Protection of the public data we re-process

Information on the processing of personal data in connection with the Dixit platform

privacy

Notice made under article 14 of the General Data Protection Regulation. Last updated: 10 September 2026.

1. About this notice

Dixit Platform SAS publishes dixitplatform.com, a political intelligence platform for public affairs professionals: in-house government relations teams, consultancies, trade associations, unions, foundations and public bodies.

To produce that intelligence, Dixit Platform re-processes public data concerning politicians, members of parliament, members of government, senior civil servants, interest representatives listed on the French High Authority for Transparency in Public Life (HATVP) register, and professionals taking part in official public debates.

Because those data were not collected directly from the individuals concerned, Dixit Platform makes this notice available to them under article 14 GDPR (EU 2016/679). This notice is the appropriate measure provided for in article 14(5)(b) GDPR, direct individual notification being impossible or requiring disproportionate effort given the number of individuals concerned.

2. Controller

The controller is:

Dixit Platform SAS
A French simplified joint-stock company with a share capital of EUR 14,000
Nanterre Trade and Companies Register, number 882 900 590
Registered office: 146 Boulevard Voltaire, 92600 Asnières-sur-Seine, France
President: Antoine Carbonell
Chief Executive Officer: Robin Osmont

3. Privacy contact

For any question about the processing of your personal data, or to exercise your rights, you may contact Dixit Platform's internal privacy contact:

Robin Osmont, Chief Executive Officer and internal privacy contact
Dedicated address: dpo@dixitplatform.com

Dixit Platform is not required to appoint a Data Protection Officer within the meaning of article 37 GDPR. The privacy contact function is carried out internally by the Chief Executive Officer.

4. Who is concerned

The categories of individuals whose public data Dixit Platform re-processes are the following:

  • French members of parliament: members of the National Assembly and senators

  • Members of the European Parliament, so far as their institutional activity is concerned

  • Members of government and of ministerial offices: ministers, secretaries of state and advisers, so far as their public institutional activity is concerned

  • Senior civil servants identified in the public exercise of their duties

  • Local elected representatives, where applicable and according to Dixit's scope at the relevant time, taking part in publicly broadcast institutional debates

  • Interest representatives listed on the HATVP register, in respect of their interest representation activity

  • Public affairs professionals taking part in officially broadcast public debates: parliamentary hearings, committees, institutional events streamed on official portals

Parliamentary staff and technical assistants are not re-processed in respect of their ordinary supporting activity. Where one of them takes part in an officially broadcast public debate, for example a public hearing, processing is limited to that specific contribution.

5. Purposes

Dixit Platform re-processes those public data for the following purposes:

  • Political intelligence: producing summaries, analyses, alerts and dashboards allowing the platform's customers to follow legislative, regulatory and institutional activity

  • Thematic mapping: allowing the platform's customers to identify the political and institutional figures competent on the subjects that concern them

  • Position tracking: following how the public positions of political and institutional figures develop on the issues that concern customers

  • Legislative monitoring: following amendments, votes, parliamentary questions and debates on legislative and regulatory texts

  • Transcription and indexing of public debates: allowing public interventions to be searched by text, with attribution to the speaker identified from public sources

6. Legal bases

Processing rests on the following legal bases:

  • Article 6(1)(f) GDPR, legitimate interests of Dixit Platform and of its customers in knowing and analysing public political and institutional activity. That legitimate interest has been the subject of a written balancing exercise against the rights and freedoms of the individuals concerned, which concludes that the legitimate interest prevails given the strictly public nature of the data re-processed and the absence of any reasonable expectation of confidentiality over data published by the institutions themselves.

  • Article 6(1)(c) GDPR, legal obligation, for the re-processing of HATVP data, whose public registration and communicability follow from the French Act of 11 October 2013.

  • Article 6(1)(e) GDPR, public interest task, for the purpose of informing the public about political life.

