Legal
This policy covers the personal data for which Turboconsultant is the controller: its commercial relationships, its website, and the technical telemetry of its distribution infrastructure. The data you process through the system stays with you — Turboconsultant neither hosts it, stores it, nor accesses it. Section 2 explains that distinction, which matters more than anything else on this page.
The controller is IPANEMA, a French simplified joint-stock company (société par actions simplifiée) with a share capital of €1,345, registered office at 11 rue Alexandre Legros, 76200 Dieppe, France, registered with the Dieppe Trade and Companies Register under number 885 118 646 (SIRET 885 118 646 00037), operating under the trading name Turboconsultant ("Turboconsultant").
For any question about personal data: jcl@turboconsultant.com.
This policy describes the processing carried out by Turboconsultant as a controller: on the one hand in its relationship with prospects, clients and website visitors; on the other hand for the technical telemetry of its distribution infrastructure.
The Turboconsultant system rests on two distinct flows.
The data you process through the system (prompts, files, content, deliverables, including data belonging to your own clients, prospects, partners or employees) travels directly between your environment and the third-party AI services you have subscribed to — notably Anthropic / Claude — under the terms of your own account. Turboconsultant does not host, store or access that data. For this processing you are the controller; the third-party providers act as processors or controllers under their own terms (see the general terms and conditions, article 9). It is for you to check the terms of those services, including where the processing takes place — first-party Claude storage is located in the United States.
Making the Turboconsultant intellectual property available and managing the licence both run through a server infrastructure operated by Turboconsultant and hosted in the European Union (Germany). This is the only flow in which Turboconsultant itself processes data, in the form of technical telemetry (section 3), excluding any business content.
| People / data | Data processed | Purpose | Legal basis (GDPR art. 6) |
|---|---|---|---|
| Prospects | identity, professional contact details, company, correspondence | B2B prospecting and commercial relationship | legitimate interest (6.1.f); consent where required (6.1.a) |
| Clients | identity, contact details, billing information, content of correspondence | entering into and performing the contract, managing the relationship | performance of the contract (6.1.b) |
| Payment | billing data; card data is processed directly by the payment provider and is not retained by Turboconsultant | collection, fraud prevention | performance of the contract (6.1.b); legal accounting and tax obligation (6.1.c) |
| Support | requests, correspondence, material you send | technical assistance with the system | performance of the contract (6.1.b); legitimate interest (6.1.f) |
| Community and communications | identity, contact details, preferences, contributions | running the community, newsletters and intelligence briefings, event registrations | consent (6.1.a) for electronic communications; legitimate interest (6.1.f) for the community |
| Website visitors | browsing data, cookies and trackers | operating and measuring the audience of the site | consent (6.1.a) for trackers that are not strictly necessary |
| Technical telemetry | per-feature usage counters tied to the licence key: licence identifier, event type, timestamp. No business content, no prompt, no file, none of your data or your clients' data. | billing, security and abuse prevention, improving the service | legitimate interest (6.1.f) |
Because telemetry can be linked back to a licence key, it is treated as pseudonymised data, not anonymous data. Retention periods for each purpose are set out in section 7.
Data is collected directly from the person concerned (form, order, correspondence, registration), generated by use of the system (technical telemetry), or — for B2B prospecting — drawn from publicly accessible professional sources, in accordance with applicable rules.
Where prospect data is collected indirectly (publicly accessible professional sources, professional networks such as LinkedIn, or referral), the person concerned is informed at the latest at first contact, in accordance with article 14 GDPR: categories of data concerned, source, purpose (B2B prospecting), legal basis (legitimate interest), and their right to object to that processing at any time.
Data is intended solely for authorised people within Turboconsultant. Turboconsultant uses processors for certain operations, notably: the payment provider Stripe; the host of the distribution and telemetry infrastructure, Hetzner Online GmbH (Germany, European Union); the website host, Vercel Inc. (United States); email, CRM and internal tracking tools; the community platform and support tools; and, for events run jointly with a partner, the webinar platform used for that event.
An up-to-date list of processors is available on request at the address above, and clients are informed of any change of processor. Each processor is bound by a contract compliant with article 28 GDPR.
When Turboconsultant runs a webinar or an event jointly with a partner, the registration form states clearly which two organisations will receive your registration and may contact you about that event, its replay and their related offers. Each organisation is an independent controller for its own list, and each honours unsubscribe requests for its own list independently. You can unsubscribe from either sender at any time.
Turboconsultant's distribution and telemetry infrastructure is hosted in the European Union (Germany). Some other processors may nevertheless process data outside the European Union. Where that is the case, Turboconsultant ensures that such transfers are covered by appropriate safeguards within the meaning of articles 44 et seq. GDPR: the European Commission's standard contractual clauses, or an adequacy decision where one exists. The list of processors concerned and the safeguards applied can be obtained on request.
A reminder: the business-data flow (section 2) falls outside this policy. Where the third-party services you subscribe to directly carry out their processing — notably United States storage for the first-party Claude service — is governed by those services' terms and is your responsibility.
| Data | Retention |
|---|---|
| Prospects | up to 3 years from the last contact left without follow-up |
| Clients (contractual relationship) | duration of the relationship, then intermediate archiving for up to 5 years (ordinary limitation period, art. 2224 French Civil Code) |
| Accounting records and invoices | 10 years, as required by law |
| Support | as long as needed to handle the request, then deletion or archiving for up to 3 years |
| Communications and community | until consent is withdrawn or the relationship ends |
| Technical telemetry | 24 months from the collection of each event; on termination, deletion within 90 days (excluding technical backups, kept 14 days); deletion on request |
| Technical backups of the licence database | 14 days (rotating) on the server |
| Cookies and trackers | in line with CNIL recommendations (13 months maximum for audience-measurement trackers) |
Telemetry retention — a rolling 24 months, deletion within 90 days of termination — is applied automatically server-side by a daily purge, in production since 19 August 2026.
The turboconsultant.com website uses technical cookies necessary for it to work. It also uses, on some pages:
You can block or delete these trackers at any time from your browser settings, and object to advertising measurement through the settings of the service concerned.
Turboconsultant implements reasonable and appropriate technical and organisational measures to protect data against loss, unauthorised access, disclosure or alteration — including in respect of its distribution infrastructure, the licence key and telemetry data — taking account of the state of the art, the costs involved, and the nature of the data processed.
Under the GDPR, everyone has the right to access, rectify, erase, restrict, object to and port their data, as well as the right to give directions as to what happens to it after their death. Where processing rests on consent, that consent can be withdrawn at any time, without retroactive effect. Where processing rests on legitimate interest — notably prospecting and technical telemetry — the person concerned may object to it.
These rights can be exercised at jcl@turboconsultant.com, together with any identity document required. Anyone may also lodge a complaint with the French data protection authority (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, www.cnil.fr.
Turboconsultant carries out no solely automated decision-making producing legal effects or similarly significantly affecting you (art. 22 GDPR), and no profiling for such purposes. No data protection officer has been appointed to date; any question can be sent to the address above.
This policy may be updated to reflect legal, regulatory or technical developments. The version that applies is the one published on the date you consult it.