Privacy policy

It applies to processing carried out:

• when browsing the Site (technical data),
• when creating and using an account,
• when subscribing to the newsletter,
• when publishing content (e.g. comments),
• when implementing security and moderation measures.

The entity that determines the purposes and means of the processing described below — the “controller” within the meaning of Article 4(7) GDPR — is:

Data provided directly

Depending on the features used, PromethEUs may process:

• Account: email address, username/profile name, account settings; hashed password (never in plain text).
• Profile (optional): photo, banner, biography, links, country, date of birth (if provided).
• Newsletter: email address, subscription/unsubscription status, technical traces related to registration.
• Published content: comments and associated metadata (date/time, account identifier).

Data collected automatically

When accessing the Site and for security purposes, PromethEUs may process:

• Technical data: IP address, user-agent, timestamps, session information, technical identifiers.
• Security data: anti-abuse events (anti-bruteforce, anti-spam, abnormal access detection), blocklists.

PromethEUs processes your data only when a legal basis exists (Article 6 GDPR).

Mandatory nature of data

• Data required for account creation/management are mandatory to provide the service.
• Profile data marked as “optional” are not mandatory.
• Newsletter consent is free: refusal does not prevent use of the Site outside the newsletter.

Data are accessible:

• to authorized members of the PromethEUs team (access limited by roles and needs),
• to providers strictly necessary for operating the Site, acting as processors or independent controllers depending on the case.

Technical providers (examples)

• Hosting / email: IONOS (France).
• Site security / protection: Cloudflare (depending on configuration).
• Audience measurement (with consent): Google Ireland Ltd, acting as processor. The consent banner is PromethEUs’s own: no third-party provider.
• Mapping / third-party content: external services (tiles, APIs, video players) that may receive technical data (IP, user-agent).

Some third-party services (e.g. online fonts, CDNs, embedded videos) may result in access to technical data (including IP address) by entities located outside the EU.

Google Analytics (only if you consent): data may be accessed by Google LLC in the United States, which is certified under the EU-US Data Privacy Framework (European Commission adequacy decision of 10 July 2023).

When transfers outside the EU exist, PromethEUs implements appropriate safeguards provided by the GDPR (e.g. standard contractual clauses) and seeks to limit such transfers when possible (e.g. self-hosting resources).

PromethEUs keeps data only for as long as necessary for the purposes pursued.

• Account: as long as the account is active; deletion/anonymization when the account is closed.
• Inactivity: an account with no login for 3 years is deleted automatically, together with the associated data. A warning email is sent 30 days before deletion; simply logging in again before that date keeps the account.
• Deletion: on your request, from your account settings (password required), your account and its data are deleted immediately and completely (comments, likes, bookmarks, contributions, newsletter subscription, community profile, posts, follows and private messages); a confirmation is sent to your address. Replies from other members to your comments are kept.
• Newsletter: until consent is withdrawn (unsubscribe); minimal technical evidence of withdrawal may be retained if necessary.
• Security/anti-abuse: technical logs (e-mail errors, security-policy reports) are kept 28 days at most. The audit log of administration actions (who did what in the console, with the IP address) is kept 12 months, as the accountability of people holding elevated access requires.
• Audience measurement: event-level data kept 2 months in Google Analytics, then only aggregated statistics remain; consent choice kept 6 months.
• Backups: limited retention (target: <= 30 days), with progressive overwrite.

The Site primarily uses strictly necessary cookies (e.g. session cookie) for operation and security.

Strictly necessary cookies

These cookies do not require prior consent (operation/security). Example:

• Session cookie (e.g. __Host-pe_sid): session maintenance/authentication, “session” or short duration.
• Stay-signed-in cookies (__Host-pe_dev, __Host-pe_remember): only if you tick “Stay signed in”. The first holds a random token (only its fingerprint is kept on our servers) that reopens your session on this device for 90 days from your last visit; you can end it from Security (“Connected devices”) or by signing out. The second only remembers, for 400 days, whether the box was ticked, so that it is pre-ticked next time.

