Privacy policy

1. Data controller

Alexis Durogene, self-employed, trading as Pactole Labs — 3 rue des Murs Saint-Yon, 76100 Rouen, France — kolbytrd@gmail.com.

2. Data collected

• Client form: first name, last name, email address, Telegram username, chosen plan, and the date and time of acceptance of the Terms of sale, the immediate access request and the risk warning.
• Messages: messages you send us on Telegram or by email (including the “Propfirm” message).
• Payment: transaction information sent by Stripe, our payment provider (amount, date, status, form reference, email). Bank details are processed only by Stripe.
• Technical data: IP address and connection logs kept by the host for site security.

3. Purposes and legal bases

• Handling your subscription request, managing your access to the private group and the training modules, client follow-up: performance of the contract and pre-contractual steps taken at your request.
• Issuing invoices and meeting accounting and tax obligations: legal obligation.
• Keeping proof of acceptance of the Terms of sale and of the waiver of the right of withdrawal, answering your questions, securing the site: legitimate interest.

Your data is never sold, rented or used for advertising.

4. Recipients

Your data is intended for Pactole Labs and, as far as they are concerned, its service providers:

• Telegram (messaging and private group);
• Stripe, for online payment. For some operations (fraud prevention, legal obligations), Stripe acts as an independent data controller: see its privacy policy;
• the site host, Netlify, which also receives client forms sent from the form;
• for the prop firm coaching, the partner in charge of registrations, only if you ask to be put in touch.

5. Transfers outside the European Union

Some providers (Telegram, the host Netlify, the payment provider Stripe) may process data outside the European Union. These transfers are covered by the safeguards provided for by the GDPR: an adequacy decision (including the Data Privacy Framework for the United States) or the European Commission's standard contractual clauses.

6. Retention periods

• Client form without a subscription: 3 years from the last contact.
• Clients: for the whole duration of the subscription, then 3 years from its end.
• Proof of acceptance (Terms of sale, waiver of the right of withdrawal): 5 years from the end of the contract.
• Invoices and accounting records: 10 years.

7. Your rights

You have the right to access, rectify, erase, restrict, object to and port your data, as well as the right to set instructions about what happens to it after your death. To exercise these rights, write to kolbytrd@gmail.com: you will receive a reply within one month.

If you believe your rights are not being respected, you can lodge a complaint with the CNIL, the French data protection authority (www.cnil.fr).

8. Cookies and technical services

The site uses no advertising cookies or audience measurement tools, so no consent banner is needed. Fonts and scripts are hosted directly on the site: your browser does not contact any third-party service to display them. The site only stores your language and sound choices in your browser, to remember them on your next visit.

9. Minors

Paid services are reserved for adults. No data is knowingly collected from minors.

10. Security and updates

Pactole Labs takes reasonable measures to protect your data. This policy may change; the date of the last update appears at the top of the page.