Cirkwi General Terms and Conditions

These General Terms of Use (hereinafter, the "GTU"), governed by French law, are intended to govern the use by any person (hereinafter, the "User") of any of the websites, widgets, applications, APIs or modules (hereinafter, the "Service") published by the company CIRCUITS SAS (hereinafter, the "Company"), registered with the Nancy Trade and Companies Register under number B 529 618 241, with its registered office at 8 Rue de la Monnaie, 54000 Nancy, and whose publishing director is its legal representative. Any access to or use of the Service constitutes the User's express and unreserved acceptance of these GTU. Every User guarantees to the Company that they hold all rights, authorisations and powers necessary to accept the GTU on behalf of the company, association or any other entity (hereinafter, the "Entity") on whose behalf they access or use the Service; access to or use of the Service by the User constitutes acceptance of the GTU by the Entity. The Company reserves the right to amend these GTU at any time. The applicable terms are those in force and accessible on the Service on the date on which the User accesses it. The Service is hosted by OVH SAS, 2 rue Kellermann, 59100 Roubaix, France. For further information, please see our Legal notice and our cookie management policy.

1. Presentation of the Services

The Services offer Users access to routes or tourist points of interest in various formats such as interactive maps, supplemented with texts, photographs, comments, images, videos, sounds, animations or any other multimedia content known or unknown to date (hereinafter, "Content"). Users may create an account on the Service (hereinafter, the "Account") under the conditions set out in Article 2 below, and thereby become a member of the Service (hereinafter, the "Member"). Content is created or supplied by contributing Members (hereinafter, the "Contributors").

2. Registration and Access

In order to benefit from all features of the Service, the User must become a Member by creating an Account using the online form provided for that purpose. Furthermore, it is the Member's responsibility to ensure that the personal data used to identify them are accurate and complete. Upon validation of the form, the User will be able to log in to their account. Access to the Account may be obtained by entering the associated username and password, the confidentiality of which is solely the Member's responsibility. Use of the Service following registration is valid for an indefinite period. The Company reserves the right to terminate it at any time, by email, with reasonable notice. In the event of non-compliance with the obligations inherent to User responsibility as set out below, access to the Member's personal area may be suspended temporarily or permanently, immediately and without notice, by deactivating your Account, without prejudice to the Company's other rights. The Member may themselves request deactivation of their Account at any time by contacting the Company in accordance with the contact methods described in the "Company Contact Details" section of these GTU.

3. Intellectual Property

3.1 Intellectual Property of the Contributors

(a) Dissemination of Content

By making Content they have inserted on the Service available, the Member becomes a "Contributor" and accepts that Users may, free of charge and for exclusively personal purposes, view and share the Content, by default, on the Service as well as on the Company's partner websites (hereinafter, the "Partner Services") or from the Service or a Partner Service, on other electronic communication media (including smartphones, tablets, connected televisions and games consoles), for as long as the Content is hosted on the Service. The Contributor may at any time, using the dedicated function available in their personal area on the Service, prohibit the dissemination of part or all of their Content on the Service or on the Partner Services. Furthermore, for the duration of the hosting of the Content and strictly within the framework of the features enabling access to the Service via the internet or other electronic communication media, the Contributor authorises the Company to reproduce/represent the Content and, where necessary, adapt its format for that purpose. The Contributor is also informed that, given the intrinsic characteristics of the internet, data transmitted, including Content, are not protected against the risks of misappropriation and/or hacking, for which the Company cannot be held liable. Where applicable, it is for the Contributor to take all appropriate measures to protect such data. In the event of deactivation of a Contributor's Account, whether initiated by the Contributor or the Company and regardless of the reason, that Contributor's Content will be removed from the Service.

The Contributor accepts that the images and other content they provide may be used as meta-images to visually represent route pages, points of interest and other content pages on CIRKWI.com. These meta-images may also be used when such pages are shared via widgets embedded on other sites or when they are shared directly on social media platforms and in search engine results. This use of images facilitates the visibility of user contributions, thereby ensuring effective promotion of content.

