Privacy Policy

Last updated: 18 October 2026

This English version is a translation provided for convenience only. The French version is the only legally binding version and prevails in the event of any discrepancy. Read the French version

This policy describes the personal data we process, why we process it, to whom it is disclosed, how long we keep it and what rights you can exercise over it. It is drawn up pursuant to Regulation (EU) 2016/679 of 27 April 2016, known as the “GDPR”, and to French Law No. 78-17 of 6 January 1978 on information technology, data files and civil liberties, as amended.

We have chosen to describe in it all the processing actually carried out, including processing that a service of this kind does not usually detail. Three of these operations deserve your particular attention: the transmission of your exchanges to language model providers, the detection of abnormal use (which involves recording technical connection data and screen capture attempts) and the collection of email addresses on our resource pages.

Article 1: Data controller

The data controller, that is, the entity that determines the purposes and means of the processing described below, is the publisher of the OctoFin platform, whose full identity is set out in Article 1 of the general terms.

For any question, request to exercise your rights or complaint relating to your data, you can write to us at support@octofin.io. Users who have an account can also use the support area built into the platform.

Article 2: Our principles

The commitments below are not statements of intent: they describe how the platform is actually built, and each of them can be verified by reading the articles that follow.

Data minimisation. We collect only the data necessary for the operation of the service. No data is requested “just in case”.
No commercialisation. We do not sell, rent or exchange your personal data, on any basis or with anyone whatsoever.
No advertising profiling. We use no advertising trackers, no social network pixels and no behavioural audience measurement tools.
No model training. We do not use your data to train artificial intelligence systems, and we do not allow our providers to do so.
Reversibility. You can delete your account and your data directly from your personal area, without having to ask us.

Article 3: Sources of the data

The data we process comes from three sources, and three only.

You, when you create your account, complete your profile, answer questions, submit an interview report, write to support or enter your address on a resource page.
Your use of the service, which automatically generates progress data and the technical connection data described in Articles 4 and 6.
Third parties, in limited cases: your identity provider if you log in via an external account, our payment provider for the status of a transaction, and a partner institution when it opens access for you.

We do not buy any files, do not carry out any data enrichment with brokers and do not collect any information about you from public sources or social networks.

Article 4: Data processed, purposes and legal bases

Each processing operation is presented below with the categories of data concerned, the purpose pursued and the legal basis that authorises it within the meaning of Article 6 of the GDPR.

4.1: Account and identity

Data: email address, first and last name, optional username and profile photo, password stored exclusively in the form of a salted cryptographic hash and never in plain text, account creation date, account status, display preferences.

Purpose: to create and manage your account, authenticate you reliably, personalise the interface and send you the communications necessary for the operation of the service (purchase confirmation, information about the expiry of your access, reply to a support request). Legal basis: performance of the contract to which you are a party (Art. 6(1)(b) GDPR).

4.2: Authentication through a third-party provider

If you choose to log in with a Google account, Google sends us only your email address, your name and a technical identifier used to link subsequent logins to the same account. We do not access your contacts, your files, your messages or any other data in your Google account, and your Google password is never disclosed to us.

Legal basis: your consent (Art. 6(1)(a)), which you can withdraw at any time by unlinking this login method from your personal area or from the security settings of your Google account.

4.3: Password strength check

When you register and each time you change your password, we check that the password you have chosen does not appear in public corpora of passwords compromised in data breaches. This check uses a so-called k-anonymity protocol: the cryptographic fingerprint of your password is calculated locally on our servers, and only its first five characters are sent to the lookup service, which returns all the fingerprints sharing that prefix. The final comparison takes place on our side.

Your password itself never leaves our servers, and it cannot be reconstructed from the fragment transmitted, which is shared by tens of thousands of different passwords.

Legal basis: our legitimate interest in protecting our users’ accounts against takeovers through the reuse of compromised credentials (Art. 6(1)(f)).

