This is a translation; in case of discrepancy, the French version prevails.

Privacy policy

Last updated: 7 November 2026

This policy replaces any previous version. In application of articles 13 and 14 of Regulation (EU) 2016/679 (GDPR) and of loi n° 78-17 du 6 janvier 1978 modifiée ("Informatique et Libertés"), it explains which data is collected on https://baiteelayla.com, why, by whom it is processed, how long it is kept and what your rights are.

1. Who is responsible for your data?

Data controller: Association BAITE ELAYLA, association loi 1901, RNA W931011477, 3 rue Bernard Palissy, 93300 Aubervilliers, represented by its President.

Contact for any question about your data: [email protected] (subject: "Données personnelles"), or by post to the address of the registered office.

The association is not required to appoint a data protection officer; the person above is your contact.

Main processor: POLENE TECH, SASU, RCS Paris 108 310 178, 138 avenue Victor Hugo, 75116 Paris, which designs, hosts (via OVH) and maintains the platform on behalf of the association, on its instructions and under a contract compliant with article 28 of the GDPR.

2. What data do we collect?

CategoryDataPersons concerned
Identitysurname, first name, date of birth, photomembers, applicants
Contact detailspostal address, postcode, city, e-mail, telephone number(s)members, applicants, donors, hall hirers
Membership informationvillage of origin (optional), membership number and date, membership-fee status, digital membership cardmembers
Member-file documentsthe documents that you or the board attach to your member file (PDF or images), for example a supporting document; image metadata (location, device) is removed on upload;members
Paymentsamount, date, purpose (membership fee, donation, booking), transaction reference, status, refunds. The association never sees your full card number: the entry and processing of banking data are carried out exclusively by Stripemembers, donors, hirers
Donationsamount, cause supported, receipt issued where applicabledonors
Bookingsdate, time slot, purpose of the event, number of people, payment, cancellationhall hirers
Classesenrolment, attendance; for a child: surname, first name, date of birth, parent's contact detailsmembers, children enrolled by their parents
Published contentannouncements, death notices, messages, submitted photosmembers, families
Google sign-in (optional)Google identifier, name, e-mail address, Google profile photousers choosing this sign-in method
Technical dataconnection logs (IP address, date, time, browser), logs of board members' actions in the administration areaall signed-in users, board members

Mandatory fields. For online membership, all the form fields are mandatory, including the photo (mandatory since July 2026), with the exception of the village of origin, which is optional. They are necessary to verify your identity, issue your membership card and manage your membership. If you do not provide them, your membership application cannot be processed. The other forms mark mandatory fields with an asterisk.

Photo check. When you submit your photo, a check verifies that a face is present. This check is carried out only in your browser, on your device: no data is sent to a third party for this verification, no biometric template is created or kept, and the photo is not used to recognise you automatically. Only the photo you approve is sent to our servers.

Address entry. When you type your address, the characters entered are sent to the public service of the Base Adresse Nationale (api-adresse.data.gouv.fr) in order to suggest existing addresses. This service receives neither your name nor your other data.

3. Why, and on what legal basis?

PurposeLegal basis (art. 6 RGPD)
Processing your membership application, having it approved by the board, managing your account and your membership cardPerformance of the membership contract (art. 6.1.b)
Collecting the membership fee, sending renewal reminders (30 days and 7 days before the due date, on the due date, 2 days after) and suspending member-only features in the event of non-renewalPerformance of the membership contract (art. 6.1.b)
Displaying your profile in the members' directory and allowing other members to contact youLegitimate interest of the association in fostering ties between its members (art. 6.1.f), with the right to object at any time — see section 7
Receiving and managing donations, publishing donation causesPerformance of the donor's commitment (art. 6.1.b); consent of the beneficiary for the publication of their first name and situation (art. 6.1.a)
Issuing tax receipts, where the association is entitled to do soLegal obligation (art. 6.1.c — art. 200 et 238 bis du Code général des impôts)
Managing hall bookings, their payment, cancellations and refundsPerformance of the booking contract (art. 6.1.b)
Managing class enrolmentsPerformance of the contract (art. 6.1.b)
Recording your registration for an event of the association and sending you its confirmation (name, telephone, e-mail, number of adults and children, chosen activities); these registrations are deleted 3 months after the eventPerformance of your request (art. 6.1.b)
Publishing death noticesConsent of the family (art. 6.1.a) for the data of relatives (contact details, photos showing living persons)
Publishing and moderating members' announcementsPerformance of the terms of use (art. 6.1.b)
Informing members about the life of the association (agenda, news, notifications)Legitimate interest (art. 6.1.f), with the possibility to unsubscribe at any time
Soliciting new donations from members and past donorsLegitimate interest (art. 6.1.f), with the right to object at any time
Signing in with GoogleYour consent, expressed by choosing this sign-in method (art. 6.1.a)
Keeping the accounts and retaining supporting documentsLegal obligation (art. 6.1.c)
Ensuring the security of the platform, preventing fraud, tracing actions in the administration areaLegitimate interest (art. 6.1.f) and, for connection data, legal obligation (art. 6.1.c)
Measuring the Site's audience anonymouslyLegitimate interest (art. 6.1.f) — see section 12
Responding to your requests and to the exercise of your rightsLegitimate interest (art. 6.1.f) and legal obligation (art. 6.1.c)

