ReCoWn Labs Privacy Policy

ReCoWn Labs Privacy Policy

Version: 1.0

Effective date: 23/08/2026

This Privacy Policy explains what data is processed in connection with the websites, online services, applications, and products published under the ReCoWn Labs identity, particularly when trial or licence requests are made and when licensing mechanisms operate.

ReCoWn Labs applies the principle of data minimisation: only information necessary for the operation of the relevant services and products, the management and security of licences, and exchanges requested by users is processed.

The controller is the publisher of the ReCoWn Labs website, identified in the website's Legal Notice.

Data protection contact: privacy@recown.fr.

B.1. Scope

Unless a specific policy states otherwise or supplements it, this policy applies to ReCoWn Labs websites, services, applications, and products. It covers in particular:

• use of ReCoWn Labs websites and services;
• trial or licence requests;
• verification of the email address;
• verification of the existence of the requesting business;
• the issuance and management of licences;
• technical communications between the relevant products and ReCoWn Labs services that are necessary for licences, updates, or security;
• transactional exchanges necessary for the service;
• retention of proof of acceptance of applicable legal documents.

B.2. Data processed when a trial or licence is requested

The following information may be processed:

• surname;
• first name;
• professional email address;
• information enabling the business to be identified or its existence to be verified, for example a VAT number or other professional identifier;
• technical information strictly necessary to protect the form and process the request.

It is used to process the request, verify that it is made in a professional context, verify the email address and, where the request is accepted, initiate the process of making the relevant product available or issuing its licence.

B.3. Verification of the business

The existence of the stated business may be verified automatically or manually using the professional information provided.

Additional information, such as a VAT number, may be requested where necessary.

The purpose of this verification is, in particular, to reserve the relevant software trials and licences for a professional audience and to prevent abusive or fraudulent requests.

B.4. Email-address verification

Verification of the professional email address may be required before a licence is issued or a product is made available.

Messages sent in this context are transactional communications relating to the request, the product, the licence, security, or operation of the service.

Information obtained from a request is not used for a newsletter or for unplanned marketing activities.

B.5. Cloudflare Turnstile

ReCoWn Labs uses Cloudflare Turnstile to protect certain forms against automated, abusive, or malicious submissions.

Technical information necessary for this mechanism to operate may be processed by Cloudflare in accordance with the framework applicable to its service.

ReCoWn Labs does not use Turnstile for advertising purposes.

B.6. Scaleway transactional emails

Emails necessary for the operation of ReCoWn Labs websites, services, applications, and products are sent using Scaleway transactional email services under the ReCoWn Labs domain, including through the infrastructure associated with mail.recown.fr.

They may concern, in particular:

• email verification;
• a trial request;
• licence issuance or management;
• security;
• a request initiated by the user.

B.6.1. Support requests and voluntary exchanges

When a user contacts ReCoWn Labs through the support process or another available channel, ReCoWn Labs may process:

• their professional contact details;
• references relating to the request, product, licence, or installation concerned;
• the content of the message and the history of exchanges;
• technical logs, screenshots, or attachments submitted voluntarily;
• information necessary for diagnosis, security, and follow-up of the request.

This information is used exclusively to respond to the request, diagnose the reported difficulty, ensure the security of the service, and keep a record of the actions taken.

Users are advised not to submit passwords, private keys, secrets, business data, personal data, or confidential information that is not strictly necessary to process their request. Where possible, it is their responsibility to mask or anonymise these elements before transmission.

Where exceptional access to sensitive information or to a user environment is necessary, its terms must be agreed in advance and may require additional arrangements.

B.7. Technical information transmitted by the relevant products

Some ReCoWn Labs products may be installed in the user's infrastructure.

Where a product uses the ReCoWn Labs licensing or update system, it may communicate periodically with ReCoWn Labs services to control and secure the licence and to provide the associated update tracking.

ReCoWn Labs may receive:

• licence status;
• information relating to update status;
• last known connection IP address;
• a one-way technical fingerprint of the installation.

B.8. Technical fingerprint

The fingerprint associated with the installation is generated using a one-way mechanism.

It does not enable ReCoWn Labs to reconstruct the original hardware characteristics used to generate it.

It is used, in particular, to verify that a licence intended for a single installation has not been duplicated or cloned.

When a new fingerprint replaces the previous one, the previous fingerprint is not retained.

B.9. Business data and licensing mechanism

Licence control is not intended to transmit to ReCoWn Labs the business data processed by products installed in the user's infrastructure.

Unless a separate feature is expressly described for a relevant product or service, ReCoWn Labs services do not access the content of business data processed locally by products installed in the user's infrastructure.

In particular, the licensing mechanism is not intended to transmit:

• the content of connected databases;
• business rows or records;
• the content of data flows;
• historised data;
• data published through the APIs of the relevant products;
• business data from connected ERP, CRM, DMS, or other applications.

