COOKIES POLICY

1. What is a cookie?

A cookie is a small text file stored on your device (computer, tablet, smartphone) when you visit a website. It allows the website to recognise your device and store certain information about your preferences or past actions.

Cookies do not damage your device and do not identify you directly. However, certain cookies may collect data that could be considered personal data and are therefore subject to the General Data Protection Regulation (GDPR) and French Data Protection Act (Loi Informatique et Libertés).

2. Who places cookies?

Cookies may be placed:

• By the website publisher (first-party cookies)

• By third parties (third-party cookies) such as analytics providers, advertising partners, or social media platforms.

3. Types of cookies used on the Website

3.1. Strictly necessary cookies (exempt from consent)

These cookies are essential for the proper functioning of the Website and its services (e.g. shopping cart, session management, security).
They do not require your consent.

3.2. Audience measurement / performance cookies

These cookies allow us to analyse the use of the Website and improve its performance (e.g. number of visits, most visited pages).
→ Consent required, unless only first-party and strictly anonymised in accordance with CNIL exemptions.

3.3. Functionality cookies

They allow the Website to remember your choices (language, preferences, login details).
→ Consent required.

3.4. Advertising and personalised content cookies

These cookies are used to display personalised ads based on your browsing behaviour.
→ Consent required.

3.5. Social media cookies

They enable content sharing or interaction with social networks (e.g. Facebook, Instagram, TikTok).
→ Consent required.

4. Cookie consent

Upon your first visit, a cookie banner appears to:

• Inform you of the use of cookies,

• Give you the option to Accept all, Reject all, or Customise your choices,

• Provide a link to this Cookies Policy.

No non-essential cookie is placed without your prior consent, in accordance with CNIL guidelines.

5. How to manage your cookie preferences?

You can change your preferences at any time by:

• Using the “Cookie settings” link available at the bottom of the Website,

• Configuring your browser settings.

Browser settings examples:

• Chrome: Settings > Privacy and security > Cookies

• Firefox: Options > Privacy & Security > Cookies

• Safari: Preferences > Privacy

• Edge: Settings > Cookies and site permissions

Please note: Blocking certain cookies may affect the functioning of the Website.

6. Cookie retention period

Cookie retention is limited to a maximum of:

• 13 months from the date they are placed, for cookies requiring consent,

• Associated data is retained for no more than 25 months.

You may withdraw consent at any time.

7. Personal data and cookies

Some cookies may collect information that qualifies as personal data (e.g. IP address, browsing data).
This data is processed in accordance with our Privacy Policy, which explains:

• The purposes of processing,

• Your rights (access, rectification, deletion, objection, portability),

• The contact details of our Data Protection Officer (if applicable),

• The right to lodge a complaint with the CNIL.

8. Third-party cookies and transfers outside the EU

Some third-party providers (e.g. Google, Meta, TikTok) may store data outside the European Economic Area.
In such cases, we ensure that appropriate safeguards are in place (e.g. Standard Contractual Clauses, adequacy decisions).

9. Updates to the Cookies Policy

This policy may be updated to comply with legal or technological developments. In case of significant changes, we will notify you (e.g. via banner or email) and request your consent again if necessary.

Last update: 13/10/2025

10. Contact

For any questions regarding cookies or the protection of your personal data, you can contact us at:

Email: hello@surfincircles.com
Postal address: 6 boulevard saint germain 75005 Paris 
Supervisory authority: CNIL (www.cnil.fr)