Privacy Policy

1. Who we are

The Pause is a leadership-coaching platform published by Become Luminous. Become Luminous acts as the data controller for your personal data within the meaning of the General Data Protection Regulation (GDPR).

For any question about your data, you can reach us at: matthieu@becomeluminous.com.

2. Data we collect

When you use the service, we collect the following categories of data:

• Account and profile data: name, email address, professional role, password (stored in hashed form by our authentication provider, never in plain text);
• Assessment results: your answers to the leadership self-assessment questionnaires and the resulting scores;
• Coaching conversations: transcripts of your exchanges with the AI coach (Lumia), retained to provide continuity and personalise your journey;
• Project files: documents you choose to upload to your project spaces;
• Organisation and team data: your membership of an organisation or team and your role within it, when your account is linked to a B2B plan;
• Strictly necessary technical data: a session cookie used to authenticate you (see the Cookies section).

3. Purposes of processing

Your data is processed for the following purposes:

• Providing the service: running your assessments, generating your results, powering the conversational coaching and your project spaces;
• Personalising your journey: tailoring content and coaching exchanges to your results and history;
• Sending transactional emails: invitations to join an organisation or project, and weekly reminders related to your practice;
• Managing organisations: administration of seats, teams and access for B2B plans;
• Keeping the service secure: authentication, abuse prevention and protection against unauthorised access.

We do not use your data for advertising and we never sell it to anyone.

4. Legal bases

Each processing activity relies on a legal basis provided by the GDPR:

• Performance of a contract (art. 6.1.b): creating and managing your account, providing the service's features, invitation emails;
• Consent (art. 6.1.a): storing your assessment results and coaching conversations for personalisation purposes — collected explicitly when you create your account — as well as weekly email reminders, which you can turn off at any time;
• Legitimate interest (art. 6.1.f): platform security and abuse prevention.

5. AI processing

The Pause's conversational coaching relies on large language models provided by Anthropic and Mistral AI. When you chat with the AI coach, the content of the conversation (together with the context needed, such as your assessment results) is sent to these providers' APIs to generate responses.

Under the terms applicable to their APIs, Anthropic and Mistral AI do not use data submitted via the API to train their models.

The Pause makes no fully automated decision producing legal effects concerning you or similarly significantly affecting you within the meaning of article 22 of the GDPR.

6. Subprocessors

We rely on the following subprocessors to operate the service:

• Vercel — application hosting and delivery;
• Supabase — authentication and database, hosted in the eu-central-1 region (Frankfurt, European Union);
• Anthropic — AI models provided via API;
• Mistral AI — AI models provided via API.

Each of these providers is bound by contractual data-protection commitments. This list may evolve; any substantial change will be reflected in this policy.

7. Hosting and data location

Your account data, assessment results, conversations and files are stored in the European Union (Supabase, eu-central-1 region — Frankfurt).

Processing of conversations by AI providers may involve transferring data outside the European Union (notably to the United States for Anthropic). These transfers are covered by appropriate safeguards within the meaning of the GDPR, such as the European Commission's standard contractual clauses.

8. Retention

Your data is retained for as long as your account is active. You can delete individual conversations or projects from within the app at any time.

When you delete your account (Settings → account deletion), all of your personal data — profile, assessment results, conversations, files — is removed from our systems. Residual backup copies are purged within a reasonable period after deletion.

9. Your rights (GDPR)

Under the GDPR, you have the following rights:

• Right of access and portability: you can export all of your data at any time, in a structured, machine-readable format, from your Settings;
• Right to rectification: you can correct your profile information directly in the app, or contact us for any other data;
• Right to erasure: you can delete your account and all of your data directly from your Settings, without needing to contact us;
• Right to withdraw consent: at any time, in particular for email reminders;
• Right to restriction and right to object: under the conditions set out by the GDPR.

To exercise a right not covered by the app's built-in features, write to us at matthieu@becomeluminous.com. You also have the right to lodge a complaint with your supervisory authority — in France, the CNIL (www.cnil.fr).

10. Cookies

The Pause uses cookies that are strictly necessary for the service to work: the session cookie issued by our authentication provider (Supabase), which keeps you signed in. These cookies do not require consent.

Only with your consent, we also use Google Analytics 4 (Google Ireland Ltd) to measure site audience: pages viewed, traffic sources, device type. No analytics cookie is set and no data is sent to Google until you click “Accept” in the dedicated banner. You can withdraw or change your choice at any time via the “Manage cookie preferences” button below; your choice is stored for 6 months.

We use no advertising cookies and no tracking devices for advertising purposes.

11. Security

We implement appropriate technical and organisational measures to protect your data: encryption of communications in transit (TLS), password hashing, strict access control (data is segregated per account and per organisation), and least-privilege internal access.

No system is infallible, so we encourage you to use a strong, unique password. In the event of a data breach likely to result in a risk to your rights, we will notify you in accordance with our legal obligations.

12. Changes to this policy

We may update this policy to reflect changes to the service or to legal requirements. The date of the latest update appears at the top of this page. In the event of a substantial change, we will notify you through the app or by email.

13. Contact

For any question about this policy or your personal data: matthieu@becomeluminous.com.