# Gallia Terms of Use and Subscription

US customer edition

Version 2026-11-08-v2. Effective and published on 8 November 2026. This version applies from the launch of the offer. Acceptance is recorded on its actual date.

These conditions describe access to Gallia's financial publications, the subscription, the risks of using the publications and the parties' responsibilities. Part A contains the contractual conditions. Part B explains how personal information is used. The privacy notice is information for you, not a blanket request for consent.

The subscription costs USD 89 per month, plus any applicable taxes disclosed before purchase. All eligible first-time subscriptions automatically include a 30-day free trial. Without a trial, the first payment is due when you confirm your subscription in Stripe. A payment method is required. The subscription renews automatically until canceled. Cancel online before an eligible trial ends to avoid the first subscription charge. Creating an account alone does not authorize a subscription charge.

## A1 Gallia and these Terms

Gallia is the name of the service operated from France and available at https://gallia.me. In these Terms, “Gallia”, “we” and “us” refer to the service provider; “you” refers to the person using an account or subscribing. Contact us at contact@gallia.me about the service, billing, these Terms or your personal information.

These Terms apply to the website, account and publications provided as part of your subscription. Any offer-specific price or trial information is presented before you purchase and included in your confirmation. A change to that offer does not retrospectively alter a period already purchased. Mandatory legal rights take precedence over a conflicting provision of these Terms.

## A2 What the subscription provides

You pay for access to Gallia's financial publications and its two portfolios, Gallia Performance and Gallia Securities, including updated portfolio holdings, general entry and exit information and the full strategy trade history. The same publications are made available to subscribers. Selecting a strategy changes the information you view; it does not create an individually managed portfolio. Account features also include a personal calendar of visit days; its Annual and Monthly views refer to visits, not investment returns.

Some aggregated performance information and charts are publicly accessible. Public previews of holdings are historical snapshots, currently fixed as of 2 February 2026, and do not show current holdings. Updated holdings and the full trade history require subscriber access, including an eligible trial or applicable payment processing grace period.

Gallia does not manage your investment money, hold your securities, access your brokerage account or execute orders. Subscription payments pay for the information service and are not money invested in the portfolios. No return on the subscription fee or on an investment is promised.

The commercial offer describes the included features. A material reduction to a paid feature is handled under section A15.

## A3 Eligibility and account use

The US customer edition is intended for adults resident in the United States. You must be at least 18 and have legal capacity to enter this contract where you live. An account is personal; provide accurate information and keep it up to date. Keep your credentials secure and tell us if you suspect unauthorized access. Gallia will not ask for your brokerage password or full payment credentials by email.

You may correct your account information or contact us for help. Account deletion and subscription cancellation are different actions. The self-service deletion control remains unavailable while a subscription is still active, including after cancellation is scheduled, or a payment is pending or requires verification. To use that control, cancel the subscription and wait until it has ended and the payment checks are complete. You may contact us at any time to request deletion or exercise your privacy rights; the technical conditions of the account button do not restrict those rights. Closing an account does not erase records that must lawfully be retained, as explained in Part B.

## A4 General publications and independent decisions

The publications may include general signals concerning buying, holding or selling particular securities. They are not adapted to your income, assets, debts, objectives, experience, tax position or tolerance for loss. We do not determine whether a particular investment or strategy is suitable for you. General explanations provided by support do not become an individual investment plan.

You choose whether to use the information and decide the orders, amounts and timing of any investment through your own intermediary. Consider your circumstances and seek qualified individual advice when needed. Gallia does not provide individual tax or legal advice, or assess whether you should follow a strategy.

## A5 Understanding the published results

The published portfolio returns are calculated from historical prices, and historical operations are reconstructed under the strategies’ rules. They are not an audited record of an account actually executed for you or a record of investment returns earned by subscribers. The date of a reconstructed operation may precede publication of the updated information. An entry price used in the calculation is not an offer to transact at that price.

The current strategies use a signal observed at a daily close and take the next available trading session's opening price as the entry price. Fractional shares are permitted. The allocations described below are strategy calculations, not assessments of how much you personally should invest.

