Cookies. <em>The strict minimum.</em>

This policy aims to inform you, in application of article 82 of French law n° 78-17 of 6 January 1978 as amended (« French Data Protection Act »), article 5.3 of directive 2002/58/EC known as « ePrivacy » and the guidelines and recommendations of the French Data Protection Authority (CNIL) of 17 September 2020, of the cookies and trackers placed on your terminal during your visit to the grandlineweb.com site, of their purpose, their duration and the means at your disposal to control them. It is supplemented by the privacy policy which describes all personal data processing operations carried out by Grand Line Web.

Article 1. Definitions

1.1 Cookie

A cookie is a small text file placed by a website on your terminal (computer, tablet, smartphone) during your visit. It allows the site to store certain information relating to your browsing, identification or preferences, for a defined duration. The term « cookie » covers, by extension, all trackers referred to in article 82 of the French Data Protection Act, whether HTTP cookies, invisible pixels, local storage (localStorage, sessionStorage), fingerprinting or any other similar technology.

1.2 Session cookie vs persistent cookie

A session cookie is automatically deleted when the browser is closed. A persistent cookie is kept on your terminal for a defined duration, until its expiry or manual deletion.

1.3 First-party cookie vs third-party cookie

A first-party cookie is placed directly by the visited site (in this case grandlineweb.com). A third-party cookie is placed by a domain distinct from the visited site, generally a technical provider or an integrated service.

Article 2. Applicable legal framework

The placement and reading of cookies on your terminal is governed by :

• article 82 of the French Data Protection Act, transposing directive 2002/58/EC ;
• Regulation (EU) 2016/679 of 27 April 2016 (GDPR) when cookies process personal data ;
• the CNIL guidelines adopted by deliberation n° 2020-091 of 17 September 2020 ;
• the CNIL recommendation adopted by deliberation n° 2020-092 of 17 September 2020.

In application of these texts, cookies are divided into two distinct regimes :

• strictly necessary cookies for the provision of an online communication service expressly requested by the user, as well as those intended to enable or facilitate electronic communication : exempt from prior consent ;
• all other cookies (audience measurement, profiling, advertising, comfort features) : subject to the user's explicit, free, specific, informed and unambiguous consent, collected prior to their placement and revocable at any time.

Article 3. Cookies used on grandlineweb.com

The grandlineweb.com site uses a deliberately limited number of cookies, divided into two categories.

3.1 Strictly necessary cookies (no consent)

These cookies are essential for the operation of the site and your security. They are placed without prior collection of your consent, in accordance with the exemption provided for in article 82 paragraph 2 of the French Data Protection Act.

3.2 Audience measurement cookies (with consent)

These cookies are placed only if you explicitly consent via the consent banner presented at the first loading of the site, or later via the « Manage cookies » module. You can withdraw this consent at any time under the same conditions.

These cookies allow audience measurement of the site (number of visitors, pages viewed, browsing journeys, device type, traffic source) for exclusively statistical purposes, in a logic of continuous improvement of the site. The data collected is pseudonymized : the IP address is truncated before any recording (IP anonymization activated by default on Google Analytics 4), and no cross-referencing with personal data is carried out.

Data collected via Google Analytics 4 may be transferred by Google LLC to its servers in the United States. This transfer is governed by the Data Privacy Framework (DPF), an adequacy decision adopted by the European Commission on 10 July 2023 (decision (EU) 2023/1795), guaranteeing a level of data protection essentially equivalent to that of the GDPR. Google LLC is certified under the DPF — you can verify its certification at www.dataprivacyframework.gov.

Article 4. Cookies the site does not use

By explicit commitment, the grandlineweb.com site uses none of the following trackers :

• advertising cookies, particularly remarketing or retargeting ;
• social network cookies (Facebook, X/Twitter, LinkedIn share buttons, etc.) ;
• behavioral or commercial profiling cookies ;
• cross-site tracking cookies ;
• invisible pixels, web beacons or advertising platform tags (Meta Pixel, TikTok Pixel, Google Ads, etc.) ;
• fingerprinting techniques (browser digital fingerprint) for tracking purposes ;
• font or script loading cookies from third-party CDNs likely to track the user.

