This translation is provided for information only. Only the French version is legally binding.

Legal document

Cookie and tracker policy

Version 1.0 — never in force

Archived version, replaced on 23 October 2026. See the version in force

Article 1 — Purpose and scope

This policy informs Users of the Cookies placed or read when they visit the Site, of their purposes and lifetime, and of the means available to them to accept or refuse them or to withdraw their consent. The related Processing of Personal Data is described in the personal data protection policy.

Article 2 — Definitions

In this document, the following capitalised terms have the meaning given below, in the singular as in the plural:

“Publisher”: the company AXO-LAB, single-shareholder simplified joint-stock company (SASU), registered under SIREN number 103 310 017, which publishes and operates the Site and the Service.
“Site”: the website available at www.recto-medias.fr and its subdomains.
“User”: any person who accesses the Service, in whatever capacity.
“Cookie”: any tracker, in particular a text file, placed or read on the User’s device when visiting the Site.
“Personal Data”: any information relating to an identified or identifiable natural person, within the meaning of Article 4(1) of the GDPR.
“Processing”: any operation performed on Personal Data, such as collection, storage, consultation, disclosure or erasure, within the meaning of Article 4(2) of the GDPR.
“GDPR”: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“French Data Protection Act”: French Law No. 78-17 of 6 January 1978 on information technology, data files and civil liberties (loi Informatique et Libertés).

Article 3 — Legal framework

Under Article 82 of the French Data Protection Act, placing and reading Cookies on a User’s device require their prior consent, given after clear and complete information, unless the sole purpose of the Cookies is to enable or facilitate communication by electronic means, or they are strictly necessary for the provision of a service expressly requested by the User.

The Publisher applies the guidelines (deliberation No. 2020-091) and the recommendation (deliberation No. 2020-092) of the French data protection authority (Commission nationale de l’informatique et des libertés, CNIL) of 17 September 2020 on cookies and other trackers.

Article 4 — Cookies used

The Site only uses first-party Cookies, placed by the Site itself. It places no advertising Cookies or social network Cookies, and loads no resources from a third-party service: typefaces, images and scripts are served from the Publisher’s servers, and the Matomo audience measurement tool is installed on those same servers.

Cookies placed by the Site
Name	Issuer	Purpose	Category	Lifetime	Consent
recto_consentement	Recto (first-party cookie)	Stores your cookie choices, their date and the version of the cookie policy.	Strictly necessary	6 months	Not required
recto_langue	Recto (first-party cookie)	Remembers the language of the Site chosen by the User (French or English), when it differs from that of their browser.	Strictly necessary	6 months	Not required
mtm_consent_removed	Recto, via Matomo (first-party cookie)	Remembers your refusal of audience measurement, so that no measurement is carried out.	Strictly necessary	6 months	Not required
_pk_id.*	Recto, via Matomo (first-party cookie)	Visitor identifier, specific to the Site, used to recognise a returning visit.	Audience measurement	13 months	Required
_pk_ses.*	Recto, via Matomo (first-party cookie)	Groups together the pages viewed during the same visit.	Audience measurement	30 minutes	Required
mtm_cookie_consent	Recto, via Matomo (first-party cookie)	Tells Matomo that you have accepted audience measurement cookies.	Audience measurement	6 months	Required

Article 5 — Audience measurement

5.1 Before the User makes a choice

As long as the User has not made a choice, no audience measurement Cookie is placed. Visits are measured without Cookies, with Matomo configured in line with the conditions for exemption from consent set by the CNIL: the sole purpose of the measurement is to produce anonymous statistics, the IP address is truncated by two bytes, the data are neither combined with other Processing nor passed on to third parties, no tracking takes place from one site to another and the data are kept for twenty-five months at most.

5.2 After acceptance

If the User accepts audience measurement, the audience measurement Cookies listed in Article 4 are placed. They make it possible to recognise a returning visit, for thirteen months at most, and are used for no other purpose.

5.3 After refusal or withdrawal of consent

If the User refuses audience measurement or withdraws their consent, existing audience measurement Cookies are deleted and audience measurement is entirely disabled for their browser: no visit data are collected any more, with or without Cookies.

Article 6 — Obtaining consent

6.1 Cookie banner

On their first visit, the User is invited to make their choice through a banner offering three buttons that look the same: “Accept all”, “Refuse all” and “Customise”. Refusing is as easy as accepting. The “Customise” button allows a choice to be made category by category; no box is ticked by default. The banner does not prevent the Site from being viewed; choosing “Continue without accepting” amounts to a refusal.

6.2 Storage of the choice

The User’s choice, whether acceptance or refusal, is kept for six months, a period that the CNIL presents as good practice, in the recto_consentement Cookie, together with its date and the version of this policy in force at the time of the choice. The banner is shown again when this period expires, or when a new version of this policy comes into force.

Article 7 — Managing preferences and withdrawing consent

The User may change their choices or withdraw their consent at any time, as easily as they gave it, using the “Manage my cookies” link at the bottom of every page of the Site, or the button below.

The User may also set their browser to refuse or delete Cookies. Deleting the recto_consentement Cookie causes the banner to be shown again.

Article 8 — Contact

Any question about this policy may be sent to AXO-LAB by email at contact@recto-medias.fr.

Article 9 — Amendments to the policy

9.1 Amendments

The Publisher may amend this policy, in particular to take account of changes to the Service, to the regulations or to case law. Each amendment gives rise to a new version, numbered and dated, published on the Site. Earlier versions remain available from the version history at the end of the document.

A new version comes into force on the date it states. Where the amendment is substantial, the Publisher informs Users by a notice on the Site and, for Users with an account, by email, before it comes into force.

Version history

Successive versions of the document
Version	Entry into force	Changes
2.0 (in force)	5 November 2026	Launch of the Service: the session of the signed-in area is described with its real duration (seven days at most, not readable by page scripts), together with the recto_session marker that signals an open session without holding its secret; the _pk_ref Cookie, set by Matomo after acceptance to measure where visits come from, is added; the retention period of audience measurement data is corrected to six months at most.
1.2	28 October 2026	Addition of the recto_theme Cookie, strictly necessary, which remembers the display theme (light or dark) chosen by the User when it differs from the setting of their device.
1.1	23 October 2026	Brought into line with the co-ownership and operating agreement signed on 22 October 2026: identification of the publisher and of its contact details (new definition of the Publisher, contact details of the project and of the publisher).
1.0	Never in force	First version.