Privacy and Cookie Policy

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Version 2 - Date of publication: 21 July 2026

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Introduction

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ABYSSALE, publisher of the Abyssale Platform whose General Terms and Conditions of Subscription are available in the Terms of Service, is committed to respecting privacy and protecting personal data. The conditions for the collection, processing, and storage of personal data from the Platform accessible at app.abyssale.com (hereinafter "the Platform"), as well as the conditions for exercising your rights, are detailed in this Privacy and Cookie Policy.

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We have designed a concise, transparent, and comprehensible format for information regarding the data processing implemented, to help you understand the conditions under which your data is processed. For any questions regarding this policy, please email us at help@abyssale.com.

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1. General Principles

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ABYSSALE commits to comply with all legal and regulatory obligations regarding personal data protection, including the Law 78-17 of January 6, 1978 in its latest amended version, and EU Regulation 2016/679 of the European Parliament and Council of April 27, 2016 regarding personal data protection - GDPR (together the "Applicable Regulations").

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The terms and expressions used in this Privacy Policy have the meaning attributed to them by the General Data Protection Regulation 2016/679 (GDPR).

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Platform Subscription may be purchased:

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Either by a Client who is a natural person who will also be a User of the Platform: in this context, ABYSSALE is the data controller.
Or by a Client who is a legal entity, which subscribes to the Platform for one or more Users according to the chosen commitment level: in this context, ABYSSALE is the data processor.

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2. Privacy Contact

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To ensure the proper management of personal data and compliance with Applicable Regulations, Abyssale has appointed a Privacy Contact responsible for handling questions and requests relating to the protection of personal data. The Privacy Contact is your point of contact for any privacy matter.

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For any questions concerning this Policy or to exercise your rights, you may contact our Privacy Contact directly:

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By email: dpo@abyssale.com (or help@abyssale.com)
By mail: Abyssale – Attention: Privacy Contact, 49 Rue de Ponthieu, 75008 Paris, France.

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3. Description of Processing

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The characteristics of the processing operated via the Platform are as follows:

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Description of Processing
Category	Details
Processing	Creation of User accounts
Data processed	Email, last name, first name, photograph (optional data), IP address, Password (except SSO connection), Phone (optional), Connection data and logs. Exchanges with Customer Support: Content of messages, emails, and tickets sent to support (via Intercom or email). API & Integration Data: Data transmitted via the Abyssale API or third-party integrations (e.g., Make, Zapier) for the purpose of generating content.
Data subjects	Platform Users, i.e.: Either the Client, a natural person who has subscribed to the Platform; Or authorized persons (employees) by the Client, a legal entity having subscribed to the Platform.
Legal basis	Execution of the Contract: For the management of Subscriptions, User accounts, and access to the Platform. Legitimate Interest of the Company: For B2B prospecting, marketing communications to existing clients, platform security, and R&D (improving AI models). Consent: For the sending of newsletters to non-clients or the use of certain cookies.
Purpose	Authentication of Users to access and use the Platform. Management of Client/User databases. Transmission of marketing communications. Blocking User access to the Platform in case of Platform use contrary to the Contract. Statistical analysis of the Platform and usage data for the purpose of improving the Platform and its Features. Research & Development (R&D): Training and refining internal algorithms and machine learning models (AI) to improve generation quality, using anonymized and/or aggregated data on the basis of the Company's legitimate interest. Where Abyssale acts as data processor, AI training is governed by the controls set out in the Terms of Service and the applicable agreement (opt-out / opt-in setting) and never relies on the Company's own legitimate interest.
Duration of processing	From the creation of the User account to the deletion of the User account plus three (3) months or for the entire duration of the Subscription plus 3 (three) months (intended, if applicable, to reactivate the User accounts of the Client who ultimately wishes to subscribe to a new subscription). It is specified, however, that the data may be archived for a period of five (5) years after the end of the Contract for evidentiary purposes only in case of litigation. Upon termination of the Contract, the Client has a thirty (30) day period to retrieve its Content as set out in the Terms of Service; after this period the deletion timelines above apply, without prejudice to the archiving and any legal or accounting retention periods. Personal data is deleted according to the timelines above. However, data that has been anonymized or aggregated (in such a way that the User is no longer identifiable) may be retained indefinitely for statistical, analytical, and product improvement (R&D) purposes.
Subsequent processors	Amazon Web Services - Ireland: hosting Auth0, Inc. (subsidiary of Okta) - European Union: User authentication and storage and securing of passwords. Brevo - European Union: Marketing and transactional communication by email Intercom - European Union: Instant messaging tool - Abyssale/Client chat for support. Third-Party AI Providers (including but not limited to OpenAI, Anthropic, Black Forest Labs, Google, Alibaba/Qwen, Seedance, Flux) - EU and outside the EEA (including the USA and, depending on the model selected by the Client, other countries): Processing of prompts and generation of text/visual content. Updates to Sub-processors: The Company reserves the right to update this list of sub-processors to ensure the continuity and quality of the Platform. The Client agrees to be notified of such changes via the Platform or email and maintains the right to object for legitimate reasons within thirty (30) days.

