Privacy Policy
Draft V03 — 20 October 2026. This notice describes documented aspects of the PJP project. It is not a final policy: the identified points must be checked before publication and before the relevant data collection begins.
1. Controller and contact
Marc Herry, a French sole trader operating as Private Journey Planner, is the intended controller for processing connected with his business. Supplied address: 109 Impasse de la Rousselle, 12700 Naussac, France. For data questions or requests: contact@privatejourneyplanner.com.
2. Privacy Policy: Documented data and purposes
The draft Wix contact forms request contact and travel-project information: first name, last name, email, destination or project, dates and message, depending on the form version. They are intended to receive enquiries and prepare a response. Fields marked with an asterisk are required by the form; it cannot be submitted without them. Differences between the French and English fields still require review in a separate intervention.
The planning questionnaire covers contact details, travellers and children, destinations, dates, budget, preferences, transport, accommodation and specific needs. Its purpose is to prepare a tailored proposal. The retrieved document also requests travellers’ names; the necessary scope must be decided before use. Do not enter passport or identity-document copies or numbers, or payment-card information, in free-text fields.
The planned commercial workflow covers enquiries, quotations, orders, deliverables, correspondence, payment amounts and references, invoicing and evidence of acceptance or early-performance requests. This notice does not state that the complete workflow is operational.
Review of the PJP Airtable schema also confirms fields for nationality or travel document used, document validity, declared health or vaccination information and travel preferences. The presence of these fields does not demonstrate their necessity or collection from real clients. The French and English Wix planning questionnaires have been identified: each contains 44 response fields across 11 steps. Access is password-protected. This technical identification does not validate the necessity of every requested item or the processing of sensitive information.
3. Legal bases requiring review
For quotations and planning requested by the person, the basis to assess is taking pre-contractual steps; for an ordered service, performance of the contract. Retention required by accounting or tax legislation relies on the relevant legal obligation. These are proposed classifications to be reviewed for each processing activity; they do not establish how the tools are actually configured.
Other enquiries, security, any marketing and dispute handling require separate documented assessment. Submitting a form is not blanket consent to every use.
4. Sensitive information and other travellers
Allergies, medical treatments or mobility needs may reveal health information. The existing questionnaire anticipates collecting it, but an Article 9 GDPR condition, appropriate information and, if selected, a separate explicit-consent mechanism have not been demonstrated. This is a blocking issue before real collection of this information. Avoid medical details in the general contact form.
These data require both an Article 6 legal basis and an exception to the Article 9 prohibition. Accepting the Terms and Conditions does not demonstrate explicit consent to this processing. Information collected must be limited to what is necessary.
Arrangements for informing other travellers and protecting children’s data remain to be defined. A customer completing a questionnaire on their behalf does not remove PJP’s obligation to examine these issues.
5. Tools and recipients
Wix is used for the website and its forms. Professional Gmail is used for correspondence. Airtable and Make are already present in PJP’s preparation and automation environment; technical records show client, trip, document and payment tables and workflows under preparation. They do not establish that every Wix enquiry is automatically transferred to those tools.
An isolated test environment is being prepared to transfer Wix questionnaire answers to Make and then to an Airtable test base, for AI-assisted analysis and preparation of a Travel Brief. Make scenario 8101177 is inactive according to the R03 record. This test environment does not demonstrate activation of commercial processing. The AI provider and model actually used, access permissions, contractual safeguards and retention periods for copies must be confirmed before real personal data are processed.
Actual access, transmitted data categories, processors and any artificial-intelligence services must be inventoried for each flow. The documented commercial scenario and withdrawal protections remain under preparation. This notice does not announce their activation.
Payment card and PayPal are planned payment methods. The contracts, connections and actual providers selected remain to be confirmed. The draft payment page does not collect bank details directly; this does not establish the absence of processing by an external payment provider.
