Cookie Management Policy

1. Purpose and Legal Framework

This policy governs the use of trackers on the Site. It describes the nature of the trackers that may be used, their purposes, their retention period, the legal bases that justify them, as well as the means available to you to express, refuse, change, or withdraw your consent.

The placement and reading of trackers are governed by a precise set of rules. The Publisher undertakes to comply with all applicable texts, and in particular:

• Article 82 of Law No. 78-17 of 6 January 1978 on information technology, data files and civil liberties (known as the « loi Informatique et Libertés »), which transposes into French law Article 5.3 of Directive 2002/58/EC known as the « ePrivacy » Directive and requires prior information and consent for any operation to access or store information on a user's terminal device;
• the Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data ("GDPR"), in particular its Article 6(1)(a), which establishes consent as a legal basis for the processing;
• the amending guidelines and the "cookies and other trackers" recommendation adopted by the Commission nationale de l'informatique et des libertés (CNIL), which specify the practical arrangements for obtaining consent, the requirement that refusal be as simple as acceptance, the recommended retention periods, and the list of trackers exempt from consent.

This policy is informative in nature and is binding on the Publisher. It reflects MARA LABS's commitment to placing respect for your privacy at the center of the Site's design, in accordance with the principle of data protection by design (privacy by design).

2. What is a cookie or tracker

The term "tracker" refers, generically, to any technology that reads or writes information on an internet user's device. The "cookie" is the best-known form, but not the only one. The regulations cover all such mechanisms, regardless of their technical or commercial name.

The main categories are as follows:

• HTTP cookies: small text files placed by a site's server or a third party and stored by the browser. They are sent back to the server with every request and make it possible, for example, to recognize a device from one visit to the next.
• Local storage (local storage and session storage): internal browser storage areas that retain information on the device without automatic transmission to the server. This is the technology used by the Site to remember your cookie preferences.
• Invisible pixels (web beacons or tracking pixels): very small, often transparent images embedded in a page or email to signal that it has been viewed. The Site does not use any.
• Identifiers and fingerprints: techniques for recognizing a device based on a combination of its technical characteristics (fingerprinting) or on persistent identifiers. The Site does not use any of these techniques.

All such mechanisms are treated identically under the law. As soon as they access information stored on your device or write information to it, they fall under Article 82 of the loi Informatique et Libertés, regardless of their technical nature.

3. Principles applicable to the placement of trackers

The guiding principle is that of prior consent. Unless an exemption is expressly provided for, no tracker may be placed or read before the user has expressed agreement through a clear affirmative action. Silence, inaction, merely continuing to browse, or scrolling the page never constitute consent.

Certain trackers are exempt from consent. Regulations and the CNIL acknowledge that trackers strictly necessary for the provision of an online communication service expressly requested by the user, or whose exclusive purpose is to enable or facilitate electronic communication, may be placed without prior collection of consent. They remain nonetheless subject to an information obligation, which this policy fulfills.

Refusal must be as easy as acceptance. In accordance with the CNIL's recommendation, the user must be able to refuse trackers as easily as they can accept them. The consent banner deployed on the Site accordingly offers, at the same level and with equivalent visibility, an option to accept, an option to refuse and an option to customize their choices.

Consent must be freely given, specific, informed, and unambiguous. It is requested purpose by purpose, with the user retaining the ability to accept certain categories of trackers while refusing others. It may be withdrawn at any time, as easily as it was given, without such withdrawal affecting the lawfulness of processing based on consent given before that withdrawal.

4. Categories of trackers and overview

Trackers fall into several categories according to their purpose. This classification determines the applicable legal regime, and in particular whether or not your consent must be obtained. The table below sets out an overview of these categories and specifies, for each one, its status on the Site.

As things currently stand on the Site, only the category of strictly necessary trackers is activated. No audience measurement, functional, advertising, or social media tracker is deposited.