Non-essential cookies

With your consent only, PromethEUs measures its audience with Google Analytics 4 to know which pages are read and how visitors move from one page to another. Nothing is loaded from Google before you accept: no script, no cookie, no request.

• Cookies _ga and _ga_<ID> (Google Analytics): random visitor identifier, 13 months at most, never extended, set only on the site you visit (prometheus-euro.eu or swipe.prometheus-euro.eu).
• Data sent: page address without its search terms or tokens, page title, origin of the visit (referring site without its path, and utm campaign if any), approximate country/region, device type. No account identifier, no advertising signal, no cross-device tracking (Google Signals disabled).
• Choice cookie pe_consent (PromethEUs): remembers your choice for 6 months, valid on prometheus-euro.eu and swipe.prometheus-euro.eu, together with a random identifier. That identifier, your choice and its date are kept for 25 months on our servers as proof of consent, without your IP address or any other data.
• Never measured: the member area, the donation page, the administration console, login and password-reset pages.

Refusing is as easy as accepting and has no effect on your use of the Site. You can change your mind at any time; withdrawing deletes the Google Analytics cookies.

Cookie settings

The Europe Live map shows how many people are watching it at the same time, and — only if you choose to share it — roughly which area they are watching from. These are two separate things.

The counter

No consent is required and no personal data is processed: a random, opaque token is generated for the browser tab, kept for 90 seconds, and never linked to an account. It is regenerated for every new session and deleted when the tab closes.

Sharing your area

• Legal basis: your consent (GDPR art. 6.1.a), asked once and refused by default.
• Source: your browser’s geolocation, which asks for its own permission. IP-based geolocation is never used — it cannot be consented to.
• Precision: your position is rounded to a cell of about 110 km in your browser, before anything is sent. The server never receives a precise position.
• Aggregation: only cells holding at least three watchers are shown. A cell with fewer is not displayed at all.
• Retention: 90 seconds. Expired rows are deleted on every write.
• No IP address is stored or read by this feature. Web server access logs record IP addresses for every HTTP request, as on any website; that is separate from this processing.
• Withdrawal: one click in the map settings panel, exactly where you granted it. Your stored cell is erased immediately.
• Refusing changes nothing else on the map. Only the ability to see other people’s areas depends on sharing your own.

The Swipe 2027 questionnaire (swipe.prometheus-euro.eu) keeps your answers in your browser only: no answer is sent to us while you play. If you have a PromethEUs account, you can choose to save your answers to it, to find them again on another device.

