Privacy policy

1. Who is responsible for your data

The controller of the personal data described in this policy, meaning the entity that decides why and how that data is processed and that is accountable for it under the General Data Protection Regulation, is Innolope LLC, the operator of fragnoir.com and of the Fragnoir applications. Wherever this policy says "we", "us" or "Fragnoir", it refers to that company acting in that capacity.

You can reach us about anything in this policy, including any request to exercise the rights described in section nine, by writing to [email protected]. We read every message sent to that address, and privacy requests are handled by the same small team that builds the product rather than being routed into an outsourced ticketing system, which is one of the genuine advantages of being a company of our size.

2. The scope of this policy

This policy covers the Service as defined above and nothing else. In particular, it does not cover the websites and applications operated by the fragrance retailers we link to, and this distinction matters more for Fragnoir than it would for most services, because sending you to a retailer is one of the main things our product does. The moment you follow a link from Fragnoir to a shop such as Notino, Flaconi, Douglas or any other merchant, you have left our Service and entered theirs, and everything that happens from that point onwards — the cookies that shop sets, the analytics and advertising technology it runs, the account you may hold with it, and the payment details you may enter — is governed by that retailer's own privacy policy and is entirely outside our control and our knowledge. We never see, receive or store your payment details, because we never process a payment; we are an index and a comparison tool, not a shop.

This policy also does not cover any correspondence you may have with us through channels other than the Service, such as a social media platform, where the platform operator is an independent controller of the message you send and applies its own terms and privacy rules to it.

3. What we collect when you simply visit this website

When you load a page on fragnoir.com, our infrastructure necessarily processes the technical information that any web server needs in order to send a page back to you and to defend itself against abuse. That information consists principally of your IP address, the page or file you requested, the date and time of the request, the referring page where applicable, and the user-agent string that identifies your browser and operating system. We process this on the legal basis of our legitimate interest under Article 6(1)(f) of the GDPR in operating a website that is available, reasonably fast and not trivially easy to attack, and we have concluded that this interest is not overridden by your interests because the data is minimal, is not used to build any profile of you, is not combined with any other dataset, and is retained only briefly as described in section eight.

In addition to those server-side records, a single first-party cookie named fragnoir_consent may be stored in your browser. It contains nothing but a record of the choice you made about analytics, the version number of the consent notice you were shown, and the timestamp of your decision. It exists solely so that we can honour your decision and avoid asking you the same question on every page, and it is set only once you have actually made a choice.

4. Analytics, and why nothing loads until you say so

Fragnoir uses Google Analytics 4 to understand which pages people find useful, how visitors arrive, and where they give up — the ordinary questions that any product team asks in order to decide what to improve next. We have deliberately implemented this in the strictest way that the technology allows: the Google Analytics script is not merely disabled, blocked or told to withhold consent when you have not opted in, it is not inserted into the page at all, which means that in the absence of your consent your browser never makes a single network request to any Google domain on our behalf and Google therefore never learns that you visited us. This is a meaningfully stronger position than the common industry practice of loading the tag immediately and setting a consent flag afterwards, and we chose it on purpose.

Where you do consent, the legal basis is your consent under Article 6(1)(a) of the GDPR together with the applicable national implementations of the ePrivacy Directive, we instruct Google to anonymise IP addresses, and we disable the advertising and personalisation features of the product so that the data is used for audience measurement rather than for building an advertising profile. Your consent is entirely voluntary, refusing it costs you nothing and changes no feature of the Service, and you may withdraw it at any moment with effect for the future by opening the "Cookie settings" link that appears in the footer of every page and choosing the essential-only option, which removes our analytics from any subsequent page load.

5. What we collect when you contact us

If you write to us through the contact form or by email, we process the email address you provide, the content of your message, and any information you voluntarily include within it, for the single purpose of reading your message, investigating whatever it concerns and replying to you. The legal basis is our legitimate interest under Article 6(1)(f) in responding to people who take the trouble to contact us, or, where your message concerns a contract or a potential contract with us, the pre-contractual and contractual basis in Article 6(1)(b).

Messages sent through the contact form are delivered to our inbox by our email processor, Resend, which acts on our documented instructions under a data processing agreement and does not use the content of your message for its own purposes. Because the form does not require an account, and because we would rather not hold correspondence indefinitely, we periodically review and delete old contact threads once the matter they concern has been resolved and no legal reason to retain them remains.

6. What the applications will process once they launch

The Fragnoir applications for iOS and Android are in development at the time of writing and are not yet available, so nothing described in this section is happening today. We are nevertheless setting out our intentions here, because a privacy policy that only tells you about the past is of limited use when deciding whether to trust a product.

When the applications launch they will process, in broad terms, the following categories of data: an account identifier and, where you choose to create a full account rather than remain anonymous, an email address or the identifier supplied by Apple or Google when you use their sign-in services; the barcodes you scan and the fragrance pages you open, which are needed in order to show you results and to tell you what you have already looked at; the contents of your fragrance wardrobe, meaning the bottles you mark as owned, wished for or merely sampled, together with any personal ratings and private notes you attach to them; the ratings, note votes and reviews you submit to the community, which are published under the identity you choose and are therefore visible to others; and pseudonymous records of the outbound clicks you make to retailers, which exist so that our affiliate partners can attribute a sale to us and so that we can detect fraud and understand which comparisons are useful.

