Article 01Data controller
SAIME3i, a consulting and strategic intelligence firm, determines the purposes and means of the processing described in this policy.
Registration: N° 47036025 — RAKEZ — Address: VUNE2844, Compass Building - Al Hulaila. Al Hulaila Industrial Zone - FZ, Ras Al Khaima, UAE
Contact: contact@saime3i.com
No data protection officer has been appointed, the nature and volume of processing not requiring such appointment. Any question concerning personal data is handled directly by the firm’s founder and receives a written response.
A register of processing activities is maintained and available upon reasoned request.
Article 02Our principles
Our profession consists in establishing what is verifiable and distinguishing what is not. That requirement applies to our own handling of data.
- Open sources only. We employ no non-public collection method, no intrusion, no unauthorised access, no surveillance of individuals.
- Minimisation. We collect only what is necessary to the purpose pursued, and seek no special category data.
- No resale, no marketing. Your data is neither sold, rented, transferred, nor used for prospecting.
- No tracking. Our website sets no advertising cookie and uses no audience measurement tool.
- No automated decision-making. Our conclusions result from human analysis. No automated profiling produces effects concerning any person.
We never reach a conclusion about a person. Our verdicts bear on assertions, with their sources and their limits.
Article 03If you are a prospect or client
This processing concerns persons who contact us, correspond with us, or entrust us with an engagement.
Data processed
- Identity, role, organisation
- Professional contact details
- Content of exchanges and description of the request
- Information provided in the course of an engagement
- Billing data
Purposes and legal bases
| Purpose | Legal basis |
|---|
| Handling an incoming request and conducting the scoping call | Pre-contractual measures at your request |
| Issuing a proposal and performing the engagement | Performance of the contract |
| Invoicing, accounting, recovery | Legal obligation and performance of the contract |
| Traceability of work and defence in the event of challenge | Legitimate interest |
We use your data for no marketing purpose. Should we send you a publication, it is only following your explicit request, and every message includes a means of unsubscribing.
Article 04If you are subject to a verification
This section concerns you if an organisation engaged us to verify an entity of which you are a director, partner, agent or legal representative. Your data is then processed without having been collected from you.
What we process
- Your identity and roles, in your professional capacity alone
- Your corporate offices and declared shareholding links
- Public mentions concerning you in the press and official publications
- Your entries in public registers
- Published decisions concerning you as representative of an entity
Where this data comes from
From publicly accessible sources, exclusively. Commercial registers, official publications, institutional transparency portals, the press, public communications of the entity concerned.
We carry out no collection from you, from a private third party, or by any non-public means. We access no protected data. We do not monitor you.
What we never process
- No special category data — origin, political opinions, beliefs, health, sexual life, trade union membership
- No data concerning your private life unconnected to your professional capacity
- No data concerning your relatives
Should such data appear incidentally in a public source, it is neither used nor reported in our work.
Why we do it — legal basis
This processing rests on legitimate interest: our client’s interest in assessing a risk before committing contractually or financially, and our own in carrying on our activity. That basis requires a balancing exercise, which we have conducted and summarise here.
Balancing exerciseNecessity. An organisation about to contract cannot assess an entity’s reliability without considering the persons who direct and bind it.
Proportionality. Processing is confined to public sources, seeks no special category data, bears on your professional capacity alone, is limited in time to the engagement, and its results are communicated to the commissioning party alone.
Reasonable expectations. A director may reasonably expect that their offices, mandates and public professional record will be consulted by a partner about to contract with their organisation.
Safeguards. Our verdicts bear on assertions and never on persons. Every deliverable states what could not be established, and expressly specifies that such a statement constitutes neither an accusation nor a denial. Every source is traced and dated.
Who receives this data
The commissioning party alone. No third party, no resale, no pooling between engagements. Where applicable, an affiliated analyst or correspondent working on the engagement, bound by equivalent confidentiality obligations.
For how long
The duration of the engagement plus three years. That period allows us to substantiate every element of our conclusions should they be challenged — which is a safeguard for you as much as for our client. Thereafter, data is deleted.
Your rights in this situation
You hold the rights listed in Article 9, and in particular a right to object, exercisable at any time on grounds relating to your particular situation.
A request to object or to erase is examined case by case. It may be refused where retention remains necessary for the establishment, exercise or defence of legal claims — in particular where our conclusions are subject to challenge. Any refusal is set out in writing with reasons.
