Privacy policy

1. Data controller

The data controller is the publisher of Clubs Actionnaires. Contact: contact@clubsactionnaires.fr.

2. Data processed

The public website does not require a user account. Newsletter subscriptions and community voting process an email address for their own operation; that address is never copied into audience analytics.

Regardless of your choice, a technical counter adds page loads by day, path, language and consent state. It sets no cookie, creates no identifier and stores no IP address, user agent or device attribute.

Vercel Web Analytics and Speed Insights are separate from the site's first-party measurement. They load independently of the privacy banner: Web Analytics provides aggregated data about visits, pages, country, browser and operating system, while Speed Insights measures real-user page performance. Web Analytics does not use advertising cookies; Vercel describes its visitor signal as a temporary hash that is renewed daily.

Kissmetrics is loaded only after you consent to audience measurement. It receives pseudonymous page-view, click and form submission events, together with technical reporting context. Clubs Actionnaires does not send the values entered into fields, including email addresses, to Kissmetrics.

With your permission, we may also process:

• a random first-party identifier transformed into a server-side HMAC, session, viewed paths and meaningful actions such as searches, company views, votes and newsletter signups;
• an approximate country, region or city when supplied by the hosting edge, device class, browser family and major version, operating-system family and version when available, language, time zone, rounded screen resolution, pixel-density class, referrer host and UTM campaign parameters, without storing a raw IP address or full user agent;
• optional information you declare yourself: age range, investing experience, shareholder status, account type, objective and investment horizon. These are never inferred from browsing;
• local display preferences such as the light or dark theme.

3. Purposes and legal bases

• Website operation, security and preference storage: legitimate interest.
• Identifier-free aggregate counting: legitimate interest, limited to page-load totals and choices expressed in the privacy banner.
• Audience measurement and service improvement: consent, using first-party pseudonymous events.
• Optional audience profile: consent and voluntary declaration, used only to understand broad reader needs.
• Newsletter subscription and delivery: consent and performance of the requested service.

4. Cookies and local storage

The site uses strictly necessary cookies for voting and security. After permission, two random first-party identifiers group a session and its actions; they are not used to identify you across websites. The light or dark theme preference is stored locally and is not used for advertising.

Aggregate page-load counting uses no cookie, local storage or identifier. Declining still disables detailed journey, device and interaction measurement.

Vercel Web Analytics and Speed Insights do not depend on the choice made in this banner. Vercel can therefore keep measuring page views, general device characteristics and performance, while a refusal disables only the detailed first-party measurement stored by Clubs Actionnaires.

The Kissmetrics script is not loaded before audience-measurement consent. If you withdraw that consent, Clubs Actionnaires stops sending new events to Kissmetrics; data already received remains subject to Kissmetrics' retention and deletion rules.

Audience measurement and the optional audience profile are disabled by default and have separate controls. The banner offers decline, accept and customize choices with the same level of simplicity; the Privacy control lets you change or withdraw your choice at any time. No advertising cookie or cross-site tracking is used for this measurement.

You can restrict cookies in your browser. Some features may then work less effectively.

5. Recipients and processors

Data may be processed by Vercel Inc. for hosting, Web Analytics and Speed Insights, Supabase for server-side pseudonymous event storage, Kissmetrics for consented audience measurement and behavioral reporting, infrastructure or DNS providers, and beehiiv for newsletter subscriptions and delivery.

Transfers outside the European Economic Area may occur under the safeguards provided by the relevant service provider, such as standard contractual clauses.

6. Retention

Raw audience events are retained for no more than 90 days, subject to the deletion policy. First-party visitor identifiers last up to 30 days and session identifiers are short-lived. Local theme preferences remain until removed in the browser. Newsletter data is retained until unsubscription or a valid deletion request.

7. Your GDPR rights

Subject to legal conditions, you may request access, correction, deletion, restriction, objection or portability by contacting contact@clubsactionnaires.fr. You may also lodge a complaint with the French data protection authority, the CNIL, at www.cnil.fr.

8. Security

Reasonable technical measures are used, including HTTPS and security headers. No information system can guarantee absolute security.

9. Updates

This policy may be updated. The version published online is the applicable version.

10. Legal notice

See also the legal notice.

11. Data controller identity

The data controller is Bastien Coulonnier, publisher of Clubs Actionnaires. For questions about your data, use the contact address provided in this policy.