4.4: Learning progress

Data: lessons, interview reports and case studies viewed and completed — with, for each, the dates on which they were opened, the furthest page reached and the active reading time (counted only when the tab is displayed and you are present in front of the screen), which make it possible to mark content as read without you having to declare it —, answers given to questions and their accuracy, time taken to answer each question (from its display to your first answering action), duration and composition of training sessions, mastery indices calculated per chapter, an estimate of the strength of your memory for each question, work streaks, personal notes you write. Added to this are your answers to the weekly check-in (where your interview search stands, the interview on which you choose to focus your preparation, a chapter to push or to see less of) and your reactions to the suggestions of the calendar and of training: accepted, postponed or declined, with the optional reason for a refusal (“already mastered”, “not this topic”, “too long”), the time and duration proposed, as well as a record of the suggestions that the service itself withdrew. Finally, added to this are your starting profile — the position you are aiming for, your self-assessed technical level, the time you expect to devote to preparation and the module you want to work on first, as you indicated them at onboarding or, failing that, in your beta application (Article 10) —, your answers to the initial diagnostic if you take it (ten questions, optional), and the readiness score we calculate for each of your interviews.

Purpose: to show you your progress, feed the spaced repetition mechanism that determines which questions are shown to you again and when, identify the concepts you are weak on and adapt your programme. Response time is recorded in order to distinguish a confident answer from a hesitant one — it does not yet enter into any calculation; the memory estimate is used to predict what you will have retained by the date of your interviews. Your reactions to suggestions and your answers to the weekly check-in adjust the following suggestions: a refusal pushes a topic back, an “already mastered” triggers a short check instead of a penalty, a chosen focus steers the week — for a limited time, their effect fading over time. Your starting profile guides your first sessions and the first calendar suggestions as long as no interview has been entered, and sets the suggested pace until your own pace has been measured; the diagnostic gives a first picture of what you already know; the readiness score compares what the bank requires, according to the published interview reports, with what you will know on the day of the interview. These calculations are performed on our servers, are not transmitted to any third party and do not train any model. This data is at the heart of the service: without it, the personalisation that makes it worthwhile would be impossible. Legal basis: performance of the contract (Art. 6(1)(b)).

To find out whether our suggestions are useful, we also record, for each calendar suggestion, the date on which it was first shown to you and the date on which you completed it, and, for each training session, where you launched it from (today’s session, calendar, assistant, an interview’s page…). These records are used only to feed the anonymous counters described in Article 14: they do not change anything that is offered to you. Legal basis: our legitimate interest in checking that the service keeps its promises and in improving it (Art. 6(1)(f)).

4.5: Interviews and interview reports

Data: the interviews you record in your calendar (institution, job title, date) and the interview reports you choose to submit after taking them.

Purpose: to align your revision programme with your actual deadlines, remind you to submit your interview report, and feed the database of interview reports made available to other users. The interview reports that are shared are published in a form that does not identify you by name.

Legal basis: performance of the contract for tracking your deadlines; our legitimate interest in building a documentary database useful to all users for making the interview reports available (Art. 6(1)(f)), it being specified that submitting them is entirely at your initiative and that you can request their removal.

4.6: Support and messaging

Data: content of the messages you send to support, any attachments, history of exchanges and internal follow-up notes. Purpose: to process your request, keep a record of it in the event of a subsequent complaint and improve the quality of the service. Legal basis: performance of the contract.

4.7: Referral

Data: the referral code assigned to you, the link to the referred users who used this code, associated progress events. Purpose: to operate the referral programme and award the corresponding benefits. Legal basis: performance of the contract, at your request to take part in it.

4.8: Technical error reports

When a page fails to display or an action fails in your browser, a technical report is sent to our own servers, where it is written to the operations log. It is the browser-side counterpart of the errors that our servers already log: without it, a failure that occurs only on your device would be known to no one — not even to us.

Data: the type and message of the error, the first lines of its technical trace, and the path of the page concerned. Added to this is the information that any request inherently transmits to a server — IP address and browser used.

What is removed before sending, and again on arrival: an error message is free text, which may accidentally contain what you had just typed. Email addresses, sequences of digits, identifiers and URL parameters are therefore replaced with neutral labels, on your device before sending and again on our server. URLs are reduced to the path of the page: no query, no fragment — this is what guarantees that a password reset link cannot end up in a log. No identifier links a report to an account or to a visit.