We are unable to disclose our client’s identity, that information being covered by professional confidentiality and by our contractual undertakings.
Article 05Website visitors
Our website sets no cookie for audience measurement, tracking or advertising. We employ no behavioural analysis tool.
The only data processed is that which you voluntarily enter in the scoping form: name and organisation, email address, nature of the need, description of your situation, and your consent.
Our host retains technical logs — IP address, timestamp, request type — for security and operational reasons. These logs are not used for analytical purposes and are purged according to the host’s schedule.
Article 06Recipients and processors
Your data is neither sold, rented, nor transferred to third parties for commercial purposes.
It may be processed by the following technical providers, acting on our instructions and bound by contract:
| Provider | Role |
|---|
| Vercel Inc. (440 N Barranca Avenue #4133, Covina, CA 91723, USA) | Website hosting and technical logs |
| n8n — the firm's own infrastructure, hosted on its own server | Routing and processing of requests submitted via the contact form |
| Cloudflare, Inc. | Routing of incoming email to the firm's mailbox |
Affiliated analysts and correspondents. Some engagements require an analyst or local correspondent. Each is bound by a contract containing confidentiality and data protection obligations equivalent to our own, together with a declaration of interests.
Authorities. Your data may be communicated to competent authorities where the law so requires.
Article 07Transfers outside the European Union
Some of our technical providers, as well as some of our local correspondents, are established outside the European Union. Transfers of data may therefore occur.
Such transfers are governed by the appropriate safeguards provided for under applicable regulation — in particular the standard contractual clauses adopted by the European Commission, or any other recognised mechanism.
You may obtain details of the safeguards implemented upon request to contact@saime3i.com.
Article 08Retention periods
| Data | Period |
|---|
| Request not pursued | 3 years from last contact |
| Client relationship | Duration of the relationship, then 3 years |
| Deliverables, sources consulted and working papers | Duration of the engagement, then 3 years |
| Data concerning verified third parties | Duration of the engagement, then 3 years |
| Accounting and billing records | Applicable statutory period |
| Host technical logs | Per the host’s schedule |
Why three yearsOur conclusions are valid as at a date, within a scope and with determined sources. Retaining these elements allows us to substantiate every assertion in a deliverable should it be challenged — by our client, by a third party, by an auditor or by a court.
Premature deletion would deprive all parties of that possibility. This retention is therefore a safeguard, not a convenience.
Beyond these periods, or upon an admissible request, data is securely deleted.
Article 09Your rights
AccessObtain confirmation that processing concerns you, and a copy of the data held.
RectificationHave inaccurate data corrected or incomplete data completed.
ErasureRequest deletion of your data, in the cases provided for by regulation.
RestrictionRequest suspension of processing in certain circumstances.
ObjectionObject, on grounds relating to your particular situation, to processing based on legitimate interest.
PortabilityReceive the data you provided to us, in a structured, machine-readable format.
To exercise these rights: contact@saime3i.com. We respond within one month, extendable by two months for complex requests, of which you would be informed.
We may request proof of identity where the request leaves reasonable doubt as to the identity of the requester.
Limits. A right may be restricted where retention remains necessary to comply with a legal obligation, or for the establishment, exercise or defence of legal claims. Any refusal, whole or partial, is set out in writing with reasons.
Article 10Security
- Encryption of data in transit and of storage media
- Strong authentication across all professional accounts
- Access limited to the founder, save contractual engagement of an affiliate on a specific mandate
- Strict compartmentalisation of files: no information flows between engagements
- Prior anonymisation of third-party data before any processing involving an external automated system, identifiers being restored outside those systems
- Encrypted backup with periodic restoration testing
- Secure deletion upon expiry of retention periods
In the event of a data breach likely to result in a risk to your rights and freedoms, we inform the competent authority and, where the risk is high, the persons concerned, within the regulatory time limits.
Article 11Contact and complaints
For any question concerning this policy or the exercise of your rights: contact@saime3i.com. Every request receives a written response.
If you consider that the processing of your data does not comply with applicable regulation, you have the right to lodge a complaint with a supervisory authority — in France, the Commission nationale de l’informatique et des libertés, whose website is accessible at cnil.fr.
Version 2.0 — July 2026. Any change gives rise to a numbered and dated version.