Cookie Policy

1. Purpose and scope

The purpose of this Policy is to inform you, in a clear and complete manner, about the nature of the cookies and trackers used by CloseHunt, the purpose pursued by each of them, their legal basis, their retention period and the means available to you to give, refuse or withdraw your consent.

It applies to the marketing site available at closehunt.io and to the CloseHunt application available at app.closehunt.io. It supplements our Privacy Policy, which describes all processing of personal data carried out by CloseHunt in its capacity as data controller for account, billing and usage data. For the prospect data that the customer uploads or targets through the platform, the customer acts as data controller and CloseHunt acts as processor, in accordance with the Terms of Use (CGU), the Terms of Sale (CGV) and the Data Processing Agreement (DPA); those aspects do not fall within the scope of this Cookie Policy.

CloseHunt is committed to using only the trackers genuinely necessary for the operation of its services and deliberately limits its reliance on non-essential trackers. This document honestly and exhaustively describes the cookies actually placed; it does not mention any cookie that is not in fact used.

2. What is a cookie or a tracker?

A "cookie" is a small text file placed on and/or read from the hard drive of your device (computer, tablet, smartphone) through your browser when you visit a site or use an application. The term "tracker" refers, more broadly, to any technology that allows information to be read from or written to your device, whether HTTP cookies, tokens stored in the browser's local storage (localStorage, sessionStorage), invisible pixels or equivalent techniques.

A cookie or tracker may, in particular, recognise your device, remember your preferences, maintain your authentication session or ensure the security and proper operation of the service. On its own it does not identify you by name, but it may, depending on the case, constitute personal data within the meaning of the GDPR.

From a legal standpoint, a distinction is drawn between trackers strictly necessary for the operation of the service (so-called "essential" or "exempt" trackers), which do not require your consent, and non-essential trackers (non-exempt audience measurement, advanced personalisation, advertising, social sharing), which require your prior consent.

3. Legal basis: consent and exemptions

The placement and reading of trackers is governed by Article 82 of the French Data Protection Act, which transposes Article 5.3 of the ePrivacy Directive. The principle is that any operation accessing or storing information on your device requires your prior consent, which must be freely given, specific, informed and unambiguous, evidenced by a clear affirmative act.

The law nonetheless provides for two categories of trackers exempt from consent, in accordance with CNIL guidelines: (i) trackers whose sole purpose is to enable or facilitate electronic communication, and (ii) trackers strictly necessary for the provision of an online communication service expressly requested by the user. These essential trackers may be placed without obtaining consent, their lawfulness resting on the necessity of providing the service as well as on the publisher's legitimate interest in ensuring the security and proper operation of that service.

For any non-essential tracker, CloseHunt obtains your prior consent before any placement or reading. Until you have consented, no non-essential tracker is placed. You can refuse as easily as you can accept, and withdraw your consent at any time, without this hindering access to the essential features of the service.

• Essential / exempt trackers: lawfulness based on the necessity of the service and on legitimate interest (security, operation) — no consent required.
• Non-essential trackers: lawfulness based on prior consent (Article 82 of the French Data Protection Act; Article 6(1)(a) GDPR) — refusal and withdrawal possible at any time.

4. Inventory of the cookies and trackers actually used

In the interest of transparency, the inventory below lists all of the trackers actually used by CloseHunt as at the date of this Policy. CloseHunt places no advertising cookie, no marketing-profiling cookie and no third-party advertising-network tracker.

Language preference cookie "NEXT_LOCALE" — Purpose: to remember the display language (French or English) you have selected, so as to present the interface in your chosen language. Category: essential tracker, strictly necessary for the provision of the requested service. Legal basis: exemption from consent. Issuer: CloseHunt (first-party cookie).

Authentication session cookie / token — Purpose: to maintain your session once logged in, to identify you securely from one page to another and to protect your account (in particular against request forgery). Scope: application only (app.closehunt.io); this tracker is not placed on the marketing site for logged-out visitors. Category: essential tracker, strictly necessary for the online communication service expressly requested. Legal basis: exemption from consent. Issuer: CloseHunt (first-party cookie).

To date, CloseHunt does not operate any non-exempt audience-measurement tool or any analytics cookie subject to consent. Should such a tool be deployed, this Policy would be updated and a consent-collection mechanism would be presented beforehand.

• NEXT_LOCALE — language preference — essential — exempt from consent — first party — lifespan: up to 1 year.
• Authentication session — secure session maintenance (dashboard only) — essential — exempt from consent — first party — lifespan: for the duration of the session or until expiry/logout.

5. Possible third-party cookies (payment)

CloseHunt does not use any advertising networks or third-party tracking trackers. However, certain features involve third-party providers that may place their own cookies, strictly within the scope of the function they perform.