Nothing is stored on or read from your device on this occasion, and these reports are not used for any audience measurement: they count nothing and feed no dashboard. Legal basis: our legitimate interest in ensuring that the service works and in fixing what does not (Art. 6(1)(f)). Duration: that of the operations logs of our host, which purges them according to its own retention policy; we keep no copy of them elsewhere, and none of these reports is linked to an account.

4.9: Notifications and personal tracking tools

Some features of the Platform send you email notifications, if you turn them on, and let you keep track of your steps. What follows applies to every OctoFin notification you turn on or receive.

Data: if you turn on notifications, your preferences (the topics and criteria you choose, the email frequency) and, for each notification, the item concerned, the time it was spotted and the time the email was sent; the items you track: those you set aside or add yourself, their status and outcome, their dates, your notes and the interviews you link to them; the date of your last visit to certain pages, to flag what is new since then.

Purpose: to notify you according to your settings, without ever notifying you twice about the same item: at most one email per hour, grouping what is new, or a summary every morning, as you choose. These emails contain no advertising; each one includes a one-click unsubscribe link, without logging in. The spotting and sending times are also used to check that notifications go out quickly. The items you track are a memory aid: their deadlines appear in your Calendar and, on the platform only, reminders (an approaching deadline, an interview, three weeks without news); they are visible only to you and are not passed on to anyone. Legal basis: performance of the contract, at your request (Art. 6(1)(b)): nothing is sent until you have turned on notifications, and you can turn them off at any time from your account.

Article 5: Conversational assistant and model providers

The platform includes an assistant based on language models operated by third-party providers. This means that some data leaves our servers: we detail this here so that you can make an informed decision as to whether or not to use it.

5.1: What is transmitted, and to whom

What is sent: the content of the messages you send to the assistant, as well as the extracts of educational content needed to formulate a relevant answer.
What is also sent, since 22 September 2026: a short summary of your preparation, sent to the learning assistant so that its answers take your situation into account. It contains the upcoming interviews you have entered yourself (institution, team, round, date), your progress by chapter and the titles of the last questions you got wrong — and, as long as no interview has been entered, the position you said you were aiming for when you joined. Neither your name, nor your email address, nor any account identifier is included, and the guidance assistant does not receive it.
What it consults when answering, since 24 September 2026: when your question calls for it, the learning assistant itself reads, during the conversation, the details of your preparation (your upcoming interviews and your readiness score for each of them, your progress on each chapter, your latest mistakes) or the slots already taken in your calendar over the period for which you ask it to plan. This information is sent to it under the same conditions as the summary above. It only suggests: no session is launched and nothing is added to your calendar without your click. During a fit interview, your answers are messages like any other.
To whom: to the providers of the language models used, acting as processors within the meaning of Article 28 of the GDPR (see Article 11 of this policy).
What we keep on our side: the history of your conversations, so that we can show it to you again from one session to the next; with each answer, a record of what the assistant consulted to write it (which counts, which resources, never their content) and the suggestions displayed below it (session, time slot) with their status; as well as a usage log (timestamp, volume and cost) used to apply quotas and detect automated use.
Model training: we do not allow our providers to use your exchanges to train, fine-tune or evaluate their models.

5.2: Recommended use

We recommend that you do not share with the assistant any confidential information, any data that could identify a third party, or anything covered by a confidentiality undertaking you may have given to an employer or a recruiter.

Legal basis: performance of the contract, as the assistant is one of the features included in the access. You may of course choose not to use it without this affecting the rest of the service.

Article 6: Content protection and detection of abnormal use

Our educational content is the very purpose of the service and represents most of its value. We therefore implement protection measures that involve processing certain data about you. We detail them here for the sake of transparency, as such processing is rarely documented elsewhere.

6.1: Detection of account sharing

Data: for each device from which you log in, a random identifier stored in a cookie in your browser (see Article 14), the browser and operating system type, the dates of first and last use, the number of days of use, as well as the last IP address and the last approximate location (city, country) of the device. This information is updated at most once a day: we do not keep a history of your addresses or of your logins.

Purpose: to identify sets of indicators revealing the use of the same account by several people, in breach of Article 5 of the general terms. The indicator used is the number of devices used over a period of thirty days: a computer and a phone are normal use; a significantly higher number is examined by an administrator, who takes no decision on the basis of this figure alone.

