Privacy notice

This privacy notice explains how Afthonios processes your personal data when you visit the afthonios.com website, contact us, request trial access, take modules or use the website assistant. Cookies are described in the Cookie policy.

Data processed, depending on your situation

• You visit the website: technical connection data, described under “When you visit the website”.
• You visit the website or contact us in a professional capacity: the information you enter in the contact form (first name, last name, job title, organization, e-mail address, type of request and any details you choose to give).
• You have requested trial access: see “When you request trial access” below. This access works with a sign-in link sent by e-mail, without a password.
• Your organization gives you access to modules: your account information (name, e-mail address) and your progress in the modules.
• You have a legacy account or subscription: your account information (name, e-mail address, encrypted password), your progress through the courses, and the subscription and billing data processed by Stripe. We do not collect your payment card details: they are processed exclusively by Stripe.
• You use the catalog assistant: the text of your questions, see “When you use the catalog assistant”.
• Someone from your organization invites you to discover the modules: your first name, your last name if given, and your e-mail address, see “When you invite colleagues”.

The data concerned

Fields marked as required are needed to process your request; the others are optional. Sending the form does not sign you up for a newsletter.

• The information you enter: first name, last name, job title, organization, e-mail address, type of request, your message and, depending on the request, any details you choose to give (module or topic concerned, number of employees, volume, arrangements, roll-out timetable, preferred language).
• The language of the page from which you write and the date of your request.
• To limit abuse, a daily counter of submissions tied to a truncated network prefix — never to your full IP address. These counters are deleted once they are no longer needed, usually the next day.

Why, and on what legal basis

• Answering your request and following up on our exchanges, including with an acknowledgment of receipt: steps taken at your request prior to entering into a contract (Article 6(1)(b) GDPR) or, when you write on behalf of your organization, our legitimate interest in answering the requests we receive (Article 6(1)(f)).
• Keeping a copy of your request in our database, so that it is not lost if an e-mail fails to send: our legitimate interest (Article 6(1)(f)).
• Offering, in connection with your request, to discuss your training project: our legitimate interest (Article 6(1)(f)), see “Purposes and legal bases”. You may object at any time.

Recipients

• Your request is sent by e-mail to the Afthonios team, who handle it, and stored in our database.
• Service providers: Resend (Plus Five Five, Inc., United States) for sending e-mails, including the acknowledgment of receipt; Neon for the database; Vercel for hosting; Google Workspace (Google Ireland Limited) for receiving your request and sending our replies. See “Recipients and processors”.

Retention period

Your contact details and your request are kept for no more than three years from their collection or from the last relevant contact initiated by you. If your request leads to a contract, the exchanges relevant to that contract are kept with it.

You may exercise the rights described under “Your rights” at any time.

The data concerned

• The contact details given in the form: first name, last name, job title, organization and work e-mail address. The language in which you made your request is also recorded. All fields of the trial access form are required to open your access.
• Sign-in and security information: you sign in with a temporary link sent by e-mail, without a password. Once you are signed in, the session cookie described in the Cookie policy keeps you signed in. As for any account on the website, the IP address and type of browser used when signing in are recorded with the session, for account security. To limit abuse, we keep a daily counter of requests, tied to a truncated network prefix and to a fingerprint of the e-mail address — never to your full IP address; these counters are deleted after a few days.
• Management of your access: the dates of your request, of the sending of the link, of the first opening of a module, of the end of your access, of any extension or reactivation and of the sending of the trial messages; the modules and formats you view, and your progress.
• Your learning answers and your feedback: depending on the format, the answers you enter in the activities and the feedback based on them are recorded with your progress, so that you can resume your exploration.
• Your requests for help and our exchanges: the messages you send us, in particular by replying to a trial e-mail, and the messages we send you.
• Proof that you accepted the terms: the date, the version of the terms accepted and the language of the page.
• Your objection to offers to talk, if you have expressed it, so that we can respect it.

What this data is used for

Your request does not sign you up for a newsletter.

Legal bases: managing your access, the messages needed for it to work, the learning experience and answering your requests are based on the performance of the trial access terms you accepted (Article 6(1)(b) GDPR); the security of the access, proof of your acceptance, internal statistics on trial access use and offers to talk are based on our legitimate interest (Article 6(1)(f)).

• Opening, securing and managing your trial access, and telling you its dates.
• Sending you the messages needed for it to work: access link, reminder, confirmation, end.
• Giving you the learning experience and your personalized feedback.
• Answering your requests.
• Producing internal statistics on how trial access is used (number of requests, modules opened, videos watched, contact requests), as totals, to improve our modules and our offer. These statistics are not used to assess you individually.
• Offering, in some messages, to discuss your training project. You may object at any time: your trial access is not closed as a result, and you will still receive the messages needed to sign in or for an action you have requested.

