Privacy policy

Last updated: September 2026

KLS Records Publishing places particular importance on the protection of your personal data.

This Privacy Policy is intended to provide you with clear and transparent information about the personal data that may be collected when you use the website comptinesausoleil.com, the purposes for which this data is processed, the persons who may have access to it, and your rights.

This policy applies to the processing of data carried out by KLS Records Publishing in connection with the website comptinesausoleil.com and the services associated with Comptines au Soleil.

1. Data Controller

The data controller for the processing of personal data described in this policy is:

KLS Records Publishing
SASU with share capital of EUR 2,000
Registered office: 8 Résidence du Parc de Petit-Bourg, 91000 Évry-Courcouronnes, France
RCS Évry: 853 113 520
E-mail: admin@kls-records-publishing.com

For any questions relating to the protection of your personal data or to exercise your rights, you may contact KLS Records Publishing at this address.

2. What Personal Data Is Collected?

We apply a data minimisation principle: only data necessary for the purposes pursued is collected.

In connection with the services currently offered, we may in particular process the following data:

Data You Provide Directly

When you request to receive free content or a resource offered by Comptines au Soleil through our lead-generation funnel, we may collect:

  • your first name;

  • your e-mail address;

  • any information you choose to provide to us in the course of your communications with us.

Fields that are necessary to provide the requested content are identified as such on the relevant form.

In this context, we do not ask you to provide special categories of personal data within the meaning of Article 9 of the GDPR.

Technical and Browsing Data

When you visit our website, certain technical information may be processed automatically, particularly in connection with audience measurement, subject to your consent where required:

  • IP address or technical information associated with your connection;

  • device and browser type;

  • pages visited;

  • date and time of visits;

  • data relating to browsing and interactions with the website;

  • statistical data relating to the use of the website.

This information may in particular be processed by Google Analytics, under the conditions described below.

3. What Are Your Data Used For?

Your personal data may be processed for the following purposes:

A. Provision of Requested Resources

When you provide your e-mail address in order to receive a kit, resource or free content offered by Comptines au Soleil, your data is used to:

  • record your request;

  • send you the requested content;

  • ensure the communications necessary for the delivery of this content;

  • follow up on your request.

B. Lead Management

When you agree to receive our commercial communications, your contact details may be used to:

  • send you content, advice and resources;

  • present Comptines au Soleil’s products and services to you;

  • inform you of our news;

  • offer you commercial offers;

  • manage our relationship with you.

C. Website Audience Measurement

Subject to your consent where required, we use Google Analytics to measure traffic to and use of our website and to improve its content and operation.

Google Analytics notably provides statistics relating to visits, pages viewed and use of the website.

Google states that, for users located in the European Union, IP addresses are not individually recorded or stored by Google Analytics, although they may be used temporarily to determine approximate location information. (Google Analytics Help)

D. Compliance with Our Legal Obligations

Certain data may also be processed where necessary to:

  • comply with a legal or regulatory obligation;

  • respond to a request from an administrative or judicial authority;

  • establish, exercise or defend a legal claim.

4. What Are the Legal Bases for Processing Your Data?

Depending on the processing concerned, KLS Records Publishing relies in particular on the following legal bases provided for by Article 6 of the GDPR.

Performance of a Service or Pre-contractual Measures

Data necessary to respond to a request made by the user, including the delivery of a requested resource, may be processed in order to perform the requested service or take the measures necessary to provide it.

Consent

Your consent is used in particular where required by applicable regulations, especially for:

  • sending commercial communications by e-mail to individuals;

  • certain cookies and trackers used for audience measurement;

  • certain tracking mechanisms that may be used in electronic communications.

Consent must result from a positive action on your part and cannot be inferred from your mere use of the website. For electronic commercial prospecting directed at individuals, the CNIL notably requires prior consent obtained through a positive action, such as an unchecked checkbox. (CNIL)

You may withdraw your consent at any time.

