Privacy Policy -

P.AI.R Privacy Policy

Welcome to P.AI.R!

We value your Privacy

This notice describes what information we collect, how we use it, and, if necessary, those with whom we share it.

By visiting pair.nrf.digital and enrolling in P.AI.R program, you are accepting the practices described in this Privacy Policy. Your use of the website and courses is also subject to our Terms and Conditions of Use.

This Privacy Policy enters into effect as of 20 May 2025.

This Privacy Policy may change from time to time. Your continued use of our website and the services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
This Privacy Policy is GDPR–compliant(EU regulation), and as such also in accordance withThe California Online Privacy Protection Act (CalOPPA – U.S regulation).

1. General Information

The personal data of the users that are collected and processed through the website:
pair.nrf.digital
Data processing will be under the responsibility and in charge of:
Nathalie RAMANANTSOA-FRAT
Contact: admin@nrf.digital
Mailing address:
P.AI.R (CATALYST Consulting)
11 rue Voltaire
93170 Bagnolet
France

2. Types of Information Gathered

The information we learn from customers helps personalise and continually improve your experience at pair.nrf.digital. Here are the types of information we gather:
Information You Give Us:
You provide information when you search, read and watch the content, purchase a service or communicate with us. As a result of those actions, you might supply us with the following information:

First and last name
Email address
Postal address
Phone number (includes WhatsApp)
IP address
Payment information
Any additional information relating to you that you provide to us directly through our websites or indirectly through our websites or online presence such as ‘cookies’.

P.AI.R will not collect any personally identifiable information about you, unless you consent and provide it.

Payment information:

Your credit card and debit card information or payment information will be processed by the Stripe payment platform, which will treat and safeguard your data with total security and for the exclusive purpose of processing the purchase of the services.
Please consult Stripe privacy policy here: https://stripe.com/gb/privacy.

P.AI.R reserves the right to contract any payment platform available in the market, which will treat your data for the exclusive purpose of processing the purchase of the services.

Google Analytics:

We use Google Analytics provided by Google, Inc., USA (“Google”). These tool and technologies collect and analyse certain types of information, including IP addresses, device and software identifiers, referring and exit URLs, feature use metrics and statistics, usage and purchase history, media access control address (MAC Address), mobile unique device identifiers, and other similar information via the use of cookies. The information generated by Google Analytics (including your IP address) may be transmitted to and stored by Google on servers in the United States. We use the Google Analytics collection of data to enhance the website and platform and improve our service.

Automatic Information:

Like many websites, we use “cookies.” We obtain certain types of anonymous information, which is not personally identifiable, when your web browser accesses P.AI.R or third-party content served by or on behalf of P.AI.R on other websites. Some of the information we collect and analyse includes the Internet Protocol (IP) address; computer and connection information such as browser type, version, and connection speed; purchase history; and the content you searched for, viewed, and possibly purchased. For more information on how we use cookies and your control options, please refer to our full Cookies Policy.

3. How We Store Your Data and How Long We Keep Your Data

Our Website is hosted on Infomaniak Ethical Cloud.
Their data centres are all Switzerland-based.

We retain personal data as long as necessary to provide services, comply with legal obligations, resolve disputes, and enforce agreements.
Data related to billing is retained for up to 10 years in line with French tax requirements.
Your personal data will be kept for the time necessary for the provision of the services or until the user withdraws his consent.
The user’s personal data will be deleted from our database immediately after the user withdraws his consent.

4. How We Use your Information

In general, we primarily use the information we collect to provide, maintain, protect and improve our current website and services and develop new services. We use personal information collected through our site as described below and described elsewhere in this Policy to:

Identify you as a user in our system.
Provide the services (Course Creation, Workshop Creation and Assessment -Time Audit, AI Readiness, …).
Process payment for services.
Improve our services, website, and how we operate our business.
Understand and enhance your experience using our website and services.
Send emails through bulk email delivery platforms.
Communicate with you and answer your questions and comments through our support team.
Send you related information, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages.
Communicate with you about upcoming events and news about products and services offered by P.AI.R and our selected partners.
Marketing purposes of P.AI.R.
Link or combine your information with other information we get from third parties to help understand your needs and provide you with better service.
Protect, investigate and deter against fraudulent, unauthorised or illegal activity.