For products designed for local processing, business data remains in the environment in which the relevant product is installed, subject to the features expressly selected by the user and described in the documentation or terms specific to the product.

B.10. No analytics or marketing

As at the publication date of this version, ReCoWn Labs does not use:

• Google Analytics;
• Matomo;
• a comparable audience-analysis tool;
• advertising systems;
• marketing profiling of visitors;
• a newsletter populated from trial requests.

Any change to these processing activities must lead to this Policy being reviewed and, where necessary, updated before activation.

B.11. Proof of acceptance

Where a document requires acceptance, ReCoWn Labs services may retain:

• the relevant product, licence, or request;
• the document;
• the version;
• the language presented;
• the content fingerprint;
• the UTC date/time;
• acceptance status.

This proof provides a record of the version that was actually presented and accepted.

B.12. Purposes

Information may be processed in order to:

• process a trial or licence request;
• verify the email address;
• verify the existence of the business;
• make a product available and issue or manage a licence;
• check its validity;
• prevent cloning or abusive use;
• provide update-related functions;
• secure the services;
• respond to a user request;
• retain proof of legal acceptance.

B.13. Legal bases

Depending on the processing concerned, data may be processed where necessary:

• to take steps requested by the user in order to obtain and use a paid or trial version of a product;
• for the relationship associated with making it available;
• for legitimate interests relating to system security, the prevention of abuse, and protection of the licensing mechanism;
• to comply with a legal obligation where applicable.

The Privacy Policy is not presented as blanket consent to all processing activities.

B.14. Recipients and service providers

Information is accessible only to the persons and service providers who legitimately require access in order to provide the service.

Technical service providers may include, in particular:

• Scaleway for infrastructure and transactional emails;
• Cloudflare for Turnstile and protection of the relevant forms.

ReCoWn Labs does not sell the personal data collected.

B.15. Retention periods

Data is retained for a period proportionate to its purpose.

Abandoned or unsuccessful trial request

Planned maximum period: 3 months after the last interaction, unless a legitimate need or obligation requires a different retention period.

Product or trial licence issued

Information necessary for managing, securing, and tracking the product or licence may be retained for the duration of the licence or trial and then for a maximum period of 12 months after its expiry, unless a legitimate need or obligation requires a different period.

Support requests

Support exchanges and materials submitted voluntarily may be retained for the time required to process the request and then for a maximum period of 12 months after it is closed, unless security requirements, a user request, a dispute, or an obligation requires a different period.

Attachments or sensitive data that are no longer necessary for diagnosis must be deleted or anonymised as soon as possible.

Technical and security logs

Technical, connection, and security logs may be retained for a maximum period of 12 months from their collection, except where a security incident, fraud, legal obligation, or the defence of rights justifies longer retention that is strictly necessary.

Proof of acceptance

Proof may be retained for the period necessary to establish and defend rights relating to the relevant use, within the limits of applicable limitation periods.

Technical fingerprint

Only the fingerprint currently associated with the installation is retained in the intended mechanism. When it is replaced, the previous fingerprint is not retained.

B.16. Cookies and trackers

ReCoWn Labs currently does not use advertising or audience-measurement cookies.

Certain mechanisms strictly necessary for operation or security, including Cloudflare Turnstile, may process the technical information necessary for their operation.

If additional tools requiring consent are added, the website and this policy must be adapted before activation.

B.17. Security

ReCoWn Labs implements technical and organisational measures intended to protect processed information against unauthorised access, alteration, disclosure, or destruction.

The user remains responsible for securing their own infrastructure, credentials, access controls, systems, and backups.

B.18. Transfers and service providers

Where the services used permit, ReCoWn Labs favours the hosting and processing of data within the European Economic Area.

Certain service providers, including Cloudflare, may nevertheless process technical information from countries outside the European Economic Area or involve entities established in those countries.

Where an international transfer of personal data takes place, it must be based on a mechanism recognised by the applicable regulations, such as an adequacy decision, standard contractual clauses, or another appropriate safeguard.

Detailed information concerning processing by service providers is set out in their respective contractual and privacy documents.

B.19. Data subject rights

Subject to the conditions laid down by the applicable regulations, individuals have, in particular, the following rights:

• access;
• rectification;
• erasure;
• restriction;
• objection;
• portability where this right applies.

Requests may be sent to:

privacy@recown.fr

Identity verification may be requested where necessary to protect the data concerned.

Individuals also have the right to lodge a complaint with the competent supervisory authority. In France: the CNIL.

B.20. Changes to the policy

The Privacy Policy may change to take account of changes to ReCoWn Labs websites, services, applications, products, or the regulations.

New versions are versioned and published in the legal repository.

A new version does not retroactively amend the version legally linked to an already-issued licence where that historical link must be retained.

B.21. Contact

For any question relating to data protection:

privacy@recown.fr

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