This policy explains which personal data Rotarchi processes, why, who it is shared with, how long it is kept and how to exercise your rights, in accordance with the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and the French Data Protection Act. It describes how the service actually works on the date shown above.
1. Data controller
The controller of the data collected through Rotarchi is the publisher of the service:
- Company name
- Drag and Code SARL (société sous régime offshore), en collaboration avec AI Studio EI
- Legal form
- Drag and Code : SARL de droit tunisien, régime offshore. AI Studio : entreprise individuelle
- Registration
- AI Studio EI : SIREN 103 261 186, SIRET 103 261 186 00011. Drag and Code SARL, société tunisienne, sans immatriculation française.
- Registered address
- 9 rue de la Levée de Sevreau, 79000 Niort, France
- Privacy contact
- mohamed.ezzaouia@drag-and-code-tunisia.com
No Data Protection Officer (DPO) has been appointed to date. For any question about your data, write to the contact address above.
Allocation of roles between the publisher and customer organisations for the data they enter in their projects (controller or processor): [to be completed]
2. Data we process
Account and profile
Email address, first name, last name, display name, company, status (professional or individual) and occupation, bio, time zone and, if you add one, a profile picture. Your password is never stored in plain text: our authentication provider keeps it in hashed form.
Sign-in with Google or Microsoft
If you choose this sign-in method, the provider sends us your email address, your name and an account identifier. We never receive your Google or Microsoft password.
Account security
Security log: event type (sign-in, sign-out, password or email change, two-factor authentication enabled, Google or Microsoft account linked…), date and browser used (user agent). Two-factor authentication factor (TOTP) if you enable it. Your IP address is not stored in this log: it is only used temporarily, in memory, to limit abusive attempts (sign-in, sign-up, contact form).
Organisations and collaboration
Organisations you belong to and your role, invitations sent or received (invitee email address, role, dates), organisation activity log (invitations, role changes, departures). Professional details entered for report letterheads: name, address, phone, email, website, SIRET, French architects' register number, logo.
Projects
Project name and reference, address and municipality, cadastral parcels, programme, planning constraints, 3D versions and generated reports.
AI assistant
Messages exchanged with the built-in assistant and automatic summaries of long conversations. Usage metrics for AI features (feature used, duration, number of tokens, model, outcome), without the content of the exchanges.
Billing (once the paid plan opens)
Company name, SIREN or EU VAT number, billing email, Stripe customer and subscription identifiers, plan, number of seats, trial dates. Your billing address and card details are entered directly with Stripe: Rotarchi neither receives nor stores them. To grant only one trial per person, a fingerprint of your email address (computed with a secret key, from which the address cannot be recovered) is kept in a dedicated register.
Demo requests
Name, email, company, role, phone and message entered in the home page form. This data is emailed to the Rotarchi team; it is not stored in the application database.
Technical data
Strictly necessary cookies and local storage (see section 11). As with any web service, the infrastructure hosting the application logs technical connection data (IP address, date, page requested), kept for 12 months at most.
Rotarchi does not ask for any "sensitive" data within the meaning of Article 9 GDPR (health, opinions, origin, etc.). Avoid entering such data in free-text fields (assistant messages, project descriptions).
3. How this data is collected
- Directly from you: sign-up, profile, project and billing forms, messages to the assistant.
- From Google or Microsoft, if you use them to sign in.
- From another user: the administrator of an organisation who invites you enters your email address.
- Automatically, when you use the service: security log, AI usage metrics, necessary cookies.
- From Stripe, for payment and subscription status, once the paid plan opens.
The cadastral, planning and risk data shown for a parcel comes from public sources; it describes land, not people.
4. Purposes, legal bases and retention
Each processing activity relies on a legal basis under Article 6 GDPR. Consent is only requested where it is actually required.