For the transcription of public debates and attribution to the identified speaker, which may in certain technical cases generate a voice signature capable of being treated as biometric data within the meaning of article 9 GDPR, processing rests on article 9(2)(e) GDPR: data manifestly made public by the data subject. Sources are strictly limited to official public portals: plenary and committee sittings of the French and European parliaments, officially broadcast parliamentary hearings, and sittings of the Council of the European Union streamed live on institutional websites.

7. Categories of data

The categories of personal data processed by Dixit Platform include:

  • Public identity data: surname, first name, offices, mandates, dates of taking up and leaving office

  • Political or organisational affiliation as made public: parliamentary group, party, organisation represented

  • Public professional contact details: constituency office address, institutional email, switchboard telephone number

  • Institutional output: interventions in sittings, amendments, private members' bills, parliamentary questions, reports, votes

  • Officially broadcast public statements: text transcription and, where applicable, attribution to the speaker

  • Social media posts made in the course of political or interest representation activity, where the accounts are public

  • Public declaratory information: HATVP declarations for interest representatives, and public declarations of assets and interests

No private-life data that have not been made public are processed. No special category data are processed beyond what follows from the public expression of political opinions by the individuals concerned in the exercise of their duties.

8. Sources

Data are collected from the following official public sources:

  • The website and open data of the French National Assembly (assemblee-nationale.fr)

  • The website and open data of the French Senate (senat.fr)

  • The European Parliament website (europarl.europa.eu)

  • The Official Journal of the French Republic and the Légifrance website

  • French government websites and open data, datagouv.fr, INSEE

  • The HATVP register of interest representatives (hatvp.fr)

  • The European Union Transparency Register

  • Official portals broadcasting sittings and hearings

  • Institutional websites: ministries and independent administrative authorities

  • The official public social media accounts of the individuals concerned

9. Recipients

The data re-processed are accessible to the following persons and entities:

  • Customers of Dixit Platform, subscribed to the platform under a commercial agreement. The list of customers is not public.

  • Authorised staff of Dixit Platform, strictly so far as necessary to carry out their duties.

  • Dixit Platform's technical sub-processors, whose list is kept up to date and available on request at dpo@dixitplatform.com.

The public institutional data processed by Dixit Platform are accessible to its customers through the platform's web interface, its application programming interface and its MCP connector, and therefore, where the customer so chooses, to the assistance tools it uses and for which it remains responsible.

Data are not sold to commercial third parties and are not made available to advertising organisations.

10. Transfers outside the European Union

Some of Dixit Platform's technical sub-processors are located outside the European Union, in particular in the United States: Postmark for transactional emails, OpenAI for language model analyses, HubSpot for customer relationship management, and GitHub for source code.

Language model analyses relying on Google Gemini are run through Vertex AI, under Google's Cloud Data Processing Addendum, rather than through the consumer Gemini interface. The endpoint used is the Vertex AI global endpoint, so processing may take place outside the European Union, and that transfer is covered by the same framework as those above.

Those transfers are covered by the following measures:

  • Standard contractual clauses adopted by the European Commission on 4 June 2021

  • Adequacy decisions where they exist

  • Adherence to the Data Privacy Framework for the providers concerned

  • Additional security measures: encryption in transit and at rest, restriction of the data transmitted, and a contractual undertaking from AI providers not to train language models on customer data

The detailed list of sub-processors and of the transfer bases is available on request at dpo@dixitplatform.com.

11. Retention

Dixit Platform applies a simple and traceable principle: the retention period of the public data it re-processes is aligned on the availability of the official public sources. For as long as the public source keeps the data, Dixit Platform keeps them too. As soon as the public source withdraws the data, Dixit Platform withdraws them too, within ninety (90) days of the unavailability being confirmed.

