Data controller
The controller for processing related to this website and contact enquiries is Kevin Lefebvre EI, trading as Initial IA.
- Registered office
- 32 rue de Paris, 92100 Boulogne-Billancourt, France
- SIREN
- 947 791 836
- Personal data contact
- contact@initial-ia.com
Data concerned
On the Initial Brain and AI Integration pages, as soon as a valid telephone number is entered, that number and the other completed fields are saved progressively, even if the form is not finished. They are used to contact you about your enquiry. A notice beside the telephone field explains this saving. The data is retained in an enquiry table separate from audience measurement and sent to Initial IA's private notification channel. A temporary technical identifier in browser session storage allows the same enquiry to be completed; it does not contain your contact details.
To unlock the Astra guide, your email, the requested resource, the request source and its dates are saved in a table separate from audience measurement, on our infrastructure. This access does not automatically subscribe you to a newsletter or trigger an email. A functional cookie keeps your guide access on this device for 30 days.
The website currently has no client account or payment facility. When you write to us, we may receive your name, professional contact details, company, enquiry content and any attachments you choose to provide.
On the Initial Brain and AI Integration pages, the Cal.com calendar unlocks after your enquiry has been approved and saved with a name and email. Booking sends Cal.com your contact details, company, submitted context, time zone and selected time slot. A technical identifier links the booking to your enquiry; its status is stored on our infrastructure to prevent duplicate submissions. When you submit the brief form or request access to a beta tool, the completed fields, including your email, company and technical preferences, are sent to Initial IA to handle your request.
With consent, our own audience measurement tool, hosted on our infrastructure, records pages viewed, visit source, device type, duration, reading depth and certain actions, such as opening the calendar, submitting a form or using a tool. No personal form fields or IP addresses are stored in audience measurement events.
When the GA4 identifier is enabled, some of these actions are also sent to Google Analytics 4 after consent: page viewed without URL parameters, action type, functional source and GA4 technical identifiers. Advertising signals, advertising personalisation and form data remain disabled. Google states that it does not log or store individual IP addresses of users in the European Union after using them technically to determine approximate location.
With consent, PostHog Cloud EU receives page views, functional actions and session recordings with entered fields masked. URL parameters, fragments, network bodies and headers are excluded. The administration panel and embedded frames are not recorded. No named profile is created or linked to forms. Collection uses PostHog's European endpoints and can be stopped from the Cookies page.
Technical logs, such as IP address, date, time, browser and request, may be processed by the hosting infrastructure to deliver and secure the website. Their exact scope will be confirmed with the production hosting provider.
Purposes and lawful bases
- Responding to an enquiry and preparing a proposal: pre-contractual steps requested by the individual or a legitimate interest in handling business enquiries.
- Arranging a requested appointment: pre-contractual steps and practical management of the time slot, confirmations and any changes.
- Managing a client relationship: performance of the contract, service follow-up and compliance with related legal obligations.
- Ensuring operation and security: legitimate interest in preventing abuse, diagnosing incidents and protecting the service.
- Measuring and improving the website: consent to measuring useful content and reviewing journeys that lead to an enquiry, without advertising or matching activity to the identity supplied in forms.
- Meeting an obligation or defending rights: legal obligation or legitimate interest, depending on the circumstances.
Required information
Information sent by email or through the booking module is voluntary. However, a reply address and basic context are needed to handle your enquiry usefully; selecting a time slot is required to confirm an appointment. Where information is essential to entering into a contract, this will be specified in the relevant documents.
Recipients and processors
Data is accessible to authorised people at Initial IA and, strictly as necessary, technical providers, professional advisers or legally authorised authorities. It is not sold.
The website, primary analytics database and administration panel are hosted on infrastructure operated in France by PRODISTRIB. Cal.com provides appointment booking when its module is enabled and used. Discord receives private operational form notifications and temporary panel access codes. Google is involved only for the supplementary GA4 view when configured and accepted. Brevo may store professional contact details in lists corresponding to the request and send transactional confirmations when that function is enabled. These providers access only the data needed for their work.
Location and transfers
Initial IA prioritises controlled architectures and can offer environments hosted in France or deployed at the client's premises. This commercial commitment does not, however, fully describe this website's data processing.
The website is hosted in France. The location applicable to booking data and notifications depends on the configured Cal.com and Discord services and their current terms. Where a provider involves a transfer outside the European Economic Area, Initial IA checks the applicable safeguards, including an adequacy decision or standard contractual clauses.
When GA4 is enabled, requests from devices in the European Union are first processed on regional servers according to Google's documentation, after which measurement data may be processed on Google's global infrastructure. Regional settings and the disabling of Google signals are retained in Initial IA's configuration.
Retention periods
An enquiry from a prospect that does not lead to a contract may be retained for up to three years from collection or the prospect's last active contact. Data relating to a contractual relationship is retained during that relationship, then archived according to applicable legal periods and evidential needs.
Administration panel events and technical browsing data are retained for a maximum of thirteen months where needed for improvement, security or technical measurement of the service. Data that is no longer needed is deleted or anonymised, unless retention is legally required.
Your rights
Depending on the processing, you may request access, rectification, erasure, restriction or portability of your data, or object to its use. Where processing is based on consent, you may withdraw it at any time without affecting earlier processing.
Write to contact@initial-ia.com specifying your request. Proof of identity will only be requested if there is reasonable doubt. You may also lodge a complaint with the CNIL.
Security and automated decisions
Initial IA implements technical and organisational measures appropriate to the risk and limits access to those who need it. In the current website version, visits do not automatically lead to profiling or decisions producing legal effects.
Policy updates
This policy will be updated when payment, a client area, a new measurement purpose, a significant booking journey change or a new data processing provider is introduced. The date at the top of the page identifies the version consulted.