AI assistance actions are configured in Airtable to analyse raw questionnaire answers and prepare the Travel Brief, research, itinerary and documentary checks. Some actions use an entire record; an AI summary field also references trip attachments. Bright Data web search and webpage-reading tools are configured in some actions. An Airtable script includes a call to a Make webhook in the EU1 zone. These configuration findings do not prove that every flow has run on real data or that processing is exclusively European. The models actually used, recipients, access, contractual safeguards and retention of copies remain to be checked. Do not provide medical information in free-text answers or attachments intended for these processes before the safeguards are validated.
6. Retention and transfers
Enquiries without an order: data are retained for 12 months after the enquiry is closed.
French and English questionnaires: complete answers are deleted no later than 3 months after the case is closed. Detailed operational data used to prepare and revise the trip are also deleted no later than 3 months after closure, except where a legal obligation requires specific information to be retained.
Client record and useful relationship history: a limited record may be kept for client relationship and loyalty communications for up to 3 years after the commercial relationship ends or the last relevant contact initiated by the client, as applicable. This record is separate from the operational case file. Complete questionnaires are not retained for loyalty campaigns, and sensitive information contained in answers must not be transferred to marketing files.
Invoices and accounting records: retained for 10 years from the end of the relevant financial year. Other legal retention obligations apply only to the records that must be retained; they do not justify keeping the complete questionnaire. Required records are kept separately with restricted access.
Archiving a case is not deletion. The periods above define the retention policy decided by PJP; they do not demonstrate that automated deletion of every copy has already been implemented.
Contractual safeguards, processing countries and any access from outside the European Economic Area remain to be checked for PJP’s accounts. Provider documentation describes international processing; Airtable notably states that US hosting is the default. This draft does not guarantee exclusively European hosting or that safeguards have already been verified for PJP.
Wix’s public documentation distinguishes the Irish hosting entity from the initial recipient of visitor data, Wix.com Ltd in Israel. Its processing agreement provides for adequacy for that transfer and standard clauses or other Article 46 safeguards for certain onward transfers. This is the provider’s documented framework, not validation of every PJP data flow.
Airtable’s public agreement annex does not anticipate sensitive data. Before health data are transferred to this tool, contractual suitability and the safeguards actually agreed must therefore be checked; a generic agreement does not validate this processing.
The retention periods above were approved by PJP on 24 October 2026. Automated deletion rules are being prepared; no deletion automation is being created or activated in this intervention. The Airtable automation named “Immediate archiving after delivery” updates the file and does not demonstrate deletion. Conditional clearing of temporary fields does not demonstrate erasure of all operational copies, logs or backups. Provider-side deletion and backup arrangements remain to be specified; no unverified provider retention or deletion period is promised.
7. Your rights
Subject to GDPR conditions, you may request access, rectification, erasure or restriction and, where applicable, portability or objection. Where processing relies on consent, you may withdraw it without affecting earlier lawful processing. Email contact@privatejourneyplanner.com with your request and information enabling your file to be located. Proportionate identity verification may be needed; an identity-document copy is not systematically required.
Contact details and a limited client relationship history may be used for loyalty communications only where permitted by the applicable legal conditions, with consent obtained where required. You may object easily, free of charge and at any time by emailing contact@privatejourneyplanner.com. Your data must then no longer be used for these commercial communications. Minimal information may be kept separately solely to ensure that your objection is respected.
The usual response period is one month; a further two months may apply under GDPR conditions, with notification within the first month. You may complain to the French supervisory authority, CNIL: https://www.cnil.fr/fr/plaintes.
8. Automated decisions and cookies
The questionnaire AI analysis provides for a completeness score and AUTO, REVIEW or BLOCK outputs. These outputs do not by themselves demonstrate a solely automated decision with legal or similarly significant effects. Actual effects, human controls and opportunities to challenge decisions remain to be checked before reaching any conclusion under Article 22 GDPR.
Cookies are addressed in a separate provisional notice. The unresolved points above prevent this policy from being described as complete and ready for publication.