) | 3 years from the last contact, including after the erasure of their other data; only the identifier, the date, the subject matter of the consent or of its withdrawal, and the version of the text presented are retained |
| Trackers and information stored on the terminal equipment | (Article 14) — lifetime ≤ 13 months, consent requested again at least every 6 months |
| Requests to exercise rights and complaints | The time needed to handle the request, then 5 years for evidentiary purposes; any proof of identity requested is deleted as soon as verification has been carried out |
| Consents to the publication of a testimonial (Article 8.3) | Until withdrawal, then 5 years for evidentiary purposes |
| Job applications | 12 months, with the person's consent beyond that period |
| Invoicing data and accounting records | 10 years, pursuant to the accounting record retention obligations applicable to the Publisher |
| Evidence of a customer's consent and contractual acceptance | 5 years from the end of the relationship |
| Receipts of payment (amount, currency, date, offer, processor reference) | TEN (10) YEARS from the financial year concerned, pursuant to the accounting record retention obligations. Upon erasure of the account, the entry is ANONYMISED: the customer identifier and the payment email address are deleted; the amount and date remain. |
| Technical and security logs | 12 months |
| Log of technical access denials (Art. 3.4.ⓓ) | 30 days |
| Call recordings — person who has not subscribed | 6 months from the call, deleted by the Publisher at the telephony provider |
| Call recordings — customer | 12 months from the call |
| Content of short messages and emails relating to an identified customer or prospect | Duration of the relationship, then aligned with the period applicable to account data |
| Metadata of exchanges (date, time, direction, duration, contact details used) | May be retained after the erasure of the content, for the purpose of traceability of the relationship, within the limit of the period applicable to account data |
Prior to the expiry of the 18-month period, the data subject is informed by electronic means, with a minimum notice period of one month, and has the option of downloading all of their data by means of the export function provided for in Article 13. Upon expiry of such period, the data are erased or irreversibly anonymised.
In the event of a request for erasure, erasure takes place without undue delay, subject to data whose retention is required by law or necessary for the establishment, exercise or defence of legal claims.
The erasure of a conversation covers the entire exchange: the text as well as any attachments thereto.
Article 13 — Your rights
13.1 What are your rights, and how can you exercise them?
In accordance with Articles 15 to 22 GDPR, the data subject has the following rights:
ⓐ Right of access (Art. 15): to obtain confirmation as to whether or not personal data concerning them are being processed and to obtain a copy thereof, including the outputs of the processing referred to in Article 6 which relate to them and are not displayed to them. ⓑ Right to data portability (Art. 20): to receive their data in a structured, commonly used and machine-readable format. The Application includes a full export function, together with an automatic completeness check. ⓒ Right to rectification (Art. 16): directly in the Application or upon request. ⓓ Right to erasure (Art. 17): the deletion of the account and associated data may be requested directly from the Application. The request opens a 14-day grace period, during which it may be cancelled; upon expiry of such period, the deletion is final and irreversible. ⓔ Right to withdraw consent (Art. 7(3)): at any time, without affecting the lawfulness of prior processing. ⓕ Right to object (Art. 21): to processing based on legitimate interests, and at any time and without giving reasons as regards direct marketing. ⓖ Right to restriction of processing (Art. 18). ⓗ Right to set out instructions regarding the fate of their data after their death (Art. 85 of Law No. 78-17 of 6 January 1978, as amended).
How to exercise these rights: by email to confidentialite@papainshape.com. The Publisher responds within one month of receipt of the request, which may be extended by two further months where necessary, taking into account the complexity and number of requests, the data subject being informed thereof. Proof of identity may be requested where there are reasonable doubts concerning the identity of the requester.
The above rights may be exercised in respect of the Application, the legacy channels referred to in Article 3.2 and the archives referred to in Article 6 alike, for as long as the latter subsist.
The right of access and the right to data portability also extend to calls, short messages and emails relating to the data subject: metadata, content of messages and call recordings, where they still exist in light of Article 12.
13.2 How to withdraw consent, and how to object to processing?
| What you wish to stop | Where to do so |
| Receiving our marketing emails | Unsubscribe link included in each message, or request to the address set out in Article 1 |
| Receiving our SMS messages | Reply STOP to any SMS message received, as indicated upon receipt of the first SMS message, or send a request to the address set out in Article 1 |
| Receiving notifications | Application settings, and your phone settings |
| Import from Apple Health or Health Connect | Your phone settings, or the Application |
| Advertising and measurement trackers | Tracker management mechanism (Article 14), at any time |
| The processing of your fitness and well-being data | Withdrawal of the consent referred to in Article 5 — such withdrawal may prevent the continuation of the coaching |
| The publication of a testimonial | Request to the address set out in Article 1 (Article 8.3) |
| All processing | Deletion of the account from the Application (Article 13.1.ⓓ) |
The recording of a call may be refused at the beginning of the call, by informing the person on the line, under the conditions set out in Article 3.10: the exchange then continues without recording. Such refusal may also be sent in advance to the address set out in Article 1.