No decision producing legal effects concerning you is made in a fully automated way: membership is approved by the board. The suspension of member features after the due date is an automatic consequence of non-payment, which you can lift by renewing your membership fee or by contacting the board.

Your data is never sold or used for advertising purposes.

4. Who has access to your data?

Within the association: the board members, each according to their role (for example, the treasurer for payments). They are bound by confidentiality.

Other members: only the information displayed in the directory (section 7), if you have not objected to it.

The public: only content published voluntarily (death notices, donation causes, public announcements).

Our service providers (processors), who act only on the association's instructions:

ProviderRoleLocation of the data
Polene Tech (Paris)design, development, maintenance of the platformFrance
OVH SAS (Roubaix)hosting of the servers and data; the Site's e-mails (confirmations, reminders, notifications) are sent from the association's own server, with no third-party platformFrance
Cloudflare, Inc.delivery of the Site, DNS, security, encrypted storage of backups, anonymous audience statisticsUnited States and worldwide network — see section 5

Providers acting as separate data controllers, subject to their own privacy policy:

ProviderRoleLocation
Stripe Payments Europe Ltd (Dublin, Ireland)card payments (membership fees, donations, bookings), refunds, fraud preventionEuropean Union, with possible transfers to Stripe, Inc. (United States)
Google Ireland Ltd (Dublin, Ireland)sign-in with a Google account, only if you choose this optionEuropean Union, with possible transfers to Google LLC (United States)

Authorities: your data may be disclosed to authorised authorities (tax administration, judicial authority) where the law requires it.

5. Transfers outside the European Union

Some providers (Cloudflare, and where applicable Stripe and Google) may process data in the United States. These transfers are governed by:

  • the European Commission adequacy decision of 10 July 2023 on the EU–US data protection framework (EU-US Data Privacy Framework), to which these companies have adhered;
  • and, in addition, the standard contractual clauses adopted by the European Commission (decision 2021/914).

The backups stored with Cloudflare are encrypted before they are sent: Cloudflare has no access to their content.

You can obtain a copy of these safeguards by writing to [email protected].

6. How long do we keep your data?

DataRetention period
Membership application not completed (form started, not paid)90 days, then deletion
Membership application refused by the boarddeletion within one month of the refusal (payment and refund data is kept for accounting purposes, see below)
Member data (including the photo)for the whole duration of the membership, then 3 years from the end of the last membership fee, in order to invite you to rejoin; then deletion or anonymisation
Member-file documentsduration of the membership, then deletion with the file (at the latest 3 years after the end of the membership)
Account deleted at your requestdeletion within 30 days, except data that the law requires to be kept
Accounting records: payments, hire invoices, tax receipts, refunds10 years from the closing of the financial year (the period of article L. 123-22 du Code de commerce, applied out of caution; the minimum tax-audit period is 6 years, art. L. 102 B du Livre des procédures fiscales), in restricted-access archiving
Non-member donor data3 years from the last donation, then deletion (excluding accounting records)
Donation-cause page (first name and situation of the beneficiary)duration of the collection, then removal from the public page within 3 months; immediate deletion at the beneficiary's request
Death noticesonline for 12 months, then removal; immediate removal at any time at the family's request
Hall bookings (excluding accounting records)3 years from the date of the event
Class enrolments (including children's data)duration of the activity year, then 1 year
Announcements published by membersuntil their expiry date or their removal, and at the latest at the end of the membership
Messages sent to the association3 years from the last exchange
Connection logs1 year
Logs of actions in the administration area1 year
Backupsdaily encrypted backup, kept 7 days on the server and 30 days off-site; deleted data therefore disappears permanently from the backups at the latest 30 days after its deletion
Audience statisticsanonymous and aggregated data, with no time limit

7. Members' directory

The directory is accessible only to signed-in members whose membership fee is up to date. It is never public nor indexed by search engines.

It contains only the information allowing members to recognise one another, in particular your surname and first name. Your profile photo is visible to other logged-in members in the directory; you can hide it at any time from your profile ("Hide my photo from the directory"). Your village of origin, your postal address and your date of birth are never displayed there. Other members can contact you from the directory.

