01Who processes your data
The data controller is IMERSIA LAB, a société par actions simplifiée
registered under SIREN number 945 170 330, whose registered office is at
64 rue d’Ivry, 27000 Évreux, France.
IMERSIA LAB is not required to appoint a data protection officer: it carries out
neither large-scale systematic monitoring nor large-scale processing of sensitive data.
Your requests are handled directly by Enzo Tessier, President, at
contact@imersialab.com.
In accordance with Regulation (EU) 2016/679 (GDPR) and the French Data
Protection Act, IMERSIA LAB keeps a record of its processing activities, available to
the CNIL.
02What we collect, and why
We collect only what we need in order to reply and to carry out our work. No data is
sold, rented or passed to a commercial partner.
| Data | Why |
On what basis |
| First name, last name, email address, phone, company, preferred reply
channel | To get back to you and look at your request |
Pre-contractual steps taken at your request (art. 6.1.b) |
| Type of event, date, place, number of guests, duration, budget in mind, free
message | To price the booking and check it is feasible |
Pre-contractual steps taken at your request (art. 6.1.b) |
| Billing details, signed quotes, invoices |
To carry out the order and keep our accounts |
Performance of the contract and legal obligation (art. 6.1.b and 6.1.c) |
| Exchanges by email or WhatsApp | To follow up the relationship and keep a
record of what was agreed |
Legitimate interest in documenting our exchanges (art. 6.1.f) |
| Photographs and videos taken in the cabin | To give you your content at
the end of the session | Performance of the service you request by starting the
session (art. 6.1.b) |
| IP address, pages viewed, date and time, device type |
To keep the site secure and measure its audience |
Legitimate interest in security, consent for measurement (art. 6.1.f and
6.1.a) |
| Business email address of a former prospect |
To tell you about something new on a comparable offer |
Legitimate interest, with one-click unsubscribe (art. 6.1.f) |
The fields marked as required in the form are the ones without which we cannot
reply. The others are optional: leaving them blank does not stop your request going
through.
We collect no sensitive data within the meaning of article 9 of the GDPR, and we
carry out neither profiling nor automated decision-making.
03The photos and videos taken in the cabin
The Clubby cabin photographs and films the people who step into it. That is the whole
point of the experience, and it deserves to be said plainly.
- You are told before you go in. There is signage at the cabin
entrance, and a message appears on the inside screen before the session starts.
- You decide. The session only starts when you start it from the
screen. You can stop it at any point.
- The content is yours. The prints come out of the cabin; the videos
are given to you through a secure link at the end of the session.
- We erase them within 48 hours. After that, the files are
permanently deleted from our servers. We keep no copy.
- We never publish them without your agreement. Using an image for
communication requires separate written permission, freely given and revocable at any
time. Refusing changes nothing about your access to the cabin.
We use no facial recognition, no biometric identification, and we never match content
to a named identity.
The event organiser is required to tell their guests that the cabin is there. If you
would like an image of you deleted before the 48-hour deadline, write to us: we delete
it the same day.
04Children
The cabin can be used from the age of five; under-fourteens must be accompanied by a
responsible adult.
Capturing the image of a child requires the permission of the holder of parental
authority. It is for the event organiser to make sure of this and to tell us of any
objection; we act on it immediately.
No image of a child is used by IMERSIA LAB for communication purposes, whatever
permission may have been obtained elsewhere.
The site’s contact form is not intended for children under fifteen.
05Who has access to your data
Internally, only the people who need it have access: the sales team for quote
requests, management for invoicing.
Externally, we use the following technical providers, bound by a processing agreement
within the meaning of article 28 of the GDPR:
| Provider | Role |
Location |
| OVH Cloud — OVH SAS | Hosting of the site and of the form
data | France |
| Google Workspace — Google Ireland Limited | Receiving and storing our
email exchanges | European Union; transfers outside the EU covered by standard
contractual clauses |
| Google Analytics 4 — Google Ireland Limited | Site audience
statistics | European Union; transfers outside the EU covered by standard
contractual clauses |
| WhatsApp — Meta Platforms Ireland Ltd | Exchanges when you
choose to write to us on that channel | Ireland, with transfers to the United
States |
| Our accountant | Keeping the accounts | France |
Your data may also be disclosed to administrative or judicial authorities where the
law requires it.