Overview of P.AI.R Data Processing Patterns and Legal Basis:

P.AI.R processes personal data in strict compliance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.
Every instance of personal data processing is grounded in a clearly identified legal basis, as required by Article 6 of the GDPR.
The principal legal bases upon which P.AI.R relies include:

Basis

Purpose

Comments

Consent

Where required, we request your explicit, informed, and freely given consent before processing your personal data for specific purposes, such as for marketing communications or analytics tracking.

Your onsent is always revocable, can withdraw your consent at any time without detriment by emailing us at: admin@nrf.digital

Contractual Necessity

We process your personal data when it is necessary to perform P.AI.R services, or to take steps your request prior to entering into a contract.

For example, processing is required to enroll participants in the P.AI.R program and deliver course content and services

Legal Obligation

In certain cases, such as maintaining records for tax or regulatory purposes

Legitimate Interest

These interests may include improving our services, ensuring the security of our platform, and conducting analytics to enhance user experience.

In such cases, a careful balancing test is conducted to ensure that individuals’ rights are respected

For each processing activity, P.AI.R identifies and documents the appropriate legal basis, and this information is made available to you here.
Where the processing purpose changes, we will reassess the legal basis and, if necessary, seek renewed consent or establish a new lawful ground for processing.

5. How Do You Get My Consent?

P.AI.R is an opt-in service. By purchasing a service and providing us with your personal information to communicate with you, you agree that we collect and use your information. You can withdraw your consent by contacting us through the contact information or the contact page, or directly by emailing: admin@nrf.digital.

6. How We Share Information

Information about our customers is an important part of our business, and we are not in the business of selling it to others. We share customer information only as described below.

With Third-Party Service Providers:

We employ other companies and individuals to perform functions on our behalf. Examples include process payments (Stripe), sending email, analysing data, providing bespoke apps, providing search results and links.
They have access to your personal information needed to perform their functions, but may not use it for other purposes.
P.AI.R primarily processes and stores personal data within the European Economic Area (EEA). However, certain services—such as web analytics provided by Google Analytics—may involve the transfer of personal data to countries outside the EEA.
Indeed, anonymised analytics information processed by Google, may be transferred to and stored in the United States. We rely on Standard Contractual Clauses approved by the European Commission for these transfers.
All our international data transfers are conducted following Chapter V of the GDPR, which requires that any transfer of personal data to a third country or international organisation ensures an adequate level of data protection. P.AI.R ensures that such transfers are compliant with the latest adequacy decisions and that users are informed and, where required, have provided consent for analytics cookies and data processing

P.AI.R never mails its customer database on behalf of a third party.

In Protection of P.AI.R and others:

We release personal information only when we believe release is appropriate to comply with the law, enforce or apply our Terms and Conditions of Use and other agreements, or protect the rights, property, or safety of P.AI.R stakeholders, our users or others. This includes exchanging information for fraud protection and credit risk reduction with other companies and organisations.

With Your Consent:

Other than as set out above, you will receive notice when personally identifiable information about you might be shared with third parties and have an opportunity to choose not to share the information.

Anonymous Information:

P.AI.R primarily uses the anonymous browsing information collected automatically by our servers to help us administer and improve the learning management platform and Our Website. We may also use aggregated anonymous information to provide information about Our Website to potential business partners and other unaffiliated entities.
This information is not personally identifiable.

Email Address:

The email address that you supply to us for the purpose of receiving our email communications will never be rented or sold to a third party.

7. Protecting Your Information

P.AI.R Team implements all necessary measures to prevent access to, alteration of, or disclosure of your personal information.
Audit systems are in place for all sensitive elements.
This information is treated with the utmost confidentiality and is not sold or distributed. Under no circumstances is it communicated to anyone who requests it, except by court order or formal complaint from a third party.
P.AI.R follows generally accepted industry standards to protect the personal information submitted to us, both during transmission and once pair.nrf.digital receives it.
We protect your information’s security during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. If transactions are processed on Our Website, transaction information is transmitted to and from Our Website in encrypted form using industry-standard SSL connections to help protect such information from interception. We restrict authorised access to your personal information to those who have a legitimate purpose to know that information to provide products or services to you and those you have authorised to have access to such information.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while P.AI.R team strives to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
Last, we will not sell, distribute, or lease your personal information to third parties.

