Privacy Policy

At Adagely, we place the utmost importance on protecting your personal data. This privacy policy informs you, in accordance with the General Data Protection Regulation (GDPR — Regulation EU 2016/679) and the French Data Protection Act (loi Informatique et Libertés), about how we collect, use, and protect your data.

1. Data controller

The data controller for data collected via the website adagely.com and the Adagely application is:

Slifer Solutions has not appointed a Data Protection Officer (DPO) due to its size and the nature of its activities. For any questions regarding your data, please contact us directly at the address above.

2. Data collected

Depending on how you interact with our services, we collect the following data:

2.1 Waitlist registration

• Email address
• Date and time of registration
• GDPR consent (timestamped)

2.2 Website browsing

• Display preference (light/dark theme), stored locally via localStorage — never transmitted to our servers

2.3 Data not collected

We do not collect any browsing data (IP address, pages visited, session duration), use no tracking or advertising cookies, and rely on no behavioural analytics tools (Google Analytics, Hotjar, etc.) on this website.

3. Purposes and legal bases for processing

Purpose	Data involved	Legal basis (GDPR)
Notification at the launch of the Adagely application	Email	Consent (Art. 6.1.a)
Sending project progress updates	Email	Consent (Art. 6.1.a)
Compliance with legal obligations	Registration data	Legal obligation (Art. 6.1.c)

We do not engage in any profiling or automated decision-making based on your data.

4. Data retention period

• Email address (waitlist): retained until the commercial launch of Adagely, then converted into a user account if you wish, or deleted. If the application is not launched within 3 years of your registration, your data will be deleted.
• Unsubscription: upon receipt of your deletion request, your data will be erased within 30 days.

5. Data recipients

Your data is never sold or transferred to third parties for commercial purposes. It may be shared only with the technical service providers necessary for the operation of the service, strictly within the scope of their duties:

• Website host: Vercel Inc. — 440 N Barranca Ave #4133, Covina, CA 91723, United States. Data is processed in data centres located in Europe (Frankfurt). Vercel is certified under the EU-US Data Privacy Framework.
• Email service provider: Brevo (formerly Sendinblue) — Sendinblue SAS, 106 boulevard Haussmann, 75008 Paris, France. Data is processed in compliance with the GDPR in data centres located in the European Union.

No transfer of data to third countries not covered by an adequacy decision or appropriate safeguards is carried out, except for Vercel (Data Privacy Framework).

6. Cookies and trackers

The adagely.com website uses only:

• localStorage — key theme: stores your display preference (light or dark mode). This is not a cookie in the strict sense — this data remains on your device and is never transmitted to our servers. No consent is required for this purely functional storage.

We use no third-party cookies, no tracking pixels, and no advertising trackers.

7. Your rights

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

• Right of access (Art. 15 GDPR) — obtain a copy of the data we hold about you
• Right to rectification (Art. 16 GDPR) — correct inaccurate or incomplete data
• Right to erasure (Art. 17 GDPR) — request deletion of your data (“right to be forgotten”)
• Right to restriction (Art. 18 GDPR) — request temporary suspension of processing
• Right to data portability (Art. 20 GDPR) — receive your data in a structured, machine-readable format
• Right to object (Art. 21 GDPR) — object to the processing of your data
• Right to withdraw your consent at any time, without affecting the lawfulness of processing prior to withdrawal

To exercise any of these rights, send your request to: hello@adagely.com. We will respond within a maximum of 30 days. Proof of identity may be requested to verify your identity.

You also have the right to lodge a complaint with the competent supervisory authority:

8. Data security

We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, destruction, or disclosure:

• Data transmission encrypted via HTTPS (TLS)
• Data access restricted to authorised personnel only
• Hosting with a certified provider (Vercel)

In the event of a data breach likely to result in a high risk to your rights and freedoms, we will inform you as soon as possible, in accordance with Article 34 of the GDPR.

9. Changes to this policy

We reserve the right to modify this privacy policy at any time, in particular to comply with any legal, regulatory, or technical developments. The date of the last update is indicated at the top of this page. In the event of a substantial change, we will inform you by email if you are registered on our waitlist.

10. Applicable law and jurisdiction

This policy is governed by French law and European Union law. In the event of a dispute not resolved amicably, the French courts shall have exclusive jurisdiction.