Privacy policy
This policy explains which personal data Maleda processes, why, for how long, with whom, and how to exercise your rights. It complies with the General Data Protection Regulation (GDPR) and the ePrivacy Directive.
Contact for any question: contact@maleda.eu.
Who is responsible for what
Maleda (the publisher MALEDA SAS, 17 rue de la caserne, 57710 Aumetz, France) acts in two different roles:
- Maleda is the controller for merchants’ accounts, invoicing, the security of the Service, the directory, the verification of addresses and companies, the referral programme and the visitors of the main website.
- The merchant is the controller for the data of its own customers: bookings, orders, subscribers to its notifications (“bell”). Maleda is then its processor and processes the data only on the merchant’s instructions, under the data processing agreement.
If you are a shop’s customer, it is therefore first of all that shop which decides how your data is used; its contact details appear on the “Legal information” page of its website.
Data subjects
- Visitors of Maleda and of shop websites, who look for a business or browse a website.
- Merchants’ customers: people who book an appointment, place a pick-up order or subscribe to a shop’s notifications.
- Merchants and their staff who use the Merchant area.
- Referrers: merchants, professionals or private individuals who take part in the referral programme, and referees, merchants who created their account using a referral code.
Maleda is aimed at professionals and is not designed for children. It does not knowingly collect data from children under 16; if you believe a child has sent us data, write to us.
Data, purposes, legal bases and retention periods
The periods below are those that Maleda applies. After them, the data is deleted or anonymised, unless a legal retention obligation applies.
Merchants (Maleda is the controller)
| Data | Purposes | Legal basis | Retention |
|---|---|---|---|
| E-mail address, name (optional), language, country, version and date of acceptance of the terms | Create and manage the account, identify you, write to you about your subscription | Contract (Art. 6.1.b) | Duration of the contract, then deletion within 30 days |
| Business information: name, address, telephone, business number (SIRET, VAT…), trade, hours, absences, products, prices, allergens entered by the merchant, texts, photos, GPS coordinates derived from the address | Create and publish the website and the directory listing, sort “near me” results | Contract; legitimate interest in presenting businesses in the directory (Art. 6.1.f) | Duration of the contract, then deletion within 30 days |
| Sign-in link and code (only SHA-256 fingerprints are kept), number of attempts | Authenticate you without a password | Contract; legitimate interest in security | Valid for 15 minutes, single use, 5 attempts; expired fingerprints are deleted during the daily maintenance |
| Sign-in session (token fingerprint, expiry date) | Keep you signed in | Contract | 30 days at most; deleted on sign-out |
| Subscription: country, currency, billing period, options, amount, status, end of period, Stripe identifiers (customer, subscription), payment events | Invoice, manage the subscription and its cancellation, keep accounts | Contract; legal obligation | Accounting records and invoices: 10 years (Art. L. 123-22 of the French Commercial Code) |
| Assistant: number of requests in the month (the text of requests is not kept) | Provide the Assistant and cap its use | Contract | Duration of the contract |
| Social networks (option): page or account identifier, encrypted access token, prepared posts | Publish on your behalf, at your request | Contract | Until the account is unlinked or the contract ends |
| Verification of the address and the company: business address and city, business number (SIREN/SIRET, VAT number), country and coordinates obtained, result of the verification and date | Check that the address exists and that the company exists in official registers; determine the country (applicable price, site language); prevent fraud | Contract; legitimate interest in the reliability of the directory and in fraud prevention (Art. 6.1.f) | Result kept for the duration of the contract, then deleted within 30 days; no other copy of the data received from the registers |
