Privacy Policy

Tralo operates its own authentication, database and primary storage on a dedicated server hosted by OVHcloud in Strasbourg, France, and uses Hostinger to host its three applications. We do not sell your data or use it for targeted advertising. Readers use the service without an account; their sessions are pseudonymous by default, rather than strictly anonymous. Data processing varies depending on whether you use tralo.fr or help.tralo.fr: all such processing is described below.

The controller for the processing described in this policy is DigitConsult, a SASU with share capital of €500, Versailles Trade and Companies Register 953 671 591, 90 rue des Saules, 78370 Plaisir, France. Full legal information is set out in the legal notices.

For any question or to exercise your rights: contact@tralo.fr (subject line “Personal data”). DigitConsult has not appointed a data protection officer to date; this address is the dedicated point of contact.

This policy covers the tralo.fr website and app, the help.tralo.fr help centre, the public pages , associated emails and support correspondence.

DigitConsult acts as controller for the management of accounts, subscriptions, payments, teams, unlocks, ratings, reports, support, security and improvement of the Services.

Where an Author or their Organisation decides to ask Readers for a first name, a surname or a class, or to track their progress for educational purposes, the Author or the Organisation determines the purpose and the legal basis: they act as controller and DigitConsult as processor. The processing is then governed by the data processing agreement (DPA).

Depending on your use, we process:
• identity and account: name or pseudonym, email address, account identifier, confirmation status, creation and sign-in dates, display, retention and notification preferences, guided tour state and proof of acceptance of the legal documents;
• authentication: password processed in hashed form, active sessions, IP address and browser associated with security events, confirmation or sign-in links and, if you enable it, encrypted TOTP secret and backup codes;
• content: titles, descriptions, scenes, choices, explanations, images, folders, settings, codes and sharing links, exports and modification dates;
• teams: Organisation, members, roles, invitations, guest email address, invitation token and status, shared folder and administration actions;
• subscription: plan, billing frequency, seats, status, period dates, cancellation, grace period, Stripe customer, subscription and invoice identifiers.

Images imported into the library are served via URLs that are technically accessible to anyone who knows the address, so that they can be viewed by Readers without an account. Do not upload any confidential images. An image added via an external URL results in the browser connecting directly to the server chosen by the Author; Tralo has no control over this server or its privacy policy.

By default, a Reader does not create an account and does not enter their identity. A reading session may nevertheless include a random token, the story viewed, the scenes and choices followed, errors, the score, the state of progress and timestamps. This data is pseudonymous: it does not directly include a name, but must not be described as anonymous within the strict meaning of the GDPR.

If the Author enables identification fields, a first name, surname and/or class may be added. These fields are optional for Tralo but may be made mandatory by the Author for the purposes of their activity. The Author must inform the data subjects, select an appropriate legal basis, limit the data to what is strictly necessary and never request sensitive data. DigitConsult does not use this data for advertising, marketing or its own training of artificial intelligence models.

Le Marketplace traite : votre compte partagé avec Tralo ; votre solde de Crédits et l’historique des mouvements ; les packs achetés, remboursements et identifiants Stripe ; les Contenus Marketplace consultés, débloqués ou dupliqués ; la version et l’origine des copies ; les notes attribuées ; et, selon votre préférence, les rappels liés à une duplication.

A content report includes the category, the message, the email address provided, the account and content IDs, and the processing dates. This information is recorded in our database and a copy is sent to support via Resend so that we can review the report and, if necessary, respond to you.

Stripe notifications received via webhook may contain the transaction and billing data required for validation, reconciliation, prevention of duplicate processing, refunds and accounting records. Tralo does not receive your full card number.

On help.tralo.fr, a search yielding no results and a vote on the usefulness of an article may be forwarded to support along with the query or vote, the article, the URL and the page title. The server may attach the IP address, browser user agent, HTTP language and referrer, which are necessary for security and diagnostic purposes. The purpose is to improve the documentation and detect recurring queries. A local token stores the explicit vote so that you are not asked for it again; searches with no results are only deduplicated in memory whilst viewing the current page.