5. List of strictly necessary cookies

Strictly necessary trackers ensure the proper functioning of the Site and compliance with your choices. They cannot be disabled without degrading the service you have expressly requested, namely the memorization and observance of your cookie preferences. As such, they are exempt from consent within the meaning of Article 82 of the loi Informatique et Libertés, but are covered by this notice.

The Site uses a single strictly necessary tracker, described in the following table:

This tracker contains no directly identifying data. It merely records the state of your preferences on your own device, using your browser's local storage. No information is transmitted to the Publisher or to any third party as a result of this storage. Once the six-month period expires, your choice is deleted and the consent banner is presented to you again.

6. Audience measurement

Audience measurement involves producing anonymous or pseudonymized statistics on Site traffic. It aims to understand browsing patterns, identify the most-visited pages, and improve the Site's usability and content. It generally relies on placing cookies or reading information on the device.

As of today, no audience measurement tool is active on the Site. The Site does not place any statistics cookies and does not use any traffic analysis provider, whether internal or third-party.

Should such a tool be deployed, the following framework would apply:

• As a matter of principle, audience measurement is subject to the user's prior consent, collected via the banner, and is disabled by default.
• However, the CNIL allows a consent exemption for audience measurement solutions strictly limited to producing anonymous statistics, configured so as not to track browsing on other sites, not to allow data cross-referencing, and to offer an opt-out mechanism. Any use of such an exempted configuration would then be disclosed in this policy.
• In accordance with CNIL recommendations, the lifespan of audience-measurement cookies would be limited to a maximum of thirteen (13) months, with no automatic extension on each new visit.
• The retention period for data collected by means of these trackers would not exceed twenty-five (25) months, after which it would be deleted or anonymized.

This policy would be updated prior to any deployment. The identity of any prospective provider, the cookies concerned, their duration, and the legal basis relied upon would be added, and the consent banner would be adapted accordingly.

7. Third-party cookies, CDN, and social networks

The Site does not integrate any third-party cookies, social sharing buttons, or advertising networks. No social media content (video, news feed, “like” button) is embedded in the pages, so no third-party tracker of this kind can be placed.

The Site nevertheless uses a content delivery network (CDN) for a strictly technical purpose. In order to display its three-dimensional graphic elements, the Site loads the Three.js software library from the public jsDelivr network. This mechanism calls for the following clarifications:

• Loading this library results in the transmission of your IP address to the jsDelivr provider, for the sole purpose of the technical delivery of the file requested by your browser.
• This operation does not result in the placement of any cookie or the storage of any information on your device within the meaning of Article 82. The IP address is processed by the provider solely for the purpose of delivering the resource.
• The transmission of the IP address is technically essential to establishing the connection that enables the resource to be downloaded; it is inherent to the operation of the electronic communication protocol.

No profiling or advertising tracking is associated with this technical call. For more information on the processing of your IP address in this context, please refer to the Site's Privacy Policy.

8. Legal bases by category of tracker

Each category of tracker relies on its own legal basis, determined by its purpose. The table below sets out the correspondence between categories and their legal basis.

Processing of the IP address linked to the CDN is based on the Publisher's legitimate interest (Article 6.1.f of the GDPR) in providing a functional, high-performance site, with no tracker being placed on this occasion.

9. Collection and proof of consent

Consent is collected by means of an “opt-in” cookie management banner. This banner is displayed on your first visit, or when your previous choice has expired or been cleared. No tracker subject to consent is placed until you have expressed a positive choice.

The banner offers a granular choice. It allows you, at an equivalent level of visibility, to:

• to accept all trackers subject to consent;
• to refuse all such trackers, just as easily as accepting them;
• to customize your choices, category by category, in order to accept certain purposes and decline others.

Proof of your choice is retained proportionately. The outcome of your decision is recorded locally on your device by means of the strictly necessary tracker nullbot_consent, which allows the Publisher to respect your choice and avoid soliciting you unnecessarily. This record constitutes evidence of the expression of your will for the entire duration of its validity.

Withdrawal of consent is guaranteed. You may change your decision at any time, without having to justify your choice, by reopening the cookie management panel.