(b) Statistics

From their personal area on the Service, the Contributor may view aggregated statistics on the dissemination of their Content.

(c) Retrieval of feeds

All Content inserted by the Contributor may be retrieved by them, at any time, under the following conditions:

3.2 Intellectual Property of Other Contributors

Other Contributors of the Service (hereinafter, "Other Contributors") may upload Content in accordance with the GTU. The User undertakes not to access Other Contributors' Content for any purpose other than personal, non-commercial use, as provided for and authorised by the normal features of the Service. Furthermore, in view of the possibility of exporting Content, the User undertakes not to export Other Contributors' Content to sites that constitute or include elements constituting (i) a violation of third-party intellectual property rights, or (ii) an infringement of individuals (including defamation, insults, abuse, etc.) and privacy, or (iii) incitement to violence or hatred against any individual or group, or (iv) incitement to cruelty towards animals, or (v) sexually explicit or strongly suggestive content, or (vi) incitement to drug use or any unlawful activity, or, more generally, (vii) a breach of public order and good morals or, more broadly, a breach of applicable regulations in force.

3.3 Intellectual Property of the Company

The Service is the exclusive property of the Company. In general, the Company grants Users a free, personal, non-exclusive and non-transferable right of access to and use of the Service, subject to acceptance of and compliance with the GTU. Any other right is expressly excluded without the Company's prior written consent. Content, other than Content inserted by Contributors, included in or accessible on and/or through the Service, including any text, graphics, logos, names, trademarks, designations, tabs, features, images, sounds, data, photographs, graphics and any other material or software (hereinafter, "Cirkwi Content"), is the exclusive property of the Company or its licensors, is protected by intellectual property law and is subject to applicable laws and regulations in that regard. Cirkwi Content may in no event be downloaded, copied, altered, modified, deleted, distributed, transmitted, broadcast, sold, rented, licensed or exploited (in whole or in part) in any manner whatsoever, without the express written consent of the Company or its licensors. Users agree not to use or exploit Cirkwi Content for purposes other than those set out in these GTU. Furthermore, Users are not authorised to modify, improve, edit, translate, decompile, disassemble or create one or more derivative work(s) from Cirkwi Content (in whole or in part), unless this possibility has been expressly granted to them by the Company or by the owners of such content, under a separate agreement.

4. Liability

4.1 Liability of the Contributor

By providing Content on the Service (whether texts, photographs, Tourist Objects, comments submitted, a username or an avatar), the Contributor is required to comply with all legal and regulatory provisions in force, whether applicable in their place of residence or in the place concerned by the Content. It is therefore for the Contributor to ensure that storage and dissemination of such Content via the Service does not constitute (i) a violation of third-party intellectual property rights, (ii) an infringement of individuals (including defamation, insults, abuse, etc.) and privacy, (iii) a breach of public order and good morals (including, in particular, apology for crimes against humanity, incitement to racial hatred, child pornography, etc.). By uploading and making Content available to the public on and/or through the Service, the Contributor warrants that they hold all rights and authorisations necessary from the relevant rights holders and have paid all royalties and fees due under these terms to collective management organisations. Failing this, the Company reserves the right to remove the Content from the Service and/or deactivate the Contributor's Account without prior formality. Furthermore, the Contributor may personally incur the criminal penalties specific to the disputed content (imprisonment and fines), in addition to any award of damages. Given the community nature of the Service and out of respect for everyone's sensitivities, it is for the Contributor to maintain a certain ethic with regard to Content and/or comments uploaded and, in particular, to refrain from disseminating any violent or pornographic content.