Legal Obligation

Certain data may be retained or processed in order to comply with legal obligations to which KLS Records Publishing is subject.

Legitimate Interest

In certain cases, we may process data on the basis of our legitimate interest, in particular to ensure website security, prevent fraudulent use, defend our rights or manage certain operations necessary for our activities, provided that this does not disproportionately affect your rights and freedoms.

5. Commercial Prospecting by E-mail

When you are an individual, we use your e-mail address to send you commercial communications only when we have an appropriate legal basis and, where required by law, your prior consent.

Where consent is requested by means of a checkbox, it must be unchecked by default.

Requesting and receiving free content does not, in itself, constitute consent to receive commercial communications.

The CNIL states that electronic commercial prospecting directed at individuals generally requires prior consent, which must be freely given, specific, informed and unambiguous. (CNIL)

Each commercial communication sent by e-mail includes a simple means of unsubscribing.

You may also withdraw your consent at any time by contacting us at admin@kls-records-publishing.com.

6. Unsubscription Management

Each commercial prospecting e-mail includes, where technically applicable, a link allowing you to unsubscribe simply and free of charge.

When you unsubscribe, your data is removed from the lists used to send the relevant commercial communications.

Certain minimum information may nevertheless be retained on an opposition list in order to comply with your request not to receive commercial communications and to prevent involuntary re-registration.

The CNIL recommends that information necessary to take an objection into account be retained for at least three years and used only for this purpose. (CNIL)

7. E-mail Tracking

Certain e-mailing solutions may technically allow interactions with sent messages to be measured, including opens or clicks.

Where such tracking mechanisms are used, they may make it possible to associate certain actions with an identified recipient.

KLS Records Publishing undertakes to implement these features in accordance with applicable regulations and CNIL recommendations.

In April 2026, the CNIL published a specific recommendation concerning tracking pixels in e-mails. Certain uses, particularly for marketing purposes, require consent. (CNIL)

Important: this clause is deliberately drafted in conditional terms. It will need to be adjusted if we precisely confirm the tracking features currently enabled in your systeme.io account.

8. Use of systeme.io

To manage lead collection, delivery of resources and the sending of electronic communications, KLS Records Publishing uses the systeme.io platform, operated by ITACWT Limited, a company incorporated under Irish law.

The data entered in the relevant forms may in particular be transmitted to systeme.io in order to enable:

  • contact registration;

  • contact list management;

  • delivery of requested resources;

  • sending of e-mails;

  • automation of communication sequences;

  • management of unsubscribes;

  • and, where the corresponding features are enabled, tracking of interactions with communications.

The privacy policy published by systeme.io states in particular that ITACWT Limited is established in Ireland and that data is hosted on AWS servers located in Ireland. (Systeme.io)

KLS Records Publishing ensures that processing carried out on its behalf by its service providers is contractually governed in accordance with the requirements of the GDPR.

9. Google Analytics

The website comptinesausoleil.com uses Google Analytics for audience measurement purposes.

Where consent is required, the relevant Google Analytics features are activated only after the user’s consent has been obtained.

Google Analytics notably makes it possible to measure:

  • the number of visitors;

  • pages viewed;

  • the duration and general characteristics of visits;

  • interactions with the website;

  • certain technical data relating to devices and browsers.

Google provides settings that notably make it possible to limit certain categories of data collected and manage consent signals. (Google Analytics Help)

Processing carried out by Google in connection with Google Analytics is governed by Google’s applicable data protection terms. (Google Analytics Help)

The specific arrangements for placing and managing Google Analytics cookies are described in our Cookie and Other Tracker Policy.

10. Data Recipients

Personal data is intended for the persons and organisations that need access to it for the purposes described in this policy.

This may include:

  • authorised persons within KLS Records Publishing;

  • our technical service providers;

  • systeme.io, for lead management and electronic communications;

  • Google, in connection with Google Analytics where this feature is enabled;

  • our IT and hosting service providers, where their involvement requires access to certain data;

  • administrative or judicial authorities where required by law.

