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PRIVACY POLICY

COLBER – Financial decision assistant (Phase 1)

Last updated: January 5, 2026

ARTICLE 1 - OUR COMMITMENT

At COLBER, privacy is not an option; it is the foundation of our relationship of trust. We designed our application to put technology at the service of your understanding of financial investment, for strictly informative and educational purposes.

Our model is clear, your personal data belongs to you. We use it exclusively to provide you with analyses and decision-support tools. COLBER formally commits to never selling, renting, or transferring your personal data to third parties for commercial purposes. Our only source of value lies in the service we provide to you, not in the exploitation of your private life.

ARTICLE 2 - PRINCIPLES REGARDING THE COLLECTION AND PROCESSING OF PERSONAL DATA

In accordance with Article 5 of the European Regulation 2016/679 (GDPR), personal data is:

  • Processed lawfully, fairly, and in a transparent manner in relation to the data subject;
  • Collected for specified, explicit, and legitimate purposes (see Article 3.1 herein) and not further processed in a manner that is incompatible with those purposes;
  • Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
  • Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  • Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
  • Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

Processing is lawful only if, and to the extent that, at least one of the following applies:

  • The data subject has given consent to the processing of their personal data for one or more specific purposes;
  • Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
  • Processing is necessary for compliance with a legal obligation to which the controller is subject;
  • Processing is necessary in order to protect the vital interests of the data subject or of another natural person;
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

ARTICLE 3 - PERSONAL DATA COLLECTED AND PROCESSED DURING NAVIGATION

3.1. Data collected

The personal data collected within the scope of our activity are detailed below:

3.1.1. Navigation data

When browsing the Site or Application:

  • IP address;
  • Browser type and operating system;
  • Pages viewed, actions performed;
  • Log data and technical errors.
    This data may be collected via cookies and trackers, in accordance with the Cookie Policy.

3.1.2. User account aata

When creating a User Account:

  • Email address;
  • Login credentials (encrypted password);
  • Account settings.

3.1.3. Financial data (read-only)

When the User voluntarily connects a third-party service via API:

  • Positions and transaction history;
  • Aggregated portfolio data;
  • Performance and exposure metrics.
    COLBER never has access to the full credentials of third-party services, initiates no transactions, and holds no funds.

3.1.4. Behavioral data

Within the scope of analysis modules (notably Labo):

  • Application usage data;
  • Interactions with modules;
  • Logs allowing for the analysis of behavioral biases.
    This data is used exclusively for analytical and educational purposes.

The collection and processing of this data serve the following purposes:

  • Service Provision and Management: Account creation, authentication, access to features (Radar, Cockpit, Labo), synchronization of financial data.
  • Contract Execution: Subscription billing, management of claims and customer support.
  • Product Improvement: Analysis of logs and behaviors (in a pseudonymized manner) to fix bugs, improve Application ergonomics, and develop new features.
  • Security: Detection of fraudulent activities, securing access, compliance with legal obligations.
  • Communication: Sending transactional emails (confirmations, invoices) and newsletters (subject to consent).

3.2. Data collection method

When you use our site, the following data is automatically collected:

  • Technical connection data (IP address, server logs);
  • Navigation data via cookies (see Cookie Policy).

Other personal data is collected when you perform the following operations on the platform:

  • Registration: Collection of email and password for account creation.
  • API Connection: Read-only retrieval of financial data via API keys voluntarily provided to feed analysis modules.
  • Subscription: Processing of payment data via our secure provider (Stripe) for billing management.

They are kept by the data controller under reasonable security conditions for the entire lifetime of your account.

In the event of an inactive account for 2 years, your personal data will be deleted.

Furthermore, your data may be archived for evidentiary purposes for a period of 5 years.

In the event of account deletion, personal data is deleted or anonymized within a maximum period of 30 days, barring contrary legal obligations.

The company may retain certain personal data beyond the deadlines announced above in order to fulfill its legal or regulatory obligations.

3.3. Data hosting

The colber.app site and data are hosted by:

OVH SAS

2 rue Kellermann, 59100 Roubaix, FRANCE

Website: www.ovhcloud.com

3.4. Data recipients

The following may have access to personal data, strictly within the limits of their missions:

  • The data controller;
  • Technical service providers (OVH hosting, analysis tools, emails, support);
  • Payment service providers (notably Stripe);
  • Third-party API providers connected at the User's initiative (exchanges, brokers).

