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, not strictly anonymous. Data processing varies depending on whether you use tralo.fr or help.tralo.fr: all processes are 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 center, the public pages , associated emails, and support communications.

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 Organization decides to ask Readers for a first name, a last name, or a class, or to track their progress for educational purposes, the Author or the Organization 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: Organization, 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, in order to allow them to be viewed by Readers without an account. Do not upload confidential images. An image added via an external URL results in a direct connection from the browser 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, last name, and/or class may be added. These fields are optional for Tralo but may be made required by the Author for their activities. 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 stored 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 necessary 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 with no results and a vote on the usefulness of an article may be forwarded to support along with the request or vote, the article, the URL, and the page title. The server may include the IP address, browser user agent, HTTP language, and referrer, which are necessary for security and diagnostics. The purpose is to improve the documentation and detect recurring requests. A local token stores the explicit vote so it is not requested again; searches with no results are only deduplicated in memory while viewing the current page.

Emails sent to support contain your email address, the message content, attachments, and any information you choose to provide. Do not send sensitive data or student data that is not necessary to resolve your request.

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 student 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 center 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 required are necessary for account creation, payment, security, or processing your request; without them, the relevant operation cannot be performed. A Reader’s identity fields are disabled by default and are subject to the Author’s choice. Notes, reports, support feedback, Tchao discussions, and marketing communications are optional. Declining Tchao does not prevent you from using Tralo or contacting support via email.

Data is accessible, on a need-to-know basis: to the account holder; to authorized members of a team for shared files; to the Author or the Organization for statistics on its Readers; to Readers for content made accessible via a link; to authorized DigitConsult personnel for support, maintenance, security, and billing; and to the service providers listed in the following section.

Data may be disclosed to an authority, a court officer, an attorney, or a third party when 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 center in Strasbourg, France; OVH’s involvement is limited to the infrastructure and its DPA governs any subprocessors it uses.
• Hostinger International Ltd (Cyprus): hosting of the applications, routing of requests, and technical logs. Its DPA governs its own subprocessors 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 additional information may be requested atcontact@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 fiscal year concerned.
• Reports: for the time needed to handle them, then evidentiary 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 center 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 analyzed 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 needed, 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 affecting previous processing operations. You may also establish guidelines regarding the disposition of your data after your death in accordance with French law.

Please send your request tocontact@tralo.fr , specifying the account and the right in question. Proof of identity will only be requested in cases of reasonable doubt. We generally respond within one month; this period may be extended by two months for complex requests, after notifying you. For student data processed on behalf of an Organization, please first contact the teacher or the responsible school; 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 15 years of age. Readers may be minors but use the service without an account. Information intended for them must be written by the Author in age-appropriate language. When processing is based on consent within the framework 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 students’ 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 share any student data with it. No decision that produces a legal effect or a significant similar effect on Users or Readers is made exclusively by automated means by DigitConsult.

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 authorization is requested where legally required. The French version prevails.