10. Managing your choices

You retain control over your trackers at all times. The simplest way to review or change your preferences on the Site is to reopen the cookie management panel by clicking the button below:

Manage my cookies

You can also act directly from your browser. Most browsers let you view, block, or delete cookies and local storage data. The settings differ depending on the software used:

• Google Chrome: “Settings” menu, “Privacy and security” section, then “Cookies and other site data”.
• Mozilla Firefox: "Settings" menu, "Privacy & Security" section, then "Cookies and Site Data" section.
• Apple Safari: “Settings” (or “Preferences”) menu, “Privacy” tab, then manage cookies and website data.
• Microsoft Edge: "Settings" menu, "Cookies and site permissions" section, then "Manage and delete cookies and site data".

Manually clearing local storage will delete the nullbot_consent tracker; the consent banner will then be shown to you again on your next visit. Blanket cookie blocking from your browser may, on other sites, degrade certain features.

11. Validity period of consent and lifespan of trackers

Your choice is not kept indefinitely. In accordance with CNIL recommendations, both consent and refusal are subject to a limited period of validity, at the end of which you will be asked again for your decision so that your information remains up to date.

• Retention period of your choice: six (6) months. At the end of this period, the nullbot_consent tracker is deleted and the consent banner reappears.
• Lifespan of audience measurement cookies (in the event of future deployment): thirteen (13) months maximum, with no automatic extension.
• Retention period for audience measurement data (in the event of future deployment): twenty-five (25) months maximum.

These periods constitute maximum limits. The Publisher undertakes to retain information only for the period strictly necessary for the purposes pursued, and to delete or anonymize it at the end of the stated periods.

12. Data transfers outside the European Union

The Site does not, to date, carry out any transfer of personal data to a country outside the European Union by means of trackers. The only active tracker, nullbot_consent, remains stored locally on your device and is not subject to any transmission.

Loading the Three.js library via the jsDelivr CDN may involve the technical routing of your IP address through servers that may be located outside the European Union. This transmission is limited to delivering the requested resource and does not result in any tracker being placed. In the event of such routing, the Publisher ensures that it takes place within a framework offering appropriate safeguards within the meaning of Chapter V of the GDPR.

Should an audience measurement tool or a third-party provider be used in the future, the Publisher will ensure that any transfer outside the European Union is governed by a mechanism compliant with the RGPD (adequacy decision, standard contractual clauses or equivalent safeguards), and this policy would be updated accordingly. For more details, please refer to the Privacy Policy.

13. Consequences of refusal

Refusing trackers subject to consent has no effect on access to the Site. As the Site is a static showcase that does not depend on any convenience or measurement tracker to function, your refusal does not affect either the viewing of content or navigation between pages.

The strictly necessary tracker remains active regardless of your decision. The local storage nullbot_consent, which exists specifically to record and honor your choice, remains in use even if you refuse the other categories, because it is what makes your decision effective. Without it, the Site could not remember your refusal and would prompt you again on every visit.

You retain, at all times, the ability to change your position. A refusal expressed today may be withdrawn tomorrow, and vice versa, by reopening the cookie management panel. No usage restriction or service degradation is attached to the exercise of this right.

14. Contact, complaints and updates

For any question regarding this policy or the management of trackers, you may contact the Publisher by postal mail at the address of its registered office:

MARA LABS, SAS — 41 rue Jacquemars Giélée, 59800 Lille, France.

A dedicated contact email address will be activated as soon as the domain is opened, and will be published here.

You have the right to lodge a complaint with the supervisory authority. If you believe that the processing of your data or the management of trackers does not comply with applicable regulations, you may contact the Commission nationale de l'informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, or via its website www.cnil.fr.

This policy may evolve. It may be updated to reflect changes to the Site, applicable regulations, or CNIL recommendations, particularly in the event of the future deployment of an audience measurement tool. You will be notified of any substantial change and, where applicable, your consent will be sought again. We invite you to regularly consult this page as well as the Site's Privacy Policy and Legal Notice.