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GDPR

Privacy Policy

Translation notice. This is a translation provided for convenience. Only the French version is legally binding (T&C clause on language). Read the original in French →

Version of 18 April 2026

This policy describes the methods of collection, processing and protection of personal data implemented by Horizon Investissement in the operation of the Milodomain.com platform. It complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter the "GDPR") and with French Law No. 78-17 of 6 January 1978 as amended, known as the "Informatique et Libertés" Act.

1. Data controller

The controller of personal data processing is:

  • Horizon Investissement, SASU with share capital of €20,000
  • Registered office: 78 avenue des Champs-Élysées, Office 326, 75008 Paris
  • RCS Paris 538 158 106
  • Contact: contact form

2. Data collected

The categories of data processed by Horizon Investissement are as follows:

2.1. Identification and contact data

  • First name, last name;
  • Postal address (street, postcode, city, country);
  • Telephone number;
  • Email address;
  • Where applicable, company name and SIREN number for legal entities.

2.2. Account data

  • Unique identifier and encrypted password (bcrypt hash);
  • Timestamps of account creation, last login and acceptance of contractual terms;
  • Notification preferences.

2.3. Bidding and transaction data

  • List of bids placed, awards obtained, orders placed;
  • Bid amounts, invoice and payment amounts;
  • IP address at the time of placing the bid, user-agent.

2.4. Payment data

Bank card data and payment instrument data are collected, encrypted and stored directly by our payment service provider Stripe Payments Europe Ltd., without Horizon Investissement having access to them. Only transaction metadata (Stripe identifier, status, amount) are retained by Horizon Investissement.

2.5. Technical and browsing data

  • IP address and country of connection (for security purposes);
  • Browsing information (pages viewed, timestamps) in anonymised form via Umami Analytics.

2.6. Customer relationship monitoring and security data

  • Internal observations entered by authorised staff in connection with customer relationship monitoring (history of exchanges, supporting documents requested, ongoing regularisations);
  • Access logs to the administration back-office, including the IP address, user-agent and timestamp, for audit and traceability purposes;
  • Technical activity logs on the account (creation, modification, bid placement).

This data is only accessible to authorised personnel within Horizon Investissement, whose workstations are subject to filtering by authorised IP addresses and to exhaustive logging of their accesses. Consultation of the back-office from an unauthorised IP address is technically impossible.

3. Purposes and legal bases

Data is processed for the following purposes and on the following legal bases:

3.1. Performance of the contract

  • User account management;
  • Participation in auctions and allocation of awards;
  • Transmission of the successful Client's information to AFNIC for the constitution of the AFNIC Contact and the registration of the domain name in their name;
  • Issuance and sending of invoices;
  • Communication with the Client regarding the performance of their orders.

3.2. Legal obligations

  • Retention of invoices and accounting documents for the legal period;
  • Combating fraud and money laundering;
  • Response to requests from competent administrative or judicial authorities.

3.3. Legitimate interests

  • Security of the platform and prevention of fraudulent behaviour;
  • Service improvement and anonymised usage analysis.

3.4. Consent

The sending of commercial communications unrelated to the performance of the contract is conditional on prior consent, expressed when creating the account or at any time from the personal area. This consent may be withdrawn at any time.

4. Recipients of the data

Data is accessible only to authorised personnel within Horizon Investissement, as well as to the following subcontractors and partners, bound by contractual obligations of confidentiality and security in accordance with the GDPR:

  • AFNIC (French Association for Internet Naming in Cooperation) — recipient of AFNIC Contact information for the registration and management of the awarded domain name;
  • Partner registrar — for technical operations with AFNIC;
  • Stripe Payments Europe Ltd. (Ireland) — payment processing;
  • OVH SAS (France) — hosting of the platform;
  • Umami Analytics — audience analysis, in hosting controlled by Horizon Investissement, with anonymised identifiers;
  • Any legal counsel or judicial auxiliary, in the event of litigation strictly related to the performance of the contract.

Horizon Investissement does not sell, rent or transfer data to any third party for advertising purposes.

5. Transfers outside the European Union

Data is hosted and processed within the European Union. No transfer to a third country is carried out by Horizon Investissement. If such a transfer were to take place in the future, it would only be carried out on the basis of the safeguards provided for in Articles 45 et seq. of the GDPR (adequacy decision, standard contractual clauses of the European Commission, binding corporate rules).

6. Retention periods

  • Account data: for the entire duration of the Client's registration, then 3 years from the last activity, for prospecting purposes;
  • Bidding and transaction data: 10 years from the transaction, under accounting and commercial obligations;
  • Invoices and accounting documents: 10 years (Article L. 123-22 of the French Commercial Code);
  • Technical security and back-office access logs: 12 months;
  • Internal customer relationship monitoring observations: for the entire duration of the Client's registration, then deleted at the end of the commercial relationship, except for legal retention obligations or ongoing litigation;
  • Anonymised audience analysis data: 25 months maximum.

7. Security

Horizon Investissement implements appropriate technical and organisational measures to ensure the security of data:

  • Encryption of exchanges in TLS;
  • Hashing of passwords (bcrypt algorithm with 12 rounds);
  • Compartmentalisation of access and logging of sensitive operations;
  • Regular and encrypted backups;
  • Data breach notification procedure, in accordance with Article 33 of the GDPR.

8. Rights of data subjects

In accordance with Articles 15 to 22 of the GDPR, every data subject has the following rights:

  • right of access to their data;
  • right to rectification of inaccurate or incomplete data;
  • right to erasure ("right to be forgotten"), within the limits permitted by legal retention obligations;
  • right to restriction of processing;
  • right to portability of data provided by the person themselves;
  • right to object to processing based on legitimate interest;
  • right to withdraw consent at any time when it constitutes the legal basis for processing;
  • right to define directives concerning the fate of their data after death (Article 85 of the Informatique et Libertés Act).

These rights are exercised via the contact form or by post to the registered office. A response is provided within one month of receipt of the request, which may be extended to three months in the event of particular complexity, after informing the data subject.

The data subject also has the right to lodge a complaint with the French Data Protection Authority (CNIL), 3 place de Fontenoy, 75007 Paris.

9. Cookies and trackers

Milodomain.com uses exclusively cookies strictly necessary for the operation of the platform and security:

  • Session cookie, to maintain the user's connection;
  • CSRF protection cookie.

In accordance with Article 82 of the Informatique et Libertés Act, these cookies are exempt from prior consent. No advertising cookies, no third-party tracking cookies and no cookies for profiling purposes are placed.

Audience analysis is carried out via a self-hosted tool (Umami Analytics) which does not store any identifier allowing the user to be recognised from one visit to another.

10. Modifications

This policy may evolve due to regulatory or technical changes. Any substantial modification is brought to the attention of the Client by email or by notification in their personal area, at least 15 days before its entry into force.

11. Contact

For any question relating to the processing of your personal data, use our contact form.