Privacy policy

The controller for the processing of your personal data under the GDPR is:

• Waitlist: email address, sign-up source, IP address, browser identifier (user agent), timestamp.
• Account: email address, display name (optional), password (stored only as a cryptographic hash), role, registration date.
• Your collection: details about your fragrances, uploaded photos, ratings, notes, favourites and showcase.
• Subscription & payment: chosen plan, term and payment ID. The actual payment is handled by Mollie (see point 4).
• Access and log data: IP address, derived country and time of last access – for security and abuse prevention.
• Messages: notices/warnings we show you in the app (and by email if you wish).

• Providing your account and collection and handling the subscription – Art. 6(1)(b) GDPR (contract).
• Security, stability and abuse prevention (including IP logging) – Art. 6(1)(f) GDPR (legitimate interest).
• Waitlist and optional emails – Art. 6(1)(a) GDPR (consent), revocable at any time.
• Compliance with legal obligations, e.g. tax retention – Art. 6(1)(c) GDPR.

We share data only as far as necessary for the purposes above:

• Payments: Mollie B.V. (Netherlands) – processes your payment data.
• Email delivery: via our mail server (mail.isolutions.lu) [add an external sending service if used].
• Hosting: iSOLUTIONS S.à r.l. on its own infrastructure (Luxembourg) [adjust if external host].
• Country lookup: your IP address is sent to a GeoIP service (currently ipapi.co) to display the country. This feature can be disabled or replaced with a local solution.
• AI recommendations (if used): information about your collection is sent to Anthropic (AI service) to generate suggestions.

Where processors handle data outside the EU/EEA, this is based on appropriate safeguards (e.g. EU standard contractual clauses) [verify and specify if needed].

We use only technically necessary cookies: a cookie storing your language (flacon_lang) and a session cookie for login. No tracking or advertising cookies are set, so no consent banner is required.

• Account and collection data: until you delete your account.
• Waitlist: until you withdraw consent or the purpose ceases.
• Invoices/payment records: per the statutory retention period [in Luxembourg typically 10 years – verify].
• Log/IP data: [add retention period].

You have the right to access, rectification, erasure, restriction, data portability and objection. You can withdraw consent at any time. You can delete your account yourself or contact us at smell@flacon.lu.

You may lodge a complaint with the supervisory authority: Commission nationale pour la protection des données (CNPD), Luxembourg – cnpd.public.lu.

Transmission is encrypted (TLS/HTTPS). Passwords are stored only as hashes. We apply appropriate technical and organisational measures to protect your data.

We update this policy when features or the legal situation change. The version published here applies. Last updated: [date].