Privacy policy

1. Introduction and controller

At Les 4 Pourcents, we take the protection of your personal data seriously. This policy explains what data we collect, how we use it and what your rights are.

The controller is Blue Geneva, publisher of the service (see the legal notice), who can be reached at contact@les4pourcents.ch. This policy applies to the les4pourcents.ch website and to the Les 4 Pourcents service. It has been drawn up with regard to the Swiss Federal Act on Data Protection (FADP) and, for people located in the European Union, the General Data Protection Regulation (GDPR).

2. Data we collect

We collect the following data:

• Identification data: first name, last name, email address; if you sign in with Google or LinkedIn, the basic information provided by that service (name, email, profile picture).
• Professional data: job title, LinkedIn profile URL (optional). On the Starter and Pro plans, if you provide this URL, we retrieve the public information of your LinkedIn profile (career history, skills) to personalise your questions and analyses.
• Assessment data: answers to questionnaires, results, generated analyses and personality indicators, answers to daily questions, progress on your action plan.
• Conversations with the AI coach: the messages you send to it and its replies.
• Usage data: points, badges, level, streaks, referrals.
• Browsing and technical data: pages visited, device and browser type, IP address (technical logs), errors encountered.
• Payment data: handled by Stripe. We do not store your card details; we keep the plan subscribed to, the amount, the payment status and the related Stripe identifiers.
• Le Crépuscule newsletter: if you subscribe, your email address and the occupation you declare from a closed list (plus, if you choose "other", the free text you enter), stored in Brevo after email confirmation, until you unsubscribe.

3. How we use your data

Your data is used to:

• provide the service: assessments, AI-generated analyses, AI tool recommendations, action plan, AI coach;
• personalise your experience (questions tailored to your job and profile);
• manage your account, subscription and payments;
• send you service-related emails (welcome, results, subscription information) and, if you have consented, Shift's guidance emails (about eight emails over the first weeks, then after your first assessment) and a newsletter;
• measure audience and usage of the service in order to improve it;
• keep the service secure and detect and fix errors.

The results and analyses produced by artificial intelligence are intended for you: they are not used to make any decision that has legal effects concerning you.

4. Legal bases for processing

We process your data on the basis of:

• the performance of our contract with you (providing the service, managing your account and subscription);
• your consent (Google Analytics audience measurement cookies, Shift's guidance emails, newsletter);
• our legitimate interests (security, error detection, cookieless audience measurement, emails related to your use of the service);
• our legal obligations (retention of accounting records).

5. Data sharing and processors

We never sell your personal data. We only entrust it to the providers needed to run the service:

• Supabase: database and authentication;
• Vercel: website hosting and cookieless audience measurement (section 10);
• Railway: API hosting;
• Stripe: payment processing;
• Brevo: sending emails;
• Google (Gemini): artificial intelligence service that generates the analyses, personalised questions, recommendations and the AI coach's replies, and powers search in the Library. For this purpose it receives your answers, your job title, your LinkedIn profile information where applicable, your searches and your messages to the coach. Starter and Pro plans: this data goes through the paid offering of the Gemini API; under Google's terms, it is not used to improve Google's products, models included, and is only kept for a limited period to detect abuse. Free plan: we use the free tier of the Gemini API; under Google's terms, the content sent and the responses may then be used by Google to improve its products and services, including its models, and may be read by human reviewers;
• Google (Analytics and Tag Manager): audience measurement, under the conditions described in section 9;
• Apify: retrieval of the public information of your LinkedIn profile (Starter and Pro plans, when you provide your LinkedIn URL);
• Sentry: detection of technical errors. For a share of sessions and when an error occurs, Sentry records how the session unfolded (session replay), which may include the content displayed on screen;
• Google and LinkedIn: only if you choose to sign in with these services.

These providers are contractually bound to protect your data and may only use it to provide their services to us, subject to the reservation stated above for the free tier of Google Gemini (Free plan). We may also disclose data to authorities where required by law.