Legal basis: our legitimate interest in enforcing the contract, protecting our intellectual property rights and preserving the economic balance of the service (Art. 6(1)(f)). We have balanced this interest against your rights and consider that the collection, limited to technical data and limited in time, remains proportionate to the objective pursued.

6.2: Screen capture attempts

Data: timestamp of the event and page concerned, when a screen capture or copy attempt is detected in your browser.

No image, no screen content, no keystroke and no element of your working environment is recorded. Only the event itself is, that is, the fact that an attempt took place, when and on which page.

Purpose: to deter infringements of our intellectual property rights and, where appropriate, to provide evidence of them. Legal basis: legitimate interest (Art. 6(1)(f)).

6.3: Rate limiting and protection against abuse

Data: IP address, stored in pseudonymised form in the case of attempts to enter institution codes. Purpose: to prevent repeated login attempts, brute-force attacks on passwords and codes, as well as automated extraction of the content. Legal basis: legitimate interest in the security of the service (Art. 6(1)(f)).

As regards the assistant, we record the rate of your messages and the number of content lookups it performs for you (interview reports, searches in the resources) over the last half hour. A rate persistently beyond any genuine reading produces a flag to the team, never a block: it is examined under the conditions of Article 6.4.

6.4: No fully automated decision-making

The mechanisms described in this article produce flags, never automatic sanctions. Any suspension or termination of an account is examined by a natural person, who assesses the situation in the light of all the information available.

You are therefore not subject to a decision producing legal effects concerning you based solely on automated processing, within the meaning of Article 22 of the GDPR. In any event, you retain the right to contest a measure taken against you and to put forward your point of view.

Article 7: Payment and invoicing

Payments are processed by a payment service provider certified at level 1 of the PCI-DSS standard, the security standard of the payment card industry.

Your bank details are entered directly in an environment belonging to this provider. They never pass through our servers, are never stored there, and our teams never have any physical means of accessing them.

What we keep: a technical identifier linking you to the customer file held by this provider, the history of the access purchased, the corresponding amounts and the expiry date of your access.

Legal basis: performance of the contract for managing your access, and compliance with a legal obligation as regards the retention of accounting records (Art. 6(1)(c)), in accordance with Article L.123-22 of the French Commercial Code.

Article 8: Free resources and direct marketing

Our resource pages give you access to downloadable documents in return for providing your email address.

Data collected: your email address and the page from which the request was made, the latter allowing us to know which resources generate the most interest.
Purpose: to send you the resources requested and, where applicable, to send you communications about our offers and our new content.
Legal basis: your consent (Art. 6(1)(a)), obtained when you enter your address, after you have been informed of how it will be used.
Withdrawal of consent: you can withdraw it at any time, either via the unsubscribe link included in each of our emails, or by writing to us. Withdrawal does not affect the lawfulness of the processing carried out before it.

We never pass these addresses on to third parties for marketing purposes, and we do not include them in any database that is sold.

Article 9: Accounts opened by an institution

Where your access is opened under an agreement concluded between the publisher and a school, a university or an association, that institution may be informed of the link between your account and its licence, of the activation date of that access and of its status.

We do not disclose to the institution the details of your learning activity (neither your answers, nor your scores, nor your mastery indices, nor your personal notes, nor your interview reports), unless otherwise expressly brought to your attention before your access is opened.

Under these agreements, the publisher and the institution contractually determine their respective roles under the GDPR. The institution remains responsible for the processing it carries out on its side, in particular compiling the list of its beneficiary members.

Article 10: Applications to the beta version

During its beta phase, access to the platform is reserved for people selected following an application. The application form is accessible without an account: the data it collects is therefore not linked to any profile until the person creates one.