For Gallia Performance, the calculation starts with capital of 1,000 dollars and an amount of 150 dollars per purchase, or 15 percent of initial capital. At the start of each new year, the amount per purchase is recalculated at 15 percent of the portfolio's total value, including cash and open positions, using the last available valuation before that year's trades. The amount then remains fixed throughout the year: it is not recalculated at each purchase. Existing positions are neither sold nor resized solely because the year changes. There is no cap on the number of positions; cash from closed trades can fund new purchases. A purchase is made only if available cash can fully fund the fixed amount; otherwise, the signal is not executed. This portfolio provides for neither partial allocation nor new borrowing. When several signals are eligible, candidates are considered in the program's stock-list order, subject to available cash.

For Gallia Securities, the calculation starts with capital of 1,000 dollars and an amount of 150 dollars per purchase, or 15 percent of initial capital. At the start of each new year, the amount per purchase is recalculated at 15 percent of the portfolio's total value, including cash and open positions, using the last available valuation before that year's trades. The amount then remains fixed throughout the year: it is not recalculated at each purchase. Existing positions are neither sold nor resized solely because the year changes. There is no cap on the number of positions; cash from closed trades can fund new purchases. A purchase is made only if available cash can fully fund the fixed amount; otherwise, the signal is not executed. This portfolio provides for neither partial allocation nor new borrowing. When several signals are eligible, candidates are considered in the program's stock-list order, subject to available cash.

Gallia Performance currently uses a profit target of +18 percent and a stop threshold of -5 percent from the entry price used in the calculation. Gallia Securities uses +16 percent and -4 percent respectively. These are rules for each portfolio position, not promised portfolio returns or guaranteed limits on your losses. Exit thresholds are tested against daily high and low prices. A threshold fill is assumed at the threshold price; when both target and stop are reached in one daily bar, the calculation gives the stop priority. A real order may execute at a different price, fail to execute or suffer a loss beyond a displayed stop threshold. Your intermediary may also limit fractional-share orders or the instruments available to you.

Portfolio valuations include closed operations and the latest available value of open positions. When a new quote is missing, a validated stored quote may be used for valuation, retaining its actual date. Missing market data cannot establish what happened at every moment of a session.

The current calculations do not deduct the subscription fee, brokerage commissions, bid-ask spreads, slippage, account fees, financing costs or personal taxes. They do not account for margin requirements, margin calls, forced liquidations or intermediary borrowing limits. They do not separately credit or reinvest dividends. Provider price adjustments and corrections may nevertheless affect the historical price series. The calculations use the quotations received for each instrument and do not account for currency conversions or an investor's foreign-exchange gains or losses. They are not an account valuation or net investment return realizable in USD, EUR or another account currency.

The cumulative return is the change in portfolio value relative to its starting value. The annualized return is the equivalent compounded annual rate over the calculation period, currently starting on 1 January 2015, calculated using elapsed days and a 365.25 day year; it is not the arithmetic average of yearly returns. A yearly return compares portfolio value with the previous year-end value, or the initial value for the first year. The current year's result covers only the available part of that year. Net asset value is the sum of the value of open positions and the cash balance. Both portfolios fund purchases solely from available cash, with no borrowing. Success rates and average holding durations concern closed strategy operations, not all holdings or subscribers' trades.

The Gallia Performance +18 percent/-5 percent method, with an amount per purchase set at 15 percent of total portfolio value at the start of the year and fixed throughout that year, no position-count cap and purchases fully fundable from cash, has applied to publications since 17 October 2026. Gallia Securities uses +16 percent/-4 percent parameters and the same principle of an amount per purchase set at 15 percent of total portfolio value at the start of the year and fixed throughout that year, with purchases fully funded by cash, no borrowing and no position-count cap. The parameters and methods of both strategies remain unchanged by this wording update. The history from 1 January 2015 is recalculated using this method: it is not a record produced by applying these rules to a real account since 2015. Previous document versions remain available in their archives; this update does not change the actual date of a previous acceptance.

Calculations using historical prices and comparisons between parameter sets can introduce hindsight, selection and survivorship biases or overfitting. Historical strategy success may not persist. Results, trade reconstructions and comparisons with indices can change when data are corrected or a disclosed method is revised. Different calculation methods, investment timing, dividend treatment, costs and risk exposure can produce different comparisons. The calculation date and the period covered should be read together.