Article 5. Collection and management of consent

5.1 Consent banner

On your first visit to the grandlineweb.com site, a banner fixed at the bottom of the screen informs you of the use of cookies. Three options are offered, presented with strictly equivalent visibility :

• Accept all cookies, including audience measurement cookies ;
• Refuse all non-strictly-necessary cookies ;
• Customize your preferences by category via a detailed window.

In accordance with CNIL recommendations, refusing cookies is as simple as accepting them. No cookie subject to consent is placed until you have made an explicit choice.

5.2 Consent terms

Your consent, when required, is :

• free : you are subject to no constraint to grant it, and refusing it has no consequence on access to site contents or on the possibility of contacting the Provider ;
• specific : it is collected separately for each category of non-necessary cookies ;
• informed : the purpose, duration and identity of the issuer of each cookie are communicated to you before collection ;
• unambiguous : it is expressed by a clear positive act (clicking on the « Accept » button or activating the slider for the relevant category), excluding mere page scrolling, clicking on another element of the site or any tacit deduction.

5.3 Conservation of consent proof

Your choices are kept in the gl_consent cookie for six months, accompanied by the date and time of collection and the version of the cookie policy you consented to. This information allows the Provider to demonstrate, in case of inspection, compliance with the conditions of validity of consent, in accordance with article 7.1 of the GDPR.

Article 6. Modification or withdrawal of your consent

You can modify your preferences or withdraw your consent at any time, without this affecting the lawfulness of previous processing.

6.1 Via the « Manage cookies » module

A link entitled « Manage cookies » is permanently accessible from the footer of the site. It opens the detailed customization window allowing you to enable or disable each category of non-necessary cookies and save your new preferences.

6.2 Via your browser settings

You can also configure your browser to block or delete cookies, whether first-party or third-party. Each browser has its own management procedures, accessible below :

• Mozilla Firefox
• Google Chrome
• Apple Safari
• Microsoft Edge

6.3 Via the Google Analytics-specific opt-out

You can specifically object to Google Analytics tracking, on all sites using this tool, by installing the official deactivation add-on available at : https://tools.google.com/dlpage/gaoptout.

Article 7. Consequences of refusing or deleting cookies

Refusing or deleting audience measurement cookies has no consequence on your browsing experience : all site contents and features remain fully accessible.

Refusing or deleting strictly necessary cookies is technically possible via your browser settings, but may significantly alter the operation of the site. The following are particularly likely to be affected :

• form submission (contact form, customer area) ;
• persistence of browsing language between pages ;
• security of exchanges (loss of CSRF protection) ;
• the storage of your cookie preferences themselves.

Article 8. Third-party cookies and transfers outside the European Union

The only third-party cookie placed by the site, subject to your consent, comes from Google LLC as part of the Google Analytics 4 service. The characteristics of this transfer are described in article 3.2 of this policy and specified more broadly in article 7 of the privacy policy.

No other third-party cookie, no external tracking script, no call to a CDN likely to identify the user is integrated into the site.

Article 9. Modification of this policy

This policy may be modified at any time to reflect applicable technical, functional or regulatory developments. The date of last update is indicated at the top of the page. In the event of substantial modification of the cookies used or purposes pursued, your preferences will be automatically reset and a new consent will be requested.

Article 10. Contact

For any question relating to this cookie policy or the exercise of your rights :

• By email : contact@grandlineweb.com
• By post : Rafael Da Mota Cerqueira — Grand Line Web, 9 Place de l'Église, 43100 Vieille-Brioude, France

You also have the right to lodge a complaint with the French Data Protection Authority (CNIL) :

• 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07
• Phone : 01 53 73 22 22
• Site : www.cnil.fr

The CNIL also provides a cookie-specific complaint form at the following address : https://www.cnil.fr/fr/plaintes.