Privacy Policy

Introduction

Mamami takes the protection of privacy and personal data seriously.

This Policy applies only to the current pre-launch website. It is not the privacy policy for the future Mamami application. Future features — including member accounts, matching, events or family-related functionality — will be covered by appropriate additional information before they are made available.

Last updated: 9 October 2026.

1. Data controller

The current controller is:

[FULL NAME]

Project lead of Mamami

[POSTAL / DOMICILIATION ADDRESS]

Data-protection email: privacy@mamami.me

Mamami is currently a pre-launch project and the company intended to operate the service has not yet been incorporated.

Once that company has been incorporated and becomes responsible for the relevant processing activities, this Policy will be updated with its legal name, registered office, contact details and registration information.

2. Who the current website is for

The current website and form are intended for adults.

The Early Supporter form is not intended to collect personal data about children.

Please do not submit through the form:

• information identifying a child;
• medical or health information;
• disability information unless genuinely necessary;
• biometric or genetic information;
• racial or ethnic origin;
• political opinions;
• religious or philosophical beliefs;
• information concerning sex life or sexual orientation;
• or other sensitive information that is unnecessary for your request.

If unnecessary sensitive data are provided voluntarily, we may delete them when we become aware of them.

3. Early Supporter data

When you use the form, we may process:

• your first name;
• your email address;
• your area or arrondissement and, if you provide it, your postal code;
• your children’s age ranges and the topics that interest you;
• your interest in a call with the team and your preferred contact method;
• your telephone number, only if you choose WhatsApp;
• the referring page or domain where available;
• permitted campaign parameters present in the URL.

The required fields are your first name, your email address, your area or arrondissement, your children’s age ranges, your topics of interest, your answer about a call and your acceptance of contact. Optional fields are: postal code, telephone number (needed only if you choose WhatsApp) and the marketing-communication agreement.

For each submission we also process:

• the submission language (French or English) and the timestamp of the registration;
• the consent and acknowledgement records associated with the form;
• an internal technical identifier, used as a follow-up reference;
• technical security and abuse-prevention data (see § 14 and § 15).

Purposes

We use this information to:

• record your interest in Mamami;
• handle your request;
• reply to you;
• provide follow-up directly related to your request or Early Supporter registration;
• understand, on a limited basis, how people discover Mamami.

Legal basis

This processing relies on our legitimate interests in responding to people who contact us and managing Mamami’s pre-launch phase.

Optional marketing communications rely on separate consent where consent is legally required.

Internal team notification

Each new Early Supporter registration generates an internal email notification for the Mamami team. It is sent through Cloudflare’s email-sending service and delivered to the team mailbox hosted by Zoho Mail (see § 17 and § 18).

The notification contains the first name, email address, telephone number if provided, area or arrondissement, interests, the answer about a call, the submission language, the date and an internal reference. It does not contain the children’s age ranges, the postal code, the IP address or the form’s security tokens. Only authorised team members can access it, and they can reply to it directly; the reply is then sent to you.

4. Early Supporter retention

Early Supporter and enquiry data are retained for no longer than:

24 months from your initial Early Supporter registration.

Data collected through your Early Supporter registration is retained for a maximum of 24 months from your initial registration, unless it is no longer needed earlier or a separate legal obligation justifies further retention. Subsequent correspondence (emails, meetings, calls, profile updates or resubmissions) does not automatically extend this period.

This maximum period is justified by the purpose of the Early Supporter programme: following up with people who are interested and preparing the community launch. It is not a period generally mandated by the GDPR, but the result of our own assessment.

The Early Supporter programme is temporary and distinct from future Mamami mobile application accounts.

You may request earlier erasure of your personal data at privacy@mamami.me, subject to the conditions set out in the GDPR.

If you later become a Mamami member, data needed for the membership relationship may be retained for the duration of that relationship and, where no separate legal retention obligation applies, for up to 30 days after account closure or an applicable deletion request.

Data that must exceptionally be retained to comply with a legal obligation, or to establish, exercise or defend a legal claim, may be kept for as long as is strictly necessary for that purpose.

The 24-month period is our retention rule for Early Supporter data.

Once the fixed deadline has passed, the Early Supporter record is deleted automatically from our database, together with the rows that depend on it, unless a documented hold or exception applies. This automatic deletion is active on the production website. The reference date remains your initial registration: later correspondence does not move it.

Deleting the database record does not automatically delete the corresponding notifications and correspondence kept in the team mailbox. Those are cleaned up separately by the team from a temporary internal cleanup list produced by the system, so that the two operations can be tracked independently. That list contains only what is needed to locate the messages (the email address and the internal reference), and is removed or redacted once the cleanup is confirmed.

A verified erasure request sent to privacy@mamami.me is handled as a priority and covers both the database record and the corresponding mailbox messages; it does not wait for the routine deadline.

5. First-party audience measurement

Mamami operates a limited internal audience-measurement system in order to understand how the website is used.

It is operated for the exclusive account of Mamami.

It is not used to:

• track you across other websites;
• build an advertising profile;
• recognise you persistently;
• follow the same person across days;
• join browsing activity to an Early Supporter registration;
• enrich an individual profile;
• sell or share behavioural data for advertising.