## A6 Updates and the quality of information

Gallia normally updates its publications after the US market close, rather than continuously during trading. Instruments can trade on different exchanges, calendars and time zones. Market holidays and unavailable source data may affect updates. A publication date does not mean that every instrument has a new quote from that date. Check the calculation date and the actual quote dates displayed with the information.

We take reasonable care in preparing the publications and operating the service. Information may be delayed, unavailable or corrected. If an instrument lacks new data, the calculation may use its last validated available quote while processing other instruments. A later correction may change historical results. We will correct identified material errors and explain material changes where appropriate.

The service does not guarantee real-time prices, uninterrupted market data or that a subscriber can obtain the historical execution price used in the calculation. These limitations do not remove our obligation to provide the paid service with the care required by applicable law.

## A7 Investment risks and conflicts

Investments can lose part or all of their value. Prices can move sharply, liquidity can disappear, trading can be suspended and orders may fill at unexpected prices. Currency movements, concentrated exposure and differences between trading venues can affect results. A strategy stop or profit target is a calculation rule, not a guarantee limiting your actual loss or securing a gain.

Using financing to replicate exposure above available capital amplifies changes in value and can produce losses greater than your contribution, margin calls or forced liquidations. Neither Gallia portfolio uses borrowing.

The operator may invest personally in securities covered by Gallia and may have interests different from a subscriber's. We disclose material personal holdings and financial relationships relevant to a publication alongside that publication. Promotional coverage, sponsorship and material affiliations are identified when applicable. Support provides general explanations of the service and publications; it does not provide individual investment recommendations.

You should not treat strategy returns, testimonials or the frequency of your visits as a promise of investment success. Past performance and calculated results do not guarantee future performance.

## A8 Trial payment and automatic renewal

The standard subscription costs USD 89 per month. All eligible first-time subscriptions automatically include a 30-day free trial. The first charge is due at the end of the trial unless you cancel before it ends. Without a trial, the first payment is due when you confirm your subscription in Stripe. Your subscription then renews monthly until canceled. Applicable taxes and the amount payable are shown before purchase.

**Analytics and Data Sharing.** Gallia uses internal analytics to count visits from its campaigns and track registrations, trial starts, and first payments associated with generic campaign labels. Gallia uses these statistics internally and does not send them to Meta. Gallia does not send new registrations to Meta. By creating an account, you accept the Terms. That acceptance does not authorize advertising data sharing, and sharing is not a condition of the 30-day trial. Sections P2 through P4 describe internal analytics, and section P11 describes the previous sharing arrangement.

The trial is available only for an eligible first subscription. Cancellation or creation of a new account does not qualify you for another trial after a previous subscription or trial. Subscriptions already confirmed and Stripe checkout sessions already open before this version takes effect retain their applicable terms. Other promotions follow the conditions presented before you subscribe.

Before you provide payment details, the purchase information sets out any trial duration, the amount due at confirmation, the first charge date or a clearly explained way to determine it, the recurring amount, the billing interval and how to cancel. You authorize the subscription payment and automatic renewal separately from creating an account. That authorization covers the disclosed first charge and recurring monthly charges until cancellation. You receive confirmation you can retain, containing the subscription terms, charges and cancellation instructions. Accepting these Terms at account registration alone is not a payment authorization.

A payment method is required for the trial. If you cancel before the trial ends, the subscription fee is not due at the end of that trial. If you do not cancel, the monthly charge becomes due when the trial ends, then on the displayed renewal dates. Monthly billing is not the same as charging every 30 days. Your trial end date and subsequent monthly renewal dates are shown in the purchase and billing information.

Stripe processes subscription payments. Only payment methods actually available in your checkout can be used. Any required authorization for a bank debit is obtained through the payment process. A bank debit may take time to settle. Where Gallia grants provisional access for a debit actually in processing, its current grace period is limited to seven US banking days from the first payment attempt, within the subscription period. A retry does not restart that period. Failed payments do not establish a right to continued access. Access may be suspended for a failed or unpaid charge, subject to mandatory rights. Contact us to resolve billing problems; these Terms do not waive protections against unauthorized payments or billing errors.