| Referrer: name (optional), e-mail address, country, referral code, Stripe Connect account identifier, commissions (amounts, currency, status), payouts, tax information provided | Manage their participation in the referral programme, calculate and pay commissions, meet accounting and tax obligations, prevent fraud | Contract (referral terms); legal obligation; legitimate interest (fraud prevention) | Duration of participation in the programme; accounting records: 10 years |
| Referee (referral side): internal link to their referrer, date the account was created, amounts of subscription payments used as the basis of calculation, status | Attribute and calculate the referrer’s commission; detect self-referral and fraud | Contract; legitimate interest in running the programme and protecting it from fraud | Duration of the referee’s account and of the right to commission, then accounting records: 10 years |
| Messages you send us | Answer your requests | Legitimate interest | 3 years after the last exchange |
Visitors (Maleda is the controller)
| Data | Purposes | Legal basis | Retention |
|---|---|---|---|
| Chosen language and country (“maleda-lang” and “maleda-country” cookies) | Display the site in your language, with the prices and results of your country | Legitimate interest; cookie requested by you and strictly necessary | 1 year |
| Referrer’s code remembered (“maleda-ref” cookie), set only if you arrive through a referral link | Attach a referrer to your account if you create one within 30 days | Consent where required, otherwise legitimate interest in paying the referrer: see the cookie policy | 30 days |
| Country inferred from the network (Cloudflare header) and browser language | Choose a default language and country | Legitimate interest | Not kept |
| “Near me” position, rounded to about 1 km (“maleda-geo” cookie) | Sort businesses by distance | Consent: you click “near me” and then accept the browser’s request | Cookie of 1 hour at most, never stored on the server (see below) |
| Approximate position inferred from the IP address by Cloudflare | Sort nearby businesses when you have not shared your position | Legitimate interest | Not kept |
| Technical logs: IP address, date and time, requested address, browser | Security, abuse prevention, troubleshooting, the host’s legal obligation | Legitimate interest; legal obligation | [TO BE COMPLETED: actual retention of server logs, 12 months at most] |
Merchants’ customers (the merchant is the controller, Maleda is the processor)
| Data | Purposes | Legal basis | Retention |
|---|---|---|---|
| Booking: name, e-mail, telephone (optional), service, date and time, language, status, fingerprint of the cancellation link, deposit (amount, status, payment identifiers) | Record the appointment; send the confirmation e-mail, the reminder the day before and the cancellation; notify the merchant; manage the deposit | Performance of a contract or pre-contractual steps taken at your request (Art. 6.1.b) | Set by the merchant. Maleda’s recommendation: deletion or anonymisation 12 months after the appointment date |
| Pick-up order: name, e-mail, telephone (optional), note, items and quantities, price, pick-up slot, order number, status | Prepare the order, notify you, manage cancellation | Performance of a contract (Art. 6.1.b) | Set by the merchant. Maleda’s recommendation: 12 months after pick-up |
| Bell subscription: your browser’s technical subscription address (“endpoint”), browser encryption keys, language. No name or e-mail | Send the shop notifications you subscribed to | Consent (Art. 6.1.a): you accept the browser’s permission prompt | Until you unsubscribe, or until the browser revokes the subscription |
| Deposit payment (through Stripe Connect) | Collect the deposit on behalf of the merchant | Performance of a contract (Art. 6.1.b) | Kept by Stripe and the merchant according to their accounting and legal obligations; Maleda keeps only the payment status and its identifiers |
Bookings and orders are also visible to the merchant concerned, in its Merchant area and in the e-mails Maleda sends it. No other merchant has access: data is partitioned by shop.
The merchant is free to set the retention period for this data, in compliance with the GDPR and the law applicable to its business. Maleda recommends that it deletes or anonymises it 12 months after the appointment or pick-up, unless the law requires otherwise (for example accounting rules).
What Maleda does not do
- No advertising cookies, no third-party audience-measurement trackers, no commercial profiling.
- No sale of data.
- Google reviews are never copied into our database: only the place identifier is kept.
