Privacy policy

1. Controller

GagneLots [legal form to be completed], France, SIREN/RCS n. [to be completed]. Contact for privacy matters: contact@gagnelots.fr.

2. Data collected

• Account identity: first name, last name, date of birth, e-mail address, phone number.
• Authentication: hashed password (Argon2id, never in clear text).
• Preferences: newsletter opt-in, preferred language.
• Technical logs: IP address, sign-up and login timestamps (for security and abuse prevention).
• Quiz participation: which quizzes you answered, your score, submission date - kept to run the prize draw and show your history under "Mes participations".
• Shipping address (only if you win a prize): postal address, collected exclusively from confirmed winners on the dedicated "Mon lot" page, for the sole purpose of shipping the prize.
• Ad-free subscription (only if you subscribe to this optional, paid option): your payment is processed entirely by Stripe, our payment provider - GagneLots never collects or stores your card number.

3. Purposes and legal basis

• Account management (creation, sign-in, e-mail change, password reset) — contract (GDPR art. 6-1-b).
• Quiz participation and prize draw (recording your entry, drawing winners, shipping the prize to confirmed winners) — contract (art. 6-1-b) and, for the shipping address specifically, only for the time needed to fulfil that shipment.
• Sign-up abuse prevention (IP rate limiting, honeypot, human verification) — legitimate interest (art. 6-1-f).
• Newsletter — free, specific, informed and unambiguous consent (art. 6-1-a). You can withdraw it at any time from your personal space.
• Security logs and fraud prevention — legitimate interest (art. 6-1-f).
• Advertising that funds the free prizes (Google AdSense, personalized) — consent (art. 6-1-a), collected through the consent banner described in the cookie policy. You can withdraw it at any time from that banner.
• Optional ad-free subscription (only if you subscribe) — contract (art. 6-1-b): processing your payment and subscription with Stripe.

4. Retention periods

• Active account: for the whole duration of your account.
• Quiz entries and draw history: for the duration of your account, so "Mes participations" stays accurate.
• Inactive account: 3 years after creation, then anonymised.
• Shipping address of a confirmed winner: only for the time needed to ship the prize, then deleted.
• Newsletter: 3 years after the last interaction.
• Sign-up security logs (IP addresses): 30 days.
• Aborted sign-ups (unverified accounts): 30 days then purged.
• Password-reset / e-mail-change / e-mail-verification tokens: expiration of the token (a few hours).

5. Recipients and transfers

• Hosting: LWS (France) - no transfer outside the EU.
• Transactional e-mail sending: LWS SMTP (France).
• Anti-bot protection: Cloudflare Turnstile - Cloudflare Inc. (USA), certified under the EU-US Data Privacy Framework (Commission Implementing Decision (EU) 2023/1795).
• Advertising: Google AdSense - Google Ireland Limited / Google LLC, serves the ads that fund the site's free prizes and may set advertising cookies (see the cookie policy).
• Prize shipping: the shipping address of a confirmed winner is shared only with the carrier used to send that specific prize.
• Payment processing (only if you subscribe to the ad-free option): Stripe Payments Europe, Ltd. (Ireland) / Stripe, Inc. (USA), certified under the EU-US Data Privacy Framework - handles your payment details, GagneLots never sees your card number.

6. Your rights

Under articles 15 to 22 GDPR, you have the following rights over your personal data: access, rectification, erasure (right to be forgotten), restriction of processing, portability, objection, withdrawal of consent. To exercise them: write to contact@gagnelots.fr, or delete your account directly from your personal space (Account > Delete my account). You may also lodge a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertes, France, www.cnil.fr).

7. Security

Passwords are hashed using Argon2id. Sessions are cookie-based with the flags httponly, secure (production) and samesite=Lax, and are regenerated on each privilege change. Forms are protected by synchronizer CSRF tokens. Access to admin actions is protected by two-factor authentication (TOTP).

8. Minors

The service is strictly reserved to persons aged 18 or over. The date of birth is required at sign-up. Any account opened in violation of this rule is deleted upon detection, along with the associated data.

9. Update of this policy

This policy may be updated to reflect legal, technical or organisational changes. Substantial changes will be notified to account holders by e-mail.