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Privacy policy
Processing of personal data by the firm, under Regulation (EU) 2016/679.
Data controller
Herman Twagiramungu, avocat, 1 rue de l'Église, 95120 Ermont, is the controller for the processing described below.
The firm is not required to appoint a data protection officer: it carries out neither large-scale regular and systematic monitoring nor large-scale processing of special-category data. Requests concerning personal data are sent to cabinet@ht-avocat.com.
Data collected by this site
This site has no client area and no newsletter sign-up. The only data transmitted through it is what you voluntarily enter in the contact form:
- Identity: surname, first name
- Contact details: email address, telephone number if you provide one
- Your request: the area concerned if you give it, and your message
No browsing data is collected for audience measurement unless you have consented to it.
Purposes and legal bases
- Replying to your contact request: steps taken at your request prior to entering into a contract (article 6.1.b GDPR)
- Replying to an email you send the firm: legitimate interest in answering an enquiry (article 6.1.f)
- Audience measurement: your consent, obtained through the cookie banner and off by default
Retention periods
- Contact requests and emails that went no further: three years from the last exchange, the general limitation period applicable to an enquiry
- Cookie choice: six months, after which the banner reappears
These periods follow statutory time limits and the guidance of the French data protection authority; they are not undertakings specific to the firm. They do not apply to client files, which are governed by the retention obligations specific to the profession — five years from the end of the retainer, under article 2225 of the Civil Code.
Recipients
Your data is accessible only to the firm's lawyer. No data is sold, rented or transmitted for commercial purposes.
Two technical providers process it on the firm's behalf: Vercel Inc., which hosts the site, and Resend, which delivers form messages to the firm's mailbox. Both are based in the United States. These transfers are covered by the EU–US Data Privacy Framework, under which both companies are certified, and by the European Commission's standard contractual clauses included in their data processing agreements.
Your rights
You have the rights of access, rectification, erasure, restriction, objection and portability provided for by the GDPR. Where processing rests on your consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out beforehand.
These rights are exercised by email to cabinet@ht-avocat.com. A reply is sent within one month.
You may also lodge a complaint with the French data protection authority (CNIL) — 3, place de Fontenoy, 75007 Paris.
Professional secrecy
Information you send the firm in connection with a request for advice is covered by lawyers' professional secrecy, which is distinct from and broader than personal data protection.
That secrecy is a matter of public policy: the firm cannot be released from it, including by you.
