1. Data Controller
Personal data collected on this website is processed by Séraphine MBEZELE NGONO, sole proprietor (entrepreneur individuel), SIRET 48203259600058, email: contact@tiwiabyseraphine.com.

2. Data Collected
When you purchase a program, we collect: first name, last name, email address, postal code and country. Payment data (card number) is processed exclusively by our secure payment providers (Stripe, Klarna) and is never stored by us.

3. Purposes of Processing
Data is collected for: delivering the purchased programs (creating access to the member area), sending service emails related to your order, invoicing and complying with our legal obligations, and, subject to your consent, sending communications about our programs and news.

4. Legal Basis
Processing is based on the performance of the sales contract, compliance with legal obligations (invoicing, accounting) and, where applicable, your consent (marketing communications).

5. Recipients of Data
Data is intended exclusively for TIWIA by Séraphine and its technical subcontractors: Systeme.io (website and member area hosting, email sending), OVHcloud (contact@tiwiabyseraphine.com mailbox), Stripe and Klarna (payment), Netlify (app hosting). No data is sold or transferred to third parties. Some providers (Stripe, Netlify) may process data outside the European Union. These transfers are governed by the safeguards provided by the GDPR (standard contractual clauses of the European Commission).

6. Retention Period
Data is kept for the duration of the customer relationship, then archived in accordance with legal obligations (10 years for accounting documents). Data related to marketing communications is kept for 3 years after the last contact.

7. Your Rights
In accordance with the General Data Protection Regulation (GDPR), you have the right to access, rectify, erase, restrict, object to and port your data. To exercise these rights, write to: contact@tiwiabyseraphine.com. You may also file a complaint with the CNIL, the French data protection authority (www.cnil.fr).

8. Cookies
The website uses technical cookies that are strictly necessary for its operation (session, cart, payment).

9. Security
Data is hosted on secure servers and transactions are protected by SSL encryption.

10. Tracking app (The Renaissance Protocol app)
If you use the app included in the program, we save: your email address (for sign-in), your weight, height, food log and your Mirror photos. This information is health data. It is processed only to run your tracking, based on your explicit consent (Article 9(2)(a) GDPR), given in the app.
Hosting: data is stored by Supabase (servers located in Paris, European Union). The app is hosted by Netlify, Inc. (USA).
Retention: as long as your account is active, then no more than 3 years after your last sign-in.
Your rights: you can withdraw your consent, access, correct or delete your data at any time by emailing contact@tiwiabyseraphine.com. We reply within one month. You can also file a complaint with the CNIL (www.cnil.fr).
Your data is never sold or shared for commercial purposes.