Privacy Policy

C2SL (hereinafter “we”) is committed to protecting the privacy of visitors to its orila.co site. This policy explains, in full transparency, which data is processed when you use this site, in accordance with the General Data Protection Regulation (GDPR).

1. Data controller

2. Data collected on this site

This site is a presentation site. It contains no advertising or tracking cookie, and a single form: the one on the “Write to us” page, described below. When you browse the other pages, you do not transmit any personal data to us, and we collect none for commercial purposes. No resource of these pages — fonts, scripts, images — is loaded from a third-party server: everything is served by the site itself, so your IP address is seen by our host only.

When you write to us from the “Write to us” page, we receive your name, the name of your company if you give it, your email address, the reason you chose and your message. They are used solely to read your message and reply to you: writing to us does not sign you up for any newsletter or commercial solicitation. Your message is filed in ORILA, our own application, where only authorised staff of C2SL read it. Your IP address is used, when the message is sent, to keep bots out and limit bursts of messages; it is not stored with your message.

To keep bots out, this page uses Cloudflare Turnstile, an anti-bot check that replaces image CAPTCHAs, provided by Cloudflare, already our host. As soon as the page is displayed, your browser exchanges technical information with Cloudflare (IP address, browser type, connection characteristics); Cloudflare only passes the result of the check on to us. The check sets no advertising or audience measurement cookie; it may store in your browser a piece of technical information of its own, used only to protect the form, which makes it a strictly necessary tracker, exempt from consent.

We do, however, measure how the site is visited, using our own measurement tool, which we host ourselves and share with no third party. This measurement is anonymous and cookie-free: it records the page viewed, where you came from if applicable, the window width, the time spent, the scrolling, relative mouse positions within the page and any technical errors encountered. It places nothing on your device, does not identify you and cannot follow you from one site to another — which is why no consent banner is shown to you.

The site only keeps, in your browser's local storage, a purely technical display preference. This element is not a tracking cookie, is never transmitted to a third party and does not allow you to be identified.

Like any online service, our host processes technical connection data (IP address, browser type) for security and proper operation purposes. This data is not used by us to identify you.

3. When you use the demo or create an account

By clicking on “Try the demo” or creating an account, you access the ORILA application, which constitutes a separate service. The data you enter there (your clients, your contacts, your appointments, etc.) is processed there as part of the performance of the service contract, and governed by the terms presented at the time of registration.

4. Purposes and legal bases

• Display and security of the site — legitimate interest (providing a functional and secure site).
• Anonymous, cookie-free audience measurement — legitimate interest (knowing which pages are read and spotting failures).
• Technical display preference — proper operation of the service, without tracking.
• Reply to your messages (sent from the “Write to us” page or to our contact address) — legitimate interest in replying to you.
• Protection of the “Write to us” form against bots — legitimate interest (security of the form).
• Security of the application and abuse prevention — legitimate interest (protecting the application and its users' data against intrusion or misuse attempts).

No processing for prospecting or profiling purposes is carried out from this site.

5. Recipients and processors

We neither sell nor rent your data, and we never use it to train anything.

5.1 For this showcase site

For the showcase site, our host Cloudflare, Inc. ensures the delivery and security of the site, as well as the anti-bot check on the “Write to us” page (Cloudflare Turnstile). For this check, Cloudflare states that it also uses the technical information received, as a controller, to improve its bot detection. Cloudflare is certified under the EU–U.S. Data Privacy Framework (certification recorded as "active" on the official register on September 14, 2026); the European Commission's Standard Contractual Clauses apply in addition, as a fallback.

Messages sent from the “Write to us” page are filed in ORILA, our own application, which relies on the providers described below (hosting at Cloudflare, database at Neon, in Europe).

5.2 For the ORILA application

The application relies on the providers listed below. Each one is involved only for the stated purpose and receives only the data required for it. Those marked “if you connect it” receive nothing until you have enabled that connection in your settings, with your own credentials.

