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Rouge Belles

Legal information

Privacy policy

Last updated : 18/10/2026

English translation for convenience; the French version prevails.

Controller

Michaël Belinga, sole trader (La Clinique du Numérique), La Méridienne, 10 rue de la Verrerie, 06150 Cannes, France · contact@rougebelles.com.

Data collected and purposes

  • Former waitlist (closed on 18 October 2026, no new signups): email, language, favourite Belle (optional), signup page, collected before launch. Purpose: telling you about the launch. Legal basis: consent (GDPR art. 6.1.a).
  • Member account (required to use the chat): first name, last name, email address, password (stored only in hashed form), city, country, date you accepted the terms and privacy policy, confirmation that you are 18 or older, language. Purposes: creating and securing your account, restricting the chat to members, linking your conversations to your account (account id + Belle), sending essential emails (address confirmation, password reset). Legal basis: performance of the contract (GDPR art. 6.1.b); the age confirmation serves our obligation to keep the service adults-only. Once logged in, your conversations are linked to your account rather than the anonymous cookie.
  • Conversation memory: so each Belle remembers you, a short summary of your exchanges with her (first name or nickname, tastes, stories you shared, recent topics) is generated automatically by AI about every 10 messages. It is specific to each Belle (never shared between them), readable only through your account, and stored with Supabase (European Union). Legal basis: performance of the contract (GDPR art. 6.1.b). The chat's “Reset” button deletes the conversation and this summary; please avoid sharing sensitive data.
  • Purchases (membership, packs, custom photo): PayPal order and subscription ids, amount, status, date of the withdrawal-right waiver, chosen Belle and pack, your custom-photo description and delivered photos. Your bank details are never shared with us (PayPal). Purposes: performing and delivering the order, managing Exclusif access, refunds, bookkeeping. An order notification (reference, account email, description) is emailed to the Rouge Belles studio. Legal basis: performance of the contract and accounting obligations (GDPR art. 6.1.b and 6.1.c). Retention: 10 years for accounting records; delivered custom photos remain available while the account exists.
  • Payments: processed by PayPal (Europe) S.à r.l. et Cie, S.C.A. (Luxembourg), acting as a separate controller for payment data. We only receive the transaction confirmation (id, amount, date, offer, PayPal email) to deliver the offer and keep our accounts. Legal basis: performance of the contract and legal obligations (10-year bookkeeping retention).
  • Chat with an AI character: your messages and generated replies (last 30 exchanges per character), linked to a random anonymous ID (technical cookie rb_vid), to keep the conversation going and protect the service (rate limiting). Legal basis: performance of the requested service. Messages are sent to X.AI LLC (USA) solely to generate replies. Don’t share sensitive data. The “Reset” button deletes the conversation immediately.
  • Technical logs: IP address and connection data processed by the host for security. Legal basis: legitimate interest.

Cookies

No advertising or analytics cookies are used. Only a strictly necessary technical cookie (rb_vid, random ID, 12 months, scoped to /api/) is set when you use the chat; it is exempt from consent.

Recipients and transfers

Hosting, forms and conversation storage: Netlify, Inc. (USA). Chat reply generation: X.AI LLC (USA). Transfers rely on the EU-U.S. Data Privacy Framework and/or standard contractual clauses. Never sold. Member accounts (authentication and profile): Supabase, Inc., data hosted in the European Union (AWS, EU region); transactional emails sent via Supabase. Payments: PayPal (Europe) S.à r.l. et Cie, S.C.A.

Retention

Former waitlist emails: at most 3 years without interaction, or until you ask for deletion at contact@rougebelles.com. Conversations: at most 12 months after the last message, or until you reset them. Account: while active, then deleted at the latest 3 years after your last login; you can ask for deletion at any time at contact@rougebelles.com (account, profile, conversations and their memory summaries are then erased). Memory summaries: while the account exists, or until the conversation is reset.

Your rights

Access, rectification, erasure, restriction, objection, portability and withdrawal of consent at any time: contact@rougebelles.com. You may complain to the CNIL (cnil.fr).

Minors

The service is for adults 18+; we do not knowingly collect minors’ data.