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4. Are data subcontracted and/or shared and/or transferred outside the European Economic Area?

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Data Hosting & Processing: The Client's data is primarily hosted on servers located within the European Union (AWS - Ireland).

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Transfers for AI Features: However, the use of certain Features, in particular Generative Artificial Intelligence, requires the transmission of data (prompts, inputs) to sub-processors located outside the European Economic Area, specifically in the United States or, where the Client selects a third-party AI model whose provider is located in another country, that country.

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Safeguards: Abyssale guarantees that these transfers are carried out in strict compliance with Applicable Regulations. They are framed by appropriate safeguards, such as:

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Adherence by the sub-processor to the Data Privacy Framework (DPF) recognized by the European Commission;
Or the signature of Standard Contractual Clauses (SCCs) adopted by the European Commission, ensuring a level of protection equivalent to that of the GDPR.

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5. Is my data secure?

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We place particular importance on the security of personal data. ABYSSALE has implemented technical and organizational measures adapted to the degree of sensitivity of personal data, in order to ensure the integrity and confidentiality of the data and to protect it against any malicious intrusion, loss, alteration, or disclosure to unauthorized third parties. Nevertheless, the security and confidentiality of personal data rely on everyone's good practices; thus, the data subject is invited to remain vigilant on this issue.

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While we implement industry-standard security measures (encryption, access controls), the Client acknowledges that no transmission method over the Internet is 100% secure. Therefore, Abyssale provides these security measures as an obligation of means (obligation de moyens) and cannot guarantee absolute security.

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In the event of a confirmed Personal Data breach, where Abyssale acts as data controller (notably for individual self-service Clients), Abyssale undertakes to notify the competent supervisory authority within seventy-two (72) hours and, where the breach is likely to result in a high risk to the rights and freedoms of the data subjects, to notify the data subjects concerned, in accordance with Articles 33 and 34 GDPR. Where Abyssale acts as data processor on behalf of a Client (a legal entity), Abyssale instead notifies that Client without undue delay so that the Client, as data controller, can fulfil its own notification obligations.

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6. What are your rights regarding your data?

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As a Client User, you have the following rights regarding your personal data:

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Right of access: you can obtain information concerning the processing of your personal data as well as a copy of this personal data.
Right to rectification of your data: if you consider that your personal data is inaccurate or incomplete, outdated, you can require that this personal data be modified accordingly.
Right to erasure of your data: you can require the erasure of your personal data within the limits permitted by law.
Right to restriction of processing: you can request the restriction of the processing of your personal data in the cases provided for by legislation and regulations.
Right to define directives regarding the fate of data after your death: you have the possibility to define specific directives concerning the conservation, erasure, and communication of your personal data after your death.
Right to data portability: when this right is applicable, you have the right to have the personal data you have provided to us returned to you or, when technically possible, to transfer it to a third party.
Right to object: you can object at any time, for reasons relating to your particular situation, to processing of your personal data whose legal basis is legitimate interest.
Right to withdraw your consent: if you have given your consent to the processing of your personal data, you have the right to withdraw your consent at any time. We then cease to process your personal data without affecting previous operations for which you had consented.
Right to recourse: If needed and if a potential dispute does not reach an amicable resolution, you always have the option to approach the competent personal data protection authority to file a complaint (in France, the CNIL - 3 place de Fontenoy 75007 Paris, France).

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As a User employed by a Client, for any information regarding your rights and their exercise, the User is invited to refer to the privacy policy applicable by the Client.

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For any clarification on this privacy policy and to exercise the rights listed above, we invite you to send us a request by email to help@abyssale.com. We implement our best efforts to respond to you as quickly as possible, and in any case, within the legal deadline of one month.

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To process your request as quickly as possible, we thank you for specifying your request precisely.

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You may opt out of receiving marketing emails from us at any time by following the 'unsubscribe' link included in every email or by contacting support. Please note that even if you opt out of marketing emails, we will still send you critical non-marketing notices regarding your Subscription and the Platform (e.g., security alerts, password resets).

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Important Note for End Users (Employees/Team Members): If you use Abyssale through a Workspace provided by your employer or an organization (the 'Client'), please note that the Client is the 'Data Controller' of your data. Abyssale acts strictly as a 'Data Processor' on their behalf. To exercise your rights (access, deletion, correction), please contact your Workspace Administrator directly. We cannot process your request without their authorization.

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7. Protection of Minors

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The Platform is strictly reserved for professional use and is not intended for minors. Abyssale does not knowingly collect personal data from minors (in France, persons under the age of 15 within the meaning of the GDPR). If a parent or guardian discovers that their child has provided us with personal data, they are invited to contact us so that we can delete it immediately.

