Last updated: 22/04/2026

This policy covers the entire eCONCEPT SYSTEM ecosystem:

1. Data Controller

eCONCEPT SYSTEM (Jean BERENGUIER, sole trader)
Quartier la Croix, 97226 Morne-Vert, Martinique, France
SIRET: 887 842 979 00015
Email: admin@econcept-system.fr

As a French-registered business, eCONCEPT SYSTEM is subject to the EU General Data Protection Regulation (GDPR) and the French Data Protection Act (Loi Informatique et Libertés). The lead supervisory authority is the French CNIL.

2. Data collected on the corporate website (econcept-system.fr)

The corporate website is an information site with no contact form and no user account. No personal data is directly collected by the site.

2.1 Integrated third-party services

ServicePurposeData collectedLegal basis
Google FontsFont displayIP addressLegitimate interest
Google MapsDisplay of buildings mapIP address, browser identifier, cookiesConsent
Google reCAPTCHAAnti-spam protectionIP address, browsing behaviourLegitimate interest
LinkedIn Insight TagProfessional audience measurementIP address, cookiesConsent

2.2 Server logs

The hosting provider IONOS retains access logs (IP address, date, URL visited) for a period of 12 months for security and diagnostic purposes. These logs are retained under the hosting provider's responsibility.

3. Data collected on the myec2s applications

The myec2s applications are professional tools accessible via authentication. They rely on two distinct and decoupled data domains:

3.1 User accounts domain

Three user profiles are distinguished:

Data collected for each account:

ProfileData collected
Managing agentCompany name, SIRET, postal address, email, phone, password (hashed)
ResidentSurname, first name, email, password (hashed), flat number
eCS administratorSurname, first name, email, password (hashed)

Legal basis: performance of the CLEM contract (managing agent); mandate entrusted by the managing agent to the resident for the management of their flat's access means.

3.2 Access-control domain

This domain manages only the physical means allowing gates, pedestrian gates, doors and barriers to be opened in buildings.

Pivot identifier: the flat number. No data in this domain is linked to an identified individual.

Data processed:

Entry-history retention period: rolling 6 months. After this period, records are automatically deleted.

Legal basis: legitimate interest (building security, management of access incidents), in accordance with CNIL guidelines on residential access-control systems.

3.3 Articulation between the two domains

When a resident logs in to their personal area to declare a number plate or consult their entry history:

  1. The application reads the flat number associated with their account (accounts domain)
  2. It queries the access-control domain using this flat number
  3. The data returned (number plates, badges, entries) contains no nominative reference

This decoupling ensures that the access-control database never contains a name or personal identifier. Only the temporary software join, performed in memory at query time, allows a resident to access information relating to their flat.

3.4 IoT telemetry data

The management controllers installed in buildings report technical data (motor state, opening cycles, power-supply voltages, detected faults). This data contains no personally identifying information and is used for predictive maintenance and support.

4. Data access rights

Profile Their account Attached flat(s) Whole building eCS ecosystem
Resident Read + modify Read + manage access means of their flat No No
Managing agent Read + modify Read all flats in their buildings Yes (their buildings) No
eCS administrator Read + modify Upon formalised and traced support request Upon support request Yes (technical operation)

5. Cookies and trackers

5.1 Corporate website cookies

NamePurposeDurationType
ecs_cookie_consentStoring cookie preferences6 monthsNecessary

5.2 myec2s application cookies

NamePurposeDurationType
ecs_auth_tokenAuthenticated JWT sessionSessionNecessary
ecs_refresh_tokenSession persistence7 daysNecessary

5.3 Third-party cookies (corporate website)

Third-party services listed in section 2.1 may set their own cookies. Audience measurement and marketing cookies are only set after your consent via the cookie management banner.

6. Retention periods

DataDuration
Cookie preferences6 months
Server logs (IONOS)12 months
myec2s user accountsContract duration + 3 years
Active number plates and badgesFlat allocation duration
Entry historyRolling 6 months
IoT telemetry data24 months

7. Data recipients

The data collected is not sold, rented or exchanged with third parties for commercial purposes. It may be transmitted to the following processors:

8. Transfers outside the European Union

Certain third-party services (Google, LinkedIn) may transfer data to countries outside the EU, governed by the Data Privacy Framework (EU-US, July 2023) or Standard Contractual Clauses approved by the European Commission.

Data processed by the myec2s applications (hosted by IONOS in France) is subject to no transfer outside the EU.

9. Your rights

In accordance with the GDPR and the French Data Protection Act, you have the following rights:

To exercise these rights: admin@econcept-system.fr
Response within one month (possibly extended by two months for complex requests).

10. Lodging a complaint with the supervisory authority

As eCONCEPT SYSTEM is established in France, the lead supervisory authority is the French CNIL:

Commission Nationale de l'Informatique et des Libertés (CNIL)
3 place de Fontenoy — TSA 80715 — 75334 Paris Cedex 07, France
Phone: +33 (0)1 53 73 22 22
https://www.cnil.fr/en/home

UK-based users may also lodge a complaint with the UK Information Commissioner's Office (ICO): https://ico.org.uk/make-a-complaint/

11. Third-party privacy policies

12. Changes

This policy may be updated at any time. The last-updated date appears at the top of the document. In the event of a material change, a notice will be displayed on the website and users of the myec2s applications will be notified by email.

13. Contact

For any questions: admin@econcept-system.fr