Last updated: 22/04/2026
This policy covers the entire eCONCEPT SYSTEM ecosystem:
- The econcept-system.fr / .com corporate website
- The private applications myec2s.fr / .com (management ERP and IoT supervision for residential buildings)
1. Data Controller
eCONCEPT SYSTEM (Jean BERENGUIER, sole trader)
Quartier la Croix, 97226 Morne-Vert, Martinique, France
SIRET: 887 842 979 00015
Email: admin@econcept-system.fr
As a French-registered business, eCONCEPT SYSTEM is subject to the EU General Data Protection Regulation (GDPR) and the French Data Protection Act (Loi Informatique et Libertés). The lead supervisory authority is the French CNIL.
2. Data collected on the corporate website (econcept-system.fr)
The corporate website is an information site with no contact form and no user account. No personal data is directly collected by the site.
2.1 Integrated third-party services
| Service | Purpose | Data collected | Legal basis |
|---|---|---|---|
| Google Fonts | Font display | IP address | Legitimate interest |
| Google Maps | Display of buildings map | IP address, browser identifier, cookies | Consent |
| Google reCAPTCHA | Anti-spam protection | IP address, browsing behaviour | Legitimate interest |
| LinkedIn Insight Tag | Professional audience measurement | IP address, cookies | Consent |
2.2 Server logs
The hosting provider IONOS retains access logs (IP address, date, URL visited) for a period of 12 months for security and diagnostic purposes. These logs are retained under the hosting provider's responsibility.
3. Data collected on the myec2s applications
The myec2s applications are professional tools accessible via authentication. They rely on two distinct and decoupled data domains:
- The accounts domain: manages the identity of users connecting to the applications (managing agents, residents, eCS administrators)
- The access-control domain: manages the physical means of access to buildings (number plates, badges, entries) and contains no nominative identity data
3.1 User accounts domain
Three user profiles are distinguished:
- Managing agent / Property agency: management of one or more buildings under CLEM contract
- Resident: management of access means attached to their flat
- eCONCEPT SYSTEM administrator: technical support and configuration
Data collected for each account:
| Profile | Data collected |
|---|---|
| Managing agent | Company name, SIRET, postal address, email, phone, password (hashed) |
| Resident | Surname, first name, email, password (hashed), flat number |
| eCS administrator | Surname, first name, email, password (hashed) |
Legal basis: performance of the CLEM contract (managing agent); mandate entrusted by the managing agent to the resident for the management of their flat's access means.
3.2 Access-control domain
This domain manages only the physical means allowing gates, pedestrian gates, doors and barriers to be opened in buildings.
Pivot identifier: the flat number. No data in this domain is linked to an identified individual.
Data processed:
- Number plates (LAPI / ANPR) authorised for a flat
- RFID badges / QR codes authorised for a flat
- Entry history: date, time, access means used, access point, associated flat number
Entry-history retention period: rolling 6 months. After this period, records are automatically deleted.
Legal basis: legitimate interest (building security, management of access incidents), in accordance with CNIL guidelines on residential access-control systems.
3.3 Articulation between the two domains
When a resident logs in to their personal area to declare a number plate or consult their entry history:
- The application reads the flat number associated with their account (accounts domain)
- It queries the access-control domain using this flat number
- The data returned (number plates, badges, entries) contains no nominative reference
This decoupling ensures that the access-control database never contains a name or personal identifier. Only the temporary software join, performed in memory at query time, allows a resident to access information relating to their flat.
3.4 IoT telemetry data
The management controllers installed in buildings report technical data (motor state, opening cycles, power-supply voltages, detected faults). This data contains no personally identifying information and is used for predictive maintenance and support.
4. Data access rights
| Profile | Their account | Attached flat(s) | Whole building | eCS ecosystem |
|---|---|---|---|---|
| Resident | Read + modify | Read + manage access means of their flat | No | No |
| Managing agent | Read + modify | Read all flats in their buildings | Yes (their buildings) | No |
| eCS administrator | Read + modify | Upon formalised and traced support request | Upon support request | Yes (technical operation) |
5. Cookies and trackers
5.1 Corporate website cookies
| Name | Purpose | Duration | Type |
|---|---|---|---|
ecs_cookie_consent | Storing cookie preferences | 6 months | Necessary |
5.2 myec2s application cookies
| Name | Purpose | Duration | Type |
|---|---|---|---|
ecs_auth_token | Authenticated JWT session | Session | Necessary |
ecs_refresh_token | Session persistence | 7 days | Necessary |
5.3 Third-party cookies (corporate website)
Third-party services listed in section 2.1 may set their own cookies. Audience measurement and marketing cookies are only set after your consent via the cookie management banner.
6. Retention periods
| Data | Duration |
|---|---|
| Cookie preferences | 6 months |
| Server logs (IONOS) | 12 months |
| myec2s user accounts | Contract duration + 3 years |
| Active number plates and badges | Flat allocation duration |
| Entry history | Rolling 6 months |
| IoT telemetry data | 24 months |
7. Data recipients
The data collected is not sold, rented or exchanged with third parties for commercial purposes. It may be transmitted to the following processors:
- IONOS: hosting of servers and databases
- Google: Fonts, Maps and reCAPTCHA services (corporate website only)
- LinkedIn: audience measurement (corporate website, subject to consent)
8. Transfers outside the European Union
Certain third-party services (Google, LinkedIn) may transfer data to countries outside the EU, governed by the Data Privacy Framework (EU-US, July 2023) or Standard Contractual Clauses approved by the European Commission.
Data processed by the myec2s applications (hosted by IONOS in France) is subject to no transfer outside the EU.
9. Your rights
In accordance with the GDPR and the French Data Protection Act, you have the following rights:
- Access: obtain a copy of the data concerning you
- Rectification: have inaccurate data corrected
- Erasure: request deletion (subject to legal obligations)
- Restriction: request a temporary freeze on processing
- Objection: object to processing on legitimate grounds
- Portability: receive your data in a structured format
- Withdrawal of consent: at any time, without retroactive effect
To exercise these rights: admin@econcept-system.fr
Response within one month (possibly extended by two months for complex requests).
10. Lodging a complaint with the supervisory authority
As eCONCEPT SYSTEM is established in France, the lead supervisory authority is the French CNIL:
Commission Nationale de l'Informatique et des Libertés (CNIL)
3 place de Fontenoy — TSA 80715 — 75334 Paris Cedex 07, France
Phone: +33 (0)1 53 73 22 22
https://www.cnil.fr/en/home
UK-based users may also lodge a complaint with the UK Information Commissioner's Office (ICO): https://ico.org.uk/make-a-complaint/
11. Third-party privacy policies
- Google: https://policies.google.com/privacy
- LinkedIn: https://www.linkedin.com/legal/privacy-policy
- IONOS: https://www.ionos.fr/terms-gtc/terms-privacy/
12. Changes
This policy may be updated at any time. The last-updated date appears at the top of the document. In the event of a material change, a notice will be displayed on the website and users of the myec2s applications will be notified by email.
13. Contact
For any questions: admin@econcept-system.fr
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