Those processing activities will rest on the contractual basis in Article 6(1)(b) insofar as they are necessary to deliver features you have asked for, on consent under Article 6(1)(a) for optional analytics and for push notifications, and on legitimate interest under Article 6(1)(f) for fraud prevention, moderation and security. Before any of it begins, you will be shown an in-app privacy notice describing it in specific terms, this policy will be updated accordingly, and the applications will ship with data export and complete account deletion built into the settings screen from the first release rather than added later under pressure.

7. Who else is involved, and where your data goes

We use a small number of carefully chosen service providers, each of which processes personal data only on our documented instructions under a data processing agreement that meets the requirements of Article 28 of the GDPR. Cloudflare provides our domain name service, network-level security and content delivery, and consequently handles connection metadata as your request reaches us. Our hosting provider operates the servers on which the Service runs, which are located within the European Union. MongoDB Atlas provides the managed database in which our content and, in future, your account data will be stored, on infrastructure we have configured in the European Union. Resend delivers transactional email on our behalf. Google, through Google Analytics 4, receives usage measurement data, but only from those visitors who have actively consented to it.

Where any of these providers processes data outside the European Economic Area, that transfer is covered either by an adequacy decision of the European Commission or by the Commission's Standard Contractual Clauses supplemented by the technical and organisational measures our providers publish. Beyond these processors, we do not sell personal data, we do not share it with data brokers, we do not participate in advertising exchanges or real-time bidding, and we do not disclose personal data to third parties except where we are compelled to do so by a valid legal obligation, where it is necessary to establish, exercise or defend legal claims, or in the event of a corporate transaction such as a merger or acquisition, in which case you would be informed and the acquirer would be bound by commitments no weaker than these.

8. How long we keep things

We retain server and security logs for a maximum of thirty days, after which they are deleted, because their purpose — spotting an attack, diagnosing an outage, understanding a spike in traffic — has no useful life beyond that window. The consent cookie is stored for twelve months, at which point it expires and we ask you again, since a preference expressed a year ago should not be treated as an indefinite mandate. Correspondence you send us is kept for as long as the matter it concerns remains live and is then deleted, unless a specific legal obligation requires us to keep it longer.

Once accounts exist, account data will be retained for as long as the account does. When you delete your account we will erase the associated personal data promptly and, where a published review is involved, either delete it or sever it permanently from your identity depending on the choice you make at the point of deletion, so that the community record of a fragrance is not silently rewritten while your personal connection to it is nonetheless removed. Affiliate click records will be reduced to non-identifying aggregates after ninety days.

9. Your rights, and how to use them

The GDPR gives you a set of rights over your personal data, and we would like you to actually use them rather than treat them as decoration at the end of a policy. You have the right under Article 15 to obtain confirmation of whether we process data about you and to receive a copy of it; the right under Article 16 to have inaccurate data corrected and incomplete data completed; the right under Article 17 to have your data erased, which we will honour except where we are legally required to retain something; the right under Article 18 to have processing restricted while a dispute about accuracy or legitimacy is resolved; the right under Article 20 to receive the data you provided in a structured, commonly used and machine-readable format and to have it transmitted elsewhere; and the right under Article 21 to object at any time to processing that we base on legitimate interest, in which case we will stop unless we can demonstrate compelling legitimate grounds that override your interests.

Where processing is based on your consent, Article 7(3) additionally gives you the right to withdraw that consent at any time without affecting the lawfulness of what was done beforehand; for analytics, the "Cookie settings" control in the footer is the fastest route and takes effect immediately. To exercise any other right, write to [email protected] and we will respond within one month, extending that period only in the genuinely complex cases contemplated by Article 12(3) and telling you if we do. We do not charge for these requests. If you are unhappy with how we have handled your data or your request, you have the right under Article 77 to lodge a complaint with the supervisory authority of the EU member state in which you live, work, or believe the problem occurred, and doing so does not prevent you from also pursuing a judicial remedy.

10. Security, children, and automated decisions

We protect personal data with measures appropriate to the risk it carries, including encryption of traffic in transit, encryption of data at rest in our managed database, strict limitation of access to the few people who genuinely need it, credentials held in a secrets manager rather than in source code, and a deliberately small collection footprint on the principle that the safest data is the data you never gathered. No system is perfectly secure and we will not pretend otherwise, but we will tell you and the relevant supervisory authority without undue delay if a breach occurs that is likely to affect your rights.

The Service is not directed at children under the age of sixteen and we do not knowingly collect their personal data; if you believe a child has provided us with data, write to us and we will delete it. Finally, we do not carry out automated decision-making that produces legal effects concerning you or similarly significantly affects you within the meaning of Article 22, and we do not build advertising or behavioural profiles. The personalised recommendations planned for the applications will be based on the fragrances you have explicitly told us you like, will be visibly explicable to you, and will affect nothing except the order in which we suggest things you might enjoy.

11. Changes to this policy

Fragnoir is an actively developed product, and this policy will therefore change as the Service does, most significantly when the mobile applications are released and the processing described in section six becomes real rather than planned. When we make a change we will update the date shown at the top of this page, and where the change is material — meaning it alters what we collect, why we collect it, who receives it, or the rights you have over it — we will draw attention to it on the website and, if you hold an account, in the product itself, rather than relying on you to notice a silently edited page.