Events that may be recorded

The system uses a closed list of permitted events, for example:

• page views;
• landing-page views;
• interactions with selected calls to action;
• generic CTA position or label;
• page path;
• referrer domain;
• permitted campaign parameters.

The system is not designed to record:

• your name;
• your email address;
• your Early Supporter ID;
• the text of your message;
• a persistent visitor ID.

6. Campaign-value sanitisation

Campaign parameters received in the URL are not stored as unrestricted free text.

Before storage, values are normalised and filtered.

Values resembling certain forms of:

• email address;
• URL;
• UUID;
• long hexadecimal identifier or hash;
• long numeric identifier or telephone number

are rejected and replaced with a generic value such as `(other)`.

Page paths and relevant CTA labels are also subject to checks intended to reduce the risk of accidentally storing an individual identifier.

These safeguards reduce risk but do not claim that every possible short arbitrary token can be proven non-identifying.

Mamami does not permit campaign parameters to be deliberately used to transport individual identifiers.

7. Campaign attribution

UTM parameters apply only to the request that carries them.

They are not:

• stored in an analytics cookie;
• persisted in `sessionStorage`;
• carried into a later visit;
• turned into a visitor profile;
• joined to the Early Supporter database;
• associated with a name, an email address or any other personal record.

If you arrive with a campaign parameter and later return without it, Mamami does not attempt to reconstruct the earlier attribution by identifying you.

8. IP-address processing for audience measurement

An internet request necessarily involves network-address processing.

For audience measurement, the IP address may be processed transiently when the request is received, but it is not stored in raw form in our audience-measurement database.

Before the technical audience pseudonym is created:

• IPv4 addresses are reduced to a `/24` network prefix;
• IPv6 addresses are reduced to a `/48` network prefix.

The reduced value is then processed using HMAC-SHA-256 with a secret key, together with a daily date component.

The resulting value is a daily technical pseudonym.

It is not anonymous data

Our fingerprints are not anonymous data. They are pseudonymised data.

They are therefore treated as personal data for the purposes of the relevant GDPR rules.

The system is nevertheless deliberately designed to reduce the possibility of tracking:

• the raw IP is not stored in the audience table;
• it is reduced before pseudonymisation;
• the pseudonym is protected by a secret key;
• it changes daily;
• it is not used as a stable identifier between days;
• it is not joined to Early Supporter data.

9. “Estimated daily audience”

Mamami does not describe this measurement as an exact count of unique people.

We use the term estimated daily audience.

Several people sharing one network prefix may be counted together.

Conversely, the same person appearing on two different days does not receive a stable daily identifier that would allow them to be followed from one day to the next.

This loss of precision is intentional: counting every person exactly would require a more intrusive identification or tracking mechanism, which we have chosen not to put in place.

10. Legal basis for audience measurement

The personal-data processing needed for this limited measurement relies on our legitimate interests under Article 6(1)(f) GDPR.

Our interests are to:

• understand whether the website is being used;
• identify useful pages and calls to action;
• understand acquisition sources in aggregate;
• compare website performance over time;
• improve the pre-launch website.

We have chosen safeguards intended to reduce the impact on visitors:

• no persistent analytics visitor ID;
• no analytics cookie;
• no cross-site profile;
• no cross-device tracking;
• network reduction before pseudonymisation;
• daily pseudonym rotation;
• a closed event vocabulary;
• filtering of free-text values;
• no joining with Early Supporter records;
• limited retention;
• an easy way to object to the measurement.

11. Analytics retention

Audience events

Audience-measurement events are retained for a maximum of 400 days.

This period is approximately thirteen months.

It was chosen to allow one complete annual cycle to be compared with the corresponding period in the following year, without keeping several years of history for which the pre-launch project has no need.

These data are deleted automatically under the system’s retention policy.

Daily pseudonyms derived from the network

The pseudonymised data used for the daily audience estimate are retained for a maximum of 30 days.

They are then deleted automatically.

The 30-day period is deliberately much shorter than the period for aggregated events, because these data derive from network information.

12. Audience-measurement opt-out

You can object to this audience measurement.

The Cookies and audience measurement page displays the current state:

Audience measurement: enabled / disabled

and lets you disable it.

When you choose to disable measurement:

• new audience-measurement events are no longer sent by your browser;
• your choice is stored locally so that it continues to be respected on future visits.

The local value used for that purpose alone is:

`mamami.analytics-optout`

It is used only to remember your objection.

It is not used as an analytics identifier, to measure your activity, or to track you.

13. Cookies, browser storage and other trackers

Mamami’s first-party audience-measurement system:

• does not set an analytics cookie;
• does not use `sessionStorage` to track where a visit came from;
• does not use local storage as a visitor identifier;
• does not create a fingerprint intended to recognise a visitor persistently.

Events are sent to Mamami’s server using a same-origin network request.

The only browser storage used in connection with this measurement is the value required to remember your decision not to participate in it.

Mechanisms strictly necessary for security or technical operation may be used separately.