• Anonymous progress counter (no consent needed, no cookie): when you reach the start, a quarter, half, three quarters or the end of a path, the site adds 1 to a counter of the day, with only the path length. No answer, identifier or device data is sent, so the counts cannot be linked to you.
• Audience measurement (only with your consent, through the cookie banner): as on the rest of the Site, Google Analytics measures visits to Swipe, the time spent playing and the stages reached (start, quarter, half, three quarters, end). Your answers and results are never sent. You can change your choice at any time from Swipe settings (“Manage my cookies”).
• Data: your answers (agree, neutral, disagree, super likes), the selected path length and your priority themes. Because they reflect your political opinions, they are special-category data (GDPR art. 9).
• Legal basis: your explicit consent (GDPR art. 9.2.a), asked separately from account creation by an unticked box, dated and versioned. Without it, nothing is saved.
• Security: answers are encrypted in the database (AES-256-GCM) and bound to your account; only the number of answers is stored in clear. They are never shared, sold or used to profile you or to target you with content.
• Account: creating an account from Swipe creates a PromethEUs account, which gives access to the whole Site, not only to Swipe. The newsletter is optional and separate.
• With saving on: the order in which you answered (the comparator’s “race” chart), a daily snapshot of your five closest candidates (your trajectory, 60 at most), the cards whose answer you changed after giving it (for the analysis of your second thoughts) and the last version of the cards you have seen (so that only new ones are offered to you). These items are encrypted together with your answers.
• “New proposals” alert (optional, unticked box): an email when new cards are published. Legal basis: your consent, which you can withdraw at any time from the Swipe profile, the notification settings page or the link in every message. The origin of your account (Swipe, Waves, site, newsletter) is recorded for account management.
• In-depth analysis (optional purchase): computed by the Site from your saved answers when you open it, and not stored. Payment takes place on HelloAsso’s page; the Site only keeps the amount, date, payment status and its reference, linked to your account, for ten years (accounting records).
• Result link (optional): when you share your result, the Site stores the answers contained in the link under an 8-character code, with no account, no IP address and no name, so that the link stays short. Any first name stays in the link address. A link not opened for 18 months is deleted.
• Barometer (optional in the game): if you turn on “Take part in the Barometer”, each of your next answers is sent on its own, with no identifier, to add 1 to a daily counter for that proposal (agree, neutral or disagree). Answers you have already given are never sent. On proposal pages and the embeddable card of the day, the answer given is counted the same way. No IP address is kept (only a hash, deleted after one hour, against abuse). Percentages for a proposal are only published from 15 answers; below that, only the number of answers for each choice is shown. Per candidate, only the number of their approved proposals is published (blind ranking), never the detail of their proposals. Nothing is published on the day before or the day of a vote.
• Retention: until you delete the save (Profile tab of Swipe) or your account. They are included in the export of your data and erased with your account.

The WAVES mini-game (/waves) works without an account: your progress then stays in your browser. With a PromethEUs account, you can save it to find it again on another device and, if you choose to, appear on the leaderboard.

• In your browser (local storage, never sent without an account): high score, best wave, discovered creatures, current run, settings (sound, music, vibration, effects) and whether you have seen the tutorial. “Clear high score and bestiary” (game Settings) removes the high score, best wave and bestiary from this device; clearing the site's data removes all of it.
• On your account (if you are signed in): the same items, plus your best score and best wave of the week. This is non-sensitive game data; the score is reported by your browser and is not verified. Purpose: letting you resume your progress elsewhere. Legal basis: performance of the service you request.
• Leaderboard: off by default. If you tick “Appear on the leaderboard”, your first name, the initial of your last name, your high score and best wave (and those of the week) become visible to every visitor of the game. Unticking the box removes you from the leaderboard immediately. A run played with a cheat command is not counted.
• Account created from the game: first name, last name and email address, as for any PromethEUs sign-up. The “Waves has been updated” alert and the newsletter are optional (unticked boxes) and can be switched off at any time.
• Retention: until you delete the save (game Settings, “Delete”) or your account. Deleting the save affects neither your account nor the progress stored on the device. The save is included in the export of your data and erased with your account.
• No game-specific audience measurement: the /waves page loads neither Google Analytics nor any other tracker.

The Community area of “My space” (sign-in required, nothing is public) lets members find each other, publish short posts and exchange private messages.

• Findability: every signed-in member can find any account by its display name (your pseudonym if you set one, otherwise your first and last name) or its @username. A new account is private: others then see only your display name, photo and @username, and can ask to follow you; only the followers you accept read your bio, interests and posts. Switching to a public account makes them readable by every signed-in member. Never your email address, phone number, birth date or postal address; your country only if you tick it. To stay discreet, use a pseudonym and a @username that does not contain your name. Legal basis: performance of the community service you use; your account privacy setting is your control.
• Posts, replies, likes and follows: short texts (500 characters, no links), readable according to your account: every signed-in member if it is public, your accepted followers if it is private. A member you block sees nothing of yours and you nothing of theirs.
• Private messages are end-to-end encrypted: the keys are created in your browser and the server only stores encrypted blocks and key fingerprints. PromethEUs cannot read your messages. Your 4-digit messaging code protects your key together with a secret kept by the server (encrypted at rest), which is only released after a valid proof of the code; after 5 wrong tries code access is locked for an hour and you are warned by email. Your recovery key remains the way back in: if you lose both the code and the recovery key, your messages cannot be recovered. We do see the metadata: who writes to whom, when, and the size of each message.
• Reports: when you report a post, a profile or a message, the moderators see your report. For a message, only the text you choose to attach is passed on, in clear; the Site cannot verify it.
• Email notification (optional): a message telling you that you have a new message, never naming the sender or quoting the text, at most once every 6 hours. You can turn it off in “Public profile”.
• Retention: until you delete an item or your account. Erasing your account deletes your public profile, posts and the replies to them, likes, follows, messaging keys and your conversations on both sides. All of it is included in the export of your data (messages in encrypted form).

