Cookie Policy

Alchimie Capital LLC, Odesio

Effective date: 2026-09-12 Version: 1.3 Compliant with: Directive 2002/58/EC (ePrivacy), CNIL recommendations, EDPB Guidelines 3/2019, FSMA.

This English version is a translation provided for convenience. In the event of any discrepancy or dispute, the French version prevails.

1. What is a cookie?

A cookie is a small text file placed on your device (computer, smartphone, tablet) when you visit a website. It allows the website to recognise your device on subsequent visits.

By extension, this policy covers all similar technologies: invisible pixels, local storage, session storage, IndexedDB, mobile SDKs, digital fingerprinting.

2. Legal framework

The placing and reading of cookies are governed by:

• Directive 2002/58/EC (ePrivacy) as transposed into each EU Member State's national law
• Article 82 of the French Data Protection Act (Loi Informatique et Libertés) (France)
• Book XII of the Code of Economic Law (Belgium)
• CNIL Guidelines of 17 September 2020
• CNIL Recommendation of 17 September 2020

Key principle: apart from cookies that are strictly necessary for the operation of the service, every cookie requires your freely given, specific, informed and unambiguous consent (opt-in, not opt-out).

3. Which cookies do we use?

3.1 Strictly necessary cookies (exempt from consent)

These cookies are essential to the operation of the Services. They cannot be disabled.

Legal basis: performance of the contract + legitimate interest (Art. 82 para. 2 of the French Data Protection Act).

3.2 Audience measurement cookies (consent required)

These cookies allow us to understand how the Services are used and to improve our teaching.

Privacy-friendly configuration:

• Anonymised IP
• No sharing with third-party advertisers
• No cross-domain tracking
• Hosting in the EU region

3.3 Functional cookies (consent required)

3.4 Marketing cookies (consent required)

We do not use any third-party advertising cookie (Google Ads, Meta Pixel, LinkedIn Insight, etc.) without your explicit consent and without an active "Do Not Track" signal.

If you have accepted marketing cookies:

Refusing these cookies does not, however, make your sign-up anonymous: the origin of the link through which you arrive (utm_* parameters, conversation or referrer code) is read from the page address and recorded on your account when it is created, without placing anything on your device — see the Privacy Policy, §3.7 and §4. The cookies above serve only to retrieve this origin if you return later without going through the link again.

3.5 Cookieless audience measurement (no consent required)

We use Vercel Web Analytics to count visits and pages viewed.

This measurement neither places nor reads any cookie, and writes no information to your device (no cookie, no localStorage, no persistent identifier). Article 82 of the French Data Protection Act, which transposes the ePrivacy Directive, only covers actions intended to access information stored in your device or to write information to it: since it performs neither, this measurement falls outside its scope and therefore does not require your prior consent.

What this measurement does not do:

• no tracking of your browsing from one site to another;
• no cross-referencing with your account, your portfolio or your answers to the questionnaire;
• no transmission to third parties for advertising purposes;
• no resale or enrichment.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR) — measuring the audience of our pages in order to improve them. This interest is balanced against your rights: the absence of any persistent identifier and of any cross-referencing makes the impact on your privacy minimal.

Your right to object: you may object to this measurement at any time, without giving reasons, by writing to contact@alchimiecapital.com (see also §8: the Global Privacy Control signal is respected).

4. How can you manage your consent?

4.1 Consent banner

On your first visit, a consent banner allows you to:

• Accept all cookies (prominent button)
• Refuse all non-essential cookies (button of equal visibility)
• Customise your choice by category

In accordance with the CNIL guidelines, refusing is as easy as accepting (parity rule).

4.2 Changing your choices at any time

You can change your preferences at any time:

• Via the "Manage my cookies" link in the footer
• In your account settings ("Privacy" tab)

The change takes effect immediately.

4.3 Browser settings

You can also configure your browser to refuse or delete cookies:

• Chrome: Settings → Privacy and security → Cookies
• Firefox: Settings → Privacy & Security → Cookies
• Safari: Preferences → Privacy
• Edge: Settings → Cookies and site permissions

Warning: disabling all cookies may prevent the Services from working properly (inability to log in, lost baskets, etc.).

5. Duration of consent

Your consent is valid for 6 months. At the end of this period, the consent banner will be shown to you again.

6. Consequences of refusal

Refusing non-essential cookies does not prevent access to the Services. Some features may, however, be degraded:

• No personalisation of the learning path based on analytics
• Less accurate usage statistics for our team
• Some embedded content (YouTube) may not be displayed

7. Data sharing with issuers

Each third-party cookie may entail a transfer of data to its issuer. The privacy policies of the main issuers:

• Clerk: https://clerk.com/legal/privacy
• Whop: https://whop.com/privacy
• PostHog: https://posthog.com/privacy
• Plausible: https://plausible.io/privacy
• YouTube / Google: https://policies.google.com/privacy
• Intercom: https://www.intercom.com/legal/privacy

For transfers outside the EU, see section 5 of our Privacy Policy.

8. Do Not Track and Global Privacy Control

We respect the Do Not Track (DNT) and Global Privacy Control (GPC) signals sent by your browser. If either of these signals is enabled, we consider that you refuse non-essential cookies by default.

These signals also constitute an objection to the cookieless audience measurement described in §3.5, even though that measurement does not require your consent: when they are active, no measurement data is sent.

9. Changes to the Cookie Policy

We may update this policy to reflect the addition of new cookies or technologies. Substantial changes will be notified to you via the consent banner (which will be displayed again), with an invitation to confirm your choices again.

10. Contact

For any question relating to cookies: contact@alchimiecapital.com

Last updated: 2026-09-12, v1.3