## A9 How to cancel

You can request cancellation online from your Gallia account using the subscription cancellation control and the billing page it opens. Follow the final confirmation and check the effective date shown. If you cannot access the account or the cancellation control fails, email contact@gallia.me and clearly request cancellation of the subscription associated with your account email. We will not require a sales call as a condition of cancellation.

If you submit cancellation before the trial ends, the first subscription charge is not due and trial access normally continues until its stated end date. If a charge is taken because processing of your timely cancellation was delayed, contact us so that we can correct it. For an ordinary cancellation of a paid subscription, renewal stops and access normally continues until the end of the period already paid. We confirm cancellation and its effective date through the billing process or by email.

Cancellation stops future renewal; it does not automatically reverse a charge already due or a bank debit already initiated. This does not affect your rights concerning a timely trial cancellation, an incorrect charge, statutory withdrawal or another applicable refund right.

Signing out, closing a browser, clearing browser storage or simply ceasing to consult the website does not notify Gallia that you wish to cancel.

## A10 Fees refunds and statutory rights

Subscription fees pay for access during the billed period. Ordinary cancellation does not by itself create a prorated refund for a period during which the service remained available. There is no additional money-back guarantee unless the offer expressly grants one. A disappointing investment outcome is not, by itself, failure to provide the information service.

We will remedy duplicate or incorrect charges and deal with unauthorized-payment claims under applicable law and payment procedures. If we discontinue a paid service before the period ends and cannot provide the agreed service, we will refund the corresponding unused portion. If a material failure to provide the service is not remedied, the cancellation, price reduction or refund remedies provided by applicable law remain available.

Any statutory withdrawal, refund or other cancellation right takes precedence over the ordinary no-prorated-refund policy. The 30 day commercial trial and a statutory withdrawal period are different rights. Where the French distance-contract withdrawal regime applies, you may withdraw within 14 calendar days of concluding the subscription contract, without giving a reason. Statutory rules for calculating or extending that period, including where required information was not provided, remain applicable. Ordinary monthly renewal does not by itself create a new commercial trial; any renewed statutory right is governed by applicable law.

To exercise an applicable withdrawal right, send a clear statement to contact@gallia.me before the deadline. You may use the form in section A17, but it is not compulsory. Give your name, account email and the subscription concerned, and retain proof of sending. Any online statutory withdrawal facility available to you is an additional route, separate from ordinary subscription cancellation.

Where the French withdrawal rules apply, we reimburse payments subject to reimbursement without undue delay and no later than 14 days after being informed of your withdrawal, using the original payment method unless you expressly agree otherwise, without a reimbursement fee. Payment for a service provided before withdrawal can be required only where applicable law permits it and its conditions have been met, including a valid express request to begin early and the required information; any permitted amount is proportionate to the service supplied. No subscription fee is due for days included in the advertised free trial. Merely opening an account, accepting these Terms or accessing an ongoing subscription does not establish a valid waiver of statutory withdrawal rights.

Contact us about a billing issue without unnecessary delay and provide the account email, charge date and a description, without sending full payment credentials. Contacting Gallia does not prevent you from exercising a lawful dispute, chargeback or complaint right, and we do not impose a shorter statutory claim period here.

## A11 Use of publications and intellectual property

Your subscription permits personal access to the subscribed publications during the access period. It does not transfer the software, the method or copyright in Gallia's original materials. Do not resell account access, share credentials, republish paid content as your own service or bypass access restrictions. Automated extraction of restricted content requires authorization.

Gallia’s original texts, graphic creations and software components are protected to the extent provided by applicable law. Subject to uses authorized under these Terms or by law, their reproduction, republication, redistribution or commercial exploitation requires prior written permission from the rights holder.

Third-party trademarks, software and other materials remain subject to the rights of their respective holders and applicable licenses. We do not claim ownership of public facts or prohibit quotation or other uses that applicable law permits.

Honest reviews, lawful complaints and cooperation with a regulator or court are not prohibited by these Terms.

## A12 Availability and account restrictions

Maintenance, data-provider interruptions, security incidents and events beyond reasonable control can affect access. We take reasonable steps to restore the service and address a material failure. We do not promise uninterrupted availability, but an interruption does not remove mandatory remedies or allow us to charge for a service that we unlawfully fail to supply.

