1.1. This Cookie Policy explains how Agency Cult SASU (hereinafter "TCC", "we", "us") uses cookies and similar tracking technologies on the Platform operated under the name "The Club Cult" (hereinafter "the Platform"), accessible at theclubcult.com and through the official mobile application.
1.2. This Policy complies with the ePrivacy Directive (Directive 2002/58/EC), the French Data Protection Act (Loi Informatique et Libertes), and the guidelines of the Commission Nationale de l'Informatique et des Libertes (CNIL), in particular the Deliberation n. 2020-091 of 17 September 2020 adopting guidelines on cookies and other trackers and the Recommendation of 18 March 2021.
2.1. A cookie is a small text file stored on your device (computer, smartphone, tablet) when you visit a website or use an application. Cookies allow the website or application to recognise your device, remember your preferences and provide functionality.
2.2. Similar technologies include web beacons, pixels, local storage and device fingerprinting. This Policy covers all such technologies (collectively referred to as "cookies").
We use the following categories of cookies:
3.1. Strictly Necessary Cookies
These cookies are essential for the Platform to function correctly. They enable core features such as authentication, security, session management and load balancing. These cookies do not require your consent under the CNIL guidelines, as they are exempt under Article 82 of the Loi Informatique et Libertes.
3.2. Functional Cookies
These cookies enable enhanced functionality and personalisation, such as language preferences and display settings. They may be set by TCC or by third-party providers whose services we use. These cookies require your consent.
3.3. Analytics Cookies
These cookies help us understand how Users interact with the Platform by collecting anonymous usage data. They allow us to measure traffic, identify the most popular features and improve the user experience. These cookies require your consent.
As of 1 June 2026, TCC does not deploy third-party analytics cookies. Platform analytics are processed server-side by Supabase using anonymised, aggregated data that does not require cookie consent under CNIL guidelines. If analytics cookies are introduced in the future, this section will be updated and user consent will be obtained before activation.
3.4. Marketing and Advertising Cookies
As of the effective date of this Policy, TCC does not use marketing or advertising cookies. If this changes, this Policy will be updated and your consent will be sought before any such cookies are placed.
4.1. In compliance with CNIL guidelines (Deliberation n. 2020-091), non-essential cookies (functional, analytics, marketing) are only placed on your device after you have provided informed, specific and unambiguous consent.
4.2. When you first visit the Platform, a cookie consent banner is displayed that:
4.3. Continuing to browse the Platform without interacting with the consent banner does NOT constitute consent. Only an affirmative action (clicking "Accept" or selecting specific categories) constitutes valid consent.
4.4. The consent banner is re-displayed every thirteen (13) months, in accordance with the CNIL recommended maximum cookie lifespan.
5.1. You may modify your cookie preferences at any time through the cookie preference centre, accessible from the footer of every page of the Platform and from the Account settings.
5.2. You may also manage cookies through your browser settings. Most browsers allow you to block or delete cookies. Note that blocking strictly necessary cookies may prevent the Platform from functioning correctly.
5.3. Common browser cookie settings:
5.4. Withdrawing consent for non-essential cookies takes effect immediately for future visits. Cookies already placed will expire according to their stated lifespan or may be manually deleted from your browser.
6.1. In compliance with CNIL guidelines, no cookie placed by TCC has a lifespan exceeding thirteen (13) months from the date of placement.
6.2. Session cookies are automatically deleted when you close your browser.
6.3. Consent records are retained for a period that enables TCC to demonstrate compliance with its consent obligations (proof of consent).
7.1. Cookies may collect the following types of data:
7.2. This data is processed in accordance with our Privacy Policy. The legal basis for processing data collected via consent-based cookies is Article 6(1)(a) GDPR (consent). The legal basis for strictly necessary cookies is Article 6(1)(f) GDPR (legitimate interest in ensuring Platform security and functionality).
8.1. Certain cookies may be placed by third-party service providers (e.g., Stripe for payment security). These third parties have their own cookie and privacy policies. TCC is not responsible for third-party cookies.
8.2. Stripe may place cookies strictly necessary for payment processing and fraud prevention. These cookies are exempt from consent requirements as they are essential for the service requested by the User.
9.1. TCC may update this Cookie Policy to reflect changes in the cookies used, regulatory requirements or CNIL guidance. Users will be notified of material changes through the Platform.
9.2. Where changes affect the types of cookies used or the purposes of processing, a new consent request will be presented.
For questions regarding this Cookie Policy:
Agency Cult SASU
44 Rue du Bac, 75007 Paris, Paris, France
Email: Info@theclubcult.com
Supervisory Authority:
Commission Nationale de l'Informatique et des Libertes (CNIL)
3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07
www.cnil.fr