Protecting your data
Privacy Policy
Last updated: 13/09/2026
At DUNELIA, protecting your personal data is an absolute priority. This privacy policy describes how we collect, use and protect your information in accordance with the General Data Protection Regulation (GDPR) and the French Data Protection Act.
1. Data controller
The data controller is:
- SAPENSE
- Address: 873 avenue de la Cerisaie, 83300 Draguignan, France
- Email: contact@dunelia.com
2. Data collected
We collect the following data:
2.1 Data provided directly
- Registration: last name, first name, email address and password (hashed)
- Google OAuth sign-in: last name, first name, email address and Google identifier
- Messages: text messages, videos and photos uploaded to the platform
- Beneficiaries: last name, first name, email address and relationship of the designated people
- Payments: bank details are processed directly by Stripe — we never store your card numbers
- Contact: name, email and message sent through the contact form
- Death report: identity and dates relating to the person reported, the reporter's contact details, relationship, message and official supporting document
- Order: chosen plan, timestamped evidence of acceptance of the terms and request for immediate activation
2.2 Data collected automatically
- Session cookies: session identifier to keep you signed in
- Technical data: IP address, browser type and access timestamps (server logs)
- Audience measurement: navigation and conversion events without names, email addresses or personal content, only after consent
- Advertising measurement (Meta pixel): page views and key steps (registration, order, subscription and its amount) together with technical browser information, only after consent to the “Advertising” purpose
3. Purposes of processing
Your data is processed for the following purposes:
| Purpose | Legal basis |
|---|---|
| Creating and managing your account | Performance of the contract |
| Storing content and preparing a transmission file | Performance of the contract |
| Managing payments and subscriptions | Performance of the contract |
| Sending transactional emails (verification and notifications) | Performance of the contract |
| Responding to contact requests | Legitimate interests |
| Security and fraud prevention | Legitimate interests |
| Compliance with legal obligations | Legal obligation |
| Reviewing a death report | Legitimate interests and performance of the service |
| Audience and conversion measurement | Consent |
| Measuring and optimising our advertising on Facebook and Instagram (Meta pixel) | Consent |
4. Data recipients
Your personal data may be shared with:
- Stripe: secure payment processing (PCI DSS certified)
- Google: only if you choose to sign in through Google OAuth
- Our hosting provider: LRD Héberg, for technical data storage
- Google Analytics 4 through Google Tag Manager: audience measurement loaded only after your consent; Google Ireland Limited for the European Economic Area
- Meta Platforms Ireland Limited: advertising pixel loaded only after your consent to the “Advertising” purpose (see the Cookies section)
We never sell or rent your personal data. Only the browsing data described above is shared with Meta, and only with your consent; your content, loved ones and contact details are never shared.
5. Retention periods
| Type of data | Retention period |
|---|---|
| Account data | For the lifetime of the account, then according to applicable legal obligations following an erasure request |
| Uploaded messages and content | For the lifetime of the account or until deleted by the user |
| Payment data | Card data is retained by Stripe; accounting records are kept for the applicable statutory period |
| Sign-in logs | No automated deletion is currently configured; an operational retention period needs to be formalised |
| Contact data | No automated deletion is currently configured; deletion on request, subject to legal obligations |
| Death reports and supporting documents | While the report is being reviewed, then for an archiving period yet to be formalised |
| Files transmitted to heirs (copies of content) | Six months of free access, then six months to recover access by subscribing, followed by six months of retention after advance notice (claims period); permanent deletion at the end of these periods unless an “Recipient Access” subscription is active. For a minor heir, storage is free until they come of age, before these periods begin |
| The deceased's original content | Deleted when no heir's file entitles it to be retained |
| Transmission file log (opening, emails, statuses and deletion) | Retained after content deletion as evidence of processing |
| Evidence of commercial consent | For as long as needed to prove the contract and meet legal obligations |
6. Your rights (GDPR)
Under the GDPR and the French Data Protection Act, you have the following rights:
- Right of access: to obtain confirmation that your data is being processed and receive a copy
- Right to rectification: to correct inaccurate or incomplete data
- Right to erasure: to request deletion of your data (“right to be forgotten”)
- Right to restriction: to request suspension of the processing of your data
- Right to data portability: to receive your data in a structured and readable format
- Right to object: to object to the processing of your data on legitimate grounds
- Right to withdraw consent: at any time, without affecting the lawfulness of prior processing
To exercise these rights, contact us at: contact@dunelia.com
We undertake to respond within 30 days.