We do not sell, rent or exchange any data for advertising purposes.
06Transfers outside the European Union
Our data is hosted in the European Union.
One exception: if you choose to write to us on WhatsApp, the content
and metadata of your messages pass through Meta Platforms Ireland, which may transfer
them to the United States. That transfer relies on the European Commission’s adequacy
decision of 10 July 2023 on the EU–US Data Privacy Framework, supplemented by
standard contractual clauses.
If you would rather avoid that channel, email and the site’s form remain hosted in
the European Union: it is the simplest option, and it makes no difference to how
quickly we reply.
07How long we keep it
| Data | Retention period |
| Quote request that goes no further | 3 years from our last
exchange |
| Client file | The length of the relationship, then 5 years |
| Signed quotes, invoices, accounting records | 10 years
(art. L.123-22 of the French Commercial Code) |
| Photographs and videos taken in the cabin | 48 hours, then permanent
deletion |
| Image usage permissions | The length of the use, then 5 years as
evidence |
| WhatsApp exchanges | 3 years from the last message |
| Server connection logs | 12 months |
| Audience statistics | 25 months |
| Record of your choice about trackers | 6 months |
Once these periods expire, the data is deleted or irreversibly anonymised.
08How we protect it
The site is served over HTTPS only: what you type into the form travels
encrypted.
Access to our tools is individual and protected by two-factor authentication. The
servers holding the data are in the European Union and are backed up regularly.
Content produced in the cabin is stored in a restricted-access area and deleted
automatically once the 48-hour period is up.
In the event of a data breach likely to create a risk to your rights, we inform the
CNIL within 72 hours and, where the risk is high, we inform you directly.
09Your rights
You have the following rights over the data that concerns you:
- Access — obtain a copy of the data we hold about you.
- Rectification — have inaccurate or incomplete information
corrected.
- Erasure — ask for your data to be deleted, within the limits
of our legal retention obligations.
- Restriction — ask for processing to be frozen while something
is checked.
- Objection — object to processing based on our legitimate
interest, and at any time to commercial prospecting.
- Portability — receive, in a readable format, the data you
provided to us.
- Withdrawal of consent — at any time, without affecting the
lawfulness of what was done beforehand.
- Post-mortem instructions — set out what should happen to your
data after your death.
To exercise these rights, write to us at
contact@imersialab.com or by post to
64 rue d’Ivry, 27000 Évreux, France. We reply within one month. We may ask you
for proof of identity if there is reasonable doubt about who is making the request.
If our answer does not satisfy you, you can refer the matter to the French data
protection authority: CNIL, 3 place de Fontenoy, TSA 80715,
75334 Paris Cedex 07, or
cnil.fr.
10Cookies and audience measurement
The site places no advertising cookies, no social network trackers and no cross-site
tracking tools.
Two categories only:
- Strictly necessary trackers — they make the site work and
remember your choice about trackers. They do not require your consent.
- Audience measurement — it tells us which pages are read and by
how many visitors. Tool used: Google Analytics 4.
Google Analytics 4 does not meet the exemption conditions set by the CNIL, so
its use requires your consent. A banner lets you accept or refuse it, just as easily
either way, and your choice is kept for six months. Until you accept, no audience
measurement tracker is placed.
You can change your choice at any time from that banner, or set your browser to
refuse trackers — bearing in mind that a browser setting does not replace a refusal
given on the site.
Demonstration videos only load when you click “play”: no tracker from the video
platform is placed until you start playback.
11Changes to this policy
This policy may change, particularly if we change tool or provider. The version that
applies is the one published on this page, with its update date at the top.
If we make a substantial change affecting processing that concerns you, we will tell
you by an appropriate means before it takes effect.