Article 14 — Trackers and similar technologies
14.1 Purpose of this Article
This Article describes the use of cookies and other trackers placed or read when consulting the website and using the Application, as well as the means available to the data subject to accept or refuse them.
A tracker means any file or information placed, read or written on the data subject's terminal equipment when consulting an online service, whatever the technology used: cookie, pixel, tag, device identifier, local storage, device fingerprinting.
14.2 Applicable principles
14.2.1. Trackers that are strictly necessary for the provision of the service expressly requested by the data subject, or whose sole purpose is to enable or facilitate a communication, do not require their consent, within the meaning of Article 82 of Law No. 78-17 of 6 January 1978, as amended.
14.2.2. All other trackers, in particular non-exempt audience measurement, personalisation and advertising trackers, are placed or triggered only after consent has been obtained, such consent being freely given, specific, informed and unambiguous.
14.2.3. Refusing is as simple as accepting. The absence of a choice does not constitute consent. Continued browsing does not constitute consent.
14.2.4. Consent may be withdrawn at any time, by means of the same mechanism as that through which it was obtained.
14.3 In the Application
The Application uses only trackers that are strictly necessary for the provision of the service expressly requested: authentication session and technical preferences. No advertising tracker or third-party audience measurement tracker is placed by the Application.
The identifiers and technical measurements used by the Application are described in Article 3.4. The settings of the terminal's operating system also make it possible to limit advertising tracking.
14.4 On the website — categories of trackers
| Category | Purpose | Consent |
| Strictly necessary | display of the website, authentication and session maintenance, security, fraud prevention, load balancing, storage of the choice expressed regarding trackers | Not required |
| Statistics (audience measurement) | consultation and navigation statistics, service improvement | Required, save where the measurement meets the exemption conditions within the meaning of the recommendations of the CNIL |
| Preferences | storage of display, language and browsing-comfort preferences | Required |
| Marketing (advertising, social media and campaign measurement) | running and measurement of advertising campaigns, conversion measurement, matching with advertising platforms (Article 8.2) | Required |
No tracker other than strictly necessary trackers is placed or triggered before consent has been obtained.
14.5 Retention periods
14.5.1. The lifetime of a tracker subject to consent does not exceed thirteen (13) months. It is not automatically extended upon a new visit.
14.5.2. The information collected by means of such trackers is retained for a period not exceeding twenty-five (25) months, and is then erased or anonymised.
14.5.3. Consent is retained for 6 months, at the end of which the choice is requested again. Refusal is retained for at least an equivalent period, so that it is not requested more often than consent.
14.6 How to exercise your choice
14.6.1. On the website: a dedicated tracker management mechanism, accessible from the first visit and at any time from the “Gérer mes cookies” (“Manage my cookies”) link in the footer of each page, allows trackers to be accepted or refused category by category. Refusing is as accessible there as accepting.
14.6.2. In the Application: since the trackers used are strictly necessary, no consent is required; the operating system's settings make it possible to limit advertising tracking.
14.6.3. In the browser: the data subject may configure their browser to block or delete trackers. Such setting may impair the functioning of certain services.
14.6.4. Refusing non-necessary trackers prevents neither access to the website nor access to the subscribed service.
14.7 Trackers placed by third parties
14.7.1. Certain trackers are placed by third parties whose services are integrated into the website, in particular for video distribution, audience measurement or advertising.
14.7.2. Such third parties determine, for all or part of such processing, their own purposes and means; they then act as separate controllers, under the conditions set out in Article 9.4, and their own policies apply. Their identity is set out in the table in Article 14.8.
14.7.3. Some of these measurements are carried out by means of a tag container hosted on a server of the Publisher, under one of its subdomains. This method of collection is subject to the same consent as the corresponding trackers, and the data transmitted are those referred to in Article 8.2.
14.8 Table of trackers
The detailed list of trackers placed or read on the website — their name, provider, purpose, category and duration — is set out below. It is drawn up and kept up to date automatically by the consent management mechanism, on the basis of a regular scan of the website.
14.9 Complaints relating to trackers
Any question or complaint relating to trackers may be sent to the address set out in Article 1. The rights of the data subject and the terms for exercising them are set out in Article 13; the right to lodge a complaint with a supervisory authority is available under the conditions set out in Article 16.
Article 15 — Amendments to this policy
Any material amendment is brought to the attention of data subjects within the Application and on the website. Where required by applicable law, new consent is obtained.
Each version is identified by its number — this one: Version 2.0 dated 1 October 2026 — and archived. The version applicable to a given processing operation is the one in force on the date of such processing.
This policy is published in French at papainshape.com/politique-de-confidentialite and in English at papainshape.com/privacy-policy. The two versions are identical in all respects. The English version is the one referenced in the Application's listings on the App Store and on Google Play, as well as in the Health Connect declaration.
In the event of any discrepancy between the two versions, the English version shall prevail.
Article 16 — Complaints
Without prejudice to any other administrative or judicial remedy, the data subject has the right to lodge a complaint with the supervisory authority of the Member State of the European Union of their habitual residence, place of work or place of the alleged infringement (Article 77 GDPR).