Data collected: your first and last name, your email address, your phone number, the address of your LinkedIn profile, your institution and your level of study, the position and type of internship you are aiming for, the timeframe you have in mind, the progress of your applications, whether you have done a previous internship, the preparation programmes you have already followed, your motivations, the time you can devote to preparation and your willingness to give us feedback.
Source of your visit: if you arrived via a campaign link, the parameters it contained (source, channel, campaign) as well as the site from which you came to us are recorded on your application. They help us know which channels make OctoFin known. They are read from the address of the page: nothing is stored on or read from your device, and no advertising network is informed of them. The address of the originating site is kept without its parameters, which belong to that site and not to us.
Purpose: to select the beta participants, then to contact you — by email or by phone — about your application, and to send you an activation code if it is accepted. This data is used for nothing else: it does not feed any marketing and is not cross-referenced with any other source. Your phone number in particular is used only for that contact.
A single exception, once your access is activated: if you have not answered the platform’s onboarding questionnaire, two of your answers — the position you are aiming for and the time you can devote to preparation — are used to guide your first sessions and the pace of your calendar (Article 4.4). Nothing else from your application is reused, and your onboarding answers, as soon as you give them, take precedence over them.
Legal basis: the performance of pre-contractual measures taken at your request (Art. 6(1)(b)), the application being the step prior to the provision of the service.
Mandatory nature of the answers: all fields of the form must be completed, including the phone number. An application is used to compare profiles with one another: a missing answer does not merely make yours incomplete, it makes it impossible to compare with the others. Applying is of course entirely voluntary, and not doing so has no consequence.
Recipients: only the authorised staff of the publisher who review the applications. No disclosure to any third party.

If your application is accepted, a single-use activation code is sent to you. We then keep the date on which we recorded it as sent, the date on which it was used, the account that used it and the version of the consent text in force at that time — the latter so that we can establish, if necessary, exactly what you consented to.

The first of these dates is only an internal note: the code is handed over manually, and the date serves only to ensure that we do not forget to send a code to someone whose application has been accepted. It does not concern any action on your part and has no effect either on the validity of the code or on your access.

To be completed by the publisher: the retention period stated in Article 13 for unsuccessful applications must be confirmed after legal review.

Article 11: Recipients and processors

Your data is accessible only to the authorised staff of the publisher, strictly within the limits of their duties and according to a principle of least privilege, and to the processors listed below. Each of them is bound by a contract compliant with Article 28 of the GDPR, processes the data only on documented instructions from the publisher and provides sufficient guarantees in terms of security.

Application hosting: making the service available on the internet and running the platform’s code.
Database, authentication and file storage: storage of all the service’s data and management of authenticated sessions.
Payment service provider: processing of transactions and storage of payment methods.
Language model providers: generation of the conversational assistant’s answers (see Article 5).
Email delivery service: sending transactional messages, the notifications you have turned on (Article 4.9) and, where applicable, the communications to which you have consented.
Audience measurement of the public site: counting page views and traffic sources on the pages accessible without an account. This measurement is provided by our host, without anything being stored on your device (see Article 14).
Product usage measurement: counting the steps completed in the access journey and in the platform, in order to know what is useful and where people get stuck. The records are sent by our servers, carry only an internal identifier and store nothing on your device. The processor hosts this data in the European Union (see Articles 12 and 14).
Detailed measurement and session recording of the public pages: only if you consent, a record of the pages viewed and of the clicks on the pages accessible without an account, and a recording of your browsing on the home page and on the application form. This recording reproduces the page as it is displayed — its content is ours and identical for everyone — as well as your gestures. What you type in a field is masked at source, on your device, before anything is sent: on the form, we see which field you stop at, never what you write in it. The processor is the same as for usage measurement and hosts this data in the European Union (see Article 14).

Our processors may themselves use further processors, subject to our authorisation and to the same level of obligations being maintained. Apart from the cases listed above, your data is disclosed to third parties only at the request of an authorised judicial or administrative authority, and within the limits of that request.

Article 12: Transfers outside the European Union

Some of our processors, in particular the language model providers, may process data outside the European Union. Where such transfers take place, they are governed by the appropriate safeguards provided for in Chapter V of the GDPR: an adequacy decision of the European Commission recognising a substantially equivalent level of protection, or standard contractual clauses adopted by the Commission, supplemented where necessary by additional measures.

You can obtain a copy of the safeguards in place by requesting it from us.

Article 13: Retention periods

We keep your data only for as long as is necessary for the purposes for which it was collected, plus, where applicable, the periods required by law.

