Privacy Policy

Last updated: 1 March 2026

1. Data Controller

Christophe Bouriel

Sole trader — SIRET 101 490 506 00017

IMM Les Frênes, 126 rue des Frênes, 74350 Cruseilles, France

Contact: contact@etchproof.eu

2. Core Principle: Your Document Never Leaves Your Device

ETcH is designed from the ground up never to receive the content of your files. The SHA-256 hash of your document is computed locally in your browser using the Web Crypto API. Only this cryptographic fingerprint — a 64-character hexadecimal string — is transmitted to the server.

A SHA-256 hash is a one-way function. It is mathematically impossible to reconstruct the original document from its hash. Your content remains strictly confidential, including from ETcH.

Learn more about how hashing works →

3. Data Collected and Legal Bases

Email address

Purpose: User identification, sending the confirmation link, delivering the proof artefact

Legal basis: Contract performance (Art. 6.1.b GDPR)

Retention period: Duration of service relationship + 3 years

SHA-256 hash of the file

Purpose: Anchoring on Ethereum, proof construction

Legal basis: Contract performance

Retention period: Indefinite on-chain (see §4); included in ZIP artefact

IP address and user-agent at confirmation

Purpose: Establishing the identity chain of the proof (probative value)

Legal basis: Legitimate interest (Art. 6.1.f GDPR) — the proof only has value if the identity of the person who triggered the act can be established

Retention period: Permanently included in the ZIP artefact delivered to the user; server log: 1 year

Stripe PaymentIntent ID

Purpose: Accounting and fiscal obligation

Legal basis: Legal obligation (Art. 6.1.c GDPR)

Retention period: 10 years (French commercial and tax law)

Anchored session record (hash, email, Ethereum tx, confirmation log)

Purpose: Service integrity, audit, user support

Legal basis: Legitimate interest + legal obligation (financial component)

Retention period: Indefinite for anchored sessions

Expired pending sessions

Purpose: None (automatic cleanup)

Legal basis:

Retention period: Anonymised or deleted within one year of expiry

Confirmation token

Purpose: One-time identity verification

Legal basis: Contract performance

Retention period: Deleted after use or on expiry (24 h)

Connection Data (French LCEN)

In compliance with Article 6-II of the French law on the Digital Economy (LCEN) and Decree 2011-219, ETcH retains connection data (IP address, timestamp, protocols used) for a minimum of 1 year from each operation. This data may be disclosed to judicial authorities upon lawful request.

4. Data on the Ethereum Blockchain

Anchoring on Ethereum is permanent and irreversible by design — this is precisely the value of the service. The hash of your document and the transaction timestamp are permanently recorded on the public Ethereum network.

This data does not constitute personal data: a SHA-256 hash is a cryptographic fingerprint that reveals nothing about the document's content. No third party can reconstruct your file from the hash recorded on the blockchain.

Accordingly, the right to erasure (Art. 17 GDPR) cannot apply to data inscribed on the blockchain. It does apply to ETcH's server-side data (email, IP address, session records), which can be anonymised upon request (see §6).

5. Sub-processors and Data Transfers

OVH

Role: Server hosting

Location: Switzerland (Zurich)

Safeguards: GDPR data processing agreement — adequate protection level

Stripe

Role: Payment processing

Location: USA / EU

Safeguards: Standard Contractual ClausesStripe Privacy Policy

Brevo

Role: Transactional email delivery

Location: France (EU)

Safeguards: GDPR sub-processor — data hosted in EU

Ethereum network

Role: Blockchain anchoring

Location: Worldwide (decentralised)

Safeguards: Public data by design — no personal data transmitted

No personal data is sold, rented or transferred to third parties for commercial purposes.

6. Your Rights

Under the GDPR, you have the following rights over your personal data held server-side by ETcH:

  • Right of access — obtain a copy of all data held about you by ETcH.
  • Right to rectification — have inaccurate data corrected.
  • Right to erasure — request deletion or anonymisation of your server-side data (email, IP address, session records). Note: this right does not apply to data inscribed on the Ethereum blockchain (see §4).
  • Right to data portability — receive your data in a structured, machine-readable format.
  • Right to object — object to processing based on legitimate interest.

To exercise your rights: contact@etchproof.eu

You may also lodge a complaint with your national supervisory authority. In France: CNIL — — 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07.www.cnil.fr

7. Cookies

ETcH uses no tracking, advertising or analytics cookies. The only cookies that may be set are those strictly necessary for the service to function (Stripe payment session). No consent is required for these technical cookies.

8. Security

Data is transmitted over HTTPS (TLS). The server runs on a secured VPS with SSH key-only authentication, an active firewall and automatic security updates. Ethereum private keys are never exposed in logs or API responses.

9. Amendments

This policy may be updated. The date of the last update is shown at the top of this page. In the event of a material change, a notice will be published on the site.


For any data protection enquiry: contact@etchproof.eu