Effective Date: June 2nd 2025
At Two Cities, we are committed to protecting your personal data and ensuring your privacy. This Privacy Notice explains how we collect, use, store, and protect your personal information in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and other applicable privacy laws.
1. Who We Are
Two Cities SAS
188 quai de Stalingrad, 92130 Issy les Moulineaux
Email: corporate.twocities.fr (at) gmail.com
Data Controller: Erin Frouin
2. What Personal Data We Collect
We may collect the following types of personal data:
- Name, email address, and contact information
- Billing and payment details
- Audio/video recordings (with your consent)
- Information you provide during assessments or coaching sessions
- Website usage data via cookies and analytics tools
3. How We Use Your Information
We process your personal data for the following purposes:
- To provide our services and fulfill contracts
- To communicate with you about your sessions or inquiries
- To improve our services and website functionality
- To comply with legal obligations
- With your explicit consent, for marketing communications
4. Legal Basis for Processing
We rely on one or more of the following legal bases:
- Your consent (Article 6(1)(a))
- Performance of a contract (Article 6(1)(b))
- Legal obligations (Article 6(1)(c))
- Legitimate interests (Article 6(1)(f))—such as improving service quality
5. How Long We Keep Your Data
We retain your personal data only as long as necessary for the purposes outlined in this notice or as required by law. Recordings and session data are securely deleted after the retentation date you provided us.
6. Sharing Your Data
We do not sell or rent your data. We may share data with:
- Secure service providers (e.g., payment processors, scheduling tools)
- Legal or regulatory authorities when required
All third parties are contractually obligated to safeguard your data.
7. International Data Transfers
If data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as standard contractual clauses (SCCs).
8. Your Rights Under GDPR
You have the right to:
- Access your personal data
- Correct inaccurate or incomplete data
- Request data erasure (“right to be forgotten”)
- Restrict or object to processing
- Request data portability
- Withdraw consent at any time
To exercise your rights, contact us.
9. Cookies and Tracking
Our website uses cookies to enhance functionality and analyze usage.
10. Contact & Complaints
If you have questions or concerns about this notice, please contact us.
You also have the right to lodge a complaint with your local Data Protection Authority (DPA).
We may update this notice from time to time. Any changes will be posted on this page with a revised effective date.