Privacy

We collect what the product needs to work and nothing else: your first name, your city, your answers to the questionnaire, and what you write in the journal. There is no third-party analytics tracker, no advertising pixel and no third party watching you read. We count, anonymously and without storing anything on your device, how many visits reach each step of signing up.

We do not sell your information, we do not share it for advertising, and nobody has ever paid us for it. You can have a copy or have it deleted by writing one email.

The controller is Jonathan Tellerain EI, Entrepreneur individuel, registered in France (108 012 725), at 16 rue de Siam, 75116 Paris, France. Write to contact@swan-club.com for anything on this page — it is read by a person.

We are not established in the United Kingdom and we have not appointed a UK representative, because we are not required to: the UK GDPR's representative requirement applies to controllers outside the UK who have no other route, and the direct contact address above is the route. If that changes, this page changes with it.

Under the UK GDPR every purpose needs a lawful basis. Here they are, one by one, rather than as a single sentence about legitimate interests.

• Your first name and city

  To address you and to decide which map you are shown.

  Basis: performance of the contract.

• Your questionnaire answers

  To order the rooms for you and to set the register the mentor writes in. Your age answer is used for one thing only — the 18 gate — and for nothing else, ever.

  Basis: performance of the contract.

• Your journal and your check-ins

  So that the ritual knows where you are and so that you can read back what you wrote. We do not read it to profile you and we never publish it.

  Basis: performance of the contract.

• Your mentor conversations

  Sent to a language model to get you an answer. Not used to train anything.

  Basis: performance of the contract.

• A hash of your member number

  To let you sign in. We store a one-way hash, so we cannot read the number back — not for you, not for anyone.

  Basis: performance of the contract.

• Payment and consent records

  The date, the amount, the plan, and the wording of the cancellation-right acknowledgement you ticked. That record exists so that your rights can be proved — including against us.

  Basis: legal obligation.

• Technical logs

  Errors and request records, kept briefly so that a fault can be found.

  Basis: legitimate interests — keeping the service working and secure.

We do not ask for health, religion, politics, ethnicity, sex life or anything else the UK GDPR treats as special category data, and we have no use for it.

The journal is a free text box, so you could write something of that kind in it. If you do, it is held on the same basis as the rest of the journal and treated the same way: not read to profile you, not published, and deleted when you ask. But the honest advice is that a journal inside a product is not the place for it.

Nothing is sold. Nothing is shared for advertising or for anyone else's purposes. There is no advertising pixel, no third-party analytics tracker and no social embed anywhere on this site.

That is also why you were not shown a cookie banner. Under PECR a banner is required to ask consent for non-essential cookies, and there are none to ask about.

What we do count, since 15 October 2026: how many visits reach each step of the way in — the home page, the questionnaire, the map, the order screen, the hand-off to payment. No cookie and no local storage is used for it; a random number links the steps of one visit while the page stays open, and is gone when it closes. We keep no IP address, no browser details and none of your answers, never match these counts to your membership, and delete them after 25 months. Global Privacy Control and Do Not Track are honoured automatically, and you can opt out here:

These are every company that touches your information, what they get, and where they process it. The location is checked rather than assumed — in a privacy notice it is a statement you can be held to.

• Supabase

  Hébergement de la base de données et de l'authentification

  Adresse électronique, prénom, ville, réponses au questionnaire, comptes rendus · Union européenne (Irlande)

• Vercel

  Hébergement du site

  Adresse réseau et journaux techniques, le temps du dépannage · États-Unis, avec diffusion depuis l'Europe

• Whop

  Encaissement des abonnements

  Adresse électronique, adresse de facturation, données de carte (que nous ne voyons jamais) · États-Unis

• Google Cloud (Vertex AI)

  Les conversations avec la mentore, pour la formule Le Cercle

  Le contenu des messages échangés, et le prénom · Union européenne (Belgique)

• Resend

  Envoi du numéro de membre et de la lettre hebdomadaire

  Adresse électronique, prénom · Union européenne (Irlande)

None of them may use your information for their own purposes. Each is bound by a written processing agreement.

Swan Club is operated from France, so everything about you leaves the United Kingdom. Since Brexit each of those movements is a restricted transfer and needs its own basis. There are two, and they are not the same.

To the European Union — the database in Ireland, the mentor conversations in Belgium, the emails in Ireland. The basis is adequacy: the UK has made adequacy regulations for the EU, so data may flow from here to an EU country without further safeguards.

To the United States — the hosting and content delivery, and the payment platform. The basis is either the UK extension to the EU–US Data Privacy Framework, where the recipient is certified under it, or the UK International Data Transfer Agreement, which we sign with them where it is not. We are not relying on your consent for any of it, and we are not asking you to sign anything.

The list above says where each company processes your information. If you want to know which mechanism covers a particular one, ask at contact@swan-club.com and we will tell you which, by name.

Putting the database and the mentor in the EU rather than the US is a deliberate choice rather than an accident of where we happen to be. It means one standard applies to every member of Swan Club in every market, instead of a stricter one for some.

Your account, your answers and your journal: for as long as you are a member, and for one year after you cancel, in case you come back. After that, deleted.

Records tied to a payment: as long as tax and accounting law requires, which for a French business is ten years. We cannot delete those earlier, and neither can anyone else — including us, if you ask.

Technical logs: thirty days.

Under the UK GDPR you can ask us for a copy of what we hold, to correct it, to delete it, to restrict what we do with it, to object to processing based on legitimate interests, and to have it sent to you or to someone else in a portable form.

Write to contact@swan-club.com. We answer within one month, which is the statutory deadline, and usually within a few days. We do not charge for it and we do not make you prove who you are beyond what is necessary to be sure we are not handing your information to somebody else.

The one thing we cannot do is recover your member number. The hash is one-way by design. We can issue you a new one.

There is no automated decision-making with legal effect. The order of the rooms on your map is shaped by your answers, but no decision about you is taken by a machine.

If you think we have handled your information badly, tell us first and we will try to put it right. You can also complain to the Information Commissioner's Office, which is the UK supervisory authority, at ico.org.uk, by phone on 0303 123 1113, or by post to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

You do not have to come to us first, and complaining costs you nothing.

Swan Club is for adults. The questionnaire asks your age before anything is stored and ends there if you are under 18. We do not knowingly hold information about children, and if we find that we do, we delete it and close the account.

If this notice changes we will say so here and change the date at the top. A change to what we collect or who processes it will be told to you before it applies.