Privacy policy
A discreet circle is discreet with the data of those who join it. This document states exactly what we collect, why, for how long, and what you may require of us.
Who is the data controller
The data controller is the Lutopie Business Club, whose registered office is at 60 rue François 1er, 75008 Paris, France. For any question about your data: contact@lbc-cercle.com.
To be completed before publication: legal form, registration number and, where applicable, the contact details of the data protection officer. This information must be identical to that in the legal notice and the terms and conditions of sale.
What we collect, and why
We collect only what you give us yourself. No data is bought, nor enriched from third parties. The public site and the member area do not process the same things: both are described here.
On the public site
Application to the Circle
Name, email address, telephone, occupation and, where applicable, the member who introduces you. Purpose: to consider your application and get back to you. Legal basis: pre-contractual steps taken at your request.
Newsletter
Email address only. You subscribe by writing to us: there is no form, and your address never leaves our mailbox. Purpose: to send you the Circle’s publications. Legal basis: your consent, which you withdraw by telling us so, in a message.
Pre-ordering an edition
Email address, the city you chose and the date of your consent. Purpose: to write to you when the edition you asked for is published, and to count the pre-orders for each city. Legal basis: your consent, given by ticking the box on the form. You withdraw it with a message to us, and your pre-order is erased.
Direct correspondence
The content of exchanges you initiate by email. Purpose: to reply and follow up. Legal basis: our legitimate interest in handling requests addressed to us.
In the member area
Your account
Email address, first and last name, photograph if you have one, your Google account identifier where you sign in that way, together with your tier, your emblem and the technical history of your sign-ins (IP address, browser, device, dates). Purpose: to recognise you and open only the doors of your tier. Legal basis: performance of the membership contract.
Your payment
Name, email address, amount and billing details, together with what your transfer carries: the account holder’s name, their IBAN, the date and the reference of the payment. They reach us through the Circle’s bank, which, like yours, processes them on its own account and under its own obligations. Purpose: to match your transfer to your membership, open your tier, issue the invoice and keep the accounts. Legal basis: performance of the contract, then a legal obligation.
The Atelier documents
The professional documents you deposit in your atelier, where your tier opens it. They can be seen only by you and by those of the house working on your project. Purpose: to carry out the joint project. Legal basis: performance of the contract.
The Salon and the Club
If you take your place there, the telephone number and profile linked to your messaging account for the Salon, and an account for the Club. These spaces are run by outside services, whose policies apply in addition to ours. Legal basis: performance of the contract.
Your image
Photograph, video or testimonial, only if you have consented in writing, for a specified use. That consent is never a condition of membership and may be withdrawn at any time. Legal basis: your consent.
How long we keep it
An unsuccessful application is deleted within twelve months of our reply. A newsletter subscription is kept until you unsubscribe, then deleted. A pre-order is kept for six months at most: it is deleted as soon as we send the email announcing the publication of the edition you asked for, or its cancellation. A member’s data is kept for the duration of the membership, then three years after they leave.
Documents deposited in the Atelier follow a shorter rule: they are returned or deleted at your request at the end of the membership and, failing any request, deleted no later than three months afterwards.
Beyond these periods, only the records the law requires us to keep, accounting and tax, are retained, and only for the period required.
Who has access
Your data is neither sold, nor rented, nor transferred. Within the Circle, it is accessible only to those responsible for admissions and member relations.
Outside, we rely on the categories of processors below, and on them alone. Each acts on our behalf, on our instructions, and for the stated purpose only; none uses your data for itself.
- Your application: an automation service established in the United States, which delivers the form to our mailbox
- Our email exchanges: a business email service established in Ireland, with possible processing in the United States
- The welcome message: an email sending platform established in France
- Your pre-order: the same email sending platform, established in France, which files your address in the list for the city you chose
- The site’s pages: a web host established in the United States, which keeps the technical logs
- Audience measurement: a cookie-free tool established in the European Union, which produces only aggregated statistics
- Your account and sign-in: an account management service established in the United States; and, if you sign in with a Google account, that account’s provider
- The Atelier documents: a document storage service established in Ireland, with possible processing in the United States
- The Salon and the Club: a group messaging service and an online workspace, both established outside the European Union
The fonts and scripts of our pages are served from our own server: no request goes to a font provider or a public repository when you view a page. Once you enter the member area, however, your browser talks to the accounts service, and the Atelier displays the contents of your vault from the service that hosts it.
You may at any time obtain the precise identity of each of them: write to us and we will tell you, together with the safeguards that apply.
Transfers outside the European Union. Several of these processors are established in the United States. Those transfers rely on the European Commission’s standard contractual clauses or, for certified companies, on the EU-US Data Privacy Framework. You may ask us for a copy of the safeguards in force.
Cookies and audience measurement
This site sets no tracking cookie, no advertising tracker and uses no profiling tool. You therefore have no consent banner to put up with: we have nothing to ask you to accept.
Audience measurement is handled by a tool established in the European Union, chosen for that reason: it sets no cookie, collects no personal data and performs no cross-site tracking. It produces aggregated statistics that cannot identify you.
The member area does set a session cookie, strictly necessary to keep you signed in from page to page. It is exempt from consent on that ground, and disappears when you sign out.
What happens when you leave the Circle
Whether your membership reaches its end or is terminated, the house closes the doors: your account is deleted, the share of your atelier is revoked, and you are removed from the Salon and the Club as soon as possible.
The Atelier documents follow the rule in section 03. The rest of your data is kept for three years, then erased. You may request earlier erasure: we will carry it out, subject only to the records the law obliges us to keep.
Your rights
The GDPR gives you the right to access your data, to have it corrected, to have it erased, to restrict its processing, to object to its use and to obtain a portable copy. You may withdraw your consent at any time, without affecting what was done beforehand.
One step is enough: write to contact@lbc-cercle.com. We reply within one month at the latest, and in practice well before.
If our answer does not satisfy you, you may refer the matter to the CNIL, the French data protection authority, cnil.fr, 3 place de Fontenoy, 75007 Paris.
Updates
Any change to this policy is published on this page, with its date. Last updated: 3 October 2026. The legal notice and the terms and conditions of sale complement this document.