Privacy policy
Last updated: 21 January 2025
352 Digital S.à r.l. (“we”, “us”, “our”) is committed to protecting your privacy. This privacy policy explains how we collect, use and protect your personal data when you use the franglais.org website (the “Site”).
This policy complies with the General Data Protection Regulation (GDPR), Regulation (EU) 2016/679, and the Luxembourg law of 1 August 2018 on the organisation of the National Commission for Data Protection.
1. Data controller
The controller responsible for processing your personal data is:
352 Digital S.à r.l.29 Boulevard de la Grande-Duchesse Charlotte
L-1331 Luxembourg
Grand-Duché de Luxembourg
- Trade and Companies Register (RCS) : B212612
- Email : [email protected]
- Telephone : +352 2020 3352
2. Data collected
We collect different categories of data depending on how you use the Site:
2.1 Browsing the Site
When you browse the Site, we automatically collect:
- IP address (hashed and anonymised)
- Browser type and version
- Operating system
- Pages visited and time spent on them
- Where your visit came from (referring site)
2.2 Word votes
When you vote for or against a word, we collect:
- Your vote (+1 or -1)
- A unique anonymous identifier (cookie)
- A hash of your IP address
- Date and time of the vote
Note: Your IP address is never stored in plain text. We use an irreversible cryptographic hash (SHA-256) that does not directly identify you.
2.3 Word sightings (“Submit a word”)
When you report hearing or seeing a word, we collect:
- The reported word (existing or new)
- The context in which it was used (menu, office, social media, etc.)
- The region where the word was heard
- The date when you heard it
- An example sentence (optional)
- A source URL (optional)
- A photo as evidence (optional)
- A unique anonymous identifier
- A hash of your IP address
Submitted photos are automatically processed to remove EXIF metadata (GPS location, camera details, etc.) before storage.
2.4 Contact form
When you contact us through the form, we collect:
- Your name
- Your email address
- The content of your message
2.5 Google Analytics
We use Google Analytics to understand how visitors use our Site. Google Analytics collects:
- Anonymised browsing data
- General demographic data (country, city)
- Technical data (browser, device)
IP anonymisation is enabled. For more information, see Google’s privacy policy.
2.6 OpenStreetMap
The map on the Contact page loads when you choose to display it. Your browser then contacts the OpenStreetMap tile servers, which receive your IP address and technical request information. OpenStreetMap privacy policy.
3. Purposes of processing
We collect your data for the following purposes:
| Purpose | Data used |
|---|---|
| Operation of the collaborative dictionary | Votes, sightings, anonymous identifiers |
| Preventing abuse (multiple votes, spam) | Anonymous identifiers, IP hashes |
| Calculating word rankings | Aggregated votes, sightings |
| Content moderation | Sightings, photos |
| Responding to your enquiries | Contact form data |
| Improving the Site | Browsing analytics data |
| Site security | Technical data, security logs |
4. Legal bases for processing
Under Article 6 of the GDPR, we process your data on the following legal bases:
| Processing | Legal Basis |
|---|---|
| Votes and sightings | Legitimate interests (operation of the service) |
| Preventing abuse | Legitimate interests (security and integrity) |
| Analytics cookies (Google Analytics) | Consent |
| Functional cookies | Legitimate interests (technical operation) |
| Contact form | Consent (voluntary submission) |
| Site security | Legitimate interests (protecting systems) |
5. Recipients of data
Your data may be shared with:
5.1 Authorised personnel
Employees and collaborators of 352 Digital S.à r.l. who are authorised to process data as part of their duties (moderation, support, development).
5.2 Processors
| Processor | Service | Location |
|---|---|---|
| Google LLC | Analytics, fonts | United States (Data Privacy Framework) |
| Mailgun Technologies, Inc. | Sending emails | United States (Data Privacy Framework) |
| Wordfence / Defiant, Inc. | Security | United States |
| Imagify / WP Media SAS | Image optimisation | France |
| WP Rocket / WP Media SAS | Caching | France |
5.3 Authorities
We may be required to disclose your data to the competent authorities in response to a lawful request (court order or official demand).
6. International data transfers
Some of our processors are located outside the European Economic Area (EEA), particularly in the United States.
These transfers are protected by:
- The EU-U.S. Data Privacy Framework for certified companies
- The European Commission’s Standard Contractual Clauses (SCCs)
You can request a copy of the appropriate safeguards by contacting us.
7. Retention periods
| Type of data | Retention Period |
|---|---|
| Votes | For the life of the dictionary (anonymised data) |
| Approved sightings | For the life of the dictionary |
| Rejected/spam sightings | 6 months after rejection |
| Anonymous identification cookie | 1 year |
| Contact messages | 3 years after the last exchange |
| Analytics data | 26 months (Google Analytics setting) |
| Security logs | 12 months |
8. Data security
We use appropriate technical and organisational measures to protect your data:
- HTTPS/TLS encryption for all communications
- Cryptographic hashing (SHA-256) of IP addresses
- Web application firewall (WAF)
- Protection against brute-force attacks
- Regular encrypted backups
- Restricted access to personal data
- Automatic removal of EXIF metadata from photos
- Secure cookies (HttpOnly, Secure, SameSite)
9. Your rights
Under the GDPR, you have the following rights:
- Right of access (Article 15)
- To obtain confirmation that your data is being processed and receive a copy of it.
- Right to rectification (Article 16)
- To have inaccurate or incomplete data corrected.
- Right to erasure (Article 17)
- To request the deletion of your data in certain circumstances.
- Right to restriction of processing (Article 18)
- To request that processing of your data be suspended.
- Right to data portability (Article 20)
- To receive your data in a structured, machine-readable format.
- Right to object (Article 21)
- To object to processing based on legitimate interests.
- Right to withdraw consent
- To withdraw your consent at any time for processing that depends on it.
How to exercise your rights
To exercise your rights, contact us:
- By email : [email protected]
- By post : 352 Digital S.à r.l. – Data protection – 29 Boulevard de la Grande-Duchesse Charlotte, L-1331 Luxembourg
We will respond to your request within one month. This period may be extended by two months for complex requests.
Complaint to the supervisory authority
If you believe that the processing of your data breaches the GDPR, you may lodge a complaint with:
Commission Nationale pour la Protection des Données (CNPD)15, Boulevard du Jazz
L-4370 Belvaux
Grand-Duché de Luxembourg
https://cnpd.public.lu
10. Cookies
This Site uses cookies. For details of the cookies used and your choices, please see our Cookie policy.
11. Children
This Site is not intended for children under 16. We do not knowingly collect personal data from children under 16. If you are a parent or guardian and believe your child has provided us with personal data, please contact us.
12. Changes to this policy
We may update this privacy policy periodically. The last updated date appears at the top of this page. If we make a substantial change, we will notify you through a prominent notice on the Site.
We encourage you to check this page regularly for changes.
13. Contact
For any questions about this privacy policy or the processing of your personal data:
- Email : [email protected]
- Telephone : +352 2020 3352
- Address : 352 Digital S.à r.l. – 29 Boulevard de la Grande-Duchesse Charlotte, L-1331 Luxembourg

