Privacy Policy
1. Data controller
The data controller is Nathan Manteau EI, sole trader operating under the trade name Gapless, SIREN 105445175, rue de Terssac, 81000 Albi, France. Contact: support@gapless.gg.
2. Data collected
- Account / identity: username, last name/first name where applicable, email, avatar, language, game, level, social links.
- Connection data: credentials, sign-in via Discord (OAuth), technical logs, IP address.
- Payment data: processed by Stripe; GAPLESS does not store card numbers. A customer/subscription identifier is retained.
- Coach data: profile information, rates, Stripe Connect status, tax data transmitted as part of reporting (DAC7).
- Usage data: bookings, purchases, messages, reviews, interactions.
- Proof of consent: when you accept the terms of use, this policy or the other contractual documents, GAPLESS records the document accepted, its version number, the date and time, your IP address and your browser.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Provide the service (account, booking, payment) | Performance of the contract |
| Manage subscriptions and billing | Performance of the contract |
| Customer support | Performance of the contract / legitimate interest |
| Security, fraud prevention | Legitimate interest |
| Tax obligations and reporting (DAC7) | Legal obligation |
| Audience measurement / improvement | Legitimate interest or consent |
4. Recipients and processors
Data may be disclosed to the following processors, strictly as necessary:
- Stripe (payments and coach payouts): Ireland / EU.
- Supabase (database / back-end / authentication): EU hosting (Ireland, eu-west-1).
- Vercel (website hosting): United States.
- Cloudflare (video storage, CDN, DNS): EU.
- Resend (sending transactional emails): United States.
- Discord (sign-in, community, only if you enable the feature): United States.
- Zoho (support messaging): EU.
- Anthropic (Claude) (AI script generation, only the content you submit): United States.
- Modal (AutoClip video processing): United States.
- Inngest (asynchronous processing and reminders): United States.
Transfers outside the EU (Vercel, Resend, Discord, Anthropic, Modal, Inngest in the United States): governed by appropriate safeguards (European Commission standard contractual clauses or adherence to the Data Privacy Framework).
5. Retention periods
Data is retained for as long as necessary for the purposes, then archived or deleted:
- Account: throughout the entire period of use, then deletion or anonymization at the latest 12 months after the account is closed (or after 3 years of inactivity).
- Accounting / tax data: statutory period (generally 10 years).
- Technical logs: 12 months.
- Proof of consent: for the whole lifetime of the account, then 5 years after it is closed. This is kept in order to demonstrate consent, as required by article 7(1) of the GDPR.
6. Your rights
In accordance with the GDPR, you have the rights of access, rectification, erasure, restriction, objection and portability. To exercise them: support@gapless.gg. You may lodge a complaint with the CNIL: cnil.fr.
8. Minors
The Platform is intended for persons aged at least 15. The data of a minor under 15 is only processed with the consent of the legal guardian. For access to paid services, the User's date of birth is collected at the time of the first order and, for minor Users, the email address of the legal guardian is collected for the purposes of the validation provided for in Article 4.3 of the Terms of Use. This data is retained for the duration of the contractual relationship plus the applicable limitation period.
9. Security
GAPLESS implements reasonable technical and organizational measures to protect data (encryption in transit, access control, compliant providers).
10. Changes
This policy may be updated; the date at the top indicates the latest version.
