Privacy Policy
Update on 09/05/2025
The present Privacy Policy aims to inform users of the site 10-Chairs (hereinafter "the Site") about how 10-Chairs Innovations (hereinafter "we" or "the Company") collects and processes their personal data, in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and the French Data Protection Act.
By using the Site and providing us with your personal data, you agree to the terms of this Policy. We are committed to maintaining the confidentiality and security of your data.
1. Identity of the data controller
The data controller of the data collected on the Site is the company 10-Chairs Innovations, SAS registered with the Epinal Trade and Companies Register under number 931 685 317[1], whose head office is located at 6 C Rue du Grand Breuil, 88200 Remiremont, France.
You can contact us for any questions regarding data protection: - By email: privacy@10-chairs.com (or contact@10-chairs.com) - By mail: 10-Chairs Innovations, 6 C Rue du Grand Breuil, 88200 Remiremont, France.
We only collect personal data necessary for the purposes described in Article 3. This data may be provided directly by you via the Site's forms, or collected automatically during your browsing.
2.1. Data you voluntarily provide to us: - Registration for the waiting list / Referral: email address (mandatory). We may also ask for your first name and/or last name to personalize our communications, although this is not required for registration. As part of the referral process, if you use our interface to invite friends via email, we also collect the email addresses of your potential referrals (see Article 3.3 regarding the use of this data). - Payment of an expression of intent: full name, email address, possibly mailing address (if requested for invoicing), payment amount, transaction date. Note that payment information (credit card number, PayPal identifiers) is not transmitted to us directly: it is securely processed by payment service providers (PayPal, Stripe/Typeform). However, we retain a transaction ID and the payment status. - Investment intention form: if you express interest in investing, we may collect your contact details (name, email, possibly phone) and some information about your investor profile (anticipated amount, etc.) as you provide in the dedicated Typeform. - Email contact / Support: if you contact us directly (via the mailto link or any other means), we will retain your email address and the content of your message in order to respond and follow up on your request. - Participation in the contest (referral): in addition to the registration data for the waiting list (already mentioned), we record your referral link and the number of referrals linked to your account.
2.2. Data collected automatically: - Browsing data: during your visit to the Site, we may collect information such as your IP address, technical data about your browser and device (type and version of the browser, operating system, screen resolution), the browsing path on our Site (pages visited, duration of visits, etc.), as well as the cookies deposited (see Article 6 on Cookies). - Traffic source / referral: if you arrive at the Site via a referral link, we record that a certain referrer is the source of your visit/registration. This may be done via URL parameters or tracking cookies from the referral program.
We do not collect so-called "sensitive" data within the meaning of the GDPR (health data, racial origin, political opinions, etc.), nor data related to payment cards (managed by third parties as indicated).
3. Purposes and legal bases for processing
We process your personal data for different explicit and legitimate purposes. For each processing activity, we ensure that we have an adequate legal basis (consent, contract, legitimate interest, legal obligation).
3.1. Management of the waiting list and the referral program
- Purposes: To record registrations on the waiting list; send registrants information about their position or the progress of the program; facilitate the generation and tracking of referral links; allocate purchase credits based on the number of referrals; identify winners of the referral contest and award them their prizes; detect and prevent referral fraud.
- Legal basis: Processing necessary for the execution of our Terms of Use and the Contest Regulations, which constitute an agreement between you (as a participant) and us for managing your participation in the program. Certain operations (such as sending information emails about your ranking) also fall under our legitimate interest in engaging the community awaiting the product.
3.2. Management of expressions of intent and pre-sales
- Purposes: To process your 20 € expression of intent payments; record these deposits in our customer database; provide you with a payment confirmation; integrate you into the priority list of future buyers; when the time comes, send you a promotional code or a link to deduct your 20 € credit from the product purchase; refund the deposit if necessary (e.g., if the products are not released on time or upon request for withdrawal).
- Legal basis: Processing based on the execution of a contract (our General Terms of Sale that you accept by making the expression of intent). Necessary refund operations also respect a legal obligation when related to the right of withdrawal.
3.3. Investment requests
- Purposes: To gather expressions of interest for investing in 10-Chairs; to create a list of people to contact when the investment operation (via holdings in BSA AIR) is launched; possibly filter these investment prospects based on criteria (e.g., anticipated amount) to respect the limit of 45 people.
- Legal basis: Consent. By filling out the investment intention form, you consent to provide us with this information for the purpose of being contacted about an investment opportunity. You may withdraw your consent at any time (for example, by writing to us to request the deletion of your potential investor data).
3.4. Communication and marketing (newsletter)
- Purposes: To inform members of the waiting list about project news, advancements (e.g., completion of the prototype, upcoming opening of pre-orders...), and possibly send general newsletters about the project's progress or promotional offers related to the launch.
- Legal basis: Consent or legitimate interest (prospecting for similar products/services). At the time of your registration, we may explicitly ask you if you wish to receive our newsletters or communications (consent checkbox). If you are already a customer (e.g., you have made a deposit), we may send you communications regarding products or services similar to those already provided, based on our legitimate interest in keeping you informed, in accordance with Article L.34-5 of the French Postal and Electronic Communications Code. In any case, you will have the opportunity to oppose receiving these emails at any time (via the unsubscribe link present in each sending or by contacting us).
