Privacy Policy
Introduction
Locordi, publisher of the ComposeMeNow service, attaches great importance to protecting the personal data of its users. This Privacy Policy aims to inform you about how we collect, use and protect your personal data, in accordance with the General Data Protection Regulation (GDPR) and the French Data Protection Act.
1. Data Controller
Locordi
SARL with capital of 7,500 euros
27 bis rue Estienne d'Orves, 92250 La Garenne-Colombes, France
SIRET: 831 481 353 00025
Email: contact@composemenow.com
2. Data Collected
We collect the following data:
2.1 Identification data
- First and last name
- Email address
- Password (encrypted)
2.2 Billing data
- Billing address
- Payment information (processed by Stripe, not stored by us)
2.3 Usage data
- Created agents and their configuration
- Generated and sent newsletters
- Usage statistics (opens, clicks)
- Connection logs
2.4 Our users' subscriber data
As a processor, we also process subscriber data that our users import into the service (email, name, tags, etc.). This data remains the property of our users.
3. Processing Purposes
| Purpose | Legal basis |
|---|---|
| Account creation and management | Contract execution |
| Service provision | Contract execution |
| Billing and payment | Contract execution / Legal obligation |
| Customer support | Contract execution |
| Service improvement | Legitimate interest |
| Statistics and analytics | Legitimate interest / Consent |
| Security and fraud prevention | Legitimate interest |
4. Sub-processors and Data Transfers
We use the following sub-processors:
| Sub-processor | Purpose | Location |
|---|---|---|
| Supabase | Database and authentication | UE / US (SCCs) |
| Vercel | Application hosting | US (SCCs) |
| Stripe | Payments | US (SCCs) |
| SendGrid (Twilio) | Email sending | US (SCCs) |
| OpenAI | AI content generation | US (SCCs) |
| Firecrawl | Web scraping | US (SCCs) |
| Cloudflare | Security (Turnstile) | US (SCCs) |
SCCs = Standard Contractual Clauses approved by the European Commission for data transfers to third countries.
5. Data Retention
| Data type | Duration |
|---|---|
| Account data | Account duration + 3 years |
| Billing data | 10 years (legal obligation) |
| Newsletters and statistics | Account duration + 1 year |
| Connection logs | 1 year |
| Subscriber data | Account duration (under user control) |
6. Your Rights
Under the GDPR, you have the following rights:
- Right of access: obtain a copy of your personal data
- Right to rectification: correct inaccurate or incomplete data
- Right to erasure: request deletion of your data
- Right to restriction: limit the processing of your data
- Right to portability: receive your data in a structured format
- Right to object: object to processing based on legitimate interest
- Right to withdraw consent: withdraw your consent at any time
To exercise your rights, contact us at: contact@composemenow.com
You can also file a complaint with your local data protection authority.
7. Data Security
We implement the following security measures:
- Data encryption in transit (HTTPS/TLS)
- Password encryption (bcrypt)
- Secure authentication (JWT)
- Row Level Security (RLS) on database
- Anti-bot protection (Cloudflare Turnstile)
- Regular backups
- Restricted access to production data
8. Cookies
For more information about our use of cookies, see ourCookie Policy.
10. Applicable Local Law
This Privacy Policy is based on European regulations (GDPR). However, if you are located in a country with different data protection laws (USA/CCPA, UK, Canada/PIPEDA, etc.), additional rules may apply. You are responsible for complying with data protection laws applicable in your country of residence. ComposeMeNow cannot be held liable for non-compliance with local regulations that would apply to your specific situation.
9. Modifications
We reserve the right to modify this Privacy Policy at any time. In case of substantial changes, we will notify you by email or via the Service.
Last updated: December 12, 2025