During a payment operation, the payment flow is operated by our payment provider (Stripe). On that occasion, Stripe may place its own cookies, in particular for the purpose of securing the transaction and preventing fraud. These cookies are placed by Stripe in its capacity as provider and are governed by its own cookie and privacy policy. They operate only in the context of payment and are not used by CloseHunt for advertising purposes.

Outside the payment context, no third-party tracker is placed. No data is shared with third parties for advertising-targeting purposes.

• Payment (Stripe) — transaction-security and fraud-prevention cookies placed by the payment provider, only during a payment operation — governed by the provider's policy.

6. Managing consent: accept, refuse, withdraw

Since CloseHunt currently places only essential trackers that are exempt from consent, together with, where applicable, the payment provider's (Stripe) cookies during a transaction, no action is required on your part for essential trackers. Should CloseHunt deploy non-essential trackers subject to consent, a consent-management banner would be presented on your first visit; you could then accept them, refuse them all, or make a choice on a per-purpose basis, and change or withdraw your choice at any time via the link or preference-management module accessible from that banner.

You may control and delete cookies at any time using your browser settings. Most browsers allow you to accept or refuse cookies, delete those already placed and be notified before any new placement. The settings differ from one browser to another; they are generally accessible from the "Options", "Settings" or "Preferences" menu, under the "Privacy" or "Security" heading.

Please note that blocking or deleting essential trackers (language preference, authentication session) may impair the proper operation of the service, prevent you from staying logged in to the application or reset your display preferences.

• Google Chrome: Settings > Privacy and security > Cookies and other site data.
• Mozilla Firefox: Settings > Privacy & Security > Cookies and Site Data.
• Microsoft Edge: Settings > Cookies and site permissions.
• Apple Safari: Settings / Preferences > Privacy.
• To find out more, you may consult the CNIL website (www.cnil.fr), under the "Cookies and other trackers" heading.

7. Retention period

Essential trackers are retained for as long as is strictly necessary for their purpose: the language preference cookie is retained for a maximum of one year, and the authentication session token is retained for the duration of the session, until you log out or until the session expires.

In accordance with the CNIL recommendation, where consent is required for non-essential trackers, that consent is not retained beyond a period of thirteen (13) months; on expiry of that period, your consent would be sought again. In any event, the lifespan of the non-essential trackers themselves does not exceed thirteen (13) months, and the information collected through them is not retained beyond twenty-five (25) months without renewal of consent.

The retention period of the cookies placed by the payment provider during a transaction is governed by that provider's own policy.

• NEXT_LOCALE: up to 12 months.
• Authentication session: duration of the session (until logout or expiry).
• Consent to non-essential trackers (where applicable): retained for a maximum of 13 months, then re-consent.
• Non-essential trackers (where applicable): maximum lifespan of 13 months; associated data retained for no more than 25 months.

8. Personal data and your rights

Where the trackers described in this Policy process personal data, that processing is carried out by CloseHunt in its capacity as data controller and is governed by the GDPR as well as by our Privacy Policy, to which we invite you to refer.

Under the conditions provided for by the GDPR, you have a right of access, rectification, erasure, restriction, objection and portability of your data, as well as the right to withdraw your consent at any time where processing is based on it. You may exercise these rights by writing to [email protected] or to our Data Protection Officer (DPO) at [email protected].

You also have the right to lodge a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, www.cnil.fr) if you consider that the processing of your data does not comply with the applicable regulations.

9. Hosting

The CloseHunt site and application are hosted within the European Union by Scaleway SAS, 8 rue de la Ville l'Évêque, 75008 Paris, France. The essential trackers described in this Policy are first-party trackers, and the information they contain is not transferred outside the European Union by CloseHunt.

Any cookies placed by the payment provider may involve transfers framed by the appropriate safeguards provided for in Chapter V of the GDPR, under the conditions described in that provider's own policy.

10. Amendments to this Policy

CloseHunt reserves the right to amend this Cookie Policy at any time, in particular in order to adapt it to changes in its services, in the applicable regulations or in CNIL recommendations. The applicable version is the one published on the site as at the date of your visit, identified by the "Last updated" reference at the top of this document.

In the event of a substantial change, in particular in the event of the deployment of a new non-essential tracker subject to consent, your attention would be specifically drawn to it and, where applicable, your prior consent would be obtained before any placement.

11. Contact

For any question relating to this Cookie Policy, you may contact us at [email protected]. For any question relating to the protection of personal data, you may write to [email protected] or to our Data Protection Officer at [email protected]. For any legal question, you may write to [email protected].

This Policy is governed by French law. Any dispute relating to its interpretation or performance shall, failing amicable resolution, fall within the exclusive jurisdiction of the Commercial Court (Tribunal de commerce) of [VILLE_SIEGE], in accordance with the jurisdiction clause agreed between professionals.