Privacy Policy

1. Preamble

This Privacy Policy is intended to inform users (hereinafter “User(s)”) of the cold-is-gold.com website (hereinafter “the Site”) about how Cold is Gold (OVB Agency), acting as a data controller (or data processor, as the case may be), collects, uses, and protects their personal data in the course of its business lead generation activities (cold emailing campaigns, database creation, etc.).

Cold is Gold (OVB Agency) is committed to complying with applicable data protection laws, in particular Regulation (EU) 2016/679 of April 27, 2016 (GDPR) 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 Form / Quote: last name, first name, email address, phone number, company name, etc.
• Account creation form (if applicable): username, password, role or position within the company, etc.
• Messages and communications: all information voluntarily provided by the User (emails, messages on the Site, etc.).

3.2 Data collected automatically (cookies, connection logs)

• Cookies: small files stored on the User’s device to facilitate browsing and enable certain features (audience analysis, saving preferences, etc.). Details are provided in Section 7 below.
• Technical data: IP address, browser type and version, browsing data, pages visited, etc.

3.3 Prospect data for cold emailing

As part of the provision of our services (creating databases, sending email campaigns), we may need to process data related to prospective clients (last name, first name, job title, work email address, etc.).

• Responsibility: Depending on the circumstances, we may act as a data controller (e.g., creating and selling databases) or a data processor (e.g., when you provide us with your own prospect databases). GDPR obligations vary accordingly, and a data processing agreement may be entered into with our clients.

4. Purposes and Legal Basis of Processing

The personal data collected is used for :

• Providing our services: responding to contact requests, preparing quotes, and managing project follow-up (Article 6(1)(b) of the GDPR — performance of a contract).
• Manage the business relationship: billing, payment tracking, and sending information related to the service (Article 6(1)(b) of the GDPR — performance of a contract).
• Marketing and promoting our services: sending newsletters or promotional emails to B2B contacts (Article 6(1)(f) of the GDPR — legitimate interest), provided that the data subjects may object at any time.
• Analyzing and improving the Website: measuring traffic, identifying potential technical issues, and optimizing the user experience (Article 6(1)(f) of the GDPR — legitimate interest).
• To comply with our legal obligations: dispute resolution, requests to exercise rights, tax and accounting compliance, etc. (Article 6(1)(c) of the GDPR — 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 (web hosting providers, email marketing services, CRM providers, etc.) acting as data processors and subject to a contractual confidentiality obligation.
• Business partners or subcontractors involved in the provision of services (e.g., database development, providers of GDPR-compliant tools).
• Administrative or judicial authorities (in the event of a 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. Data Retention Period

• Contact information (forms): retained for as long as necessary to manage the business relationship (up to 3 years from the last contact, if no contract has been entered into).
• 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 a data controller, we comply with the principles of the GDPR (reasonable retention periods, updates, right to object). When we act as a data processor, the retention period is defined by the contract entered into with the Client.

7. Cookies and Other Tracers

7.1 Definition

Cookies are files stored on your device (computer, smartphone, etc.) when you visit the Site. They serve various purposes, such as remembering your preferences, measuring traffic, and securing your session.

7.2 Types of cookies used

• Technical/functional cookies: essential for the proper operation of the Site.
• Audience measurement cookies: used to compile traffic statistics (Google Analytics or other tools).
• Targeted advertising cookies (where applicable): to enable us to offer you personalized content.

7.3 Cookie management

During your first visit, you will be notified about the use of cookies and given the option to accept, reject, or customize them. You can also adjust your preferences or delete cookies through your browser settings. Please note that rejecting certain cookies may interfere with your browsing experience on the Site.

8. Data security

We implement technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction (e.g., HTTPS protocol, regular backups, restricted access policy).

However, despite our best efforts, no system is completely secure, and we cannot guarantee absolute security.

9. Your rights

In accordance with the GDPR and the French Data Protection Act, you have the following rights regarding your personal data:

• Right of access: to obtain confirmation that your data is being processed and, if so, to receive a copy of it.
• Right of rectification: request the modification of inaccurate or incomplete data.
• Right to erasure (“right to be forgotten”): Request the deletion of your data within the limits provided by law.
• Right to restrict processing: request suspension of processing of your data in certain cases.
• Right to object: You may object to processing based on our legitimate interest, or opt out of marketing communications 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
• Mailing address: Cold is Gold (OVB Agency) — 761 Rue Nationale, 69400 Villefranche-sur-Saône

We may ask you to provide proof of identity to verify the validity of your request.

9.1 Right to File a Complaint

If you believe your rights have not been respected, you may file a complaint with the relevant supervisory authority (in France, the CNIL).

10. Data Transfers Outside the EU

If, for certain services (e.g., email marketing solutions hosted outside the EU), your data is transferred outside the European Economic Area, we ensure that such transfers are subject to an adequate level of protection (such as an adequacy decision by the European Commission, standard contractual clauses, etc.), in accordance with applicable law.

11. Outsourcing of Data

When we act as a subcontractor on behalf of our Clients (e.g., managing cold email campaigns targeting their prospects), we are committed to complying with the obligations under the GDPR, including:

• Process data only on customer's instructions,
• Guarantee data confidentiality and security,
• Do not subcontract to a third party without prior authorization,
• Assist the Client in conducting impact assessments, breach notifications, etc.
• Delete or return data at the end of the contract.

12. Links to Third Party Sites

The Site may contain hyperlinks to third-party websites. We have no control over these sites and cannot be held responsible for their privacy policies or practices. We encourage you to review the privacy policy of each site you visit.

13. Policy Update

We may need to modify this Privacy Policy to reflect changes in our practices or to comply with new regulations. In the event of a substantial change, we will notify you via a notice on the Site or by email.

The latest version is always available on our website.

14. Contact

If you have any questions regarding this Privacy Policy or the exercise of your rights, please contact us:

• By email: support@agence-ovb.fr
• By mail: Cold is Gold (OVB Agency) — 761 Rue Nationale, 69400 Villefranche-sur-Saône