Privacy Policy — Fimelo

The data controller is:

Benoît Rouyer, a natural person, in the process of creating a business.

Trade name: Fimelo Official contact email: app@axiocoach.fr User support email: app@axiocoach.fr Website: https://axiocoach.fr

The publisher may update administrative information relating to its activity in the event of changes to its legal situation, registration, domicile, or organization.

Fimelo may collect the following categories of data:

Identification data: email address, user ID, account information, login method, account preferences.

Usage data: usage history of certain features, creative preferences, modules viewed, interactions with the application, settings chosen by the user, use of free or premium functions.

Data entered by the user: project names, descriptions, progress steps, personal notes, wishlist, equipment, creative categories, organizational preferences, comments, saved ideas, and content voluntarily entered into the application.

Photos and visual content: photos of finished projects, photos of materials, photos of products, images imported into the gallery, images associated with projects, photos used voluntarily as part of certain artificial intelligence features.

Data related to artificial intelligence features: requests formulated by the user, photos or information voluntarily transmitted to generate a suggestion, result generated by the AI, creative preferences used to personalize responses.

Technical data: device type, operating system, application version, technical identifiers, error logs, data necessary for the proper functioning, security, and stability of the application.

Subscription-related data: subscription status, type of offer subscribed to, activation date, expiration date, premium status, technical transaction information transmitted by Apple App Store, Google Play, and/or RevenueCat.

Communication data: messages sent to support, assistance requests, claims, exchanges related to the account, subscription, or operation of the application.

Fimelo does not ask the user to enter sensitive data within the meaning of the GDPR.

The user agrees not to voluntarily enter sensitive, confidential, or third-party data into the application without authorization.

Data is collected and used for the following purposes:

• creation and management of the user account;
• access to the application's features;
• backup and synchronization of creative projects;
• management of the photo gallery;
• management of ongoing and completed projects;
• management of the wishlist;
• management of creative equipment and materials;
• personalization of the user experience;
• generation of creative suggestions;
• use of artificial intelligence features;
• creation of montages, ideas, or creative aids;
• management of reminders and notifications;
• management of subscriptions and premium rights;
• restoration of purchases;
• improvement of the application's functioning, stability, and security;
• diagnosis and correction of bugs;
• user assistance and technical support;
• prevention of abuse, fraud, or non-compliant use;
• compliance with applicable legal, accounting, or regulatory obligations.

Depending on the processing involved, data is processed on the following legal bases:

Performance of the contract: to provide access to the application, features, user account, projects, gallery, subscriptions, and premium features.

Legitimate interest: to improve the application, ensure its security, correct errors, prevent abuse, maintain service stability, and understand the general usage of features.

Consent: when the user accepts certain communications, notifications, optional options, the use of photos in AI features, or certain trackers that are not strictly necessary.

Legal obligation: when the storage or transmission of certain information is required by law, particularly regarding evidence, accounting, taxation, security, or the processing of requests related to user rights.

Fimelo may use third-party services necessary for the operation of the application, including:

• Apple App Store, for distribution of the application, in-app purchases, and subscriptions on iOS;
• Google Play, for distribution of the application, in-app purchases, and subscriptions on Android;
• RevenueCat, for technical management of subscriptions, premium rights, and purchase restoration;
• Lovable Cloud, for hosting, development, backend, or certain technical features of the application;
• Supabase or equivalent infrastructure, for authentication, database management, account management, and application storage;
• Google and Apple, for logins via Google account or Apple account when these options are offered;
• artificial intelligence services, to generate or process certain content voluntarily requested by the user;
• email services associated with the axiocoach.fr domain, for sending service, support, or information emails;
• technical services for diagnostics, security, or error correction.

These providers may process certain data only to the extent necessary to provide their services.

Fimelo does not sell users' personal data.

Fimelo does not directly collect the user's bank details.

Payments, subscriptions, and renewals are processed by the Apple App Store or Google Play, depending on the platform used.

Payment information is managed by Apple or Google according to their own rules, contractual conditions, and privacy policies.

Fimelo and RevenueCat may only receive technical information regarding the subscription status, which is necessary to activate, deactivate, verify, or restore premium access.

Fimelo allows the user to import, save, and organize photos in their projects or in their creative gallery.

Photos added by the user are used to enable the operation of the relevant features, including the gallery, project tracking, archiving of completed creations, voluntary sharing, creative montages, or certain artificial intelligence features.

User photos are not automatically published by Fimelo.

The sharing of a photo to a social network, messaging service, or third-party application is triggered only by a voluntary action of the user.

When the user voluntarily shares content to an external service, this sharing is subject to the terms of use and privacy policy of the service concerned.

Fimelo cannot control the use, conservation, republication, or distribution of content after it has been voluntarily shared by the user to a third-party service.

Fimelo may use artificial intelligence to assist the user with certain features, including:

• generation of creative ideas;
• assistance in creating or organizing a project;
• suggestion of titles, steps, themes, or inspirations;
• analysis of photos voluntarily imported by the user;
• generation of photo montages or creative visuals;
• assistance in structuring wishlists or equipment;
• personalized suggestions based on the user's creative world.

When the user uses an AI feature, the data necessary to generate the response may be transmitted to specialized technical providers.

This data may include instructions entered by the user, certain project information, certain creative preferences, or certain photos voluntarily imported into the relevant feature.

The user must not transmit sensitive, confidential, or third-party data to the AI without authorization.

