Privacy Policy (Politique de confidentialite)

Effective date: January 1, 2026

1. Introduction

This privacy policy (hereinafter, the "Policy") describes the conditions under which AEGIS TECHNOLOGIES, a simplified joint-stock company (societe par actions simplifiee) with a share capital of 48,000 euros, whose registered office is located at 12 rue de la Part Dieu - 69003 Lyon, registered with the Lyon Trade and Companies Register under number 921 440 319 (hereinafter, "AEGIS TECHNOLOGIES" or "We"), collects and processes the personal data of users (hereinafter, the "Users" or "You") of the "HUBFEED" application hosted at https://hubfeed.io (hereinafter, the "Platform").

AEGIS TECHNOLOGIES is committed to protecting the privacy of Platform Users and to processing their personal data in accordance with Regulation (EU) 2016/679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, the "GDPR") and Law No. 78-17 of January 6, 1978 on information technology, files, and civil liberties, as amended (hereinafter, the "Data Protection Act" / Loi Informatique et Libertes).

2. Data controller

The data controller for personal data collected on the Platform is:

AEGIS TECHNOLOGIES 12 rue de la Part Dieu - 69003 Lyon, France Email: legal@hubfeed.io

3. Data collected

3.1. Data provided directly by the User

In the context of using the Platform, AEGIS TECHNOLOGIES collects the following categories of data:

Identification data: last name, first name, email address;
Login data: username, password (stored in encrypted form);
Billing data: billing address, payment method information (processed by the payment service provider Stripe);
Communication data: messages sent via the contact form or support.

3.2. Data collected automatically

When using the Platform, the following data may be collected automatically:

Browsing data: IP address, browser type and version, operating system, pages visited, date and time of connection;
Technical data: access logs, performance data;
Cookies and similar technologies: under the conditions described in our cookie policy.

3.3. Data processed in the context of the Features

The User is informed that the data they collect, aggregate, and process through the Platform Features is under their sole responsibility. AEGIS TECHNOLOGIES acts as a processor (sous-traitant) within the meaning of the GDPR for the processing of such data.

4. Purposes and legal bases for processing

Personal data collected is processed for the following purposes and on the following legal bases:

Purpose	Legal basis
Creation and management of the User Account	Performance of the contract (TOU/TOS)
Provision of Platform Features	Performance of the contract
Subscription and billing management	Performance of the contract
Handling contact requests and support	Legitimate interest
Sending commercial communications	Consent
Improvement of the Platform and Features	Legitimate interest
Fraud prevention and security	Legitimate interest
Compliance with legal and regulatory obligations	Legal obligation
Production of anonymized statistics	Legitimate interest

5. Data recipients

Users' personal data may be communicated to the following categories of recipients:

Authorized AEGIS TECHNOLOGIES personnel: only persons who need access to the data in the performance of their duties;
Technical subcontractors: hosting, payment, email, and analytics service providers, strictly within the scope of their assignments;
Administrative or judicial authorities: in the context of applicable legal obligations.

Main subcontractors

Subcontractor	Purpose	Location
Ikoula	Hosting and data storage	France (Reims)
Stripe	Payment processing	United States (PCI-DSS compliant)
Resend	Transactional email delivery	United States (GDPR compliant)

AEGIS TECHNOLOGIES ensures that its subcontractors provide sufficient guarantees regarding the implementation of appropriate technical and organizational measures so that the processing meets the requirements of the GDPR.

6. Data transfers outside the European Union

Some of our subcontractors are located outside the European Union, particularly in the United States (Stripe, Resend).

In such cases, data transfers are governed by Standard Contractual Clauses (SCCs) approved by the European Commission, in accordance with Article 46 of the GDPR.

The User is informed that the legislation of certain third countries may allow access to data by governmental authorities (particularly under FISA 702 in the United States). AEGIS TECHNOLOGIES cannot guarantee that such requests will not be made.

7. Data retention periods

Personal data is retained for the following periods:

Data category	Retention period
Account data	Duration of registration, then 3 years after Account deletion
Billing data	10 years from the transaction (tax and accounting obligations)
Browsing data (logs)	12 months
IP addresses	12 months
Commercial prospecting data	3 years from the last contact
Cookies	See the cookie policy

Upon expiration of these periods, data is deleted or irreversibly anonymized.

8. Data security

AEGIS TECHNOLOGIES implements appropriate technical and organizational measures to protect personal data against unauthorized access, modification, disclosure, or destruction, including:

Encryption of data in transit (TLS/SSL) and at rest;
Strict access controls to systems and data;
Access monitoring and logging;
Regular backups;
Periodic security audits.

9. Users' rights

In accordance with the GDPR and the French Data Protection Act (Loi Informatique et Libertes), the User has the following rights over their personal data:

Right of access: to obtain confirmation as to whether or not personal data concerning them is being processed and, where it is, access to such data;
Right to rectification: to obtain the rectification of inaccurate data or the completion of incomplete data;
Right to erasure: to obtain the erasure of their data in the cases provided for by the regulations;
Right to restriction of processing: to obtain the restriction of processing in the cases provided for by the regulations;
Right to data portability: to receive the data in a structured, commonly used, and machine-readable format, or to request its transmission to another data controller;
Right to object: to object to the processing of their data on legitimate grounds, or to object without reason to processing for commercial prospecting purposes;
Right to withdraw consent: where processing is based on consent, to withdraw it at any time, without affecting the lawfulness of processing carried out prior to the withdrawal;
Right to define post-mortem directives: to define directives relating to the retention, erasure, and communication of their data after their death.

To exercise these rights, the User may contact AEGIS TECHNOLOGIES:

By email: legal@hubfeed.io
By post: AEGIS TECHNOLOGIES, 12 rue de la Part Dieu - 69003 Lyon, France

AEGIS TECHNOLOGIES undertakes to respond to any request within one (1) month of receiving the request. This period may be extended by two (2) additional months depending on the complexity and number of requests.

In the event of difficulty relating to the management of their personal data, the User may file a complaint with the French Data Protection Authority (Commission Nationale de l'Informatique et des Libertes - CNIL):

Website: https://www.cnil.fr
Postal address: CNIL, 3 place de Fontenoy - TSA 80715 - 75334 Paris Cedex 07, France

10. Minors' data

The Platform is not intended for persons under sixteen (16) years of age. AEGIS TECHNOLOGIES does not knowingly collect personal data from minors under 16 years of age.

If AEGIS TECHNOLOGIES learns that a minor under 16 has provided personal data, it will delete such data as soon as possible.

11. Modification of the Policy

AEGIS TECHNOLOGIES reserves the right to modify this Policy at any time. In the event of a substantial modification, the User will be informed by email or by a notification on the Platform at least thirty (30) days before the new version takes effect.

Continued use of the Platform after the modified Policy takes effect constitutes acceptance of the modifications.

12. Contact

For any questions regarding this Policy or the processing of your personal data, you may contact AEGIS TECHNOLOGIES:

By email: legal@hubfeed.io
By post: AEGIS TECHNOLOGIES, 12 rue de la Part Dieu - 69003 Lyon, France