Privacy policy

Last updated: 30 July 2026. This is a translation for convenience. The French version prevails.

This policy covers the https://www.disfrigo.fr website (waitlist). A dedicated app privacy policy will be published when the app launches.

Who is responsible for your data?

The data controller is Freelance Kevin Ching, a French SAS with capital of €100.00, registered office 4 rue George Sand, 78370 Plaisir, France, registered with the Versailles Trade and Companies Register (RCS) under number 900 063 868, represented by Kevin CHING. See our legal notice for the publisher’s full details.

No data protection officer (DPO) has been appointed at this stage. For any question about your personal data, write to contact@disfrigo.fr.

What data we collect and why

Waitlist

• Data: email address, preferred platform (iOS / Android / both), whether you want news about the project’s progress, site language, and where present the acquisition channel (utm_source, possibly utm_campaign), signup date.
• Purpose: notifying you about the Dis Frigo launch and, if you ask for it by ticking the corresponding box, sending you news about the project’s progress. Nothing else.
• Legal basis: your consent (GDPR article 6.1.a and article L.34-5 of the French Post and Electronic Communications Code).
• Recipient: Brevo (Sendinblue SAS, French company, EU hosting), with email confirmation (double opt-in).
• Retention: until you withdraw consent; contacts with no interaction for 3 years are purged (CNIL recommendation).
• Required vs. optional: email is required (without it we cannot notify you); the platform and the progress updates are optional.
• Unsubscribe: one click, via the link in every email.
• Your data is never sold or shared commercially.

Analytics

• Data: pages viewed, referrer, browser, country, screen size, campaign (UTM parameters) — aggregated, no cookie or persistent identifier. Includes the signup-fr / signup-en conversion events fired on the thank-you pages.
• Purpose: understanding site traffic and campaign effectiveness.
• Legal basis: legitimate interest (GDPR article 6.1.f).
• Recipient: GoatCounter, hosted within the European Union (Germany).
• Retention: data is aggregated and cannot identify you.

Hosting logs

• Data: IP address, user agent, timestamp.
• Purpose: security and service availability.
• Legal basis: legitimate interest (GDPR article 6.1.f).
• Recipient: Vercel Inc. (United States) — see “Transfers outside the European Union” below.
• Retention: per Vercel’s retention policy.

Contact emails

• Data: email address and message content.
• Purpose: responding to your requests.
• Legal basis: legitimate interest (GDPR article 6.1.f).
• Recipient: our email service provider.
• Retention: 1 year after the last exchange.

Who has access to your data

Your data is accessible to Freelance Kevin Ching and the processors listed above (Brevo, GoatCounter, Vercel), strictly within the scope of their respective roles. It is never sold, transferred, or shared commercially with third parties.

Transfers outside the European Union

Brevo and GoatCounter host your data within the European Union. Our host, Vercel Inc., is however based in the United States: hosting the site therefore involves a transfer outside the EU of part of visitors’ technical logs (IP address, user agent).

This transfer is governed by the European Commission’s Standard Contractual Clauses (Implementing Decision (EU) 2021/914 of 4 June 2021), incorporated into Vercel’s Data Processing Addendum (DPA). You can request a copy by writing to contact@disfrigo.fr, or read Vercel’s DPA at vercel.com/legal/dpa.

How long we keep it

Retention periods are detailed per processing activity above. In summary: until consent withdrawal for the waitlist (purged after 3 years of inactivity), aggregated non-identifying data for analytics, Vercel’s own retention period for hosting logs, and 1 year after the last exchange for contact emails.

Cookies and analytics

This site sets no cookies.

To measure traffic, we use GoatCounter, a privacy-friendly analytics tool hosted within the European Union. It uses no cookie, no persistent identifier, and no browser fingerprinting, and cannot track you across sites. The statistics collected (pages viewed, referrer, browser, country, screen size) are aggregated and cannot identify you.

That is why no consent banner is shown to you.

Your rights

You have the right to access, rectify, erase, restrict, and object to the processing of your data, and to port it, as well as the right to withdraw your consent at any time (this does not affect the lawfulness of processing carried out before the withdrawal). To exercise these rights, write to contact@disfrigo.fr. You can also unsubscribe at any time via the link at the bottom of every email we send you.

If you believe your rights are not being respected, you may lodge a complaint with the French supervisory authority:

Commission Nationale de l’Informatique et des Libertés (CNIL)
3 place de Fontenoy — TSA 80715 — 75334 PARIS CEDEX 07, France
www.cnil.fr

Automated decisions

No automated decision-making or profiling is carried out using your data.

Changes to this policy

This policy may evolve, notably at the app launch. The current version is always published on this page, with its update date.

Contact us

contact@disfrigo.fr — see also our Support page and our legal notice.