Legal

Privacy Policy

Last updated: October 12, 2026

Personæ helps leaders align their teams around the customer through The Personæ Method™ and the Personæ App. To do so, we process personal data. This policy explains which data, why, for how long, with whom we share it and how to exercise your rights. It applies to the personae.life website, the Personæ App and the Services of The Personæ Method™ (pre-diagnostic, Full Audit, Workshop, Deployment).

1. Who is responsible for your data?

Hugo Cusanno, sole proprietor under a business project support contract (CAPE no. C1497), SIRET 423 194 307 00090, PCE, 6 rue d'Amboise, 75002 Paris, France. Contact: contact@personae.life. We do not have a data protection officer (DPO); you can write to the same address with any question.

Our two roles:

  • Data controller: for our own needs (website, business relationship, invoicing, user accounts, security, pre-diagnostic and Full Audit interviews conducted to prepare our reports).
  • Processor for our Clients: when we process, on behalf of a Client, the data of its teams or of its own customers (data uploaded to the Personæ App, answers to the Customer IQ questionnaire, data processed during a Deployment). The Client is then the data controller and you should address your requests to it, although you may also write to us (section 11 of this policy and article 7 of the Terms and Conditions).

2. What data do we collect?

Who are you?Data processed
Website visitorIP address, browser, device, pages viewed, language preference, cookies (section 13)
Personæ App userName, work email, company, job title, password (hashed), usage data (features used, session duration, credits consumed), messages to support, content that you or your organization upload (interview transcripts, survey answers, CRM exports, inputs, documents)
Participant in a pre-diagnostic, a Full Audit or a WorkshopIdentity and job title, answers given during the discussions, content of the interviews (voice, image on video calls, transcript when they are recorded with your consent), items provided by your organization (org chart, tools used, documents), and the resulting notes and reports
Respondent to the Customer IQ questionnaireAnswers to the questionnaire, team scope, function or level, technical identifier of the questionnaire; possibly name or email depending on the distribution method chosen with your employer
Client (invoicing)Contact identity, billing details, order and payment history. Payment card data is processed by Stripe and is not stored by Personæ

We do not ask for sensitive data within the meaning of Article 9 of the GDPR (health, political opinions, religion, etc.) and ask you not to provide any. Interviewees are invited to talk about their work, not their private life.

3. Why, and on what legal basis?

PurposeLegal basis (GDPR, Art. 6)
Providing the Personæ App and managing your accountPerformance of the contract
Delivering the Services (pre-diagnostic, Full Audit, Workshop, Deployment), producing the reports and the Customer IQPerformance of the contract; for participants, the legitimate interest of our Client and our own in producing the Deliverables
Recording and transcribing interviewsConsent (section 5)
Invoicing, payment, accountingPerformance of the contract, legal obligation
Optional marketing communications (newsletter, product news)Consent
Support, security, prevention of fraud and abuseLegitimate interest
Audience measurement and non-essential cookiesConsent
Improving the service and the Customer IQ using anonymized and aggregated dataLegitimate interest
Compliance with our legal obligations (accounting, tax, responding to authorities)Legal obligation

We do not sell your personal data and do not use it for targeted advertising.

4. Where does the data come from?

Directly from you; from your employer or your organization (the Client); from your browsing on the website (cookies and trackers).

5. Recordings and transcripts

5.1. Pre-diagnostic video calls and Full Audit interviews are recorded and transcribed only if the participants consent. We ask you before starting. You may refuse or withdraw your consent at any time, with no consequence for the Service.

5.2. The recording is used to produce an accurate report without manual note-taking. Part of the extraction (summary, qualification items) is automated by AI tools.

5.3. The Workshop is not recorded.

5.4. Recordings and transcripts are accessible only to Personæ and to the processors listed in section 8. They are not passed on to other people in your organization, unless the person concerned agrees; only aggregated conclusions appear in the Deliverables.

5.5. If you no longer wish to appear in a recording or a transcript, write to contact@personae.life.

6. Customer IQ

6.1. The Customer IQ measures, through a questionnaire, how a Client's teams understand the target customer. It is an organizational indicator, never an individual assessment.

6.2. Participation is offered by your employer, who informs you of the purpose of the questionnaire. You may choose not to answer a question.

6.3. Results are reported to the Client in aggregated form, by team, level or function. No result is communicated for a group too small to preserve anonymity, and individual answers are not passed on to the employer.

6.4. The questionnaire is distributed through a secure form tool. For the Customer IQ, Personæ acts as a processor for the Client.

7. Artificial intelligence

7.1. The Personæ App and our Services use generative AI models (persona creation, interview simulation, summaries, extraction from recordings). The text you enter or upload may be sent to these providers to obtain a response (section 8).