KLS Records Publishing does not sell the personal data of its prospects or users to third parties.

We do not provide your contact details to commercial partners so that they may conduct their own commercial prospecting, unless we inform you and obtain your specific consent where required.

11. Transfers of Data Outside the European Union

Where possible, we favour service providers and infrastructures that enable data to be processed within the European Economic Area.

Certain service providers may nevertheless process certain data outside the European Union or the European Economic Area.

Where this is the case, KLS Records Publishing ensures that such transfers are governed in accordance with Chapter V of the GDPR, in particular by means of an adequacy decision, standard contractual clauses or any other legally applicable mechanism.

Google states in particular that, depending on the circumstances, it uses mechanisms such as the EU-U.S. Data Privacy Framework or standard contractual clauses for certain international transfers related to its services. (Business Data Responsibility)

12. Retention Period

We do not retain your personal data for longer than necessary for the purposes for which it was collected, except where a longer retention period is required or permitted by law.

Data Necessary to Provide a Resource

Data necessary to deliver a free resource is retained for the period necessary to manage your request and, where you have also consented to receive commercial communications, in accordance with the retention period applicable to prospecting data.

Prospect Data

Data used for commercial prospecting is retained for the period necessary for this purpose and, in accordance with CNIL recommendations, for up to three years from its collection or the last contact initiated by the prospect, unless consent is withdrawn or an earlier erasure request is made. (CNIL)

Data Relating to Objections

Information strictly necessary to keep a record of an objection to commercial prospecting may be retained for a period that makes it possible to ensure compliance with that objection, in particular in accordance with CNIL recommendations. (CNIL)

Data Relating to Google Analytics

Statistical data is retained in accordance with the retention settings configured in our Google Analytics property, within the limits necessary for the audience measurement purpose.

Data That May Be Retained for Legal Reasons

Certain data may be retained for a longer period where necessary to comply with a legal obligation or to establish, exercise or defend legal rights.

The CNIL states that a retention period must be determined according to the purpose of the processing and that data must not be retained indefinitely. (CNIL)

13. Your Rights

In accordance with applicable regulations, depending on the circumstances and subject to the conditions provided for by the GDPR, you have the following rights:

Right of Access

You may request to know whether we process data concerning you and obtain a copy of the relevant personal data.

Right to Rectification

You may request the correction of inaccurate data or the completion of incomplete data.

Right to Erasure

You may request the deletion of your personal data where the conditions provided for by applicable regulations are met.

Right to Restriction of Processing

You may request restriction of the processing of your data in the cases provided for by the GDPR.

Right to Object

You may object to certain processing based on our legitimate interest.

You may also object at any time to the use of your data for commercial prospecting purposes.

Right to Withdraw Your Consent

Where processing is based on your consent, you may withdraw your consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.

Right to Data Portability

Where the conditions provided for by the GDPR are met, you may receive the personal data you have provided to us in a structured, commonly used and machine-readable format, or request its transmission to another data controller where technically feasible. (CNIL)

14. How to Exercise Your Rights

To exercise your rights, you may contact us:

KLS Records Publishing
E-mail: admin@kls-records-publishing.com

Your request should, where possible, specify the right you wish to exercise and be accompanied by information enabling us to identify you sufficiently so that we can process your request.

Where necessary, we may request proof of identity in order to prevent an unauthorised person from accessing your data.

We respond to requests within the time limits provided for by applicable regulations.

15. Right to Lodge a Complaint with the CNIL

If, after contacting us, you believe that your rights relating to your personal data have not been respected, you may lodge a complaint with the Commission nationale de l’informatique et des libertés (CNIL).

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

You may also consult the CNIL’s official website for up-to-date information on how to lodge a complaint.

16. Data Concerning Minors

The website comptinesausoleil.com offers content and resources relating to children’s musical development.

The website is not intended to directly collect personal data from children as part of the lead collection described in this policy.