Recipients and sub-processors
Your data is accessible to authorised Maleda staff, to the merchant concerned for its own customers, and to the following providers, who act only to provide the Service:
| Provider | Role | Data concerned | Location |
|---|---|---|---|
| [TO BE COMPLETED: hosting provider name] | Hosting of the server, database, photos and backups | All Service data | [TO BE COMPLETED: hosting country] |
| Stripe Payments Europe, Ltd. | Payment of subscriptions and deposits, payout of referral commissions to referrers (Stripe Connect); also acts as a controller for its own obligations (identity checks, fraud prevention) | Merchant’s or referrer’s e-mail, amounts, identifiers; the card, bank details and identity documents are entered only at Stripe | Ireland; transfers to the United States possible |
| Resend | Sending e-mails (sign-in codes, confirmations, reminders, cancellations) | Recipient’s address and message content | United States [TO BE COMPLETED: confirm the sending region] |
| Google (Google Ireland Limited, Google LLC) | Google sign-in (verified e-mail address only), embedded maps and Street View, Google reviews | For sign-in: e-mail address; for Street View: visitor’s IP address and the shop’s address | Ireland; United States |
| Anthropic | Artificial-intelligence model of the Assistant (optional, if enabled) | Text of the request (500 characters at most), product names, today’s date; no customer data | United States |
| Cloudflare, Inc. | DNS, content delivery network (CDN), attack protection | Visitors’ IP address and requests | United States; global network |
| Base Adresse Nationale (DINUM, Etalab) | Verification of addresses in France | The shop’s address and city, never those of customers | France |
| Photon (search service based on OpenStreetMap) | Verification of addresses outside France | The shop’s address and city, never those of customers | Germany (European Union) [TO BE COMPLETED: confirm the Photon instance used] |
| Business directory (Recherche d’entreprises API, DINUM) / SIRENE database (Insee) | Verification that a French company exists | The shop’s SIREN or SIRET number | France |
| VIES (European Commission) | Verification of intra-EU VAT numbers | The shop’s VAT number | European Union |
| OpenStreetMap (Nominatim) | Geocoding a shop’s address (obtaining its coordinates) | The shop’s address and city, never those of customers | United Kingdom |
| Meta Platforms Ireland Limited | Publishing on Facebook and Instagram (option, if the merchant links its page) | Published content chosen by the merchant, access tokens | Ireland; United States |
Maleda may also disclose data to the authorities where the law requires it. Sub-processors are bound by a contract compliant with Article 28 of the GDPR; the list is kept up to date in the data processing agreement.
Transfers outside the European Union
Some providers (Stripe, Google, Anthropic, Cloudflare, Resend, Meta) may process data in the United States. These transfers rely on the European Commission’s adequacy decision of 10 July 2023 (EU–US Data Privacy Framework) where the recipient is certified under it, or otherwise on the Commission’s standard contractual clauses, supplemented where necessary by additional measures. The United Kingdom (OpenStreetMap) benefits from an adequacy decision. [TO BE COMPLETED: confirm, for each provider, certification under the EU–US framework or signature of the standard contractual clauses]
The address and company verification services (Base Adresse Nationale, business directory, VIES, Photon) are located in the European Union: no transfer outside the Union results from them.
You can obtain a copy of the applicable safeguards by writing to contact@maleda.eu.
Verification of the address and the company
When a merchant signs up or changes the address of its business, Maleda queries public sources: the Base Adresse Nationale (France) or Photon, based on OpenStreetMap (other countries), to confirm the address and obtain its country and coordinates; the business directory (SIRENE database) for a French company, and VIES for a European VAT number, to confirm that the company exists. The queries contain only the business’s address and business number, never any customer data.
The country of the verified address determines the applicable price; the address also determines the language of the business’s website. If the merchant changes its address to another country, the price is recalculated. These processing operations are automated but produce no final decision about you: in case of failure or inconsistency, a person reviews the situation and you may write to contact@maleda.eu to challenge the result.
Referral programme
The referral programme is described in the referral programme terms. Maleda is the controller of the data it involves.
What the referrer sees. The referrer sees only anonymised information about its referees: trade, city, date of the referral, status and amount of commissions. It never receives their name, the shop’s name, their contact details or any data from their site or customers. Maleda may group or hide this information where it would allow a referee to be identified.
