Our Privacy Policy

Last Updated: 28th of November, 2025

1. Introduction

This Privacy Policy explains how we collect, use, and protect your personal data when you use our website. We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

2. Data Controller

New Manager Coach, a division of D326 Holding SASU
515 Chemin de Dartaise, F-26400 Grane
info@d326.eu

+33 4 28500 006

3. What Data We Collect

We only collect personal data that you voluntarily provide to us through our contact form:

Name - so we can address you personally in our response
Email address - so we can respond to your inquiry

We do not collect any other personal data through our website.

4. Legal Basis for Processing

We process your personal data based on:

Your consent (Article 6(1)(a) GDPR) - by submitting the contact form, you consent to us processing your data to respond to your inquiry
Legitimate interest (Article 6(1)(f) GDPR) - responding to inquiries is a legitimate business interest

5. How We Use Your Data

We use the data you provide only to:

Respond to your inquiry or request
Communicate with you regarding the subject of your message

We do not use your data for marketing purposes unless you explicitly consent to this separately.

6. Data Sharing

We do not sell, rent, or share your personal data with third parties, except:

If required by law or legal process
If necessary to protect our rights or property

7. Data Retention

We retain your contact form data for:

Active correspondence: As long as necessary to respond to your inquiry
After resolution: We may keep your data for up to 3 years for record-keeping purposes and to handle any follow-up questions

After this period, your data will be securely deleted unless we are legally required to retain it longer.

8. Your Rights

Under GDPR, you have the following rights:

Right of access - request a copy of the personal data we hold about you
Right to rectification - request correction of inaccurate data
Right to erasure - request deletion of your data ("right to be forgotten")
Right to restriction - request limitation of processing
Right to data portability - receive your data in a structured, commonly used format
Right to object - object to processing of your data
Right to withdraw consent - withdraw consent at any time

To exercise any of these rights, please contact us at info@d326.eu.

9. Right to Lodge a Complaint

If you believe we have not handled your data properly, you have the right to lodge a complaint with your local data protection authority or https://www.cnil.fr.

10. Cookies and Analytics

We use cookies and similar technologies to ensure our site functions properly, to understand how visitors use our website, and to improve our services.

Google Analytics 4 (GA4)

Our website uses Google Analytics 4, a web analytics service provided by Google Ireland Limited. GA4 helps us understand how visitors interact with our website by collecting information such as:

pages viewed
time spent on pages
device and browser information
approximate geographic location (city-level)

GA4 uses cookies and may also process data through event-based tracking.

Google processes data exclusively on our behalf and according to our instructions. IP addresses are anonymised by default in GA4 before being stored or processed.

Legal Basis (GDPR)

The use of GA4 and analytics cookies is based on your consent, provided through our cookie banner in accordance with Article 6(1)(a) GDPR.

You may withdraw your consent at any time by adjusting your cookie preferences in the banner.

Data Retention

GA4 retains event data for a maximum of 14 months, after which it is automatically deleted.

Opt-Out

You can opt out of analytics tracking at any time by:

Updating your preferences via our cookie banner, or
Installing the browser add-on provided by Google: Google Analytics Opt-out Browser Add-on.

Third-Country Transfers

Google may process anonymised analytics data on servers located outside the EU. Google participates in the EU–US Data Privacy Framework, and data transfers are safeguarded by appropriate contractual and organisational measures.

Microsoft Bing Ads – Universal Event Tracking (UET)

Our website uses Microsoft’s Universal Event Tracking (UET), a tracking technology provided by Microsoft Ireland Operations Limited. UET helps us measure the performance of our Microsoft Ads campaigns and understand how visitors interact with our site after clicking an ad.

UET collects information such as:

pages visited
actions taken on the website (e.g., clicks, conversions)
time spent on the site
browser and device information
anonymised IP address (used for geolocation and fraud prevention)

This information enables us to improve our advertising effectiveness and optimise user experience.

Microsoft may combine the data with other information if you are signed into a Microsoft account. No personal data such as names, email addresses, or precise locations is shared with us.

Legal Basis (GDPR)

The use of Microsoft UET is based on your consent in accordance with Article 6(1)(a) GDPR, obtained via our cookie banner.

You may withdraw your consent at any time by adjusting your cookie preferences.

Retention & Data Processing

Data collected via UET is stored by Microsoft for up to 13 months.

Microsoft processes data in accordance with the Microsoft Privacy Statement and acts as a data processor where applicable.

Opt-Out

You can opt out of Microsoft’s personalised advertising by:

Adjusting your preferences through our cookie banner, or
Using Microsoft’s opt-out tool: https://about.ads.microsoft.com/en-us/resources/policies/personalized-ads

Third-Country Transfers

Microsoft may process data on servers located outside the EU. Microsoft participates in the EU–US Data Privacy Framework, and transfers are subject to appropriate safeguards such as standard contractual clauses.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no internet transmission is completely secure, and we cannot guarantee absolute security.

12. Children's Privacy

Our website is not intended for children under 16 years of age. We do not knowingly collect personal data from children.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top indicates when the policy was last revised. We encourage you to review this policy periodically.

14. Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact us:

Email: info@d326.eu
Address: 515 Chemin de Dartaise, F-26400 Grane
Phone: +33 4 28500 006