• Cloudflare, Inc. — hosting of the application, storage of the files and bulky content of your workspace (photos, logos, attachments, project documents, as well as the body of the emails collected from or sent through your connected mailbox, with their embedded images) and technical operating logs. That storage is located in Europe.
• Neon, Inc. — database hosting: all of your account data is stored there, on infrastructure located in Europe.
• Brevo (France) — email delivery, on two counts: the emails related to your account (address verification, forgotten password, invitations, due-date notices) and the sending of your quotes, invoices and campaigns to your own recipients. Receives the email address, the name and the content of the message.
• Your own email provider, if you choose to send from your business address: the message then leaves through your mail server, not ours.
• Pennylane (France) — accounting platform, if you connect it. It then receives your finalised invoices: your client's identity and billing details, VAT number, company registration number, line items and amounts.
• Meta Platforms — WhatsApp business messaging, if you connect your own number. ORILA receives the messages addressed to you and files them under the matching record; ORILA sends no message through this channel.
• Qonto (France) — bank connection, if you connect it. ORILA reads your accounts and transactions (date, label, amount, reference) for reconciliation; no payment order can be issued. Other banks go through the manual upload of a statement, with no third party involved.
• PayPlug (France) — collection of your subscription and of online payments. Your bank details are entered at PayPlug and never pass through ORILA: we receive only the amount, the reference and the outcome of the transaction.
• Amazon Web Services (Paris region) — delivery of the service's emails, with Brevo as a fallback. Receives the recipient's address, the name and the content of the message.
• Mistral AI (France) — processing of the requests sent to the agents, if you subscribe to the "team of agents" option. Receives the text needed for the request (extracts from the record concerned, your instruction). Used through its European endpoint; does not use your data to train its models.
• Telegram — internal alert to our team when you submit feedback or a request from the application. Receives the title, an extract of the message, your name and that of your organisation. No other data from your account is concerned.

5.3 Artificial intelligence

If you subscribe to the "team of agents" option, six agents read the records in your workspace to prepare drafts for you. The text needed for each request is then sent to Mistral AI, a French company, through its European endpoint: that data is processed in Europe and is not used to train its models. Until you subscribe to that option, none of your data is sent to such a provider.

Three limits govern this feature: what an agent prepares remains a draft that you review, except for the actions you have explicitly entrusted to it; a daily cap limits the number of requests; and nothing is sent from the public demo.

When you upload a file to bring in your existing data, ORILA may call on the same provider to recognise your columns and match them to the corresponding fields. It then receives only your column headings and a sample of a few rows — never the whole file, never automatically, and only at your request. You are informed before anything is sent and you may decline: column matching then remains entirely manual.

6. Hosting and transfers outside the European Union

The application data (that of your ORILA account) is hosted on an infrastructure located in Europe. The delivery of the showcase site is provided by Cloudflare, a company established in the United States and certified under the EU–U.S. Data Privacy Framework (certification recorded as "active" on September 14, 2026); the Standard Contractual Clauses approved by the European Commission apply in addition, as a fallback, to any transfers of technical data.

Among the providers listed in article 5, Neon, Meta Platforms and Amazon Web Services (which delivers our emails from its Paris region) are established in the United States; transfers to them are governed by the Standard Contractual Clauses approved by the European Commission, and your account data hosted by Neon stays on servers located in Europe. Telegram, established outside the European Union, receives only an internal alert (title, extract, name) and no data from your account: no Standard Contractual Clauses have been concluded with it, which is precisely why what is sent to it is kept to the strict minimum. The providers you connect yourself (accounting platform, business messaging, bank) remain governed by the contract you entered into directly with them.

7. Retention periods

• Technical browser preference: until you delete it yourself.
• Messages sent from the “Write to us” page and email exchanges with our contact: 3 years after our last exchange (messages from the “Write to us” page are deleted automatically); deleted earlier on simple request.
• Technical connection data (host): limited period for security purposes.
• Application security traces: ninety days; level reached by an account in the graduated security measures: until it is reset, after ninety days without a new attempt included in the count; counters of failed logins and of refused access keys: until one day has passed without a new failure. These deletions are automatic and take place, among other times, every night.