What the referee knows. When their account is created, the referee is told that they were referred and that a referrer receives a commission calculated on their subscription payments, without access to their data and without effect on their price. They may object to the processing concerning them and exercise their rights with contact@maleda.eu; objecting does not affect the price or their subscription, but Maleda then examines whether the link to the referrer should keep producing a commission.
Payout and checks. Commissions are paid through Stripe Connect: the referrer’s bank details and identity documents are collected and checked by Stripe, which acts under its own responsibility; Maleda receives only the account status and its identifier. Maleda may automatically cross-check certain items (e-mail address, payment account, address) to detect self-referral or fraud; no sanction is imposed without review by a person.
Your rights and how to exercise them
You have the following rights over your data: access, rectification, erasure, restriction of processing, portability, objection (in particular to processing based on legitimate interest) and withdrawal of your consent at any time, without affecting what was done before. In France you may also give instructions about what happens to your data after your death.
If you are a shop’s customer, send your request first to that shop, which is responsible for this data: its contact details appear on the “Legal information” page of its website. You may also write to contact@maleda.eu: we will forward your request to the merchant and assist it in answering.
In other cases (merchant account, visitor), write to contact@maleda.eu. We may ask you to prove your identity. We answer within one month, which may be extended by two months for complex requests (with prior notice).
To remove your position, click “near me” again; to unsubscribe from the bell, use your browser’s notification settings; to clear cookies, use your browser’s settings.
Complaint to an authority
If you consider that your rights are not respected, you may lodge a complaint with the data protection authority of your country of residence, place of work or the place of the infringement.
- In France: Commission nationale de l’informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, www.cnil.fr.
- In Luxembourg: Commission nationale pour la protection des données (CNPD), 15 boulevard du Jazz, L-4370 Belvaux, cnpd.lu.
- In other Member States: the list of authorities kept by the European Data Protection Board.
We invite you to contact us first, to try to resolve the issue.
Security
Maleda implements technical and organisational measures appropriate to the risk, including:
- encryption of exchanges (HTTPS);
- passwordless sign-in: one-time links and codes, short-lived, limited number of attempts, only fingerprints are kept;
- social network access tokens stored encrypted (AES-GCM);
- strict partitioning of data by shop: every request is limited to the shop concerned, determined by the server;
- server-side input validation, limits on sign-in requests;
- photos re-encoded and stripped of their metadata (including GPS position);
- daily database backups, kept for 14 days;
- logging of access and errors, access limited to authorised people.
In the event of a data breach likely to result in a risk to your rights, Maleda notifies the competent authority within 72 hours where it is the controller, and informs you where the risk is high.
Automated decisions and artificial intelligence
Maleda takes no decision producing legal effects concerning you or similarly significantly affecting you based solely on automated processing (Article 22 of the GDPR).
The Assistant intended for merchants proposes changes to their website from a written or dictated request; a human confirms them: simple, reversible changes can be undone with one click, the others require confirmation. Depending on the Service’s configuration, the Assistant uses built-in rules or an AI model from Anthropic (see the terms of use). The text of requests is not kept by Maleda.
Position and “near me” search
The “near me” search is optional. When you click it, your browser asks for permission to share your position. If you accept, the latitude and longitude are rounded to about 1 kilometre and placed in a cookie in your browser (“maleda-geo”) that expires after one hour at most.
This cookie is read by the server to compute the distance between you and the businesses and sort the results. Your position is never stored on the server: neither in the database nor in retained files. You can erase it at any time by clicking “near me” again or by deleting the cookie.
Without your sharing, we may use the approximate position of your connection (city or region), provided by Cloudflare, solely to sort results; it is not kept.
Voice dictation
The Assistant offers voice dictation to merchants. It uses the speech recognition built into your browser: the audio is processed by the browser’s publisher (for example Google for Chrome, Apple for Safari), under its own terms, before the transcribed text is sent to Maleda. Maleda neither receives nor keeps any audio recording. You can always type your request instead.
Changes to this policy
We may change this policy, for example if a new provider is added. The update date appears at the top of the document. In the event of a significant change, merchants are notified in advance, as provided in the terms of use.