The collection forms are intended for adults, in particular parents, professionals, establishments and organisations that may be interested in the content and products offered by Comptines au Soleil.

If you believe that a minor has provided us with personal data inappropriately, you may contact us at admin@kls-records-publishing.com.

17. Data Security

KLS Records Publishing implements appropriate technical and organisational measures to protect personal data against loss, destruction, alteration, unauthorised access or any other form of unlawful processing.

These measures may include in particular:

  • limiting access to authorised persons only;

  • securing connections;

  • using services and service providers offering appropriate safeguards;

  • updating tools and systems;

  • backup and security measures appropriate to the risks.

As no transmission or storage of data over the Internet can be guaranteed to be completely secure, we cannot guarantee the absolute security of information.

18. Cookies and Other Trackers

The website may use cookies and other trackers necessary for its operation or, subject to your consent where required, for audience measurement purposes.

The operating methods, purposes and management procedures for these cookies are detailed in our Cookie and Other Tracker Policy.

Where your consent is required, you may accept or refuse the trackers concerned and subsequently change your choices.

19. Changes to This Policy

KLS Records Publishing may modify this Privacy Policy to take account of changes in laws, regulations, case law, technology or its services.

The date of the latest update appears at the beginning of this document.

In the event of a substantial change affecting the methods of processing your personal data, appropriate information may be provided to you where necessary.

20. Contact

For any questions concerning this Privacy Policy or the processing of your personal data:

KLS Records Publishing
8 Résidence du Parc de Petit-Bourg
91000 Évry-Courcouronnes
France

E-mail: admin@kls-records-publishing.com

COOKIE AND OTHER TRACKER POLICY

Last updated: September 2026

The website https://comptinesausoleil.com/ uses cookies and other trackers that may be placed on or read from visitors’ devices.

This policy is intended to inform users about the nature, purposes and methods of use of these cookies and trackers, as well as the means available to them to manage their preferences.

This policy supplements the website’s Privacy Policy.

1. What Is a Cookie or Tracker?

A cookie is a small file or identifier that may be stored on a user’s device (computer, smartphone, tablet, etc.) when visiting a website.

The term “tracker” more broadly refers to various technologies that may, in particular, recognise a device or track certain actions carried out while browsing.

These technologies may be used to ensure the operation of the website, remember certain choices, measure audience, or, where applicable and authorised, analyse interactions with content.

2. Who Is Responsible for the Cookies Used on the Website?

The data controller for personal data potentially collected through cookies and trackers is:

KLS Records Publishing
SASU with share capital of EUR 2,000
RCS Évry 853 113 520
8 Résidence du Parc de Petit-Bourg
91000 Évry-Courcouronnes – France
E-mail: admin@kls-records-publishing.com

For any questions relating to cookies or your personal data, you may contact us at this address.

3. What Types of Cookies May Be Used?

The cookies and trackers used on the website are classified according to their purpose.

3.1. Cookies Strictly Necessary for the Operation of the Website

These cookies may be used to ensure the technical operation of the website, security, session management or the storage of choices relating to cookies.

Where they are strictly necessary for the provision of the service requested by the user or for an electronic communication, they do not require prior consent.

Cookies used to remember the user’s choice concerning other cookies are notably included in this category.

Disabling these cookies may prevent certain website features from operating normally.

3.2. Audience Measurement Cookies

The website uses Google Analytics to measure its audience and better understand website traffic.

These tools may in particular make it possible to determine:

  • the number of visitors;

  • pages viewed;

  • the approximate duration of visits;

  • browsing paths;

  • the general performance of the website;

  • any technical difficulties encountered while browsing.

At this stage, Google Analytics is considered a tracker requiring prior consent, unless its configuration is subsequently verified and documented as strictly meeting the exemption conditions defined by the CNIL.

The CNIL provides an exemption for certain audience measurement tools only where they are strictly limited to audience measurement on behalf of the publisher alone, produce only anonymous statistics, do not enable user tracking across different websites or applications, and do not result in matching or transmission to third parties incompatible with this exemption.

