Privacy

Who we are

Riviera Circle is run by the association Riviera Circle Members, an association déclarée (loi du 1er juillet 1901), founded by Vincent Fergola, who is responsible for your data. Its registered office is at 3, rue Auguste Gal, 06300 Nice, France. RNA number W062021399. You can reach us at hello@riviera-circle-members.com.

What you give us when you apply

The application form on /join asks:

• what you are into (optional);
• your budget for an evening out and for an afternoon on a boat;
• how often you are up for plans, where you are based, and why you want to join;
• your full name, age, Instagram handle, WhatsApp number and e-mail address;
• what you do and the languages you speak (both optional).

The car owners’ form on /join/cars asks instead what you drive, the car days you are up for (optional), your budget for a car day and how often you would join one, with the same contact questions.

With your answers we keep which form you used and, if you came from one of our ads, the campaign parameters in its link (utm_source, utm_medium, utm_campaign, utm_content, utm_term), so we know which ads bring applications.

Why, and on what basis

We use your application to decide whether to invite you, and, if you join, to reach you on WhatsApp and add you to the members’ group. The basis is your request to join: we cannot consider it without your answers.

Every application is read by hand by Vincent Fergola. Each one is also sent to him by e-mail, and he can read them through his own assistant software, which may use an AI model to help him sort them. Nobody is accepted or refused automatically.

The members page

If you are accepted, you appear on the public members page, /members, with your first name, the initial of your last name, what you do and your Instagram handle. Never your phone number, e-mail, age or answers. To be taken off the page, write to hello@riviera-circle-members.com and we will do it.

Meta: the pixel and the Conversions API

We advertise on Instagram and Facebook. With your consent only (the cookie choice on this site), Meta’s pixel loads from Meta’s servers, sets its cookies (_fbp, and _fbc when you come from an ad) and tells Meta which pages you view and when you send an application. If you refuse, it never loads. You can change your choice at any time under “Cookie settings” at the foot of the page.

Separately, when you send an application, our server tells Meta that an application was sent (the Conversions API), whatever your cookie choice. It sends: your e-mail address, phone number, first and last name and the country of your phone number, each scrambled with SHA-256 before it leaves our server; your IP address and browser identification; Meta’s cookies or the ad’s click identifier (fbclid) if there are any; the page address; and which form you used. Your answers are not sent. Meta uses this to match the application to an ad click and to measure our ads. The basis is our legitimate interest in knowing which ads work; you can object at any time by writing to hello@riviera-circle-members.com.

Who else handles your data

Only the services that run the site, each for its own part:

• Vercel, which hosts the site (our server code runs in Paris);
• Supabase, our database, where applications are stored;
• Resend, which sends our e-mails;
• Google (Gmail), where a copy of each application reaches the founder’s inbox;
• Cloudflare, which stores and serves the site’s photos and videos;
• Meta, as described above.

Some of them are companies based in the United States, so your data may be processed there, under the safeguards they offer for transfers out of the European Union. We do not sell your data.

Measurement and your device

Vercel Web Analytics counts page views without cookies and without identifying you. If you came from an ad, its link parameters are kept in this browser tab until you apply, and, if you accepted the cookies, on your device for 30 days. Your cookie choice is kept on your device for six months. In the members’ app, we keep anonymous counts (such as how many phones installed it) and, if you turn on notifications, your browser’s address for sending them.

How long we keep it

We keep your application, whether or not it was accepted, until you ask us to delete it. Meta keeps what it receives under its own policy.

Your rights

You can ask to see the data we hold about you, to correct it, to delete it, to restrict its use, to receive a copy, and to object to its use, including for measuring our ads. Write to hello@riviera-circle-members.com; we answer within a month. If you think we have not respected your rights, you can complain to the CNIL, the French data protection authority, at cnil.fr.