3.5. Responses to contact/support requests
- Purposes: To respond to questions you have asked us, assist you in case of issues (e.g., difficulty registering, questions about the deposit, etc.), and generally communicate with you following your request.
- Legal basis: Legitimate interest of the Company in responding to users' requests on the Site. When it involves requests related to the execution of a contract (e.g., requests for reimbursement, exercising a right), the basis may be the execution of the contract or compliance with a legal obligation.
3.6. Operation and security of the Site
- Purposes: To ensure the proper technical functioning of the Site and its features (waiting list, payment modules, etc.); produce anonymous attendance statistics to improve our services; guarantee the security of the Site and your data (preventing attacks, detecting bugs).
- Legal basis: Legitimate interest of the Company in maintaining its Site operational and secure. Certain necessary technical cookies are deposited on this legal basis (see Article 6). Audience measurement, when conducted anonymously or in a privacy-respecting manner (without intrusive tracking), may also fall under legitimate interest.
Regarding referral data for potential referrals: If, via our interface, you enter the email address of a person to send an invitation to join the waiting list, we use this address only once to send this invitation message, mentioning your identity as a referrer[7]. We do not retain the referral's address if they do not register; it is deleted or anonymized after sending the invitation unless the invitation recipient takes action by registering (in which case, their address is collected as a new registrant). This approach aims to comply with referral and prospecting regulations: the referral is not added to our marketing database without their action or explicit consent.
4.1. Internally: The personal data collected is accessible to authorized members of the Company, only to the extent necessary for the execution of their tasks. For example, customer support staff will have access to contact details to respond to inquiries, the technical team will have access to registration information to manage the waiting list, etc. Given the small size of our start-up, it is possible that these roles are held by a limited number of people (founders, for example, may have access to all data in respect of the aforementioned purposes).
4.2. Service providers and subcontractors: We rely on trusted third-party companies to help us provide our services, for example: - Viral Loops (or equivalent service) – managing the viral referral program: this service processes the email addresses of registrants and tracks referrals (who referred whom) on our behalf. It helps us establish the ranking and award the rewards. - Typeform – online form platform: used to collect certain information (e.g., investment intentions via a questionnaire or surveys). The responses you submit via Typeform are transmitted to us and stored on their servers securely. - Payment services (PayPal, Stripe): handle financial transactions related to the expression of intent. PayPal is used for payments via PayPal account; Stripe (integrated with Typeform) may be used for card payments. These providers collect your payment data directly. We only receive a payment confirmation from them (amount, date, payer's email, transaction ID) and do not have access to your full banking details. - Hosting provider (Framer): the Site is hosted on the infrastructure of Framer B.V. Based in the Netherlands, Framer potentially stores certain technical data or site content (including possibly some user data entered in embedded forms). Framer acts as a technical subcontractor by ensuring the storage and availability of the Site. - Analysis and communication tools: we may use third-party tools such as Google Analytics (configured with IP anonymization) for audience statistics, or email-sending services (e.g., Mailchimp, Sendinblue, Lemlist) for our newsletters. These tools will only receive strictly necessary data (e.g., your email for sending a newsletter). We ensure that our providers demonstrate adequate guarantees of compliance (data processing agreements, server location, etc.).
All these providers are bound to us by a subcontracting contract requiring them to protect your data, to process it only on our behalf and according to our instructions, and not to use it for other purposes.
4.3. Legal obligations and specific cases: Beyond these providers, we do not share your personal data with any third party, except if the law requires or demands it (e.g., judicial requisition, legal obligation to transmit invoices to the tax administration containing your contact details if you made a payment). Similarly, in the event of a dispute, we may communicate certain information to legal advisors or competent authorities to defend our rights.
4.4. Transfers outside the European Union: Generally, we prioritize providers hosting data in the EU or in countries recognized as adequate by the European Commission. However, some providers (e.g., PayPal, Google) may be located or store data in the United States or elsewhere. In this case, we ensure that appropriate safeguards are in place to regulate these transfers, such as the standard contractual clauses from the European Commission or any other measures required by the GDPR. You can contact us for more details about this.
We retain your personal data only for as long as necessary for the purposes for which it was collected, and in accordance with applicable legal requirements.
For example: - Registration data for the waiting list (referral): retained as long as the referral program is ongoing and for 2 years after the end of the contest or after your last activity, unless you request its deletion beforehand. If you have not become a customer after this period, your data may be deleted or anonymized. (Exception: if you have consented to receive our marketing communications, your email address will be retained until unsubscribed or for a maximum of 3 years after your last active contact). - Data related to the expression of intent (pre-order): retained until the product is marketed and the credit is used, or until refund if necessary. Transaction records (invoices, payment receipts) are retained for 10 years in accordance with legal accounting and tax obligations in France. - Potential investor data: retained until the investment offer is concluded. If you actually join the investment, your data will be kept as long as necessary to manage that relationship (according to financial regulations). If the investment project does not come to fruition or if you decide not to participate, your data will be deleted within a maximum of 3 years after collection, unless you request deletion sooner. - Contact data (email messages): retained while your request is being processed and then archived for the applicable limitation period (generally 5 years) in case a record is needed. - Connection logs and browsing data: technical server logs are kept for a few months to ensure security. Cookies have varying lifetimes (see Article 6) but do not exceed 13 months for non-essential cookies.