You also have the right to lodge a complaint with the CNIL (French Data Protection Authority): www.cnil.fr
7. Data security
We implement appropriate technical and organisational measures to protect your data:
- HTTPS (TLS) protection for communications in production
- Passwords hashed with Argon2id
- CSRF protection on all forms
- Prepared SQL statements and attempt limits on sensitive forms
- Newly uploaded media and supporting documents stored outside the web root and served after permission checks
- Card data processed by Stripe and not stored by DUNELIA
- Mandatory email address verification
Content does not currently benefit from application-level encryption at rest or end-to-end encryption. Authorised administrators may technically access it when necessary for operations or to meet a legal obligation. Two-factor authentication is not yet available.
8. International transfers
The stated hosting provider is based in France, but the application repository does not confirm the physical location of servers and backups. Stripe and Google may process data outside the European Union under their own contractual safeguards. These locations must be confirmed with each provider.
9. Cookies and audience measurement
DUNELIA uses the following strictly necessary items:
- PHPSESSID: maintaining the session, authentication and CSRF protection; session duration
- dunelia_consent: remembering your choice about audience measurement; 180 days
- dunelia_consent_ads: remembering your choice about advertising; 180 days
Only with your consent, given separately for each purpose:
- Audience measurement — _ga and _ga_<identifier>: distinguishing visitors and sessions in Google Analytics 4; up to 2 years
- Advertising — _fbp and _fbc: Meta pixel (Facebook and Instagram), to measure visits, registrations and subscriptions resulting from our advertising; 3 months
When you arrive through a referral link, a business introducer's link or a DUNELIA campaign link (advertising, email or partner), internal trackers measure the origin of the visit:
- dnl_vid: random browser identifier to avoid counting the same visit twice; 13 months
- dnl_aff: original referral link, to pay the referrer if a subscription is taken out; 60 days
- dnl_ref: original business introducer (professional partner), for their remuneration; 90 days
- dnl_cmp: original campaign link, to measure the return from each campaign; 30 days
These measurements are used only by DUNELIA: they are neither shared with an advertising network nor combined with other websites. If you create an account or pay after such a visit, your account is linked to the original link: DUNELIA's administrators can therefore see the accounts and corresponding payments originating from each link, in order to pay referrers and choose campaigns. If you arrived through a referrer's link, the referrer can also see in their space your first name, last-name initial, the first letter and domain of your email address, your registration date, whether your email is verified and whether you have a subscription, and the commission they receive; they never see your content or your loved ones. A simple visitor's IP address is not recorded. A visit's browser and referring page are erased after 13 months, and after 25 months the visit is no longer linked to your browser. When your account is deleted, these visits are detached from it.
Only after consent, Google Tag Manager GTM-5ZHM5K8F loads Google Analytics 4 G-78F64YVEFF. The container audit of 26 July 2026 identified a page-view tag and no active advertising or social pixel. DUNELIA allows only analytics storage: advertising storage, advertising data, personalisation and Google Signals are explicitly disabled. No name, email address, message content or beneficiary data is added to DUNELIA events. The “Manage my cookies” button lets you withdraw consent, delete known analytics cookies and reload the page to stop scripts that have already loaded.
Only after consent to the “Advertising” purpose, the website loads the Meta pixel 217196214427037. It sends page views and key steps (viewing prices, registration, starting an order and a subscription with its amount), together with technical browser information, to Meta Platforms Ireland Limited. This data is used to measure the effectiveness of our advertising and optimise its delivery; Meta may also use it for its own purposes under its privacy policy. DUNELIA and Meta are joint controllers for the collection and transmission of this data. Data may be transferred to Meta Platforms, Inc. in the United States under the EU–US Data Privacy Framework. No name, email address, message content or beneficiary data is sent to Meta.
Refusing does not prevent any functionality. The “Manage my cookies” button lets you change each choice at any time: the relevant cookies are deleted and the page reloads to stop scripts that have already loaded.
10. Minors
The DUNELIA service is intended for adults aged 18 and over. We do not knowingly collect data about minors. If we learn that a minor has provided us with personal data, we will delete it as soon as possible.
11. Changes
We reserve the right to amend this policy at any time. In the event of a material change, we will inform you by email or a notification on the website. The date of the latest update is shown at the top of this page.
12. Contact
For any questions about this policy or your personal data:
- Email: contact@dunelia.com
- Form: Contact page