An account may be restricted where reasonably necessary for security, nonpayment, fraud, unlawful use or a material breach. We give the reason and an opportunity to address the issue when feasible, except where doing so would undermine security or legal requirements. A restriction must not be retaliation for an honest review, complaint or exercise of a legal right. Unused paid access and any refund are handled according to the reason for termination and applicable law.

## A13 Responsibility and rights that cannot be waived

Gallia is responsible for its contractual obligations and the standard of care required by law. You are responsible for the investment orders and account operations that you independently choose and conduct with your intermediary. Gallia does not guarantee market outcomes.

To the extent permitted by applicable law, Gallia is not liable for losses caused solely by ordinary market movements or by a subscriber's independent transactions outside Gallia's control. This is not an exclusion of liability for Gallia's actionable error, misleading statement, failure to provide the agreed service or other conduct for which the law provides a remedy.

Nothing excludes fraud, intentional misconduct, gross negligence or any liability that cannot lawfully be excluded or limited. Nothing requires you to waive mandatory securities-law, consumer, privacy or payment rights, access to a competent court or an available collective remedy. The cause of a claimed loss and the applicable law determine the parties' responsibility.

## A14 Personal information and communications

Part B explains personal information processing. Accepting the contractual conditions is not consent to optional advertising, marketing or every data use. Where a processing activity needs consent, a separate choice must be available. Service messages about account security, payments, cancellation or material service changes are distinguished from optional marketing.

Keep your contact address up to date so that you can receive service information. We do not request investment passwords or full payment information by email. You may unsubscribe from optional marketing without cancelling the paid service or losing mandatory notices.

## A15 Changes and discontinuation

We give at least 30 days' advance notice before an increase to your subscription price applies at a renewal. Where applicable law requires another notice within a particular time window, we provide that notice too and obtain any required consent. Required renewal reminders are provided separately from promotional messages. You can cancel before the change takes effect. We do not retroactively increase a fee already agreed for a paid period.

For a material change to these Terms or a paid feature, we describe the change and its proposed effective date before it applies. Routine updates to portfolio holdings, signals and results are part of the information service and are distinct from changes to the subscription contract. Material methodology changes are explained with the publications. Where fresh consent is legally required, continued use alone is not treated as consent. If a change materially reduces the agreed service during a paid period, the cancellation and refund remedies in section A10 remain available. Urgent security or legal measures may be taken earlier where necessary, without using that exception to bypass payment or consumer protections.

If the service is discontinued, we notify affected subscribers, stop future renewal charges and deal with unused paid access under section A10. We do not transfer your subscription to an unrelated service without an appropriate legal basis and any consent required.

## A16 Complaints applicable law and interpretation

Send a complaint to contact@gallia.me with enough information to identify the account and the issue. We will review it and respond without imposing unnecessary barriers. This contact route does not prevent a complaint to a competent authority, lawful payment dispute or court action.

French law governs these Terms to the extent permitted by applicable conflict-of-laws rules, without depriving you of mandatory consumer protections applicable in your place of habitual residence. These Terms do not impose exclusive jurisdiction in a French court, mandatory arbitration or a waiver of class actions. The courts and dispute-resolution routes available under mandatory law remain available.

If a clause cannot lawfully apply, the remaining provisions apply only insofar as they can lawfully operate and without removing mandatory rights. The English edition is intended for US customers; a French reading version is available. A translation does not reduce a protection required by law.

You receive the applicable Terms and subscription details before purchase and in your confirmation. Keep the confirmation and the version of the Terms that you accepted.

## A17 Withdrawal statement form

Use this statement only if you wish to exercise an applicable statutory withdrawal right. You may instead send any other clear statement; using this form is not a condition of exercising your right.

To Gallia, contact@gallia.me: I notify you that I withdraw from my Gallia subscription contract. Please include the date you concluded the subscription, your name, account email, postal address and the date you send the statement. A signature is needed only if you submit a paper statement. Do not include payment-card details or an account password. We will acknowledge your request and address it under section A10.

