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Data Privacy & European GDPR Protection

Privacy Policy & Personal Data Protection

LE CERCLE is committed to uncompromising privacy ethics. As an Association Loi 1901 dedicated to public interest culture, we enforce strict European General Data Protection Regulation (GDPR / RGPD) standards, operating without commercial advertising trackers, profiling cookies, or third-party data monetization.

Data protection and privacy review conducted by LE CERCLE governance board in Besançon
Figure 9.1: General Secretary Claire Delacroix conducting the annual GDPR compliance audit at 60 Rue des Granges, ensuring citizen data minimization across all volunteer registries.
Privacy & Non-Commercial Ethics Zero Commercial Monetization

Civic Trust & Data Minimization Pledge

LE CERCLE does not sell, rent, monetize, or exchange personal data under any circumstances. All membership fees and dues are fully reinvested in the association's public interest missions. Personal information collected through our contact and volunteer registration forms is utilized exclusively to facilitate non-profit community coordination, fulfill legal volunteer insurance requirements, and respond to civic correspondence.

1. Data Controller & Governance Contact

Under Regulation (EU) 2016/679 (General Data Protection Regulation) and the French Data Protection Act (Loi Informatique et Libertés as amended), the data controller responsible for personal information processed on this website is:

Data Controller: Association LE CERCLE (RNA W251003865, SIREN 847756137)
Headquarters: 60 RUE DES GRANGES, 25000 BESANCON, FRANCE
Data Protection Lead: Claire Delacroix, General Secretary
Official Privacy Contact Email: vvg354836@gmail.com
Official Telephone: +33551951462
Annual data protection ledger review and secure archive handling at LE CERCLE
Figure 9.2: The annual privacy ledger review conducted at our Besançon office, verifying that volunteer registries and contact logs are stored securely with restricted administrative access.

2. Categories of Data Collected & Statutory Legal Bases

In accordance with the principle of data minimization (Article 5(1)(c) of the GDPR), LE CERCLE collects only the minimum necessary data to fulfill its civic non-profit missions:

  • Volunteer Applications: Full name, email address, optional telephone number, neighborhood district in Besançon, and interest areas. Legal Basis: Explicit consent (Article 6(1)(a) GDPR) and preparation of non-profit membership records.
  • Civic Inquiries: Full name, email address, topic classification, and message text. Legal Basis: Legitimate interest in responding to community inquiries (Article 6(1)(f) GDPR).
  • Workshop Reservations: Full name and contact email for attendance verification and venue safety capacity limits.

Data Retention: Inquiry data is retained for a maximum duration of 12 months following resolution. Volunteer records are kept for the duration of active participation plus statutory association audit requirements under French non-profit law.

Volunteer coordinators maintaining encrypted records and safe communications at LE CERCLE
Figure 9.3: Volunteer working group leads organizing civic schedules using local encrypted spreadsheets and privacy-first community software at our Besançon operations desk.

3. Your Statutory Rights Under the GDPR

As a resident of the European Union, you hold comprehensive rights regarding your personal data:

Right of Access & Rectification

You have the right to request a full transcript of your stored data and correct any inaccuracies at any time free of charge.

Right to Erasure ("Right to Be Forgotten")

You may request the immediate deletion of your contact or volunteer history from all active association registries.

Right to Restrict or Object

You may object to specific processing categories or request the restriction of processing while an inquiry is being verified.

Right to Lodge a Complaint with CNIL

If you believe your rights have not been respected, you have the right to lodge a formal complaint with the French supervisory authority: CNIL (Commission Nationale de l'Informatique et des Libertés, 3 Place de Fontenoy, 75007 Paris, www.cnil.fr).

To exercise any of these rights, simply email our data lead at vvg354836@gmail.com or send a postal notice to our registered office at 60 Rue des Granges, 25000 Besançon. Requests are processed within 30 days without fee.

Secure open-source workstations at LE CERCLE configured with zero telemetry
Figure 9.4: Workstations in our Besançon media laboratory running Linux and free software configured with zero telemetry to protect creator privacy.

4. Cookie Architecture & Zero-Tracking Architecture

Our website is engineered according to the principles of Privacy by Design (Article 25 GDPR). We do not deploy third-party advertising cookies, cross-site trackers, or commercial analytics scripts. Any cookies used are strictly technical session cookies essential for site navigation, form security, and anti-caching protocol headers.

Civic archive researchers maintaining transparent and ethical data records in Besançon
Figure 9.5: Community researchers at LE CERCLE ensuring all public documentation complies with strict data ethical standards and French association privacy norms.