Members undertake to use the directory only for exchanges between members, to the exclusion of any commercial solicitation, extraction or disclosure to third parties (see the Terms of use).

You may opt out of the directory at any time, without justification and without consequence for your membership, by e-mail to [email protected] (subject: "Annuaire"). Your request is processed within 7 days at most.

8. Death notices

Data relating to deceased persons does not fall under the GDPR. The association nevertheless handles it with respect and discretion.

A death notice (name, photo, dates, place and time of the funeral, family contact) is published only with the family's agreement and after approval by the board. The person designated as the family contact consents to the publication of their contact details; photos showing living persons are published only with their agreement.

The family may at any time request the modification or removal of the notice at [email protected]; removal takes place as soon as possible and at the latest within 72 hours.

9. Minors

Membership is open under the age conditions laid down by the association's statutes. The data of children enrolled in classes is provided by their parents or legal representatives, who exercise their rights on their behalf. No photo of a child is published without the written authorisation of their legal representatives.

10. Your rights

You have the following rights:

  • access to your data and obtaining a copy;
  • rectification of inaccurate data (most of it can be edited directly in your profile);
  • erasure, under the conditions of article 17 of the GDPR;
  • restriction of processing;
  • portability of the data you have provided to us, where the processing is based on the contract or on your consent;
  • objection, at any time, to processing based on legitimate interest — in particular the directory, information about the life of the association and donation appeals;
  • withdrawal of your consent at any time, without calling into question the processing already carried out;
  • instructions on what happens to your data after your death (article 85 de la loi Informatique et Libertés).

How to exercise your rights: by e-mail to [email protected] or by post to the registered office (3 rue Bernard Palissy, 93300 Aubervilliers). In case of reasonable doubt about your identity, proof of identity may be requested. We reply within one month, extendable by two months for complex requests (you will be informed).

Complaint: if you consider that your rights are not respected, you may lodge a complaint with the Commission nationale de l'informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07 — www.cnil.fr.

11. Security

We implement appropriate measures to protect your data:

  • encrypted connection (HTTPS) across the whole Site;
  • passwords stored in irreversibly encrypted form;
  • access to the administration area limited to board members, according to their role, with traceability of actions;
  • protection against attacks by Cloudflare;
  • daily encrypted backups;
  • payments processed by Stripe, PCI DSS certified: no full card data is stored on our servers.

In the event of a data breach presenting a risk to your rights, the association notifies the CNIL within 72 hours and informs you where the law requires it.

12. Cookies and trackers

The Site uses no advertising, profiling or social-network cookie.

TrackerRoleConsent
Session / authentication cookiekeeping you signed in and securing your accountnot required: strictly necessary for the service you request
Cloudflare security cookies (e.g. __cf_bm, cf_clearance)distinguishing human visitors from malicious botsnot required: strictly necessary for the security of the Site
Cloudflare Web Analyticsanonymous traffic statistics (page views, performance)not required: a tool without cookies or storage on your device, creating no identifier or profile, used solely to measure the Site's audience on behalf of the association, producing anonymous data not cross-referenced with other processing
Google sign-in scriptenabling sign-in with a Google accountloaded only on the sign-in and registration pages; Google's cookies are used only if you choose this sign-in method
Stripe paymentpayment takes place on a secure Stripe page (stripe.com domain), which may set its own trackers necessary for payment security and fraud preventionnot required: strictly necessary for the payment you request
Location mapstatic image (OpenStreetMap) without trackers—

Audience measurement and search presence. The Site uses Cloudflare Web Analytics, a cookieless audience-measurement tool without profiling: it stores nothing on your device and only produces aggregated statistics (pages viewed, referrer, country, device type). Provider: Cloudflare, Inc., certified under the EU-US Data Privacy Framework. No consent banner is needed, since no cookies or trackers are set. The Site uses neither Google Analytics nor any advertising tracker. The association uses Google Search Console solely to monitor the Site's presence in Google search results; this tool collects no data about the Site's visitors.

Why is there no cookie banner? Article 82 de la loi Informatique et Libertés requires prior consent only for trackers that are neither strictly necessary for the requested service nor exempt. The trackers above are either strictly necessary, or used for anonymous audience measurement meeting the exemption conditions defined by the CNIL. No consent is therefore required. If we were ever to add a tracker subject to consent, a consent-collection tool would be put in place beforehand.

You can block or delete cookies at any time in your browser settings; signing in to your account will then no longer work.

13. Changes to this policy

This policy may change, in particular when a new feature is added. The update date appears at the top of the page. In the event of a significant change, members are informed by e-mail or by notification.