Account and learning progress: for the entire life of the account, then erased when it is deleted.
Anonymous system measurement counters (Article 14): kept as statistics. They contain no personal data — no identifier, no time, no text — and cannot be linked to anyone; deleting an account therefore has nothing to erase from them.
Login devices (Article 6.1): erased twelve (12) months after their last use, by a daily scheduled task.
Record of capture attempts (Article 6.2): twelve (12) months.
Notifications and tracking (Article 4.9): your preferences, the items you track and the date of your last visit, for the life of the account; an item you remove is erased immediately. The log of notifications sent is erased after ninety (90) days, by a daily scheduled task.
Technical error reports (Article 4.8): the retention period of the operations logs applied by our host. We keep no copy of them in our database.
Conversations with the assistant: for the life of the account, erased when it is deleted.
Addresses collected on resource pages: three (3) years from your last contact with us, in accordance with the CNIL’s recommendation on direct marketing.
Unsuccessful beta applications (Article 10): twelve (12) months from their submission, then automatic erasure. An accepted application is kept for as long as the account it allowed to be opened exists.
Activation codes: for as long as the account to which they gave access exists. The record of their use attests to the origin of the access.
Messages sent to support: three (3) years from the closure of the request, so that an exchange can be traced in the event of a subsequent complaint.
Accounting records relating to purchases: ten (10) years, pursuant to Article L.123-22 of the French Commercial Code. This legal obligation survives the deletion of the account: the data concerned is then isolated and used only to meet this obligation.

Article 14: Cookies and trackers

By default, no measurement tracker is placed on your device: not on the home page, not on the application form, not on the login or legal information pages. Until you have responded to the banner described below — and forever if you refuse — you can browse these pages entirely without any measurement tracker being written. Your refusal is stored so that we do not ask you the question again on every page, and that is the only trace it leaves.

Cookies appear once you are logged in, and only those that are strictly necessary for the operation of the service: keeping your session from one page to the next, remembering display preferences you have set yourself (collapsed sidebar, display of calendar suggestions, view chosen for the dashboard’s readiness card, postponement of the diagnostic prompt), carrying over a referral code during a login via a third-party service, protection against certain attacks, and a device identifier used for the security of your account: it makes it possible to count the devices from which the account is used (Article 6.1). This identifier is a randomly drawn number, unrelated to your identity or to your device itself, and it is read only by us. It is valid for thirteen months.

The notification settings window (Article 4.9): the page concerned keeps, in your browser’s local storage, a simple record that it has already been shown to you, so as not to show it to you again on every visit. It contains no identifier, does not leave your device and disappears if you clear the site’s data.

These cookies are exempt from prior consent pursuant to point 2° of paragraph II of Article 82 of the French Data Protection Act (loi Informatique et Libertés), which exempts trackers whose sole purpose is to enable or facilitate communication by electronic means, or which are strictly necessary for the provision of a service expressly requested.

The application form draft. This form is long. So that your answers do not disappear if you reload the page, go back, or leave the tab for a moment — to fetch the address of your profile, for example —, what you type in it is saved as you write, in the tab’s memory.

It never leaves your device until you have clicked “Submit my application”. No one other than the page itself reads it, it contains no identifier, and it is not used for any measurement.
It disappears with the tab, and we erase it as soon as your application is saved. It survives neither the closing of the tab nor a restart of the browser: once the tab is closed, there is nothing left to find, including on a shared computer. If you prefer to leave nothing, simply close it.
It is exempt from consent, in the same way as the cookies above and pursuant to the same provision: it is a tracker strictly necessary for the provision of a service you have expressly requested — submitting an application —, in the same way that an online shop keeps what you have put in your basket.

Audience measurement of the public site. We count page views and traffic sources on the pages accessible without an account only, in order to know what is read and where our visitors come from. This measurement writes nothing to and reads nothing from your device — no cookie, no local or session storage. It therefore does not fall under Article 82, and no consent is required.

What is recorded: the page viewed, any campaign parameters in the address, the site you came from, your country, your browser and the type of device. Added to this are display performance measurements, and a few markers of use of the home page — a button clicked, a question in the FAQ opened.
What is not recorded: no identifier that would follow you from one visit to the next, no profile, no cross-referencing with your account. The addresses transmitted are reduced to the path of the page and to the campaign parameters; everything else is removed from them before sending. The product pages, once you are logged in, are not measured in this way — with one exception, display performance: loading times are recorded on all pages, product included, because that is where slowness would cost the most. This record contains only the path of the page — no parameter, no fragment of the address, no identifier — and stores nothing on your device.
Legal basis: our legitimate interest in knowing the audience of our site (Art. 6(1)(f)). You may object to it at any time, under the conditions of Article 17.