Consequently, Google Analytics must not be activated before the user’s consent has been obtained until this technical analysis has been carried out.

3.3. Advertising or Targeting Cookies

As of the date of the latest update of this policy, the website is not intended to use advertising cookies or behavioural targeting cookies.

If such trackers are subsequently implemented, this policy will be updated and the user’s prior consent will be obtained where legally required.

3.4. Social Media or External Content Cookies

Certain content or features provided by third-party services may be capable of placing trackers, particularly where they enable interaction with a social network, video, map or other external service.

No tracker of this nature should be activated before the user’s consent where consent is legally required.

The precise list of services concerned will need to be updated if new integrations are added to the website.

4. Your Consent

In accordance with Article 82 of the French Data Protection Act (loi Informatique et Libertés), cookies and other trackers that are not strictly necessary for the operation of the website or the provision of a service expressly requested must be subject to prior consent.

Consent must result from a positive action by the user. Simply continuing to browse the website does not constitute valid consent.

The website must therefore enable the user to:

  • accept all;

  • reject all;

  • customise their choices, where several categories of trackers are offered.

Refusal must be as easy as acceptance. The CNIL states in particular that a “Reject all” button must be offered at the same level as the “Accept all” button, or that a solution offering equivalent ease must be implemented.

Important: no cookie subject to consent may be placed before the user has expressed their choice.

5. How Can You Change or Withdraw Your Consent?

You may change or withdraw your consent at any time.

A mechanism allowing the cookie preference centre to be reopened must remain permanently accessible on the website, for example through a “Manage my cookies” link in the footer.

Withdrawal of consent must be as easy as giving consent initially.

When you withdraw your consent, the trackers concerned must cease to be placed or read, subject to operations that are technically necessary to take your choice into account.

6. Retention Period for Cookie Choices

The choice expressed by the user concerning cookies may be retained for a limited period so that they are not asked to provide consent again on every visit.

The exact retention period must correspond to the technical configuration of the consent management mechanism actually installed on the website.

In the event of a substantial change to the purposes or trackers used, new consent may be required.

7. Google Analytics

When Google Analytics is activated after consent, certain browsing-related data may be transmitted to Google to enable audience measurement.

Google states in particular that, for users located in the European Economic Area, the United Kingdom and Switzerland, Google Analytics does not log or store individual IP addresses, although the IP address may nevertheless be used temporarily to determine an approximate geographical location before being deleted.

The specific processing arrangements nevertheless depend on the technical configuration selected for Google Analytics.

Data retention settings must be configured consistently with the retention periods stated in the Privacy Policy.

8. Cookies and Third-Party Services

Certain cookies or trackers may be placed by technical service providers acting on behalf of KLS Records Publishing or directly by third-party services.

The main services currently identified include:

  • Google Analytics, for audience measurement;

  • the technical tools necessary for the operation of the website and its consent management mechanism.

When third-party services are added, their processing arrangements may also be subject to their own privacy policies.

9. Your Choices at Browser Level

You may also configure your browser to block or delete certain cookies.

However, this configuration may limit the operation of certain website features.

The methods for managing cookies depend on the browser used.

10. Personal Data Protection

Certain cookies and trackers may enable the processing of personal data.

The processing of personal data associated with cookies and trackers remains subject to the GDPR rules, even where the tracker concerned benefits from a consent exemption under Article 82 of the French Data Protection Act (loi Informatique et Libertés).

For more specific information concerning:

  • the data collected;

  • the purposes of processing;

  • the legal bases;

  • the recipients;

  • the retention periods;

  • your rights;

you may consult our Privacy Policy.

11. Updates to This Policy

This policy may be amended to take account of:

  • changes to the cookies and trackers used on the website;

  • changes to the website’s features;

  • changes in regulations;

  • developments in the recommendations or decisions of the competent authorities.

The date of the latest update appears at the top of this page.