1. Preamble
The purpose of this Privacy Policy is to inform users (hereinafter "User(s)") of the website [URL of your site] (hereinafter "the Site") about how Cold is Gold (Agence OVB), acting as data controller (or subcontractor, as the case may be), collects, uses and protects their personal data in the context of its business opportunity generation activities (cold emailing campaigns, database building, etc.).
Cold is Gold (Agence OVB) is committed to complying with current legislation on the protection of personal data, in particular Regulation (EU) 2016/679 of April 27, 2016 (RGPD) and the amended French Data Protection Act of January 6, 1978.
2. Identity of the Data Controller
- Cold is Gold, brand of Agence OVB (SARL)
- RCS Villefranche-Tarare no. 899 970 891
- Head office: 761 rue Nationale, 69400 Villefranche-sur-Saône, France
- Tel: +33 4 83 97 01 50
- Email : support@agence-ovb.fr
The data controller (or "we") determines the purposes and means of processing personal data collected via the Site or in connection with the services offered.
3. Collected data
3.1 Data collected directly from the User
- Contact/quotation form: surname, first name, e-mail address, telephone number, company name, etc.
- Account creation form (if applicable): login, password, role or function within the company, etc.
- Messages and exchanges: all information voluntarily communicated by the User (e-mails, messages on the Site, etc.).
3.2 Data collected automatically (cookies, connection logs)
- Cookies: small files stored on the User's terminal to facilitate browsing and enable certain functions (audience analysis, saving of preferences, etc.). Details are given in Article 7 below.
- Technical data: IP address, browser type and version, browsing data, pages visited, etc.
3.3 Prospect data for cold emailing
In the course of providing our services (building up databases, sending e-mail campaigns), we may need to process prospect data (surname, first name, job title, professional e-mail address, etc.).
- Responsibility: Depending on the case, we may act as data controller (e.g. constitution and sale of databases) or subcontractor (e.g. you entrust us with your own prospect databases). RGPD obligations vary accordingly, and a subcontracting agreement may be concluded with our Customers.
4. Purposes and Legal Basis of Processing
The personal data collected is used for :
- Providing our services: responding to contact requests, drawing up quotes, managing the follow-up of assignments (Article 6(1)(b) of the RGPD - contractual performance).
- Manage the commercial relationship: invoicing, tracking payments, sending information relating to the service (Article 6(1)(b) of the RGPD - contractual performance).
- Prospecting and promoting our services: sending newsletters or promotional e-mails to B2B contacts (Article 6(1)(f) of the RGPD - legitimate interest), provided that data subjects may object at any time.
- To analyze and improve the Site: audience measurement, detection of possible technical problems, optimization of the user experience (Article 6(1)(f) of the RGPD - legitimate interest).
- Comply with our legal obligations: management of disputes, requests to exercise rights, tax and accounting compliance, etc. (Article 6(1)(c) of the RGPD - legal obligation).
5. Recipients of Data
5.1 Internal recipients
Only authorized persons within Cold is Gold (Agence OVB) may access personal data, within the limits of their respective responsibilities (sales department, support, management).
5.2 External recipients
- Technical service providers (host, emailing service, CRM, etc.) acting as subcontractors and subject to a contractual obligation of confidentiality.
- Business partners or subcontractors involved in the performance of services (e.g. database creation, suppliers of RGPD-compliant tools).
- Administrative or judicial authorities (in the event of legal obligation or legal proceedings).
We ensure that these third parties offer sufficient guarantees to comply with regulations on the protection of personal data.
6. Shelf life
- Contact data (forms): stored for the time required to maintain the commercial relationship (up to 3 years from the last contact, if no contract has been concluded).
- Customer data: retained for the duration of the contract, then archived for 5 years (legal statute of limitations) for evidentiary purposes.
- Cookies: the retention period varies according to the type of cookie (see Article 7 below).
- Prospect data: when we act as data controller, we comply with the principles of the RGPD (proportionate durations, updates, right of opposition). When we act as a subcontractor, the retention period is defined by the contract concluded with the Customer.
7. Cookies and Other Tracers
7.1 Definition
Cookies are files deposited on your terminal (computer, smartphone, etc.) when you visit the Site. They can be used for a variety of purposes, such as remembering your preferences, measuring the audience, securing your session, etc.
7.2 Types of cookies used
- Technical/functional cookies: essential for the proper operation of the Site.
- Audience measurement cookies: used to compile visitor statistics (Google Analytics or other tools).
- Targeted advertising cookies (where applicable): to enable us to offer you personalized content.
7.3 Cookie management
On your first visit, you will be informed of the use of cookies, and you will have the option of accepting, rejecting or configuring them. You can also set your preferences or delete cookies via your browser settings. Please note that refusing certain cookies may disrupt navigation on the Site.
8. Data security
We implement technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration or destruction (e.g. HTTPS protocol, regular backups, restricted access policy).
However, despite our best efforts, no system is inviolable and we cannot guarantee absolute security.
9. Your rights
In accordance with the RGPD and the French Data Protection Act, you have the following rights to your personal data:
- Right of access: obtain confirmation that your data is being processed and, if necessary, receive a copy.
- Right of rectification: request the modification of inaccurate or incomplete data.
- Right to erasure ("right to be forgotten"): request the deletion of your data to the extent permitted by law.
- Right to restrict processing: request suspension of processing of your data in certain cases.
- Right to object: oppose processing based on our legitimate interests, or refuse commercial prospecting at any time.
- Right to portability: retrieve your data in a structured, commonly used and machine-readable format, where processing is based on your consent or a contract.
- Right to withdraw your consent at any time, if the processing is based on it (e.g. cookies, newsletter).
- Post-mortem directives: define what happens to your data after your death.
To exercise these rights, please contact us at
- Email : support@agence-ovb.fr
- Postal address: Cold is Gold (Agence OVB) - 761 rue Nationale, 69400 Villefranche-sur-Saône, France
We may ask you for proof of identity to verify the legitimacy of your request.
9.1 Right to lodge a complaint
If you feel that your rights are not being respected, you can contact the relevant supervisory authority (in France, the CNIL).
10. Data Transfers Outside the EU
If, for certain services (e.g. emailing solution hosted outside the EU), your data is transferred outside the European Economic Area, we ensure that this transfer is subject to an adequate level of protection (European Commission adequacy decision, standard contractual clauses, etc.), in accordance with applicable legislation.
11. Subcontracting
When we act as a subcontractor on behalf of our Customers (e.g. management of cold email campaigns on their prospects), we undertake to comply with the obligations arising from the RGPD, in particular:
- Process data only on customer's instructions,
- Guarantee data confidentiality and security,
- Do not subcontract to a third party without prior authorization,
- Assist customers with impact analyses, vulnerability notifications, etc.
- Delete or return data at the end of the contract.
12. Links to Third Party Sites
The Site may contain hypertext links to third-party sites. We have no control over these sites and cannot be held responsible for their privacy policies or practices. We invite you to consult the privacy policy of each site you visit.
13. Policy Update
We may modify this Privacy Policy to reflect changes in our practices or to comply with new regulations. In the event of substantial modification, we will inform you by means of a notice on the Site or by e-mail.
The latest version in force is always accessible on our Site.
14. Contact
If you have any questions regarding this Privacy Policy or the exercise of your rights, please contact us at :
- By e-mail: support@agence-ovb.fr
- By mail: Cold is Gold (Agence OVB) - 761 rue Nationale, 69400 Villefranche-sur-Saône, France