14. Cloudflare Turnstile and abuse prevention

The form uses Cloudflare Turnstile to reduce spam, bots and abusive submissions.

Turnstile performs browser-side security checks and processes the technical signals required to provide that function.

Mamami uses Turnstile only to protect the form and the service.

We do not use it to:

• analyse the content of your message for advertising purposes;
• build a marketing profile;
• serve personalised advertising.

Cloudflare may also process IP addresses and other technical information transiently, as needed to operate and secure its services.

15. Abuse prevention and rate limiting

To protect the form against automated submissions, Mamami limits the number of attempts.

The IP address may be processed transiently to generate a pseudonymous value using a secret-key cryptographic function.

The raw IP address is not stored in the application rate-limit database.

The corresponding value is used only for security and abuse prevention.

Under the current configuration, the counter is deleted about one hour after the end of the relevant window (at most an hour and a few minutes).

16. Marketing communications

Submitting the Early Supporter form does not by itself constitute general authorisation to send advertising emails.

Where Mamami wishes to offer news, launch communications or offers that constitute marketing and require your consent, a separate option must be presented.

That option must be:

• optional;
• separate from form submission;
• unticked by default.

The form provides an optional, separate, unticked box for this purpose. No marketing communication is sent at present. You may withdraw your consent at any time.

Where data are used for consent-based marketing, they may be retained for a maximum of three years from collection or your last active contact, unless consent is withdrawn or the data are deleted earlier.

Withdrawal of consent does not affect the lawfulness of processing carried out before that withdrawal.

17. Recipients

Access is limited to people who need the information to:

• operate the Mamami project;
• handle Early Supporter requests;
• keep the website secure;
• operate and maintain the infrastructure;
• produce internal audience statistics.

The technical providers concerned may include:

Cloudflare

Mamami uses Cloudflare services for all or part of:

• website delivery and protection;
• server infrastructure;
• Workers;
• the D1 database;
• Turnstile;
• network security functions.

Cloudflare acts in the role applicable to the service concerned and under the corresponding contractual terms.

Zoho Mail

Mamami’s team mailbox is hosted by Zoho Mail. Internal registration notifications are delivered there. Only authorised team members have access to it.

Where a transfer outside the European Economic Area requires a protection mechanism, we rely on an appropriate mechanism recognised by applicable law (see § 18).

Mamami does not sell personal data collected through the website.

Mamami does not rent email lists.

18. International transfers

Some technical providers may process data in more than one country.

Where a transfer of personal data outside the European Economic Area requires a particular protection mechanism, we rely on an appropriate mechanism recognised by applicable law.

Cloudflare’s Data Processing Addendum provides mechanisms including:

• applicable adequacy decisions, including the Data Privacy Framework where it can be relied on;
• European Commission Standard Contractual Clauses for the transfers concerned.

Zoho Mail hosts the team mailbox in its European region. We do not assume that all processing necessarily takes place within the European Union.

We therefore do not claim that all website data are necessarily processed exclusively in France.

19. Technical logs

Infrastructure may generate technical logs necessary for:

• service operation;
• error diagnosis;
• security;
• abuse detection.

These may contain technical data such as a network address, a timestamp, a requested route or other request information.

They are not used by Mamami to build a marketing profile.

Their retention depends on the technical service concerned and the configuration actually enabled.

Where Mamami controls or selects it, retention is limited to what security and diagnosis require.

20. Your rights

Subject to the conditions laid down by the GDPR, you may in particular request:

• access to your data;
• rectification;
• erasure;
• restriction of processing;
• objection to processing based on our legitimate interests;
• exercise of your right to portability where its legal conditions are met;
• withdrawal at any time of consent where processing relies on it.

You may also object at any time to the use of your data for marketing purposes.

To exercise your rights:

privacy@mamami.me

We may request information reasonably necessary to verify your identity where justified.

21. Complaints

If you believe your rights are not being respected, you may lodge a complaint with:

Commission nationale de l’informatique et des libertés — CNIL

Official website: cnil.fr

We also invite you to contact us first so that we can look into your request.

22. Automated decisions

Mamami does not use data collected through the website to make decisions about you based solely on automated processing that produce legal effects or similarly significant effects.

Automated security mechanisms such as Turnstile and rate limiting serve only to protect the form and the infrastructure.

23. Security

Mamami implements technical and organisational measures intended to reduce the risks of unauthorised access, loss, alteration and misuse.

These measures include in particular:

• HTTPS;
• request-size controls;
• rate limiting;
• anti-bot protection;
• limiting the data collected;
• pseudonymisation of certain technical data;
• limited retention periods;
• access controls;
• filtering of analytics fields;
• automatic deletion of certain technical data.

No information system can however guarantee absolute security.

24. Changes to this Policy

This Policy may change when:

• the website changes;
• new processing activities are introduced;
• a new provider is used;
• the Mamami company is incorporated;
• the Mamami application launches;
• the law changes.

The date at the top of the page indicates the version in force.

Significant changes will be brought to the attention of the people concerned where the law requires it.

25. Contact

For any question about data protection:

privacy@mamami.me