After these periods, we delete or anonymize personal data. We may retain certain information beyond this if the law requires us to or if it is necessary for the assertion, exercise, or defense of rights in legal proceedings (for example, retention of relevant data in the event of a dispute).
6.1. What is a cookie?
A cookie is a small text file placed on your device (computer, smartphone...) when you visit a website. It allows the site to recognize your device on each subsequent visit, for the duration of the cookie's validity.
We use the following cookies on the Site: - Strictly necessary cookies: These cookies are essential for the operation of the Site and allow you to use its basic functions. For example, they remember your ongoing registration on the waiting list or your login (if applicable) and are used to secure the referral mechanism. Without these cookies, certain services of the Site (like tracking your position on the list) cannot be provided correctly. - Performance / analytics cookies: These cookies gather information about how visitors use the Site (most frequently visited pages, any error messages...). They help us to improve the functioning of the Site. We use tools like Google Analytics configured with IP anonymization for this purpose (which means your IP address is truncated so as not to identify you). The data collected is aggregated and anonymous. - Third-party functional cookies: Some modules embedded in the Site may set their own cookies. For example, our forms (hosted via Typeform) or the integration of the PayPal payment process may use cookies necessary for their operation. Likewise, if we display third-party multimedia content (YouTube videos, etc.), these services may set cookies subject to their own policies.
We do not use advertising or third-party targeting cookies on the Site at this time.
6.2. Consent and cookie management:
Upon your first visit to the Site, a cookies banner informs you of the purposes of the cookies and offers you the option to accept, refuse, or customize their deposit (excluding necessary cookies). Your choice will be retained for a maximum duration of 13 months, after which you will be asked for your consent again.
You can modify your cookie preferences at any time using the cookie management module available on the Site (link "Cookie settings" at the bottom of the page) or through your internet browser settings. Most browsers allow you to control cookies (accept them, block them, delete them).
Please note that refusing necessary cookies may lead to unavailability of certain features of the Site (e.g., the referral system might not work correctly without a cookie to remember the link).
To learn more about cookies and how to control them, you can visit the CNIL website: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.
The Company attaches great importance to the security of your personal data. We implement appropriate technical and organizational measures to protect your data against unauthorized access, disclosure, loss, or destruction. These measures include encryption of communications (Site in HTTPS), data backup procedures, strict access management for our staff and our providers, etc.
We also require our subcontractors to maintain a level of security consistent with industry standards for any processing of your data.
In the event of a personal data breach likely to result in a high risk to your rights and freedoms, we will inform you promptly, as well as the competent supervisory authority (CNIL), in accordance with legal requirements.
In accordance with regulations, you have the following rights concerning your data: - Right of access: obtain confirmation that data concerning you is being processed, and where applicable, access to it and receive a copy, as well as information on the purposes of processing, the categories of data concerned, etc. - Right to rectification: correct inaccurate personal data concerning you and complete incomplete data. - Right to erasure (right to be forgotten): in certain cases, obtain the deletion of your data (e.g., if no longer necessary, if you withdraw your consent, or if you object and no overriding legitimate interest justifies keeping it). - Right to restriction: request the temporary freezing of the use of some of your data, for example to resolve a dispute or to verify the accuracy of contested data. - Right to object: object at any time, for reasons relating to your particular situation, to the processing of your data based on the legitimate interest of the Company. In particular, you can object to commercial prospecting (newsletters) and we will cease this processing. - Right to portability: receive in a structured, commonly used, and machine-readable format the personal data that you provided to us directly, when the processing is automated and based on your consent or a contract, in order to transmit it to another provider if you wish. - Post-mortem directives: in France, the right to define directives on the fate of your data after your death (retention, deletion, communication). You can inform us of specific directives.
To exercise your rights, please contact us at the details provided in Article 1. We may ask you for proof of identity if necessary, in order to ensure that we do not disclose your data to an unauthorized person.
We will strive to respond within 1 month of receiving your request. This deadline may be extended by 2 months in the case of complex or multiple requests, but we will keep you informed.
If despite our efforts you believe your rights are not being respected, you can file a complaint with the competent supervisory authority. In France, the CNIL (www.cnil.fr) is the authority responsible for ensuring respect for privacy.
The services of 10-Chairs (waiting list, expression of intent, etc.) are intended for an adult audience. We do not knowingly collect data from individuals under 15 years old without parental consent. If a minor under 15 has registered without parental authorization, the parent or guardian can contact us to request the deletion of the child's data.
10. Changes to the Privacy Policy
We may update this Privacy Policy, for example in the case of legal changes or changes in our processes. In case of substantial modification, we will inform users (for example via a notice on the Site or by email) and update the date below.
We encourage you to regularly consult this page to stay informed of our privacy practices.