8. Your Rights

You have the following rights in relation to your personal data provided to P.AI.R:

Access your personal data
Request the correction of inaccurate data
Request its deletion
Request a limitation on the processing of your data
Oppose the treatment of your data
Request your portability
Not be subject to automated individual decisions

The Users can exercise all these rights by contacting us through the contact information or the contact page and indicating the reason for their request. We aim to respond to all requests within one month of receipt, per GDPR Article 12. You may be asked to verify your identity before your request is processed. Without preconception to any other administrative appeal or legal action, the User shall have the right to submit a claim to a Control Authority. If you consider that processing your personal data is inappropriate under the regulations, or if you do not see the exercise of your rights satisfied, the control authority in which the claim was filed will inform the claimant about the course and result of the claim.

EU Members’ Rights: GDPR Compliance :

If you are habitually located in the European Union, you have the right to access, rectify, download or erase your information, and the right to restrict and object to certain processing of your information.
While some of these rights apply generally, certain rights apply only in certain limited circumstances.
We describe these rights below:

Access and Porting: You can access your information at any time.
Rectify, Restrict, Limit, Delete: You can also rectify, restrict, limit or delete much of your information by contacting us at admin@nrf.digital.
Object: Where we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.
Revoke consent: Where you have previously provided your consent, you have the right to withdraw your consent to continue processing your information at any time. For example, you can withdraw your consent by updating your settings. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis or if your withdrawal of consent was limited to certain processing activities.
Complain: Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

Additionally, if you are a European resident, note that we are processing your information to fulfil contracts we might have with you or to pursue our legitimate business interests listed above.
You can see more about these rights at:
https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en
Additionally, please note that your information will be stored at our cloud provider Infomaniak, in their data centres in Switzerland.

Children’s Online Privacy Protection :

We comply with the requirements of the GDPR (General Data Protection Regulation), and the California Online Privacy Protection Act (CalOPPA) regarding the protection of the personal data of minors.
Note that Our Website, platform and services are all directed to senior executives and business owners. Access to P.AI.R Program is subject to a formal 1:1 interview and recruitment process, thus ensuring that we do not onboard underage participants.
We do not collect any information from anyone under 13 years of age.

9. Editing and Deleting Information

If you believe any information we hold about you is incorrect or incomplete, please write to or email us as soon as possible at admin@nrf.digital. We will promptly correct any information found to be incorrect.
You can change, modify, rectify, and delete your Information at any time; please contact us through the contact information or at admin@nrf.digital.
To opt out of the P.AI.R email list, follow the instructions included in our emails. Your request should be processed within 48 hours.

10. Suppliers and Other Third Parties

Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of information pair.nrf.digital collects from you. If you disclose your information to others, whether other users or suppliers in P.AI.R, different rules may apply to their use or disclosure of the information you share with them. P.AI.R team does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.
P.AI.R team is not responsible for the privacy or security practices of other websites on the Internet, even those linked to or from the pair.nrf.digital website. P.AI.R team encourages you to ask questions before you disclose your personal information to others

11. Changes to This Privacy Policy

The P.AI.R team will post modifications to this Privacy Policy by date to inform you of any changes. Any modification will also be shared within the P.AI.R community. The P.AI.R Team reserves the right to modify this Privacy Policy at any time; please review it frequently.

12. Enforcement

We regularly review pair.nrf.digital compliance with this Policy and regulatory requirements updates. Please feel free to direct any questions or concerns regarding this Policy or P.AI.R treatment of personal information by contacting us at admin@nrf.digital. When we receive formal written complaints, our policy is to contact the complaining user regarding their concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between P.AI.R and an individual.

13. Related Documents

This Legal Notice should be read in conjunction with our:
Terms and Conditions https://pair.nrf.digital/program-agreement/
Privacy Policy https://pair.nrf.digital/program-agreement/
Legal Notice https://pair.nrf.digital/program-agreement/
Program Agreement https://pair.nrf.digital/program-agreement/

P.AI.R Privacy Policy (V1.0)
This Privacy Policy was last updated on 20 May 2025 and is effective as of that date.

14. Contact Us

If you have questions or concerns about this Cookies Policy and the handling and security of your data on this site, please get in touch with us through our contact page or contact at: admin@nrf.digital