Product usage measurement. We also count the steps completed in the access journey and in the platform, in order to know what is useful and where people get stuck. These records are sent by our servers, not by your browser: they write nothing to and read nothing from your device, and therefore fall no more under Article 82 than the audience measurement above.

What is counted: the submission of a beta application and its outcome, the activation of an access, the completion of the setup journey, the lessons opened and completed, the training sessions started and completed — with their duration and their overall result —, the filters used on a page, the clicks to an external site and the items you mark in your tracking tools. These are facts and totals: none of your answers, no question wording, no content you have written is transmitted.
How you are designated: by an internal identifier, that of your account in our database, which does not designate you anywhere else. Neither your name, nor your email address, nor your institution is transmitted. And as long as no account exists — at the application stage — no profile is created with our processor: only the fact is counted.
What happens if you activate an access: the steps of your application already counted — its submission, its acceptance, and the labels that accompany them (level of study, target position, originating campaign) — are then linked to the internal identifier of your account. This is what allows us to know how many accepted applicants actually become users. No data identifying you by name is transmitted on this occasion: only two internal identifiers are linked. As long as you do not activate an access, your application is not linked to any profile, and it never will be if you do not join.
Legal basis: our legitimate interest in improving the service (Art. 6(1)(f)). You may object to it at any time, under the conditions of Article 17.

Measurement of the smart systems. To find out whether the calendar, training and the assistant keep their promises, our servers also keep anonymous daily counters, in our own database. Like usage measurement, they write nothing to and read nothing from your device.

What is counted: the calendar and training suggestions offered, seen, accepted, postponed, declined — with the reason for the refusal — and completed; the sessions launched and completed, according to where they were started from; the assistant’s tools used and the time slots added from it; the steps completed in the weekly check-in; the views of the readiness score.
In what form: a total per day, per event and per category — “on 25 September, 14 sessions launched from the calendar”. No identifier, no time, no text: the database refuses to record anything other than a word drawn from a closed list and a number. A counter therefore never says who, nor when during the day.
Legal basis: our legitimate interest in checking that the service keeps its promises (Art. 6(1)(f)). The team’s accounts are not included.

Detailed measurement and session recording — subject to your consent. The measurements described above tell us how many and what, never why someone gives up. To understand this, we ask your permission to record your browsing on the public pages in more detail, and to record your gestures on the home page and on the application form. A banner asks you the question, and nothing is stored or sent before you have accepted.

What is recorded if you accept: the pages viewed, the elements you click on and the places where you click in vain, where you came from, your country, your browser and your device. Added to this, on the home page and on the application form only, is a recording of your browsing.
What the recording contains — and what it does not: it reproduces the page as it is displayed and your gestures on it — pointer movements, clicks, scrolling, hesitations. The visible content of these pages is ours: it is the same for every visitor and says nothing about you. On the other hand, everything you type in a field is replaced with neutral characters on your device, before anything at all is sent: the input field remains visible, its content never leaves your browser. Network requests, headers and the console are not captured.
Why the application form is recorded, and what this changes for you: it has twenty fields over three screens, and we do not currently know where the people who give up stopped — they leave us no data, so we learn nothing from their abandonment. The recording shows us which field you stopped at, never what you had written in it: your name, your address, your phone number and your answers are masked before leaving your device, even if you never send the form.
Where it stops: no product page, once you are logged in, is measured or recorded in this way — not the lessons, not the training sessions, not the interview reports. The password reset page is excluded too. Two independent mechanisms prevent it, and both would have to fail for a single image of it to get out.
How long: session recordings are erased after thirty days. The cookie that keeps your choice is valid for one year, after which you are asked the question again.
Legal basis: your consent (Art. 6(1)(a) GDPR and Art. 82 of the French Data Protection Act). You can withdraw it at any time, as easily as you gave it, from the link at the bottom of this page. Withdrawal takes effect immediately: capture stops on the open page and the trackers placed are erased, without waiting for a reload.

