Cookie Management Policy
Version 2.3 – Last updated:
This Cookie Management Policy (the “Cookie Policy”) informs users of the website www.eureka-fripe.com (the “Site”) about how Les Chiffonniers d’Eureka Fripe, a simplified joint-stock company (SAS) with share capital of €1,000,000, registered office: 159 route de Paris, 76920 Amfreville-la-Mi-Voie, France, uses cookies and other tracking technologies during browsing.
This Cookie Policy complements the Site’s Privacy Policy and Terms & Conditions.
1. What is a cookie?
A cookie is a small text file placed on the user’s device (computer, tablet, smartphone) when visiting a website. It stores certain information relating to the user’s browsing activity or preferences. Some cookies are essential for the proper functioning of the Site (“necessary” cookies), while others are used to measure traffic or improve the browsing experience.
2. Applicable legal framework
This Cookie Policy complies with:
- Regulation (EU) 2016/679 of 27 April 2016 (General Data Protection Regulation – GDPR);
- the French Data Protection Act of 6 January 1978 as amended; and
- the European ePrivacy Directive.
Local rules may apply in certain countries of access (e.g., the United Kingdom, Germany). These are specified in Section 10, “Territorial scope and local specificities”.
3. Cookies used on this Site
This Site uses:
- essential technical cookies required for its operation (e.g., language preference, consent banner and choices via Borlabs, hCaptcha anti-bot protection on forms);
- first-party audience measurement cookies via Matomo (self-hosted in France), configured for anonymised analytics; and
- Google Ads marketing cookies, subject to your consent, used to measure the performance of our advertising campaigns and optimise media spend.
Google Ads marketing cookies are managed through Borlabs Cookie and are only activated after your explicit acceptance of the “Marketing” category. Before you provide consent, no advertising cookies and no Google Ads signals of any kind are sent or activated.
The Site uses three categories of cookies:
- Necessary – essential for the Site to function properly (language selection, consent management, hCaptcha security on forms);
- Statistics / Analytics – anonymised first-party audience measurement (Matomo on-premise; see the table below for details);
- Marketing (optional) – used to measure the effectiveness of Google Ads campaigns and, if you consent, to support our advertising actions.
If you refuse the “Marketing” category, these cookies are not set.
| Cookie name | Provider / Domain | Purpose | Retention period | Type |
|---|---|---|---|---|
| pll_language | www.eureka-fripe.com | Polylang: remembers the user’s chosen language to display the correct version of the site on subsequent visits. | Up to 1 year | Strictly necessary |
| borlabs-cookie | .www.eureka-fripe.com | Saves consent preferences (enabled/disabled categories) via the Borlabs banner. | 2 months | Strictly necessary |
| borlabs-cookie-gcs | .www.eureka-fripe.com | Stores Google Consent Mode values (e.g., ad_storage, ad_user_data, ad_personalization) after the user’s choice. | 2 months | Strictly necessary |
| __cf_bm | hcaptcha.com / newassets.hcaptcha.com | hCaptcha (Cloudflare Bot Management): strictly necessary security cookie used to distinguish humans from bots and prevent automated form submissions. No advertising purpose. | Variable, up to 1 day (typically ~30 minutes) | Strictly necessary (Security) – third-party |
| __cflb | api.hcaptcha.com | hCaptcha / Cloudflare Load Balancer: ensures availability and reliability of the anti-bot service. | Variable, up to 1 day | Strictly necessary (Security) – third-party |
| hmt_id | api.hcaptcha.com | Technical identifier used by hCaptcha as part of bot-protection (may appear only in certain contexts). | Variable, up to 1 year (context-dependent) | Strictly necessary (Security) – third-party |
| _pk_id.* | www.eureka-fripe.com | Matomo (on-premise, hosted in France): assigns an anonymised unique ID for internal traffic analytics (consent-exempt in FR/EEA under CNIL conditions). | Up to 1 year | Statistics / Analytics (consent-exempt) |
| _pk_ses.* | www.eureka-fripe.com | Matomo (on-premise): temporary session ID for anonymous journey analysis. | 1 hour | Statistics / Analytics (consent-exempt) |
| Marketing cookies (Google Ads) | ||||
| _gcl_au | .eureka-fripe.com | Google Ads (Google Click Identifier): helps attribute ad clicks to conversions and measure campaign performance. Set only after explicit consent. | 90 days | Marketing / Advertising (requires consent) |
Except for the Google Ads marketing cookie (_gcl_au) set in first party by the domain .eureka-fripe.com and only after your explicit consent, as well as the hCaptcha security cookies — __cf_bm (domains hcaptcha.com / newassets.hcaptcha.com), __cflb and, where applicable, hmt_id (domain api.hcaptcha.com) — set as third-party when a protected form is displayed and/or validated, all other cookies used on this Website are set by the domain www.eureka-fripe.com.
