Legal Notices

2. Privacy Policy

This privacy policy explains how we collect, use, process and protect your personal information in accordance with the General Data Protection Regulation (GDPR).

2.1 Data Collection

We collect the information that you provide us directly when you register for our services, fill out a form or communicate with us. This information may include your name, email address, phone number and any other information that you choose to provide us.

2.2 Data Usage

We use your personal data for:

• Provide, maintain and improve our services
• Process transactions and send related notifications
• Respond to your comments, questions and requests

3. Use of Cookies

Our site uses cookies to improve your browsing experience. Cookies are small text files stored on your device that help us analyze how users use our site.

3.1 Types of cookies used

• Essential cookies: Necessary for the functioning of the site
• Analytics cookies: To analyze how visitors use our site
• Functional cookies: To remember your preferences
• Advertising cookies: To deliver relevant advertisements

3.2 Cookie Control

You can control and/or delete cookies as you wish. You can delete all cookies already on your device and configure most browsers to prevent them from being placed.

4. User Rights

In accordance with the GDPR, you have the following rights regarding your data:

• Right of access: You can request a copy of your personal data
• Right to rectification: You can request correction of your inaccurate data
• Right to erasure: You can request deletion of your data
• Right to restriction of processing: You can request to limit the processing
• Right to data portability: You can request the transfer of your data
• Right to object: You can object to the processing of your data
• Right to lodge a complaint: You can lodge a complaint with the Data Protection Authority (APD/GBA, Belgium)

5. Commercial prospecting (B2B)

When we contact you as part of our commercial prospecting, we process certain professional data that we did not collect directly from you.

5.1 Source of the data

We collect this data from publicly accessible professional websites (your site and the contact information published on it). The data concerned is: the professional email address, the company URL / domain name, the publicly displayed contact name and your site's public SEO metrics.

5.2 Legal basis

This processing relies on our legitimate interest (art. 6.1.f GDPR) in offering our SEO services to professionals whose website shows room for improvement. A legitimate interest assessment (LIA) documents this legitimate interest and is reviewed annually.

5.3 Right to object

You can object to this processing at any time: every email contains a one-click unsubscribe link with immediate effect. Once unsubscribed, your address will never be contacted again.

5.4 Retention period

Your prospecting data is kept until you object, and for no longer than one year after our last contact. If you unsubscribe, your address is kept durably in our suppression list for the sole purpose of never contacting you again.

5.5 Recipients

Your prospecting data is not disclosed to any third party for commercial purposes. Two processors are involved, each with a distinct scope: Plus Five Five, Inc. (Resend), United States, delivers our messages and processes your professional email address and no other data; GROW IT SASU (ChatSEO), established in France, performs the technical analysis of your website and processes its URL, excluding your email address and your contact name. That analysis relies on artificial-intelligence models operated outside the European Union, under the conditions set out in the "International Transfers" section.

6. Contact Us

Data controller: HARGILE (operating through SMART), Productions Associées ASBL, Rue Coenraets 72, 1060 Brussels · BCE 0896.755.397. For any question about this policy or to exercise your rights: charles@hargile.com.

7. International Transfers

Two transfers of data outside the European Economic Area take place, both governed by the European Commission's Standard Contractual Clauses (Implementing Decision (EU) 2021/914). To deliver our emails, we use Plus Five Five, Inc. (Resend), United States. For the technical analysis of your website, our processor established in France stores the reports in Germany and relies on artificial-intelligence model providers established in the United States, acting as sub-processors; those providers are contractually prohibited from training their models on the data processed.

8. Contact Support

Data protection officer: as HARGILE operates through SMART (Productions Associées ASBL), the processing of your data falls under SMART's DPO, reachable at dpo@smart.coop (Smart, Data Protection Officer, Rue Coenraets 72, 1060 Brussels).