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8. Cookie Policy

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ABYSSALE is committed to respecting privacy and protecting personal data. It uses various trackers/cookies on its website (hereinafter "the Site") to measure audience and integrate services to improve the interactivity of the Site.

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This cookie usage policy should be read in coordination with the Privacy Policy.

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8.1 What is the purpose of this Cookie Policy?

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To allow you to benefit from the services offered by our Site, such as browsing or optimizing its use, our Site uses cookies.

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The recording of cookies during your visit to the Site is carried out according to the choices you expressed during your first visit (via the cookie banner) or can express at any time (via the cookie settings tool) in accordance with this Policy.

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This policy is formulated in application of the following regulations:

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Article 5(3) of Directive 2002/58/EC as amended in 2009, which establishes the principle of prior user consent before storing information on their terminal or accessing information already stored on it; unless these actions are strictly necessary for the provision of an online communication service expressly requested by the user or have the exclusive purpose of enabling or facilitating communication by electronic means;
Article 82 of the French Data Protection Act of January 6, 1978, as amended;
The guidelines and recommendations of the CNIL (French Data Protection Authority).

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8.2 What is a cookie?

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When browsing our Site, information relating to the navigation of your device (computer, tablet, smartphone, etc.) on our Site may be recorded in text files called "cookies", installed on your browser.

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There are different types of cookies:

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Necessary Cookies: these technical cookies are essential and strictly necessary for the proper functioning of the Site; the Site will not function as expected without them. These cookies do not store any personally identifiable data.
Analytical Cookies: these analytical cookies are used to understand how visitors interact with the Site. These cookies help provide information on the number of visitors, bounce rate, traffic source, etc.
Functional Cookies: these functional cookies allow the execution of certain functionalities such as sharing the content of the Site on social media platforms, collecting comments, the "Chat" function, and other third-party functionalities.
Advertising Cookies: these advertising cookies are used to provide visitors with personalized advertisements based on previously visited pages and analyze the effectiveness of the advertising campaign.

8.3 What cookies are collected on the Site and for what purposes are they collected?

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Abyssale uses Axeptio to manage cookies on our website. For a complete and up-to-date list of the cookies used on our site, including their specific purposes and lifespans, please click on the Axeptio widget available on the Abyssale website.

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The Axeptio widget provides transparency about:

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All necessary cookies essential for site functionality
Analytical cookies used to understand user behavior
Functional cookies that enable additional features
Any advertising cookies that might be used

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This approach ensures you always have access to the most current information about the cookies deployed on our site.

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8.4 Cookie Management

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These trackers/cookies allow the main services of the Site to function optimally. You can technically block them by using your browser settings, but your experience on the Site may be degraded.

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We invite you to visit the CNIL website for all information relating to the control of cookies by browser: https://www.cnil.fr/fr/cookies-et-autres-traceurs/comment-se-proteger/maitriser-votre-navigateur

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Additionally, you have the option to object to the use of analytical cookies and/or functional cookies of the Site, from the cookie banner and the cookie settings widget available via the 'Cookie Management' link located in the footer of the Site.

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Note: For complete transparency and real-time information, users can view the comprehensive list of cookies, their purposes, and lifespans by clicking on the Axeptio widget available on the Abyssale website.

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8.4.1 Cookie management widget

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This widget allows you to choose to accept or refuse the deposit of cookies subject to consent on our site.

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At any time, by clicking on the button [cookie preferences], you can access the widget and modify your preferences.

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8.4.2 Browser software settings

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You can configure your browser software so that cookies are stored in your device or rejected, either systematically or according to their issuer.

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You can also regularly delete cookies from your device via your browser.

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Remember, however, to configure all browsers on your different devices.

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For cookie management and your choices, the configuration of each browser is different. It is described in your browser's help menu, which will allow you to know how to modify your choices regarding cookies. As examples:

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for Internet Explorer™: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies;
for Safari™: https://support.apple.com/fr-fr/guide/safari/sfri11471/mac;
for Chrome™: https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en;
for Firefox™: https://support.mozilla.org/fr/kb/protection-renforcee-contre-pistage-firefox-ordinateur?redirectlocale=fr&redirectslug=Activer+et+d%C3%A9sactiver+les+cookies;
for Opera™: https://help.opera.com/en/latest/web-preferences/#cookies.

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We draw your attention to the fact that by configuring your browser to refuse cookies, certain functionalities, pages, and areas of our site, which require the use of cookies, will not be accessible, for which we cannot be held responsible.

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For more information on how to configure your browser software, we invite you to consult the website of the French National Commission for Information Technology and Civil Liberties: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.

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9. Modification of this Document

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We invite you to regularly consult this policy on our Site. It may be updated according to the legal and regulatory context, the CNIL doctrine, and the evolution of the Site/Platform.