Privacy Policy
Unapproved MERRAPI privacy draft: processing purposes, possible legal bases, recipients, retention, rights and audit requirements.
1. Controller and scope
Proposed controller: Henock LOMONGO, entrepreneur individuel (EI), micro-entrepreneur regime. Projected professional domiciliation address: 78 avenue Faidherbe, 92600 Asnières-sur-Seine, France (proprietor-declared projected address, not established as registered in the supplied documents; RNE verification and written consent for public display pending), registration [SIREN/SIRET] in [REGISTRY]. Tax identifier if applicable: [VAT IF APPLICABLE]. MERRAPI is the commercial brand; MERRAPI Aviation and MERRAPI Aircraft Care are two divisions of the same sole proprietorship, not separate legal entities or controllers by virtue of those divisions. The proprietor declared this identity and micro-entrepreneur status on 2026-10-09; no independent verification against up-to-date RNE/Sirene records has been completed. Registration, specific identity/address details and actual controller responsibilities remain to be verified before release.
Privacy contact: [PRIVACY CONTACT]. Professional contact details: [PROFESSIONAL EMAIL] and [PROFESSIONAL PHONE]. These placeholders are not usable contact addresses. This draft covers the website and intended enquiry handling, including external tools where applicable; the actual processing inventory must be reconciled before release.
2. Categories and sources of data
Potential Charter and Empty Leg enquiry data include requested routes, dates, passenger numbers, opportunity references and requirements; contact data may include names, email addresses, telephone numbers and correspondence. Forms are suspended from this preparation website, and collection fields must be verified against the actual forms before reactivation.
Aircraft Care enquiries may involve aircraft registrations, photographs, aircraft location and non-technical scope information. These can reveal people, identifiers or sensitive operational details. Their necessity, recipients and access restrictions must be reviewed. Do not submit identity documents, passenger lists, sensitive personal data, third-party faces or confidential aircraft details through this preparation site.
Website infrastructure may process IP addresses, browser/device information, request timestamps, security events and technical logs. Cookies, local storage, embedded services and tracking technologies require audit. The site does not assert that no data is collected, no cookies exist or no transfer occurs.
If the website is released as an informative showcase without active forms or alerts, processing would be expected to be limited to visiting the site. Even then, the hosting and delivery infrastructure, any platform error or usage telemetry, and the loading of web fonts from a third-party provider may involve the visitor's IP address and technical request data being received by those providers. Whether such processing actually occurs, by whom, where and for how long remains to be verified and documented before release.
3. Purposes and possible legal bases
After compliance approval, responding to a user-initiated feasibility enquiry may rely on steps taken at the person's request before a potential contract (GDPR Article 6(1)(b)), only where genuinely applicable. A general informational response may instead require a documented legitimate-interest assessment (Article 6(1)(f)). Neither basis authorizes a prohibited transport sale or aircraft intervention.
Security, abuse prevention and necessary technical administration may rely on legitimate interests after necessity, proportionality and balancing are documented. A specific applicable legal obligation may support Article 6(1)(c), but the obligation must be identified rather than assumed.
Optional marketing must be separate from enquiry handling, with its own lawful basis and any required prior consent (Article 6(1)(a)). Consent must be freely given, specific, informed and withdrawable; it must not be bundled into a mandatory response-to-enquiry checkbox. Non-essential cookies or trackers require any applicable prior consent. No marketing or tracking activation is authorized by this draft.
4. Required fields and minimisation
Required versus optional data, and the consequences of not providing necessary data, must be identified for each approved purpose. No blanket collection is justified. Photos, registration numbers and location information must be limited to the minimum needed for an approved feasibility review and accessible only to authorized recipients. Hotel, Security and Airport Assistance options are suspended pending necessity and scope review.
5. Recipients, processors and external tools
Recipients and processors: [PROCESSORS/RECIPIENTS]. Potential tools include Tally for intended forms, WhatsApp for intended alerts or correspondence, and internal operational tools, each subject to confirmation. Their legal role (processor or independent controller), contracting entity, instructions, subprocessors, permissions and agreements must be recorded rather than assumed.
No public form or alert link is active in this preparation version. External forms may still exist separately; this draft neither corrects nor approves them. No statement is made that an external service follows this policy or that all internal recipients are already identified. Sharing with an operator or facility requires a defined lawful purpose, minimum necessary data and verified recipient arrangements.
6. Hosting and international transfers
Actual website and tool hosting, access countries, subprocessors and international transfers: [ACTUAL HOSTING/TRANSFERS]. Effective host: [HOST LEGAL NAME], [HOST ADDRESS], [HOST PHONE]. Data residency, support access and backups must be confirmed from current contracts and configurations.
Where transfers outside the EEA occur, identify the destination and applicable safeguard, such as an applicable adequacy decision or standard contractual clauses with required assessment and supplementary measures. A method for obtaining relevant safeguard information must be established through the verified privacy contact. No absence of transfer or adequacy of safeguards is asserted.
7. Retention and deletion
Retention schedule: [DATA RETENTION]. Define periods or defensible criteria separately for unanswered enquiries, closed feasibility reviews, correspondence, aircraft photos and identifiers, security logs, consent records and any legally required records. No fixed number of months is asserted in this draft.
Deletion procedures must cover Tally, relevant WhatsApp data, internal tools, exports, shared copies and backups where applicable. Access restrictions, deletion triggers, legal holds, backup expiry and recipient notification must be documented and tested. Data must not be retained merely because a tool permits it.
8. GDPR rights and requests
Subject to applicable conditions, individuals may request access, rectification, erasure, restriction, portability and objection, including objection to direct marketing. Where processing relies on consent, withdrawal does not affect the lawfulness of prior processing. No solely automated decision-making with legal or similarly significant effect is authorized here; actual tool practices must still be verified.
Requests should be sent to the verified [PRIVACY CONTACT] once approved; this placeholder is not a functioning channel. Establish proportionate identity checks, secure handling, internal ownership and the statutory response process, normally within one month of receipt with lawful extensions where applicable. Do not demand identity documents systematically. Individuals may lodge a complaint with the competent supervisory authority, including the CNIL in France.
9. Security and incident handling
Appropriate technical and organisational measures must be assessed and documented: role-based access, account security, secure transmission, restricted photo/registration access, export control, backups, deletion and incident handling. No absolute security guarantee or unverified encryption or certification claim is made.
Assign responsibilities for incident assessment, processor notification, and any required supervisory-authority notification or communication to affected individuals within applicable legal deadlines. These procedures remain release blockers until documented and tested.
10. Cookies, trackers and storage
Cookie/tracker inventory and settings: [COOKIES/TRACKERS]. Audit website infrastructure, fonts, external embeds, browser storage, analytics and external destinations. Classify purposes, providers, lifetime and legal requirements. Do not claim cookie-free status before audit.
No analytics script, non-essential tracker or consent simulation is introduced by this preparation. If a verified inventory later requires consent, implement an appropriate prior-consent mechanism with genuine refusal and withdrawal before activation; an unnecessary banner is not a substitute for an audit.
11. Version and approval
DRAFT — NOT FOR PUBLICATION. Effective date: [EFFECTIVE DATE]. Before publication, verify each factual statement, replace all placeholders, align all forms and notices, complete the processor register and retention/deletion procedures, and obtain explicit release approval.