Last updated 2026-10-18Published by INEYA Studio
Privacy policy
This policy describes what personal data LOKAL processes, why, on what legal basis, who receives it, how long it is kept and what you can require of us. It describes what the service actually does; it is not a template.
1. Who is responsible
INEYA Studio, 36 rue de Wattignies, 75012 Paris, France, is the data controller. Write to hello@ineya.studio for anything in this policy, including to exercise your rights.
2. What we collect, and why
| Data | Why | Legal basis | Kept |
|---|---|---|---|
| Email address, plus the market you were looking at, the page that referred you and your language, when you join the waiting list | To tell you when LOKAL covers your market | Your consent | Until you unsubscribe, and at most 3 years without any interaction |
| Email address, licence key, plan, market, and the Stripe customer and subscription identifiers, when you subscribe | To open your access, keep it working and support you | Performance of the contract | 3 years after the end of the subscription |
| Billing details and payment method | To take payment | Performance of the contract, and legal obligation for invoices | Held by Stripe. Invoices kept 10 years, as French commercial law requires |
| Where you came from: the campaign tags (utm_source, utm_medium, utm_campaign, utm_content, utm_term) and the ad click identifier (fbclid, ttclid, gclid) in the link you followed, saved with your waiting-list entry | To know which campaigns bring subscribers, and to tell the ad platform you came from that its ad worked (section 5) | Our legitimate interest in measuring our own advertising. You can object at any time, and Global Privacy Control or Do Not Track switches it off automatically | As long as your waiting-list entry |
| The same campaign tags and click identifier, attached to your Stripe checkout session as metadata | To know which campaign a subscription came from | Our legitimate interest in measuring our own advertising | Held by Stripe with the payment record |
| Your IP address and browser (user agent) when you open checkout | To report the subscription to the ad platform you came from, which needs them to match the ad click | Our legitimate interest in measuring our own advertising | 45 days, then deleted |
| Pages viewed, without cookies and without any cross-site identifier | To know which pages are useful | Our legitimate interest in measuring our own audience, with no profiling | 25 months |
| Server logs: IP address, time, page, error | Security, abuse prevention, diagnosing failures | Our legitimate interest in keeping the service up | 12 months |
We do not ask for, and have no use for, anything about your clients. Market updates are generated from public market data, not from your contacts. Do not send us client files.
3. Cookies and measurement
LOKAL sets no cookie and runs no advertising pixel in your browser. Audience measurement runs on our own server in France, stores no cookie, builds no profile, and honours the Do Not Track and Global Privacy Control signals: if your browser sends either, nothing is recorded at all.
We use your browser's local storage, never to follow you to other sites, for: your licence key and the address it belongs to, so you stay signed in; the last market you opened and your edits to the generator; a note that you joined the waiting list; and lokal.attr, which holds the campaign tags and ad click identifier of the link you arrived by, for 28 days, so that they reach us with the form you submit. lokal.attr is not written at all when your browser sends Global Privacy Control or Do Not Track, and an existing one is erased. You can clear all of it from your browser settings at any time.
4. Automated decisions
There are none. Nothing on LOKAL profiles you or makes a decision about you automatically.
5. Who else receives data
| Processor | Role | What it gets | Transfer safeguard |
|---|---|---|---|
| Stripe Payments Europe, Ltd. (Ireland) and Stripe, Inc. (United States) | payment and subscription management | your email address, billing details and payment method, which you enter on Stripe's own hosted page | Standard Contractual Clauses for the transfer to the United States |
| OVH SAS (France) | hosting | everything stored by the service, on servers in the European Union | no transfer outside the EU |
| INEYA Studio (self-hosted, France) | cookieless audience measurement (DealTrail) | page views without cookies and without cross-site identifiers, respecting Do Not Track | no transfer outside the EU |
| Meta Platforms Ireland Ltd. (Ireland) and Meta Platforms, Inc. (United States) | measuring our Facebook and Instagram ads (Conversions API, sent from our server) | only if you arrived by clicking one of our Meta ads, and only when you join the waiting list, start checkout or subscribe: your email address hashed with SHA-256, your IP address, your browser (user agent) and the ad click identifier (fbclid) | transfer outside the EU, under Standard Contractual Clauses |
| TikTok Technology Limited (Ireland) and its group companies | measuring our TikTok ads (Events API, sent from our server) | only if you arrived by clicking one of our TikTok ads, and only when you join the waiting list, start checkout or subscribe: your email address hashed with SHA-256, your IP address, your browser (user agent) and the ad click identifier (ttclid) | transfer outside the EU, under Standard Contractual Clauses |
That is the complete list. We do not sell personal data and we do not pass it to data brokers. If a legal request compels disclosure, we comply only to the extent required and, unless legally barred, we tell you.
Meta and TikTok only receive anything when you arrived by clicking one of their ads, and only the four items listed above. They use it to measure our ads and may use it to improve how ads are shown, under their own privacy policies. US state privacy laws, such as California's CCPA, call this "sharing" personal information for cross-context behavioural advertising. You can opt out in two ways: turn on Global Privacy Control or Do Not Track in your browser, which we honour automatically (nothing is sent, and the campaign tags and click identifier are not stored), or write to hello@ineya.studio with the subject "Do not share my personal information".
6. Where the data lives
Everything LOKAL stores itself is on servers in the European Union, at OVH SAS. The exceptions are payment data, handled by Stripe, and the ad measurement data sent to Meta or TikTok when you came from one of their ads, both under the safeguards listed above.
7. Security
Traffic is encrypted in transit. Payment pages are hosted by Stripe and we never see a card number. Access to the production database is restricted to the publisher, and it is backed up with the restore itself verified, not merely the backup job.
8. Your rights
You can require access to your data, correction, erasure, restriction, portability, and you can object to processing based on legitimate interest. Where processing rests on consent, you can withdraw it at any time without affecting what was lawful before. Write to hello@ineya.studio; we answer within one month. If you are unhappy with the answer, you can complain to the French supervisory authority, the CNIL (cnil.fr), or to the authority where you live.
If you are a resident of California or another US state with an equivalent law, the same rights apply to you, exercised the same way, and we do not discriminate against you for using them. We do not sell your personal information. We share it, as those laws define the word, only in the case described in section 5, and you can opt out as described there.
9. Children
LOKAL is a professional tool and is not directed to anyone under 16. We do not knowingly collect their data.
10. Changes
If this policy changes materially, subscribers are told by email before the change takes effect. The date at the top of this page always reflects the version in force.
Questions about anything on this page: hello@ineya.studio.