Privacy Policy – Twelve Assistant

This is a translation provided for convenience. In case of dispute, the French version prevails.

Privacy Policy

Effective date: January 1, 2021
Last updated: August 2, 2026

1. General Information

SAS LONI MUSIQUE (hereinafter “LONI MUSIQUE” or “we”), registered with the Paris RCS under number 899 527 048, with its registered office at 6 rue d’Armaillé 75017 Paris, is committed to protecting the privacy and personal data of users of the Twelve Assistant service.

This privacy policy describes how we collect, use, store, and protect your personal data in accordance with:

  • The General Data Protection Regulation (GDPR) No. 2016/679 of April 27, 2016;
  • French Law No. 78-17 of January 6, 1978 on Information Technology, Data Files and Civil Liberties, as amended by Law No. 2018-493 of June 20, 2018;
  • The French Consumer Code.

2. Data Controller

The data controller responsible for processing your personal data is:

SAS LONI MUSIQUE
6 rue d’Armaillé
75017 Paris, France
RCS Paris 899 527 048
Email: support@twelve-assistant.com
Phone: +33 6 95 24 19 17

3. Data We Collect

We collect the following categories of personal data:

3.1 Account and Subscription Data

  • Full name
  • Email address
  • Subscription type and status
  • Payment information (processed by our payment service providers)
  • Subscription start and end dates

3.2 Technical Data

  • IP address
  • Browser type and version
  • Operating system
  • Device information
  • Connection logs and usage data

3.3 Usage Data

  • Pages visited
  • Features used within Twelve Assistant
  • Session duration and frequency
  • Interactions with educational tools

4. Legal Basis and Purposes of Processing

We process your personal data on the following legal bases and for the following purposes:

4.1 Contract Performance

Processing necessary to provide the Twelve Assistant service:

  • Creating and managing your user account
  • Processing subscriptions and payments
  • Providing access to the Tools
  • Customer support and technical assistance

4.2 Legitimate Interest

  • Improving and optimizing the service
  • Analyzing usage to develop new features
  • Preventing fraud and ensuring security
  • Sending service-related communications

4.3 Consent

  • Sending marketing communications (newsletters, promotional offers)
  • Using non-essential cookies and trackers

4.4 Legal Obligation

  • Compliance with accounting and tax obligations
  • Responding to legal requests from authorities

5. Data Recipients

Your personal data may be shared with:

5.1 Service Providers

  • Payment processors: Stripe, PayPal (for secure payment processing)
  • Hosting providers: WP Engine (website and application hosting)
  • Email service providers: For transactional and marketing emails
  • Analytics providers: For usage statistics and service improvement

All service providers are selected for their compliance with GDPR and are contractually bound to process data only on our instructions and to implement appropriate security measures.

5.2 Legal Authorities

We may disclose your data if required by law, court order, or regulatory request.

6. International Data Transfers

Some of our service providers may be located outside the European Union. In such cases, we ensure that appropriate safeguards are in place, including:

  • Standard contractual clauses approved by the European Commission
  • Adequacy decisions by the European Commission
  • Privacy Shield certification (where applicable)

7. Data Retention

We retain your personal data for the following periods:

  • Active subscriptions: Duration of the subscription plus 3 years (limitation period)
  • Cancelled subscriptions: 3 years from cancellation date
  • Accounting data: 10 years (French legal requirement)
  • Marketing data: 3 years from last contact or until consent withdrawal
  • Usage logs: 12 months

After these periods, data is securely deleted or anonymized.

8. Your Rights

Under GDPR and French data protection law, you have the following rights:

8.1 Right of Access

You can request a copy of all personal data we hold about you.

8.2 Right to Rectification

You can request correction of inaccurate or incomplete data.

8.3 Right to Erasure (“Right to be Forgotten”)

You can request deletion of your data, except where we have legal obligations to retain it.

8.4 Right to Restriction of Processing

You can request temporary suspension of data processing in certain circumstances.

8.5 Right to Data Portability

You can request your data in a structured, machine-readable format to transfer to another service.

8.6 Right to Object

You can object to processing based on legitimate interest or for direct marketing purposes.

8.7 Right to Withdraw Consent

Where processing is based on consent, you can withdraw it at any time.

8.8 How to Exercise Your Rights

To exercise any of these rights, contact us at:

  • Email: support@twelve-assistant.com
  • Mail: LONI MUSIQUE, 6 rue d’Armaillé, 75017 Paris, France

We will respond within one month of receiving your request.

9. Security Measures

We implement appropriate technical and organizational measures to protect your personal data:

  • SSL/TLS encryption for data transmission
  • Secure authentication and password hashing
  • Regular security audits and updates
  • Access controls and employee training
  • Backup and disaster recovery procedures

10. Cookies and Tracking

We use cookies and similar technologies to:

  • Maintain your session and authentication
  • Remember your preferences
  • Analyze website traffic and usage patterns
  • Improve user experience

You can control cookie settings through your browser preferences. Note that disabling certain cookies may affect service functionality.

11. Minors

Twelve Assistant is intended for adults (18+) and emancipated minors. We do not knowingly collect data from children under 15 without parental consent. If we become aware of such collection, we will delete the data immediately.

12. Changes to This Policy

We may update this privacy policy from time to time. Changes will be posted on this page with an updated effective date. Significant changes will be communicated by email to active subscribers.

13. Contact and Complaints

For any questions about this privacy policy or our data practices, contact us at:

Data Protection Contact:
Email: support@twelve-assistant.com
Mail: LONI MUSIQUE, 6 rue d’Armaillé, 75017 Paris, France

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the French data protection authority:

CNIL (Commission Nationale de l’Informatique et des Libertés)
3 Place de Fontenoy
TSA 80715
75334 Paris Cedex 07, France
Website: https://www.cnil.fr

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