8. Your rights

In accordance with articles 15 to 22 of the GDPR, you have the following rights:

• Right of access to your data
• Right of rectification
• Right to erasure
• Right to restriction of processing
• Right to object
• Right to portability
• Right to withdraw your consent at any time
• Right not to be subject to a decision based solely on automated processing and, where such a decision is taken, right to obtain human intervention, to express your point of view and to contest it

To exercise these rights, write to us at [email protected]. We reply within one month. You may also lodge a complaint with the CNIL (Commission nationale de l'informatique et des libertés, 3 place de Fontenoy, 75007 Paris, cnil.fr).

9. Security

We implement appropriate technical and organizational measures: encryption of communications (HTTPS/TLS), restricted access to data, and hosting on a secure infrastructure.

Security traces and automatic measures in the application. To protect the application and its users' data, we record certain abuse attempts: inserting unambiguously executable code into an input field such as a name, sending more than twenty invitations within one hour, attempting to access the data of an organization of which the person is not a member, and repeated attempts to log in or to use an access key. Each trace contains the date, the type of attempt, the name of the field concerned, the originating network address, the organization in which it took place, the measure applied, whether an internal alert was sent and, where applicable, the account concerned, the data targeted or the public beginning of the access key concerned; lifting a measure also leaves a trace, which identifies the person at C2SL who lifted it. To slow down repeated attempts, we also keep counters of failed logins, linked to the network address and to a fingerprint of the identifier entered (never the identifier itself nor the password), and counters of refused access keys, linked to the public beginning of the key and to the network address. This processing is based on our legitimate interest in ensuring the security of the service (Article 6(1)(f) and recital 49 GDPR). Traces are kept for ninety days, then deleted automatically, among other times every night; only the level reached by the account in the graduated measures, the number of attempts taken into account, the type and field of the last attempt, its date and the end of any measures in progress are kept until the count is reset, after ninety days without a new attempt included in that count. The alerts our team receives about these attempts contain no account identifier, no network address and no value entered.

Inserting such code and sending more than twenty invitations within one hour automatically trigger the measures provided for in article 10 of the terms of use, which only affect the account concerned: immediate suspension for such code; for invitations, a warning, then a restriction, for twenty-four hours, of the sensitive actions listed in that article, then a suspension. Successive suspensions last twenty-four hours, then one week, then thirty days; beyond that, each suspension lasts thirty days and C2SL, which sees the suspensions in progress, may lift it before it ends. An attempt to access the data of another organization is only recorded, and an alert may be sent to C2SL about it, without any automatic measure (no warning, restriction or suspension) and without being counted; the same applies to inserting code by means of an access key, to inserting code that already appears, exactly as it is, in the data received by the organization and is reused to create a record, and to inserting code into the name entered when signing up for the Service, before the email address is confirmed as well as at the time of that confirmation (accepting an invitation, which confirms the address, is not covered). During a restriction or a suspension, the access keys created by the person are subject to the same measure. Lifting a measure leaves the count unchanged, unless C2SL finds that the measure resulted from an error: the last attempt that gave rise to a warning, a restriction or a suspension then ceases to be counted. These automated decisions are necessary for the performance of those terms (Article 22(2)(a) GDPR). You may at any time obtain the intervention of a person at C2SL, express your point of view and contest the measure, by writing to [email protected]. Repeated attempts to log in with a wrong password only lead to a temporary block, of fifteen minutes at most, of login attempts made with the same identifier from the originating network address, or of all logins from that address when failures are found there on more than twenty different accounts within one hour; repeated use of a refused access key leads to no block, the key remaining refused. None of these attempts leads to the suspension of the targeted account.

10. Changes

This policy may change, in particular if we add another form, a new provider or an audience measurement tool relying on cookies (a consent mechanism would then be put in place). The date of the last update appears at the top of this page.