Create and manage your account, authenticate you
- Data
- Account and profile, Google or Microsoft sign-in
- Legal basis
- Performance of the contract (Art. 6(1)(b))
- Retention
- Until the account is deleted (see section 9)
Secure your account and the service
- Data
- Security log, two-factor factor, IP address (temporary)
- Legal basis
- Legitimate interest: security of the service (Art. 6(1)(f))
- Retention
- Log: 12 months. IP address: not stored by the application
Provide the service: projects, planning analysis, simulation, reports
- Data
- Projects, parcel data, generated results
- Legal basis
- Performance of the contract (Art. 6(1)(b))
- Retention
- As long as the project exists in the organisation
Enable collaboration within an organisation
- Data
- Membership, role, invitations, activity log, report letterhead
- Legal basis
- Performance of the contract (Art. 6(1)(b))
- Retention
- Membership: until you leave or delete your account. Invitations: 30 days after acceptance, revocation or expiry. Activity log: 12 months
Answer your questions with the AI assistant
- Data
- Messages, summaries, project context
- Legal basis
- Performance of the contract (Art. 6(1)(b))
- Retention
- Until the messages, the project or the account are deleted
Apply quotas and monitor the use and cost of AI features
- Data
- AI usage metrics
- Legal basis
- Legitimate interest: cost control and abuse prevention (Art. 6(1)(f))
- Retention
- Metrics: 180 days. Quotas: 7 days (35 days for planning analysis)
Send service emails (address confirmation, password reset, invitations, end of trial)
- Data
- Email address, organisation name
- Legal basis
- Performance of the contract (Art. 6(1)(b))
- Retention
- Not kept by the application after sending
Manage billing and subscriptions (once the paid plan opens)
- Data
- Billing data, trial register
- Legal basis
- Performance of the contract (Art. 6(1)(b)) and accounting obligations (Art. 6(1)(c))
- Retention
- Accounting records: statutory retention period (10 years in France). Trial register: 3 years
Keep proof that you accepted the Terms
- Data
- Accepted version, date
- Legal basis
- Legitimate interest: proof of the contractual relationship (Art. 6(1)(f))
- Retention
- Until the account is deleted
Answer demo requests
- Data
- Contact form data
- Legal basis
- Pre-contractual steps taken at your request (Art. 6(1)(b))
- Retention
- 3 years from the last contact
Send you product news or offers
- Data
- Email address
- Legal basis
- Consent (Art. 6(1)(a)), given and withdrawn in Account > Preferences
- Retention
- No such email is sent to date
Rotarchi uses no audience measurement, targeted advertising or commercial profiling tool without your prior consent. With your consent, these tools are loaded by Google Tag Manager (Google), whose processing may involve a transfer of data outside the European Union.
5. Who can see your data within Rotarchi
Members of your organisations
All members of a shared organisation, whatever their role, see the member list: name, display name, email address, picture, occupation, role and joining date. They see neither your sign-in activity nor your security log.
Owners and administrators
They additionally see pending invitations, the organisation activity log and the members' AI usage metrics (feature, duration, volume — never the content of the exchanges).
Projects and conversations
An organisation's projects are available to its members according to their role. Your conversations with the assistant remain private: no other member can read them, even on a shared project.
Invitation links
An invitation page shows the invited email address and the inviter's name to anyone who holds the link. Do not forward it.
The publisher
People authorised to administer the service can technically access the data, only to the extent necessary for its operation, security and support.
6. Service providers and recipients
We use the following service providers, who only receive the data they need for their task:
Supabase
- Role
- Database, authentication, file storage (profile pictures, logos), sending of authentication emails
- Data
- All application data
Application host (see the legal notice)
- Role
- Running the web application
- Data
- Data passing through the application, technical logs
Mistral AI
- Role
- Language models: assistant, conversation summaries, reading and extraction of public planning documents
- Data
- See section 7
Brevo
- Role
- Sending service emails (invitations, trial) and forwarding demo requests
- Data
- Recipient email address, message content
Stripe (once the paid plan opens)
- Role
- Payment, subscription, invoices, tax calculation
- Data
- Company name, billing email, SIREN or VAT number, billing address, payment method (entered directly with Stripe)
Google, Microsoft (if you use them)
- Role
- Sign-in with your existing account
- Data
- Standard authentication exchange (OAuth)
Rotarchi also queries public services: geographic and planning data (IGN — Géoplateforme and API Carto, Géoportail de l'urbanisme, Géorisques) and the French government company directory (SIREN check when subscribing). Our server sends them parcel references or geometry, the municipality code, the address text typed in the search, or the SIREN number — never your name or email.
Base maps and planning documents (PDF) are, however, loaded directly by your browser from IGN servers (data.geopf.fr), which therefore receive, like any website you visit, your IP address and technical information about your browser.
Rotarchi does not sell or rent your data and does not use it for advertising. It may be disclosed to authorities where the law requires it.
7. Artificial intelligence
Several features rely on language models provided by Mistral AI: the conversational assistant, automatic summaries of long conversations, and reading and extracting rules from public planning documents (local urban plans).
Data sent
Your message, the previous messages of the conversation (or their summary), the context of the displayed project (name, municipality, address, parcels, programme, planning sources), plus your status, occupation and company name to tailor the answers. Your name, email address and identifier are not sent.
Documents
Only public planning documents (Géoportail de l'urbanisme) are sent to Mistral AI for reading. Rotarchi does not offer personal document upload.
Retention at Rotarchi
Messages and their summaries are kept in your private history until deleted. Usage metrics do not contain the content of the exchanges.
Use by the provider
Mistral AI processes this data in the European Union. It does not use it to train its models. It may keep it temporarily for security, abuse detection and its legal obligations.
Reliability
Answers are generated automatically and may contain errors. They are not reviewed by the Rotarchi team: check them before any use (see the Terms).
Do not send the assistant personal data about third parties (for example your clients' contact details) that your question does not need.
None of these features makes decisions producing legal effects concerning you or similarly significantly affecting you within the meaning of Article 22 GDPR: they support your analysis, the final decision is yours.