What we do not do with your learning answers

The sample group report shown in the trial space is based on fictitious data, unrelated to your answers.

The trial access modules do not use any artificial-intelligence service: your answers are not sent to any AI provider.

Our administration interface does not display participants’ learning answers; it shows the information needed to manage access (contact details, dates), as well as these overall statistics.

• They are not passed on to your employer.
• They are not used to qualify you commercially.
• The website assistant has no access to them.
• They are not used, in a form that identifies you, to train any system.

When you invite colleagues

From your trial space, you can invite colleagues from your organization. We then record the first name, the last name if given and the e-mail address of the person invited, the date of the invitation and the language of the e-mail. Your colleague receives a single e-mail stating who invited them; no reminder is sent. An invitation that is not taken up is deleted after 30 days. We do not tell you whether your colleague has taken up the invitation; if they request access, the link between the two accesses is kept for our internal follow-up.

Legal basis: our legitimate interest, and that of the person inviting, in allowing the modules to be discovered within the same organization (Article 6(1)(f) GDPR).

Recipients and service providers

Your data is intended for the Afthonios team in charge of trial access and of following up requests. It is hosted and processed by the technical service providers listed under “Recipients and processors” (hosting, database, e-mail delivery, video delivery, file storage).

Retention periods

• Learning answers and progress during the trial: we delete the learning data that identifies you 30 days after your access actually ends, including any extension or reactivation. A discussion about a project does not extend this period. If your account also has another access to the modules, the data kept under that other access is not affected.
• Professional contact details: when they are used to offer you a conversation, they are kept for no more than three years from their collection or from the last relevant contact initiated by you. A message sent by Afthonios does not restart this period.
• Sign-in account, proof of acceptance and objection: kept for as long as your professional contact details.
• Invitations not taken up: deleted after 30 days.

Your rights

You have the rights described under “Your rights”: access, rectification, erasure, restriction, objection and portability. To exercise them: info@afthonios.com or connect@afthonios.com.

Your answers in the modules

So that you can resume a module where you left off, we record your progress and your answers in that module.

Depending on the module, this record includes your progress (steps completed, part of the video watched), the choices and answers you enter in the activities, including texts you write, and tracking events (module viewed, started, completed). Legal basis: providing the service you have access to, under your subscription, your trial access or the access provided by your organization (Article 6(1)(b) and (f) GDPR).

When you use the assistant or a module’s coach, to limit abuse we keep a daily counter tied to your account or, if you are not signed in, to a truncated network prefix — never to your full IP address.

If you proofread modules for us

If you proofread our modules at our request, we record your name, your email address, your review languages and your comments, together with their location in the module and the date; the Afthonios team and the other reviewers for the same language can see them, on the basis of our legitimate interest in having our modules proofread (Article 6(1)(f) GDPR), and we keep them until the end of your proofreading assignment.

Artificial intelligence in the modules

The modules of the 2026 series, including those of the trial access, do not use any artificial-intelligence service: the feedback you read in them is prepared in advance by our team. Only four modules that predate this series offer AI-generated feedback.

Coach in some interactive modules: in modules that offer personalized AI feedback, this feedback is generated from the text you enter in the exercise concerned and from your positions in the self-assessment. These elements are sent to Anthropic PBC (United States) to produce the feedback. The generated feedback is stored with your progress.

Anthropic acts as a processor. This content is kept by Anthropic for a maximum of 30 days for security purposes and is not used to train its models.

Legal basis: our legitimate interest, and that of your organization, in giving you access to the training provided for in the contract it has concluded with us (Article 6(1)(f) GDPR). Individual reporting under your name is based on your consent (Article 6(1)(a)), which you may withdraw at any time.

Legal bases at a glance

• Performance of a contract or steps taken at your request prior to entering into a contract (Article 6(1)(b)): trial access, legacy subscriptions, access to the modules, answering your requests.
• Legitimate interest (Article 6(1)(f)): website security and abuse prevention, cookieless audience measurement, backups, catalog assistant, access provided by your organization, offers to talk to professionals, invitations of colleagues, internal statistics on trial access use.
• Legal obligation (Article 6(1)(c)): keeping accounting records, answering requests from the authorities.
• Consent (Article 6(1)(a)): individual reporting under your name to your organization, where this option exists.

We disclose data to the authorities only where the law requires us to do so.

We reply within one month, which may be extended by two months if the request is complex. If we have reasonable doubts about your identity, we may ask you to confirm it.

Complaint: if you consider that your rights have not been respected, you may lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement. In France, this is the Commission nationale de l’informatique et des libertés (CNIL); in Cyprus, where Afthonios is established, the Commissioner for Personal Data Protection.

Changes to this notice

We may change this notice to reflect changes to the website or to the regulations. The date of the last update is shown at the top of this page.