In practice:

  • Data relating to a current mandate or office: retained for as long as the data remain available on the institutional websites (National Assembly, Senate, European Parliament, Official Journal, Légifrance, the websites of the institutions concerned)

  • Data relating to a past mandate or office: retained for as long as the data remain available on the institutional websites. Once the individual leaves office, social media monitoring stops immediately. Only data already collected and still available on the official public sources continue to be retained

  • Data specific to HATVP interest representatives: retained for as long as the data remain available on the HATVP website (hatvp.fr). If the HATVP deletes the data, Dixit Platform deletes them too

  • Audio and video of public debates: retained for as long as the content remains available on the institutional websites that broadcast it

  • Transcripts of public debates: aligned on the retention period of the data relating to the individuals identified in the transcript

  • Technical backups: 7 days after the primary deletion

Anyone may obtain detailed information on the periods applying to their particular case by writing to dpo@dixitplatform.com. The full retention policy is documented in an internal procedure and is available on request.

12. Your rights

Under articles 15 to 22 GDPR, you have the following rights over your personal data processed by Dixit Platform:

  • Right of access: to obtain confirmation that data concerning you are being processed, and to receive a copy of them together with the associated information (article 15)

  • Right to rectification: to obtain the rectification of inaccurate or incomplete data (article 16)

  • Right to erasure: to obtain the deletion of your data in the cases provided for by the GDPR (article 17)

  • Right to restriction of processing: to obtain the temporary freezing of processing (article 18)

  • Right to portability: to receive your data in a structured and reusable format (article 20)

  • Right to object: to object, on grounds relating to your particular situation, to the processing of your data (article 21)

  • Right not to be subject to an automated decision: Dixit Platform carries out no automated decision-making within the meaning of article 22 (article 22)

How to exercise your rights

You may exercise your rights at any time by writing to:

dpo@dixitplatform.com

Your request will be handled within one month of receipt, in accordance with article 12(3) GDPR. That period may be extended by a further two months where the request is complex, in which case you will be informed within the initial month.

To help us handle your request, please state in your email:

  • The nature of your request: access, rectification, erasure, objection and so on

  • Your identity and, where applicable, your public office

  • The precise subject of the request, for example the deletion of a specific item of data, or an objection to the monitoring of your social media activity after leaving office

If you are a former elected representative or a former member of government and you wish Dixit Platform to stop re-processing data relating to your activity after leaving office, your request will be handled as a priority and will receive an answer suited to your particular situation.

Right to complain

If, after contacting us, you consider that your rights have not been respected, you have the right to lodge a complaint with:

Commission Nationale de l'Informatique et des Libertés (CNIL)
3 place de Fontenoy
TSA 80715
75334 Paris Cedex 07, France
Website: www.cnil.fr

You may also lodge a complaint with the supervisory authority of the Member State of your habitual residence.

13. Why there is no direct individual notification

Several thousand individuals are concerned by the processing described here: French and European parliamentarians, members of government, senior civil servants, HATVP interest representatives, and professionals taking part in official public debates. Direct individual notification, by post or by email to each individual, is in practice impossible or requires disproportionate effort.

In accordance with article 14(5)(b) GDPR, Dixit Platform puts in place this public notice as an appropriate measure to protect the rights, freedoms and legitimate interests of the individuals concerned. This notice is:

  • Accessible without authentication and indexable by search engines

  • Updated as soon as a significant change in the processing warrants it

  • Visibly linked from the website's privacy policies and general terms

  • Complete as regards the information required by article 14 GDPR

This approach follows the recommendations of the public affairs GDPR guide published jointly by ACAP, AFCL, APAP and SCRP in 2024.

For interest representatives listed on the HATVP register, public registration also constitutes information laid down by law within the meaning of article 14(5)(c) GDPR.

This notice is reviewed annually by Dixit Platform's internal privacy contact. Any substantial change is recorded in the version history, available on request at dpo@dixitplatform.com.

Version history: version 1.0 of 13 May 2026, version 1.1 of 9 September 2026, version 1.2 of 10 September 2026.

Version in force since September 10, 2026. Every published version is archived at a permanent address, listed on the Legal documents page.