8. Data location and transfers outside the European Union
The publisher of Rotarchi is identified in the legal notice; its address is located in France. The application database is hosted in the European Union, in Ireland (AWS, eu-west-1 region).
Some providers are companies established outside the European Union or use sub-processors that are. These transfers are covered by the safeguards of Chapter V GDPR:
Supabase
- Data location
- Ireland (AWS, eu-west-1 region). Supabase, Inc. is a US company; some of its sub-processors are located in the United States.
- Safeguard for transfers outside the EU
- European Commission standard contractual clauses (Decision 2021/914), included in Supabase's data processing agreement
Mistral AI
- Data location
- European Union
- Safeguard for transfers outside the EU
- Standard contractual clauses if a Mistral AI sub-processor located outside the EU is involved
Brevo
- Data location
- European Union (France, Germany, Belgium)
- Safeguard for transfers outside the EU
- No transfer outside the EU announced by the provider
Stripe (once the paid plan opens)
- Data location
- European Union and United States
- Safeguard for transfers outside the EU
- EU-US Data Privacy Framework (2023 adequacy decision), supplemented by standard contractual clauses
Application host (Hostinger)
- Data location
- France (Paris)
- Safeguard for transfers outside the EU
- Server located in France: no transfer outside the European Union for hosting the application
If you sign in with Google or Microsoft, these companies process the sign-in data as independent controllers, under their own privacy policies.
9. Retention periods
Account and profile
- Retention
- Until the account is deleted
Account pending deletion
- Retention
- Deactivated for 30 days (can be cancelled at any time), then permanently deleted. You can also delete it immediately.
Profile picture and organisation logo
- Retention
- Deleted with the account or organisation, within 24 hours of permanent deletion
Security log
- Retention
- 12 months, automatic daily purge
Conversations with the assistant
- Retention
- Until you delete them, or the project or account is deleted
AI usage metrics
- Retention
- 180 days. If you delete your account earlier, they are detached from your account.
AI usage quotas
- Retention
- 7 days (35 days for planning analysis)
Projects of a shared organisation
- Retention
- As long as the organisation keeps them. If you delete your account, they stay with the organisation, no longer linked to you.
Projects in your personal workspace
- Retention
- Deleted with your account
Organisation invitations
- Retention
- 30 days after acceptance, revocation or expiry
Organisation activity log
- Retention
- 12 months
Proof of acceptance of the Terms
- Retention
- Until the account is deleted
Trial register (email fingerprint)
- Retention
- 3 years
Billing data at Stripe
- Retention
- Statutory retention period for accounting records (10 years in France)
Demo requests
- Retention
- 3 years from the last contact
Server technical logs
- Retention
- 12 months at most
Database backups
- Retention
- 30 days at most, automatically rotated
10. Your rights
Under Articles 15 to 22 GDPR, you have the following rights:
Right of access
Obtain confirmation that your data is processed and receive a copy of it.
Right to rectification
Have inaccurate or incomplete data corrected.
Right to erasure
Request the deletion of your data, in the cases provided for by the GDPR.
Right to restriction
Request the temporary suspension of processing, in certain cases.
Right to data portability
Receive the data you provided to us in a structured, machine-readable format.
Right to object
Object to processing based on legitimate interest, on grounds relating to your particular situation.
Withdrawal of consent
Withdraw consent at any time, without affecting processing already carried out.
Instructions after death
Set instructions regarding what happens to your data after your death (French Data Protection Act, Art. 85).
Several rights can be exercised directly from your account:
- Access and portability: Account > Data > "Download my data" (JSON file: account, profile, preferences, Terms acceptances, security log, organisations, projects you authored, conversations with the assistant, AI usage metrics).
- Rectification: Account > Profile, and Account > Security for email and password.
- Erasure: Account > Data > "Delete my account".
- Optional emails and cookies: Account > Preferences.
For any other request, or if you no longer have access to your account, write to the contact address in section 1. Proof of identity may be requested if there is reasonable doubt about your identity. We reply within one month, which may be extended to three months for complex or numerous requests; you will be informed if so.
12. Security
Rotarchi applies measures proportionate to the risk: encrypted connections (HTTPS), hashed passwords, available two-factor authentication, data isolation per organisation at database level, password confirmation for sensitive actions, sign-in attempt limits, sign-out of other devices after a password change.
No measure offers absolute security. If a data breach is likely to result in a high risk to your rights, you will be informed as provided for by the GDPR.
13. Minors
Rotarchi is intended for real estate professionals and adult individuals with a project. The service is not intended for minors and does not knowingly collect data about them.
14. Changes to this policy
Each version of this policy is numbered and dated at the top of the page. In case of a significant change, you will be informed in the application or by email before it takes effect. Previous versions are available on request.
15. Complaints
If you believe that the processing of your data does not comply with the regulations, you can lodge a complaint with the French data protection authority (CNIL) — 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France — www.cnil.fr — or with the supervisory authority of your country of residence.
16. Contact
For any question about this policy or your personal data, write to the contact address in section 1.