6. Transfers outside Switzerland and the European Union

Most of our providers are established in, or process data in, the United States. Depending on the provider, these transfers are covered by its certification under the Swiss–U.S. and EU–U.S. Data Privacy Framework or by the standard contractual clauses recognised by the Swiss Federal Data Protection and Information Commissioner (FDPIC) and the European Commission.

7. Data retention

• Your account data (profile, assessments, results, conversations with the AI coach) is kept for as long as your account exists. It is deleted within 30 days of a request to delete the account.
• Accounting records relating to your payments are kept for 10 years, as required by Swiss law (art. 958f of the Code of Obligations).
• Technical logs and error reports are kept for a limited period set by our hosting and monitoring providers (from a few days to a few months).
• Google Analytics audience data is kept for no more than 14 months.
• Technical backups are erased as part of their normal rotation cycle.

8. Your rights

Under the FADP and, where applicable, the GDPR, you have the following rights:

• Right of access: obtain a copy of your data;
• Right to rectification: correct your data;
• Right to erasure: delete your account and your data;
• Right to data portability: receive your data in a commonly used format;
• Right to object and to restriction: object to certain processing or ask for it to be restricted;
• Withdrawal of consent: withdraw any consent given (cookies, guidance emails from your profile or the unsubscribe link, newsletter) at any time, without affecting processing already carried out.

To exercise these rights, including to delete your account, write to us at contact@les4pourcents.ch. We reply within 30 days and may ask you to prove your identity.

9. Cookies and consent

Functional cookies and storage. We use cookies and local storage that are strictly necessary for the service to work: sign-in session, the language cookie NEXT_LOCALE and the l4p_consent cookie, which stores your choice about measurement cookies (with a copy in your browser's local storage) for 6 months. They do not require your consent.

Google Analytics audience measurement. Google Analytics 4 (Google Ireland Ltd and Google LLC, ID G-6XSTWLY5PP) and Google Tag Manager (GTM-T559JG3G) are loaded on every page, using Google's consent mode (Consent Mode v2, so-called advanced mode). On your first visit, a banner offers two equivalent buttons, "Accept" and "Refuse"; not answering counts as refusing. By default, consent is treated as denied.

• Before you make any choice, or if you refuse, no Google cookie is set or read. Google only receives cookieless technical signals without any identifier (page viewed, timestamp, browser information, IP address as processed by Google), which it uses to model aggregated statistics.
• If you accept, Google Analytics sets its measurement cookies _ga (up to 2 years) and _ga_<ID>, used for audience measurement only. There is no advertising use: advertising signals remain denied and advertising data is redacted.
• This data may be transferred to the United States; such transfers are covered by the EU–U.S. and Swiss–U.S. Data Privacy Framework and by standard contractual clauses.
• Your choice is kept for 6 months, after which the banner is shown again. You can change it or withdraw your consent at any time via the "Cookie settings" link in the footer; refusing deletes any _ga cookies already set. Refusing does not prevent you from using the service.

10. Cookieless audience measurement

To know how many people visit the website, including visitors who refuse cookies, we also use Vercel Web Analytics (Vercel Inc.). This tool sets no cookie and assigns no persistent identifier: a visitor is only recognised for the duration of one day, through a hash computed on the server and then deleted. It cannot track your browsing from one day to the next or across other websites, and is used only to produce overall statistics (page views, referring site, country, device and browser type).

This measurement is based on our legitimate interest in knowing the audience of our service. Because it keeps nothing that could identify you, we cannot single out your visits to remove them: to avoid being measured, block requests to /_vercel/insights/ in your browser (most ad blockers already do). For any question, write to us.

11. Security

We implement appropriate technical and organisational measures to protect your data: encryption in transit (TLS), secure authentication, restricted access to data.

12. Changes to this policy

We may amend this policy, in particular when we change providers. The date of the last update is shown at the top of the page; in the event of a material change, we will inform you by email or on the website.

13. Contact and complaints

For any question about your personal data: contact@les4pourcents.ch

You may also lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC). If you live in the European Union, you may also contact the data protection authority of your country (in France, the CNIL).