Service providers act as GDPR processors and are contractually bound to data confidentiality and security.

No data is sold or transferred to third parties for commercial purposes.

3.5. Data security

COLBER implements appropriate technical and organizational measures, including:

  • Encryption of sensitive data;
  • Restricted access to data;
  • Secure protocols (TLS/SSL);
  • Access logging.
    Despite these measures, no system is completely risk-free. The User is invited to adopt good security practices.

3.6. Cookie policy

The cookies we use are mainly related to the functioning of our Site and Application and your security.

Indeed, cookies allow us to identify you and protect your data against unauthorized third parties.

Cookies thus contain your session data and encrypted session signatures.

We also use cookies to offer you personalized content.

These cookies allow us to memorize your settings and display preferences used in your personal space.

In any case, you can oppose the cookies we use and delete them (see your Cookie preferences below).

However, many features of our sites and applications that are necessary for your navigation will be disabled, so that in this case, your navigation may be degraded.

ARTICLE 4 - DATA CONTROLLER

In the context of the use of the colber.app site (hereinafter the "Site") and the COLBER mobile application (hereinafter the "Application"), personal data may be collected.

Data Controller: Thomas Fournier, individual entrepreneur (micro-entreprise).

Trade Name: COLBER

Contact Email: contact.colber@gmail.com

COLBER acts as a data controller within the meaning of Regulation (EU) 2016/679 of April 27, 2016 (hereinafter the "GDPR").

ARTICLE 5 - YOUR RIGHTS

In accordance with the GDPR, you have the following rights:

  • Right to information: via this policy (Articles 13 and 14 of the GDPR);
  • Right of access: right to access all personal data at any time (Article 15 of the GDPR);
  • Right to rectification: right to rectify inaccurate, incomplete, or obsolete personal data at any time (Article 16 of the GDPR);
  • Right to restriction: right to obtain the restriction of the processing of personal data (Article 18 of the GDPR);
  • Right to erasure: right to demand the erasure of personal data (Article 17 of the GDPR);
  • Right to lodge a complaint with a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a violation of applicable texts (Article 77 of the GDPR);
  • Right to define directives relating to the retention, erasure, and communication of your personal data after your death, in accordance with Article 40-1 of the French Data Protection Act (Loi Informatique et Libertés).
  • Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. This withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.
  • Right to portability: under certain conditions specified in Article 20 of the GDPR, you have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format and to require their transmission to the recipient of your choice.
  • Right to object: pursuant to Article 21 of the GDPR, you have the right to object to the processing of your personal data. Note, however, that we may continue to process them despite this objection, for legitimate reasons or the defense of legal claims.

You may exercise these rights by writing to us at the contact details below (Article 6).

On this occasion, we may ask you to provide additional information or documents to prove your identity.

In accordance with applicable regulations, you are entitled to lodge a complaint with the CNIL (Commission nationale de l'informatique et des libertés) in the event of an unsatisfactory resolution of your exercise of rights in France.

You can access the complaint form by clicking here.

ARTICLE 6 - EXERCISING YOUR RIGHTS

You can exercise your rights by contacting: contact.colber@gmail.com

A response will be provided within a maximum of one month from the receipt of the request.

If the request cannot be satisfied immediately, a dated acknowledgment of receipt will be sent to you.

If the request is incomplete (e.g., missing identity document), we are entitled to request additional information: the deadline is then suspended and runs again once these elements are provided.

Access to these rights is free. In certain cases, reasonable fees related to the processing of your file may be requested, for example, in the case of a request for an additional copy, or in the case of a particularly complex request.

ARTICLE 7 - CONDITIONS FOR MODIFYING THE PRIVACY POLICY

The publisher of the COLBER site reserves the right to modify this Policy at any time to ensure compliance with applicable law.

Any modifications shall not affect purchases previously made on the site, which remain subject to the Policy in force at the time of purchase and as accepted by the user during the validation of the purchase.

The user is invited to review this Policy each time they use our services, without the need for formal notice.

  • Online date: January 5, 2026
  • Last updated: January 5, 2026