Last updated: 17 September 2026.
This page is an English translation provided for convenience. The binding version is the French privacy policy.
This policy explains what personal data we collect on thefortunacircle.com, why, how long we keep it, and how to exercise your rights. We collect the strict minimum, and we never sell or rent your data.
Data controller
The data controller is [to be completed: first and last name of the entrepreneur], sole trader trading under the business name The Fortuna Circle, SIRET [to be completed: SIRET number], [to be completed: address] (see the legal notice). For any question about your data: contact@thefortunacircle.com.
The data we collect
- Subscribing to our emails: your email address and, if you provide it, your first name.
- Buying a program: your first and last name, email address, billing address and order history. Payment data is processed directly by the payment provider: we never have access to it.
- Messages you send us: your email address and the content of your message.
- Technical data: the host automatically records connection logs (IP address, date, page requested) needed for the security and proper working of the site.
- The Four Circles Test: the test runs entirely in your browser. Your answers are never sent to us and never stored.
Why we use it
- To send you our emails (guidance, new articles, the opening of our programs). Legal basis: your consent, which you may withdraw at any time using the unsubscribe link in every email.
- To perform your order and give you access to the program purchased. Legal basis: performance of the contract.
- To meet our accounting and tax obligations. Legal basis: legal obligation.
- To keep the site secure. Legal basis: our legitimate interest.
How long we keep it
- Email subscribers: until you unsubscribe, and at most three years after your last contact with us (opening an email, a click, a message).
- Customers: for the duration of the commercial relationship, then three years for prospecting purposes. Accounting records are kept for ten years, as the law requires.
- Connection logs: twelve months at most.
Who has access to your data
Your data is accessible only to the team at The Fortuna Circle and to our technical providers, who act on our instructions and are bound by confidentiality:
- OVH SAS (Roubaix, France): hosting of the site;
- Systeme.io: subscription form, sending of emails, sales pages, members’ area;
- the payment provider used at the time of the order.
Where a provider processes data outside the European Union, that transfer is framed by the safeguards provided for by the GDPR (adequacy decision or the European Commission’s standard contractual clauses).
Cookies
To date, the site uses neither advertising cookies nor analytics tools. Only cookies strictly necessary to the working of the site may be placed, for example for the administration area. If we add an analytics tool, we will ask for your agreement beforehand. Fonts are hosted on our own server: no data is sent to Google on that account. See the cookies page.
Your rights
In accordance with the General Data Protection Regulation (GDPR) and the French Data Protection Act, 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 and to give directions on what happens to your data after your death.
To exercise them, write to us at contact@thefortunacircle.com. We reply within one month. To unsubscribe from our emails, simply click the link at the bottom of any of them.
If, after contacting us, you consider that your rights are not being respected, you may lodge a complaint with the French data protection authority, the CNIL: www.cnil.fr. If you live in another EU country, you may lodge your complaint with your own national supervisory authority.
Minimum age
Our content and programs are intended exclusively for adults. We do not knowingly collect data concerning minors.