4.2 Liability of the User

The Company regards the User as responsible for their use of and own actions on the Service. For their own protection as well as that of other Users, it is therefore for the User to exercise caution when consulting and using Content, while being aware of the multiplicity of contribution sources as well as the Company's liability as described in the section below. Given the collaborative nature of the Service's Content, the Company recommends that the User verify the reliability of information relating to the Content they use, in particular by ensuring that such use does not constitute (i) a violation of third-party intellectual property rights, (ii) an infringement of individuals (including defamation, insults, abuse, etc.) and privacy, (iii) a breach of public order and good morals (including, in particular, apology for crimes against humanity, incitement to racial hatred, child pornography, etc.).

4.3 Liability of the Company

The Company makes available to Users on the Service a number of items of Content, including Tourist Objects created by Contributors. Contributors, as authors, are solely responsible for the Content they publish on the Service. Consequently, the Company's liability cannot be engaged where Content published by Contributors contravenes any legal and/or regulatory provisions in force or has caused any damage to a User or any person. CONTENT, AND IN PARTICULAR TOURIST OBJECTS, IS PROVIDED BY CONTRIBUTORS AND DISSEMINATED BY THE COMPANY FOR INFORMATIONAL PURPOSES ONLY. THE COMPANY DOES NOT IN ANY WAY CERTIFY THE RELIABILITY OF INFORMATION PROVIDED BY CONTRIBUTORS, INCLUDING MAPS, TEXTS, PHOTOGRAPHS, IMAGES, VIDEOS, SOUNDS, ANIMATIONS OR ANY OTHER CONTENT THEY INSERT ON THE SITE. THE COMPANY STRONGLY RECOMMENDS THAT USERS VERIFY SUCH INFORMATION BEFORE USING IT.

5. Privacy Policy

When the User uses the Service, they entrust certain personal data to the Company. This privacy policy is designed to help the User understand what data the Company collects, why it collects them and what it does with them.

5.1 Rights Granted to the User under the GDPR

European data protection rules grant the User, in particular but without limitation, the following rights:

To exercise any of these rights, the User may contact the Company at any time in accordance with the contact methods described in the "Company Contact Details" section of these GTU. Right to lodge a complaint: the User has the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), the French supervisory authority, if they consider that processing of their data is not compliant with applicable regulations.

5.2 Description of Personal Data Collected

(a) Types of data collected

For widget Services: The personal data that the Company collects from Users include in particular:

These data are retained for a maximum of 15 days. For services requiring registration, in particular Cirkwi.com: The personal data that the Company collects from Users include in particular:

The Company may also collect and process data on how the User uses the Services, consults Content and other related activities. In the context of registration and login using a third-party service, such as Google OAuth (Google LLC) or Facebook Login (Facebook, Inc.), the Service may collect from the third-party service the User's personal data, including their email address (or telephone number), as well as their first and last name. Please note that use of a third-party service to register or log in is subject to that third-party service's terms of use. Furthermore, registration or login using a third-party service results from a freely given choice by the User, in that use of a third-party service is not the default means of registering or logging in and is provided solely for convenience.

(b) Cookies and other locally stored data

The Service may collect and store data on the User's device using mechanisms such as web browser storage (cookies, local storage) and application data caches.

The Service stores in particular in local storage or cookies:

This information is useful only for operation of the Service and optimisation of its usability; it is not stored on the Company's servers.

(c) Use of location data in the background

More specifically, the User's geolocation is used to guide the User when their device is in standby or when the application is running in the background, to suggest nearby points of interest and to provide a summary of their route (duration, average speed, etc.)

(d) Data used by the Company's technology partners

The Company works with partners who may set third-party cookies that are then used by them through their services. These partners are integrated only on a limited part of the Services; embedded widgets on partner sites are not affected. Below is a list, which may be amended according to the Company's needs, while remaining compliant with this privacy policy:

Data collected via Google services (including Google Analytics) may be transferred to the United States, to Google LLC. This transfer is governed by the EU–United States Data Privacy Framework (EU-US Data Privacy Framework), Google LLC being certified under that framework, as well as, additionally, by the standard contractual clauses adopted by the European Commission.

