Privacy Policy

1. Data controller

EPR Representative, Paris, France, is the data controller for the personal data collected through this website and through the provision of EPR authorized representative services. Contact: via the contact form.

2. Data we collect

Through the contact form: name, business email, company name, country, message content. Through the mandate process: company registration data, tax IDs, contact persons, product data, sales channels, and accounting data needed to file eco-organism declarations.

Through routine web traffic: IP address, browser type, pages viewed. We do not use advertising cookies. Analytics, if enabled, are configured in a privacy-preserving way (no personal profiling, no cross-site tracking).

3. Legal bases (GDPR article 6)

We rely on a different legal basis depending on the processing activity:

• Pre-contractual steps (Art. 6(1)(b) GDPR) — for quote requests, scoping conversations, contact form submissions, partnership inquiries: data is processed to respond to a request you made before any contract is signed.
• Consent (Art. 6(1)(a)) — for the lead-magnet download (PDF checklist) and any optional follow-up communications with educational content. Consent is freely given when you submit the form and may be withdrawn at any time.
• Performance of the contract (Art. 6(1)(b)) — once a mandate is signed, for filing dossiers with eco-organisms, ADEME SYDEREP, marketplace handoffs, and annual declarations.
• Legal obligation (Art. 6(1)(c)) — for French EPR retention, accounting and tax obligations.
• Legitimate interest (Art. 6(1)(f)) — for operating and securing the website (anti-spam honeypots, server logs).

4. Recipients and named sub-processors

Personal and business data is shared, strictly for service execution, with the French eco-organisms (Citeo, Léko, Adelphe, Citeo Pro, Ecosystem — which absorbed Corepile in summer 2025 for portable batteries — Ecologic, Refashion, Ecomaison, Valdelia, Screlec, Valobat, Ecominéro), ADEME via the SYDEREP system, and, when required, marketplaces verifying registration numbers (Amazon France, Cdiscount, ManoMano, Fnac/Darty, TikTok Shop FR).

Named third-party sub-processors (Art. 13(1)(e) GDPR):

• Vercel Inc. (United States) — website hosting and Web Analytics (cookieless). Privacy: vercel.com/legal/privacy-policy.
• Resend, Inc. (United States) — transactional email delivery (replies, lead-magnet links, mandate documents). Privacy: resend.com/legal/privacy-policy.
• Google LLC (United States) — externally hosted booking calendar (calendar.app.google) when you choose the “Book a 30-min call” option. We do not embed the calendar on our pages; clicking the link opens Google directly, where Google's own privacy terms apply.

5. International transfers (Art. 13(1)(f) GDPR)

The three sub-processors above are established in the United States. Transfers rely on the European Commission's Standard Contractual Clauses (SCCs) — Implementing Decision (EU) 2021/914 — as the transfer mechanism, supplemented by each provider's additional safeguards documented in their Data Processing Agreements. We rely on the adequacy mechanism where one applies. Eco-organism and ADEME data stays within the EU.

6. Retention

Contact form data: 24 months from last contact. Mandate and declaration data: kept for the duration of the contract and 10 years after termination, to comply with French commercial and EPR retention rules.

7. Your rights

Under the GDPR and the French Data Protection Act, you have the right to access, rectify, erase, restrict, and port your personal data, and to object to processing based on legitimate interest. Submit requests through the contact form. You may also lodge a complaint with the French CNIL (www.cnil.fr).

8. Cookies

The website uses only strictly necessary cookies. No consent banner is required because no tracking, profiling, or advertising cookies are deployed. If analytics is added later, a consent mechanism will be introduced in compliance with the French ePrivacy rules (article 82 of the Data Protection Act).

9. Updates

This policy may be updated. Material changes are announced on the homepage and effective 30 days after publication.