Emails sent to support contain your address, the message content, attachments and any information you choose to provide. Do not send any sensitive data or pupil data that is not necessary for resolving your enquiry.

On tralo.fr, the Tchao widget is optional and is loaded only after you agree to support trackers. It then creates a visitor identifier, knows the current page and browsing history within Tralo, and processes the messages and technical information of the conversation. On the first message, it may produce a capture of the visible page to give context to support. The widget is not loaded on the public routes intended for Readers. Do not include any pupil data or sensitive information in a conversation or a capture.

• Creating and securing the account, providing the editor, stories, teams and exports: performance of the contract or pre-contractual measures (Art. 6(1)(b) GDPR).
• Managing subscriptions, payments, invoices, refunds and cancellations: performance of the contract (Art. 6(1)(b)) and accounting, tax and consumer law obligations (Art. 6(1)(c)).
• Providing the reading statistics requested by the Author: performance of the service and, for data processed on their behalf, the documented instructions of the controller concerned (Art. 28).
• Preventing fraud, securing the Services, limiting abuse, logging operations and defending our rights: legitimate interest of DigitConsult and of users in having a secure service (Art. 6(1)(f)), or legal obligation where applicable (Art. 6(1)(c)).
• Handling reports and moderating content: legal obligation and legitimate interest in maintaining a lawful and safe service (Art. 6(1)(c) and 6(1)(f)).
• Responding to support and sending essential emails: performance of the contract or legitimate interest in assisting users (Art. 6(1)(b) and 6(1)(f)).
• Improving the help centre from searches and votes: legitimate interest in improving the documentation (Art. 6(1)(f)), taking account of the limited nature of the data and of the right to object.
• Loading the Tchao tracker: consent to storage on and reading from your device (Article 82 of the French Data Protection Act). The processing of a conversation you initiate is then based on the performance of the support service or our legitimate interest in replying to you.
• Sending optional marketing or a newsletter: on account confirmation, subscription by default to the Tralo newsletter (as stated in the terms of use), which can be withdrawn at any time from any email or from Settings → Notifications.

Fields marked as mandatory are required for account creation, payment, security or the processing of your request; without them, the relevant operation cannot be carried out. A Reader’s identity fields are disabled by default and are subject to the Author’s choice. Notes, reports, feedback on support, Tchao discussions and marketing communications are optional. Opting out of Tchao does not prevent you from using Tralo or contacting support by email.

Data is accessible, on a need-to-know basis: to the account holder; to authorised members of a team for shared files; to the Author or the Organisation for statistics relating to their Readers; to Readers for content made accessible via a link; to authorised DigitConsult staff for support, maintenance, security and billing; and to the service providers listed in the following article.

Data may be disclosed to an authority, a court officer, a legal adviser or a third party where required by law, to comply with a legally binding decision, to protect a person or to establish, exercise or defend a right. We do not sell or rent personal data.

• OVH SAS (OVHcloud) (France): hosting of the virtual private server on which DigitConsult operates authentication (Better Auth), the PostgreSQL database, the data API and library image storage. The server and the persistent data are located in the OVHcloud data centre in Strasbourg, France; OVH’s involvement is limited to the infrastructure and its DPA governs any sub-processors it uses.
• Hostinger International Ltd (Cyprus): hosting of the applications, routing of requests and technical logs. Its DPA governs its own sub-processors and any transfers outside the European Economic Area.
• Stripe Payments Europe, Limited (Ireland): payment, invoicing, fraud prevention and payment methods. Stripe may act as processor or as separate controller depending on the operation, and frames transfers through the EU-US Data Privacy Framework and/or standard contractual clauses.
• Plus Five Five, Inc. (Resend) (United States): sending and technical tracking of transactional emails, invitations, reminders, reports and help feedback. Email data and metadata are processed mainly in the United States; the Resend DPA provides for the EU-US framework and the standard contractual clauses.
• Tchao: optional chat and browsing-context widget. Tchao acts on behalf of DigitConsult and states that it uses hosting, real-time, product analytics and artificial-intelligence assistance providers that may process conversations outside the EEA. It is loaded only after consent and is not used on public Reader links.

