Privacy policy

Last updated: 5 August 2026

Introduction

WEB VENTURE places particular importance on the protection of personal data.

This policy explains how WEB VENTURE, trading as Kemea, collects and processes personal data in connection with:

• the kemea.ai website;
• the dfordirect.com website;
• professional communications relating to Kemea’s services;
• B2B commercial outreach carried out from addresses using the dfordirect.com domain.

Personal data is processed in accordance with Regulation (EU) 2016/679 of 27 April 2016 (“GDPR”) and applicable French law.

1. Data controller

The data controller is:

WEB VENTURE
A French limited liability company (SARL) with share capital of €7,700
Trading name: KEMEA
59 rue de Ponthieu
75008 Paris
France

Paris Trade and Companies Register: 382 668 002 R.C.S. Paris
VAT identification number: FR94 382 668 002

For any question or request relating to personal data: privacy@kemea.ai.

2. People covered by this policy

This policy applies in particular to:

• visitors to kemea.ai and dfordirect.com;
• representatives, directors, employees and professional contacts of hotels and hotel groups;
• professional partners and prospects;
• people communicating with WEB VENTURE in relation to Kemea.

Kemea’s services are intended for professional use and are not aimed at individual consumers.

3. Personal data that may be processed

Depending on the relationship with WEB VENTURE, the data processed may include:

Identity and professional data

• first and last name;
• job title;
• company or property represented;
• publicly available professional information.

Professional contact details

• professional email address;
• professional telephone number;
• business address.

Communication data

• content of messages exchanged;
• requests for information;
• replies;
• outreach history;
• prospecting status;
• objection requests.

Property-related information

• property name;
• address;
• website;
• publicly presented categories, services and amenities;
• public profiles and listings;
• other publicly available professional information.

Technical data

• IP address;
• date and time of access;
• browser and device;
• technical and security logs;
• information required for the operation, availability and protection of the websites.

WEB VENTURE does not request sensitive data. Individuals should not send health data, information relating to criminal offences, identity document numbers, full banking data or any other data unrelated to the purpose of the communication.

4. Sources of personal data

Personal data may be collected:

• directly from the individual;
• from their employer, property or organisation;
• through previous professional communications;
• from a property’s official website;
• from publicly available business listings;
• from professional directories, company registers, professional pages or institutional websites;
• from technical service providers required for hosting, email or security.

Where professional contact details are obtained indirectly for outreach purposes, the required information about the processing, the source of the data and the individual’s rights is provided no later than at the time of the first contact, including by means of a link to this policy.

5. Purposes and legal bases

Operating and presenting the websites

Technical data required to load, maintain, protect and make the websites available is processed on the basis of WEB VENTURE’s legitimate interest in providing and securing its online services.

Responding to requests and managing communications

Information provided to WEB VENTURE is used to answer requests, follow up communications and prepare a possible professional relationship.

Depending on the circumstances, this processing is based on pre-contractual steps requested by the individual or on WEB VENTURE’s legitimate interest in managing its professional relationships.

B2B commercial outreach

WEB VENTURE may use professional contact details to present Kemea’s services where the communication is directly relevant to the recipient’s professional role or activity.

This outreach is based on WEB VENTURE’s legitimate interest in developing its business, subject to clear information and a simple, free right to object.

Initial commercial communications are sent from addresses using the dfordirect.com domain.

Managing objections

Strictly necessary information is retained to record and respect objections and to avoid unintended future outreach.

This processing is based on the need to respect individuals’ rights and the rules applicable to commercial outreach.

Security and prevention of abuse

Technical data may be used to protect the websites, systems and communications against unauthorised access, abuse, incidents and attempted fraud.

This processing is based on WEB VENTURE’s legitimate interest in securing its services.

Legal obligations and defence of rights

Certain data may be retained or disclosed where necessary to comply with a legal obligation, respond to a competent authority or establish, exercise or defend legal rights.

6. Professional outreach and the right to object

WEB VENTURE may send commercial communications to professional contacts where the message is relevant to their role and the activity of their organisation.