We use no advertising cookies, no social network trackers and no advertising pixels. No browsing data is passed on to an advertising network or to a social network, and we do not build any profile intended to send you advertising. The only trackers subject to consent are those described just above; they concern only the public pages, and nothing is placed before you agree.

Article 15: Data security

We implement technical and organisational measures appropriate to the risk, in accordance with Article 32 of the GDPR. Without disclosing their details, which would weaken their effectiveness, these measures include in particular:

systematic encryption of exchanges between your browser and our servers, with the strict transport security mechanism enabled;
access partitioning applied at the level of the database itself, so that a query can only ever return the data to which its author is entitled;
storage of passwords in the form of salted hashes, calculated by an algorithm dedicated to this purpose;
a password policy imposing a minimum length and rejecting passwords that appear in compromised corpora;
limiting the number of login attempts and of requests, in order to contain automated attacks;
logging of administrative access and strict limitation of permissions;
separation of environments and regular review of the code against the applicable security standards.

Article 16: Data breaches

As no information system is infallible, we have defined a procedure for handling data breaches. In the event of a breach likely to result in a risk to your rights and freedoms, we will notify it to the CNIL without undue delay and, where feasible, within seventy-two (72) hours of becoming aware of it, in accordance with Article 33 of the GDPR.

Where the breach is likely to result in a high risk to your rights and freedoms, we will also inform you of it without undue delay, in clear terms, in accordance with Article 34 of the GDPR: the nature of the breach, its likely consequences, the measures taken and recommendations to mitigate its effects.

Article 17: Your rights and how to exercise them

You have the following rights over the data concerning you, under the conditions and within the limits provided for by the GDPR.

Right of access: to obtain confirmation that data concerning you is being processed and, where applicable, to receive a copy of it.
Right to rectification: to have inaccurate data corrected or incomplete data completed.
Right to erasure: to obtain the deletion of your data, subject to the legal retention obligations mentioned in Article 13.
Right to restriction of processing: to obtain the temporary freezing of a processing operation, in particular while we verify the accuracy of disputed data.
Right to data portability: to receive, in a structured, commonly used and machine-readable format, the data you have provided to us.
Right to object: to object, on grounds relating to your particular situation, to processing based on our legitimate interest, in particular the processing described in Article 6.
Right to withdraw your consent: at any time, for the processing that depends on it, without this withdrawal affecting the lawfulness of what was done before.

17.1: How to exercise them

Some of these rights can be exercised directly from your personal area: there you can modify your information, view your progress and permanently delete your account without having to ask us.

For any other request, write to us at support@octofin.io. We will reply within one month of receiving your request; this period may be extended by two months in the case of a complex request or a large number of requests, in which case we will let you know. If we have reasonable doubts about your identity, we may ask you to prove it.

17.2: Complaint to the supervisory authority

If, after contacting us, you consider that your rights have not been respected, you can lodge a complaint with the Commission nationale de l’informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, or online at cnil.fr. You can also lodge a complaint with the supervisory authority of the Member State in which you reside.

Article 18: Minors

The service is intended for students, most of whom are adults. In accordance with Article 45 of the French Data Protection Act, a minor under the age of fifteen (15) cannot consent alone to the processing of their personal data: registration then requires the joint consent of the minor and of the holder of parental authority.

Should it appear that an account has been created by a minor under the age of fifteen without this consent, we would delete it and erase the associated data as soon as possible after being informed of it.

Article 19: What happens to your data after your death

In accordance with Article 85 of the French Data Protection Act, you can set out instructions regarding the retention, erasure and communication of your data after your death. These instructions may be general, lodged with a certified trusted third party, or specific, by sending them directly to us.

In the absence of instructions, your heirs may ask us to close your account and erase your data, upon proof of their status.

Article 20: Changes to this policy

We may change this policy, in particular to take account of new processing, a change of provider or a change in the legal framework. The date of the last update appears at the top of the page.

In the event of a substantial change (new purpose, new recipient, new legal basis), we will inform you of it by any appropriate means before it comes into force, and obtain your consent where it is required.

View the General Terms of Use →Home