Hosting the main server in France ensures that the database, authentication and storage are located within the European Union, but does not mean that all technical, payment, email or support data remains exclusively within the European Union. A copy of the relevant guarantees or further information may be requested fromcontact@tralo.fr , subject to the protection of the service providers’ confidential information.

• Account and profile: for the duration of the active relationship. In the event of prolonged inactivity, the account may be deactivated or archived after prior notice; the items strictly necessary for digital rights still accessible may be kept for as long as the user does not request their deletion.
• Reader sessions and identities: according to the period chosen by the Author in their settings (30, 90, 180 or 365 days, or with no automatic limit) and at the latest until they are erased manually, the story is deleted or the service ends in accordance with the controller’s instructions. A change to a shorter period immediately deletes sessions that have already expired.
• Subscriptions, purchases and payment events (including the closed Marketplace history): for the duration of the relationship, then archiving of the items necessary for accounting, refunds, fraud prevention and disputes for the applicable statutory periods.
• Invoices and accounting records: 10 years from the close of the financial year concerned.
• Reports: for the time needed to handle them, then evidential archiving for the applicable limitation period.
• Support and complaints: while being handled, then up to 3 years after the last exchange, longer where litigation or a legal obligation justifies it.
• Help centre feedback: up to 12 months, then deletion or aggregation; Tchao conversations: for the time of the request, then no more than 12 months after it is closed, unless there is a dispute or an earlier deletion request.
• Technical logs: for the short period provided by the configuration and the provider’s contract, extended only where a security event must be analysed or proved.
• Proof of consent and acceptance: for the duration of the relationship, then for the period necessary to prove rights and obligations.

DigitConsult implements measures proportionate to the risks: HTTPS/TLS encryption, regular database backups, passwords not stored in plain text, httpOnly cookie sessions inaccessible to page scripts, optional two-factor authentication, access policies at the database row level, separation of public and privileged keys, internal access controls, rate limiting on certain operations, verification of Stripe signatures and incident management procedures.

No system offers absolute security. Use a unique password, protect your links and sharing codes, limit student data, revoke team access that is no longer required, and export any content for which your business requires an independent copy. Any vulnerabilities can be reported tocontact@tralo.fr .

Depending on the processing and its legal basis, you have the rights of access, rectification, erasure, restriction, objection and data portability, as well as the right to withdraw consent at any time without this affecting previous processing operations. You may also set out instructions regarding the handling of your data after your death in accordance with French law.

Please send your request tocontact@tralo.fr , specifying the account and the right concerned. Proof of identity will only be requested in the event of reasonable doubt. We generally respond within one month, although this period may be extended by two months for complex requests, in which case we will inform you accordingly. For pupils’ data processed on behalf of an organisation, please contact the teacher or the relevant educational establishment first; we will assist them.

You may lodge a complaint with the CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07 (cnil.fr). If your habitual residence or place of work is in another State of the European Economic Area, or if the alleged infringement took place there, you may also apply to the supervisory authority of that State: their contact details are available on the website of the European Data Protection Board.

Author accounts are not intended for children under the age of 15. Readers may be minors but use the service without an account. Information intended for them must be written by the Author in appropriate language. Where processing is based on consent in the context of an information society service, the French age of autonomous consent is 15; other legal bases may apply to public or private institutions.

Tralo does not use pupils’ stories, responses or data to train its own AI models. If a user selects the Tchao widget and sends a message, the service provider may use an AI service to generate a suggested response based on its configuration; do not provide any pupil data to it. No decision having a legal effect or a significant similar effect on Users or Readers is made by DigitConsult through fully automated means.

The list of cookies, local storage, purposes, durations and means of choice is set out in the cookie policy. This privacy policy may change to reflect a change to the Service, to a provider or to the applicable law. Any substantial change is brought to your attention by an appropriate means; fresh authorisation is requested where legally required. The French version prevails.