5.3 Purpose of Processing of Personal Data

The controller of the User's personal data is the Company, whose contact details appear in the preamble to these GTU. Management, sales, customer service, accounting and technical staff have access to the information in the performance of their duties, where necessary. Personal data collected from the User and processed by the Company are intended to:

5.4 Security of Personal Data

The Company assures the User that it recognises the importance of providing an environment in which they feel secure. The Company therefore implements precautions consistent with industry practice and the state of the art in order to protect the User's personal data against unauthorised access or unauthorised modification, disclosure or destruction, having regard to the nature of the data and the risks presented by the processing carried out.

In particular:

5.5 Data Retention Period

(a) Data stored directly with the Company

The Company undertakes to retain the User's personal data only for as long as necessary to fulfil the purposes for which they were collected and processed or, where applicable law provides for a longer storage and retention period, for the period prescribed by law. Personal data are then pseudonymised, anonymised, aggregated or erased.

(b) Cookies and other data stored locally on the User's devices

The Company informs the User through this privacy policy that web browsers and mobile devices allow them to limit the behaviour of locally stored data or disable them in settings or options. The steps differ for each browser; the User can find instructions in their browser's "Help" menu. Through the browser or their device, the User may also view cookies already stored and delete them one by one or all at once. Cookies are text files, so the User can open and read their contents. The data contained within are often encrypted and correspond to a web session, so they make sense only to the Service that wrote them. If the User disables cookies, they will no longer be able to log in to their Account on the Service or use it properly.

5.6 Communications with the User

When the User sends an email or any other communication to the Company, it may use such communications to process questions and respond to the User's requests. Performance of this service at the User's request (Article 6(1) (b) GDPR) constitutes the legal basis for processing such data.

At any time, the User may accept or refuse to receive communications from the Company, whether by email, post, telephone or any other means they may specify. Where the User gives their consent, in accordance with the provisions of the GDPR, the Company may send the User commercial or informational communications.

5.7 GDPR

In accordance with the General Data Protection Regulation (GDPR) and Law No. 78-17 of 6 January 1978 as amended, the Company maintains a record of its processing activities and implements the measures necessary to ensure compliance.

The Company undertakes to protect all of the User's personal data, which are collected and processed by the Company with the strictest confidentiality.

6. Availability of the Service

The Service is in principle accessible 24 hours a day, 7 days a week, except for scheduled or unscheduled interruption for maintenance purposes or in cases of force majeure. Being subject to an obligation of means, the Company cannot be held liable for any damage, of whatever nature, resulting from unavailability of the Service. The Company exercises the greatest vigilance but does not guarantee that the Service and the servers that make it available are free of viruses and other harmful components. It is for the User to take all appropriate measures to protect their own data and/or software from contamination by any viruses circulating on the internet and to verify that their computer configuration contains no virus and is in perfect working order.

The User accepts that the Company and its suppliers cannot in any event be held liable for material and/or intangible, direct and/or indirect damage that may result from access to or use of the Service and/or its content, including inaccessibility, loss of data, deterioration, destruction or viruses that may affect the User's computer equipment, and/or the presence of viruses on its Service.

7. Miscellaneous

Computerised records kept in the Company's systems in accordance with industry-standard security practices shall be deemed evidence of emails, registration form submissions and content. Registration forms are archived on a medium designed to ensure the fidelity and durability required by applicable European legal provisions. It is agreed that, in the event of any discrepancy between the Company's computerised records and paper or electronic documents in the User's possession, the Company's computerised records shall prevail.

8. Company Contact Details

For any question relating to these GTU or to processing carried out by the Company, or to exercise the rights granted under the GDPR, the User and/or Member may contact the Company by email at: support@cirkwi.com; taking care to prove their identity (stating their first and last name, company represented, email address and attaching a copy of their identity document)

Effective version – updated on 17 June 2026 – Circuits SAS ©