4. Consent management
When visiting the Website for the first time, an information banner managed by Borlabs Cookie allows you to review this Cookie Policy and set your preferences.
Statistics Cookies (consent-exempt)
Matomo audience measurement cookies are configured to be strictly anonymised and are hosted in France. In France and within the EEA, when these anonymisation conditions are fully met, such cookies may be exempt from consent under CNIL guidance.
Marketing Cookies (subject to consent)
The use of marketing cookies, in particular for the Google Ads service, is subject to your prior, explicit consent.
No cookies, tags or tracking signals are sent to Google before you have made your choice in the Borlabs Cookie banner.
If you accept the “Marketing” category, the global Google Ads tag (gtag.js) is loaded and conversions can be measured in full (using cookies). If you refuse, no cookies or signals — even anonymised — are sent to Google.
The Website uses Google Consent Mode v2 (basic), managed by Borlabs Cookie, ensuring that no data are shared with Google before consent is given and that no modelling is performed.
Changing your choice
You may modify or withdraw your consent at any time by clicking the cookie management icon, permanently displayed at the bottom left of the screen.
This icon opens the Borlabs Cookie Console, where you can review and adjust your preferences. Borlabs Cookie stores your choices locally in your browser and does not transmit any personal data to third parties.
Future updates
If, in the future, third-party cookies requiring prior consent are added, the Borlabs Cookie banner and this Cookie Policy will be updated so you can accept or refuse them individually, in full transparency.
5. Browser settings
You can configure your browser to accept, refuse or delete all or some cookies. The links below explain how to adjust settings:
6. Retention of preferences
Your choices (consent or refusal) are stored for a maximum of 2 months, corresponding to the validity of the borlabs-cookie. After this period, a new consent banner will be displayed.
7. Right of withdrawal and complaints
You may withdraw or modify your cookie consent at any time via the Borlabs Cookie Console, accessible permanently through the icon at the bottom left of the screen, as described in Section 4.
For any question or complaint regarding cookie management, you may contact the Data Protection Officer (DPO) at: contact@eureka-fripe.com.
If a disagreement persists, you have the right to lodge a complaint with the French Commission Nationale de l’Informatique et des Libertés (CNIL).
8. Security and confidentiality of collected data
Information collected via audience measurement cookies is fully anonymised. No full IP address or personal data are retained. Data are hosted in France by our managed service provider and are not transferred outside the European Economic Area.
9. Updating this Policy
This Cookie Policy may be updated to reflect:
- changes in applicable laws and regulations;
- new guidance from the CNIL, the ICO or other data protection authorities;
- technical updates to our measurement and consent management tools.
Any substantial change will be clearly indicated on this Website (e.g., the update date shown at the top of this page). We encourage users to review this page regularly.
10. Territorial scope and local specificities
- European Union / EEA: we apply the ePrivacy framework and the GDPR. No non-essential cookies are set without prior consent. Where analytics tools are configured to be strictly anonymous, a consent exemption may apply depending on local authorities.
- United Kingdom: under UK GDPR / PECR, consent is generally required for analytics cookies. Our banner blocks these cookies until a choice is made.
- Germany: under the TTDSG, prior consent is required for non-essential trackers; our banner prevents any placement before your choice.
- United States: we do not “sell” or “share” your information for cross-context advertising purposes. If this changes, a “Do Not Sell or Share” link and recognised opt-out signals will be implemented.
- Other countries (e.g., India, Australia): where local laws require prior consent for non-essential trackers or specific disclosures, our banner and this Policy are adjusted accordingly.