Privacy Policy
This Privacy Policy explains how Deep-5 SAS ("we", "us", "our") collects, uses, stores, and protects your personal data when you visit our website https://dusk.deep-5.com, purchase, or use the DUSK LAB software. We are committed to protecting your privacy in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the French Data Protection Act (Loi Informatique et Libertés).
1. Data Controller
The data controller responsible for processing your personal data is:
| Company | Deep-5 SAS |
| Registered address | 60 avenue François 1er, 75008 Saint-Cloud, France |
| Contact email | contact@deep-5.com |
| Data Protection Officer | dpo@deep-5.com |
2. Data We Collect
2.1 Purchase Data
When you purchase a DUSK LAB license, we collect the following data through our merchant of record, Lemon Squeezy:
- Full name
- Email address
- Billing address and country
- Payment information (processed exclusively by Lemon Squeezy; we do not store credit card numbers or payment details)
- License key and activation status
2.2 Website Analytics
We may collect anonymized, aggregated usage data about how visitors interact with our website. This data does not identify you personally and may include:
- Pages visited and time spent
- Referring website
- Browser type and operating system
- Country of origin (derived from anonymized IP)
2.3 Support Requests
When you contact us for support, we collect:
- Your name and email address
- Content of your message
- Technical information you voluntarily provide (OS version, hardware details)
2.4 Newsletter
If you subscribe to our newsletter, we collect your email address. You can unsubscribe at any time using the link included in every email.
2.5 Software Telemetry
DUSK LAB does not collect any telemetry data. The software does not phone home, does not transmit usage data, and does not require an internet connection to operate after activation.
3. Legal Basis for Processing
In accordance with Article 6 of the GDPR, we process your personal data on the following legal bases:
| Purpose | Legal Basis (Art. 6 GDPR) |
|---|---|
| Processing purchases and delivering licenses | Performance of a contract (Art. 6(1)(b)) |
| Responding to support requests | Performance of a contract (Art. 6(1)(b)) |
| Sending newsletters | Consent (Art. 6(1)(a)) |
| Website analytics (anonymized) | Legitimate interest (Art. 6(1)(f)) |
| Legal and tax obligations | Legal obligation (Art. 6(1)(c)) |
4. How We Use Your Data
We use your personal data exclusively for the following purposes:
- To process and fulfill your software license purchase
- To provide customer support and respond to inquiries
- To send product updates and newsletters (with your consent)
- To improve our website based on anonymized analytics
- To comply with legal obligations (accounting, tax reporting)
We do not sell, rent, or share your personal data with third parties for marketing purposes. We do not engage in profiling or automated decision-making.
5. Data Sharing and Third Parties
We share your data only with the following categories of recipients, strictly as necessary:
| Recipient | Purpose | Location |
|---|---|---|
| Lemon Squeezy (Merchant of Record) | Payment processing, license delivery, invoicing | United States |
| Email service provider | Transactional emails and newsletter delivery | EU / EEA |
| Hosting provider | Website hosting and serving | EU / EEA |
6. International Data Transfers
Lemon Squeezy, our merchant of record, is based in the United States. When your purchase data is processed by Lemon Squeezy, it may be transferred outside the European Economic Area (EEA). Such transfers are protected by:
- The EU-US Data Privacy Framework (DPF), where applicable
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Additional technical and organizational safeguards
You may request a copy of the applicable safeguards by contacting our DPO at dpo@deep-5.com.
7. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes described in this policy:
| Data Category | Retention Period |
|---|---|
| Purchase and license data | Duration of the license + 10 years (French accounting obligations) |
| Support correspondence | 3 years from last contact |
| Newsletter subscription | Until unsubscription + 3 years |
| Anonymized analytics | 26 months maximum |
| Invoices and accounting records | 10 years (Article L.123-22 of the French Commercial Code) |
8. Your Rights
Under the GDPR (Articles 15 to 22), you have the following rights regarding your personal data:
- Right of access (Art. 15) — Obtain confirmation of whether your data is being processed and a copy of said data
- Right to rectification (Art. 16) — Request correction of inaccurate or incomplete data
- Right to erasure (Art. 17) — Request deletion of your data, subject to legal retention obligations
- Right to restriction of processing (Art. 18) — Request restriction of processing in certain circumstances
- Right to data portability (Art. 20) — Receive your data in a structured, commonly used format
- Right to object (Art. 21) — Object to processing based on legitimate interest, including direct marketing
- Right to withdraw consent (Art. 7(3)) — Withdraw your consent at any time for consent-based processing
To exercise any of these rights, contact our Data Protection Officer at dpo@deep-5.com. We will respond within 30 days of receiving your request, as required by Article 12(3) of the GDPR.
9. Right to Lodge a Complaint
If you believe that our processing of your personal data infringes the GDPR, you have the right to lodge a complaint with the French data protection authority:
| Authority | Commission Nationale de l'Informatique et des Libertés (CNIL) |
| Address | 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France |
| Website | www.cnil.fr |
10. Cookies
Our website uses only essential cookies that are strictly necessary for the operation of the website. We do not use:
- Advertising or tracking cookies
- Third-party marketing cookies
- Social media tracking pixels
- Profiling or behavioral targeting cookies
Essential cookies include those required for language preference storage and session management. These cookies do not require consent under Article 5(3) of the ePrivacy Directive (2002/58/EC) as they are strictly necessary for the service explicitly requested by the user.
11. Children's Privacy
DUSK LAB is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16 without appropriate parental consent, we will take steps to delete such data promptly. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at dpo@deep-5.com.
12. Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encrypted communications (TLS/HTTPS), access controls, and regular security reviews. However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The updated version will be posted on this page with a revised "Last updated" date. We encourage you to review this policy periodically. For material changes, we will notify registered customers by email.
14. Contact
For any questions regarding this Privacy Policy or our data processing practices, please contact us:
| General inquiries | contact@deep-5.com |
| Data protection (DPO) | dpo@deep-5.com |
| Postal address | Deep-5 SAS, 60 avenue François 1er, 75008 Saint-Cloud, France |