A donation can be made by SEPA bank transfer, from your bank to the association’s, or — when this option is offered on the donation page — by bank card or SEPA direct debit through HelloAsso, a payment platform for associations. In both cases the Site never receives your card number or IBAN. You can give by transfer without telling us anything; if you want a receipt after a transfer, you can declare your donation through a form.

The declaration form collects your first name, last name, postal address, country, email address and the announced amount. This information is encrypted in the database and readable only by the association’s treasurer, from an account protected by two-factor authentication. When the transfer is credited, the association’s bank also makes available the payer’s name, the IBAN of the debited account, the amount, the date and the reference.

For a card or direct-debit payment, you are redirected to HelloAsso’s payment page, where you enter your payment details and identity; HelloAsso is responsible for that processing under its own privacy policy and sends you your receipt. Once the payment is confirmed, the Site receives from HelloAsso your first name, last name, email address, postal address (if entered), the amount and the payment date. These are encrypted in the database, readable only by the association’s treasurer, and kept for ten years (accounting obligation). If you enter your name or email on our page before paying, they are passed to HelloAsso only to pre-fill its page.

Donations do not give rise to a tax receipt. You can ask for access to your data, for its correction, or for the erasure of a declaration not followed by a transfer, by writing to the association. Data that accounting law requires us to keep cannot be erased before the end of the retention period; your other rights remain.

PromethEUs implements appropriate technical and organizational measures, including:

• access control (roles),
• anti-abuse protection (anti-bruteforce/anti-spam),
• logging of sensitive actions,
• backups and restoration procedures.

In accordance with the GDPR, you have the following rights: access, rectification, erasure, restriction, objection, portability (under the conditions provided by law).

Where processing is based on your consent (e.g. the newsletter), you may withdraw that consent at any time, without affecting the lawfulness of processing carried out before withdrawal (Article 7(3) GDPR). Withdrawal is as easy as giving consent (unsubscribe link in every message or request sent to the address below).

You may also give general or specific directives on the fate of your personal data after your death, in accordance with Article 85 of French Law No. 78-17 of 6 January 1978 (“Informatique et Libertés”).

Exercise of rights: support@prometheus-euro.eu (subject: “GDPR — Exercise of rights”).

You can download a copy of your data yourself, at any time, from your account settings (password required); the copy is a JSON file and does not contain your password or security codes.

PromethEUs may request additional information to verify your identity before processing a request.

A response is provided within GDPR time limits (typically 1 month, extendable in certain cases).

You may lodge a complaint with the competent supervisory authority, notably the CNIL for France.

PromethEUs does not carry out any automated decision-making, including profiling, producing legal effects concerning you or similarly significantly affecting you within the meaning of Article 22 GDPR.

The automated anti-abuse measures described in the “Security” section (anti-bruteforce, anti-spam) may temporarily restrict access to the Site; such measures may be contested at any time via the contact address given in the “Your rights” section.

PromethEUs may update this policy to reflect changes to the Site, its services, or applicable law. The update date appears in the header.

Information relating to the identity of the publisher, the publication director and the hosting provider of the Site is set out in the Juridisk Boð.