Each message must make it possible to identify WEB VENTURE or Kemea, understand the professional nature of the communication and object easily and free of charge to future outreach.

An individual may object:

• by replying “stop” to the message received;
• or by emailing privacy@kemea.ai.

Any objection is recorded as soon as reasonably possible and used to prevent further commercial outreach to the relevant address.

WEB VENTURE does not sell personal data and does not disclose contact details to third parties for their own marketing without an appropriate legal basis.

7. Recipients and service providers

Personal data is accessible only to:

• authorised persons within WEB VENTURE;
• service providers required for the hosting and security of the websites;
• professional email and collaboration service providers;
• advisers and competent authorities where required by law.

As of the date of this policy, the kemea.ai and dfordirect.com websites are hosted by OVH.

Service providers act only within the scope of their assigned tasks and under the applicable contractual terms.

8. Transfers outside the European Economic Area

Some technical service providers may be established in, or make data accessible from, countries outside the European Economic Area.

Where personal data is transferred, WEB VENTURE relies on a mechanism recognised by applicable law, such as an adequacy decision, the European Commission’s Standard Contractual Clauses accompanied where necessary by additional safeguards, or another appropriate lawful mechanism.

Further information about the applicable safeguards may be requested at privacy@kemea.ai, subject to confidential or legally protected information.

9. Retention periods

Prospecting data

Data used for prospecting purposes is retained for three years from collection or from the last contact initiated by the prospect.

A unilateral message sent by WEB VENTURE does not extend this period.

Objection list

Information strictly necessary to respect an objection is retained for at least three years from the request and is then reviewed to avoid unintended future outreach.

It is used only for that purpose.

Professional communications

Messages and information required to manage a professional relationship may be retained for the duration of the communications and then archived for a period proportionate to evidentiary needs and the defence of WEB VENTURE’s rights, within applicable legal retention periods.

Technical and security logs

Technical and security logs are retained for a limited period, generally between six and twelve months, unless an incident, specific legal requirement or documented evidentiary need justifies a longer period.

Data subject requests

Information relating to the exercise of rights is retained for the time needed to handle the request and then for up to five years in order to demonstrate the response and compliance with applicable obligations.

At the end of the applicable retention period, data is deleted, anonymised or placed in a restricted-access intermediate archive where required by law or justified by potential litigation.

10. Security

WEB VENTURE implements technical and organisational measures proportionate to the risks, including:

• access control and restriction;
• encryption of communications;
• protection of systems and accounts;
• technical logging;
• appropriate backups;
• security updates;
• incident management;
• contractual oversight of service providers.

No system can guarantee absolute security. Anyone who becomes aware of a vulnerability or unauthorised access is asked to contact privacy@kemea.ai promptly, without exploiting or publicly disclosing the issue.

11. Individual rights

Subject to the conditions provided by applicable law, individuals may request:

• access to their data;
• rectification;
• erasure;
• restriction of processing;
• data portability where applicable;
• objection to processing based on legitimate interests;
• withdrawal of consent where processing is based on consent.

The right to object to commercial outreach may be exercised at any time, free of charge and without providing a reason.

To exercise a right, individuals may contact:

privacy@kemea.ai

or write to:

WEB VENTURE
59 rue de Ponthieu
75008 Paris
France

Proof of identity will be requested only where there is reasonable doubt and only to the extent necessary.

Individuals may also lodge a complaint with the French Data Protection Authority (CNIL):

CNIL
3 place de Fontenoy
TSA 80715
75334 Paris Cedex 07
France

12. Cookies and similar technologies

Information relating to cookies and similar technologies is set out in the Cookie Policy available on kemea.ai.

In their current version, the websites do not use advertising cookies, audience-measurement tools requiring consent or non-essential personalisation mechanisms.

This policy will be updated before any new technology is activated that would change this position.

13. Changes to this policy

WEB VENTURE may update this policy to reflect changes to the websites, services, service providers or applicable law.

The date of the latest update is shown at the top of the document. The version published on kemea.ai is the version currently in force.