7.2. Your content is not used to train AI models. We do not do so, and we use our providers' API offerings, whose terms exclude training on our data.

7.3. No decision producing legal or similarly significant effects on a person is made solely by automated means.

7.4. Personas are AI-generated representations, not real people. Interactions with a persona are flagged as AI-generated.

8. Who receives your data?

We disclose your data only to those who need to know it (ourselves and, where applicable, our partners working on a Service, who are bound by confidentiality) and to the following processors, with whom we have data protection commitments in place.

ProcessorRoleProcessing location
ScalewayHosting of the Personæ App, database and storageFrance, European Union
AI model providersPersona generation, interview simulation, summaries, extractionUnited States and/or European Union depending on the provider
StripePayment and subscription billingEuropean Union and United States
Work tool providers (video conferencing, recording and transcription, messaging, forms, client files)Delivery of the Services and relationship with our ClientsEuropean Union and United States
BrevoSending emails (onboarding sequence, transactional messages and, with consent, communications)France, European Union
ContentsquareAudience measurement and website usage analysis (journeys, heatmaps, session replay), with consentEuropean Union and United States
HubSpotCustomer relationship management and, with consent, tracking of website visitsEuropean Union and United States

We may also disclose data to an authority where required by law, or to a successor if our business is taken over (with the same safeguards).

9. Transfers outside the European Economic Area

Our data is hosted in the European Union. Some processors (in particular AI model, payment and work tool providers) may process data in the United States or elsewhere. These transfers are governed by an adequacy decision of the European Commission (in particular the Data Privacy Framework where the provider is certified under it) or by the standard contractual clauses, supplemented where necessary by additional measures (Article 46 of the GDPR). You can request a copy of the safeguards from contact@personae.life.

10. How long do we keep your data?

DataRetention period
Personæ App account and contentDuration of the contract. At the end, export available for 30 days, then deletion or anonymization within 30 days, unless required otherwise by law
Pre-diagnostic, Full Audit or Workshop with no follow-on: notes, reports, recordings and transcripts3 years after the end of the Service or the last contact, unless consent is withdrawn or erasure is requested
Clients: client file, Deliverables, correspondenceDuration of the contract, then 3 years
Answers to the Customer IQ questionnairePseudonymized, kept for the duration of the contract, then deleted or anonymized; aggregated results may be kept to measure change over time
Invoices and accounting documents10 years (French Commercial Code, Art. L.123-22)
Connection and security logs12 months
Cookies and trackers13 months maximum
Anonymized and aggregated dataNo time limit

At the end of these periods, the data is deleted or irreversibly anonymized.

11. Your rights

Under the conditions set out in the GDPR, you have the following rights: access, rectification, erasure, restriction, portability (JSON or CSV export), objection (at any time for processing based on legitimate interest), withdrawal of consent (without effect on past processing) and the right to set instructions for what happens to your data after your death.

To exercise them, write to contact@personae.life. We respond within one month (extendable by two months for a complex request, in which case we inform you). We may ask for proof of identity in case of doubt. If your data is processed on behalf of your employer or a Client, we forward your request to them.

You may also lodge a complaint with the CNIL, the French data protection authority (cnil.fr, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France).

12. Security

We protect your data through: encryption in transit (TLS) and at rest; isolation of workspaces; authentication and access control, limited to what is strictly necessary; hosting with a European provider; logging and monitoring; regular review of our practices and our providers; confidentiality undertakings from authorized personnel. In the event of a data breach presenting a risk, we notify the CNIL within 72 hours and, where it presents a high risk, the data subjects. For a Client for whom we act as processor, we notify the Client within 48 hours.

13. Cookies and trackers

  • Essential cookies (session, authentication, language, security): necessary for the website and the Personæ App to work, they cannot be disabled.
  • Audience measurement cookies: set only with your consent through the banner, which you can change or withdraw at any time. They are used to understand how the website is used: pages viewed, journeys, clicks and scrolling, including through the replay of browsing sessions (Contentsquare), and to link your visits to your contact record if you have given us your details (HubSpot). What you type into our forms is masked in these replays.

We do not use advertising cookies.

14. Minors

Our services are intended for adult professionals. We do not knowingly collect data from minors. If you believe a minor has sent us data, write to contact@personae.life: we will delete it as soon as possible.

15. Changes and contact

We may update this policy, in particular as our services or our company evolve. In the event of a significant change, we will inform you by email or by a visible notice on the website before it takes effect. The date of the last update appears at the top of this page.

Contact: Hugo Cusanno, PCE, 6 rue d'Amboise, 75002 Paris, France. contact@personae.life