Content generated by artificial intelligence may contain errors, approximations, inconsistencies, or imperfect results.

The user remains solely responsible for the use, modification, publication, or sharing of the generated content.

Fimelo does not voluntarily collect sensitive data.

The user is requested not to enter sensitive data into the application.

Sensitive data notably includes data relating to health, political opinions, religious beliefs, ethnic origin, sexual orientation, biometric data, or genetic data.

If the user voluntarily enters such data into the application, they do so under their own responsibility.

The user is solely responsible for the information they enter, import, or save in the application.

When the user imports a photo, image, product, creation, reference, text, or any other content belonging to a third party, they guarantee that they have the necessary rights or authorizations.

Fimelo is not intended to receive personal data from third parties without authorization.

The user agrees to comply with the applicable regulations on personal data protection and intellectual property rights when using Fimelo.

Data is kept only for the period necessary for the purposes for which it is processed.

As an indication:

Account data: for the entire duration of the user account's existence.

Subscription-related data: for the duration of the subscription, then for the period necessary for administrative, accounting, technical, or legal management.

Project data: for the duration of use of the service, unless deleted by the user or upon request to delete the account.

Photos and visual content: for the duration of use of the service, unless deleted by the user or upon request to delete the account.

Wishlist and equipment data: for the duration of use of the service, unless deleted by the user or upon request to delete the account.

Data related to AI features: for the period necessary to provide the service, improve operations, ensure security, and for technical management, unless deleted or anonymized where applicable.

Support data: for the duration necessary to process the request, then for a reasonable period allowing for the follow-up of the user relationship.

Technical data and error logs: for a limited period necessary for security, diagnostics, bug fixes, and application improvement.

The user may request the deletion of their account and data, subject to applicable legal retention obligations.

In the event of account deletion, the data is deleted or anonymized within a maximum period of 30 days, unless otherwise required by legal obligation.

Fimelo implements reasonable measures to protect data against unauthorized access, loss, alteration, disclosure, or misuse.

These measures may include authentication mechanisms, access restrictions, application security measures, technical controls, backups, or error monitoring devices.

However, no computer system can guarantee absolute security.

The user must also ensure the confidentiality of their login credentials and use a sufficiently secure password.

Some technical providers used by Fimelo may be located outside the European Union or process data from third countries.

When necessary, Fimelo ensures that these transfers are governed by appropriate safeguards, such as standard contractual clauses, adequacy decisions, or mechanisms recognized by applicable regulations.

Fimelo may send notifications related to the operation of the application, including:

• project reminders;
• ideas of the day;
• progress follow-ups;
• creative suggestions;
• organizational reminders;
• premium features;
• important information related to the account or subscription.

The user can accept or refuse notifications from their device settings.

Refusing notifications does not prevent use of the application, but may limit certain reminders or guidance offered by Fimelo.

The user may receive communications relating to the service, their account, or their subscription.

Communications strictly necessary for the operation of the service may be sent regardless of marketing consent.

Optional marketing communications will only be sent when the user has accepted them, or in cases authorized by applicable regulations.

The user may unsubscribe from marketing communications according to the terms indicated in the messages received or by contacting Fimelo at the following address: app@axiocoach.fr

Fimelo may use technologies necessary for the operation of the service, authentication, security, session management, error correction, and technical measurement of usage.

Trackers strictly necessary for the functioning of the application may be used without prior consent.

Trackers that are not strictly necessary, particularly for advanced audience measurement, non-essential personalization, or marketing purposes, are subject to user consent when required by regulations.

The user can manage certain preferences from within the application or from their device settings when these options are available.

In accordance with the GDPR and applicable regulations, the user notably has the following rights:

• right of access to their data;
• right to rectification;
• right to erasure;
• right to restriction of processing;
• right to object;
• right to data portability where applicable;
• right to withdraw consent when processing is based on consent;
• right to define instructions regarding the fate of their data after death where this right is applicable.

To exercise their rights, the user can contact Fimelo at the following address:

app@axiocoach.fr

A response will be provided within the timeframes stipulated by applicable regulations.

The user can request the deletion of their account from the application when this feature is available, or by email at the following address:

app@axiocoach.fr

Account deletion leads to the deletion or anonymization of associated data within a maximum of 30 days, unless otherwise required by legal obligation.

Deleting the Fimelo account does not automatically cancel a subscription purchased via the App Store or Google Play.

The user must separately cancel their subscription from their Apple or Google account if they wish to end automatic renewal.

Fimelo is not intended for minors under 15 years of age without the authorization of their legal representative.

When a minor uses the application, their legal representative is responsible for their use, the content imported, the data entered, and, where applicable, the purchase of a subscription.

Fimelo reserves the right to delete an account when it appears that it is being used by a minor without appropriate authorization.

If the user believes that their rights are not being respected, they may file a complaint with the CNIL:

Commission Nationale de l'Informatique et des Libertés Website: https://www.cnil.fr

This privacy policy may be modified at any time to take into account developments in the application, services used, features offered, technical providers, commercial offers, or applicable regulations.

The user will be informed of significant changes when necessary.

The applicable version is the one published in the application and/or at the following address at the time of use of the application:

https://axiocoach.fr/confidentialite/fimelo

The last update date is indicated at the top of the document.

For any questions regarding this privacy policy, the processing of personal data, the user account, the subscription, or the exercise of GDPR rights, the user can contact Fimelo at the following address:

app@axiocoach.fr