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# Part B Privacy Notice

Version **2026-11-08-v2**. Effective and published on **8 November 2026**. This notice applies from the launch of the offer.

This notice describes how Gallia uses personal information when you visit the website, create an account or subscribe. It is Part B of this document. Accepting the Terms is not blanket consent to personal information processing. The new offer does not establish retroactive consent. The retention rules introduced on 14 October 2026 continue to apply. The limited statistics described here replaced the optional campaign measurement on 21 October 2026 without assigning a new origin to earlier accounts that had none.

<a id="privacy"></a>

## P1 Who is responsible for your information

**Gallia**, operating the service from France at [gallia.me](https://gallia.me), is responsible for the processing described here. Questions and privacy requests can be sent to **contact@gallia.me**. The EU General Data Protection Regulation (GDPR) applies to Gallia's processing through its French establishment, including when subscribers live in the United States.

## P2 Information we process

**Accounts.** The registration form requests your first and last name, email address and password. Account records include an account identifier, registration language, confirmation and recovery information and authentication records. The authentication service stores passwords in hashed form. Never send us a password by email. An older account may not contain every field requested in the current registration form.

**Subscriptions and payments.** We process subscription and trial dates, payment and cancellation status, amounts and currency, and payment-service customer and subscription identifiers. Gallia sends Stripe the account email, language and an account reference to create and manage billing. Gallia's account database does not store complete payment-card numbers. Stripe receives payment credentials directly and may request additional billing information through its payment interface.

**Preferences and visits.** We process language and display preferences. For signed-in users with subscriber access, including an eligible trial or payment processing grace period, the personal activity calendar records visit dates, the date recording began and a time zone. It records at most one entry per account and day; the calendar does not store an IP address or a list of pages viewed. A visit may be recorded when an eligible signed-in subscriber views a public page as well as the account area. This is a calendar of website visits, not a record of investment transactions or returns.

**Arrivals and campaigns.** Gallia counts arrivals on public pages as daily totals by landing page and generic source, medium, campaign and content labels in the links. These counters retain no visitor identifier, account identifier, individual timestamp, name, email address, IP address or browser fingerprint. Landing pages come from a limited list, without arbitrary URL parameters or fragments. Account and Campaigns are not counted as public landing pages. These totals cannot recognise a returning person or link an individual arrival to an account; a reload or new opening may be counted again.

**Statistics relating to new registrations.** When a new account is created, Gallia retains only the generic campaign labels still present in the registration link, with the account identifier and its registration and confirmation dates. Without an available label, the origin remains unknown; we do not reconstruct an earlier journey. To count trials and valid first positive payments, we then use the necessary dates, subscription and invoice references, amount, currency and payment status. These records do not copy your name, email address or IP address and do not include a list of pages viewed. Reports compare campaign totals without linking anonymous arrival counters to a person. A zero or invalidated payment is not a paying conversion. These internal measurements use no external advertising pixel and are not sent to advertising platforms. The optional sharing described in P11 is separate.

**Technical requests.** Technical information is involved even when you visit without an account. Requests to the website and its service providers may include an IP address, browser information, request URLs and timestamps. Connection and security records can also include errors and information needed to investigate misuse. The absence of an IP address in the personal visit calendar does not mean that technical requests contain no IP address.

**Correspondence and evidence.** We process messages and information you provide for support, a complaint, withdrawal or a privacy request. Account and billing records can establish service requests and their handling. At new account registration, we record your acceptance of the Terms using your account identifier, the language and version accepted, the address and integrity reference of that version, and the actual acceptance time recorded by the server. We preserve a protected copy of the accepted text. We do not add an IP address to this acceptance record or create acceptance records for earlier accounts without an actual acceptance event. The document's stated effective date is not your acceptance date.

First and last name, email and password are required by the current registration form. Billing and authorization information required at payment is necessary to establish and administer the subscription. Without the required information, the corresponding account or payment cannot be completed. We do not request your brokerage password or access to your investment account. Avoid sending unnecessary financial or sensitive information in support messages. The service is intended for adults; contact us if you believe an account contains a child's information.

## P3 Purposes and legal bases

We use necessary account and subscription information to create and authenticate your account, provide subscriber access, manage billing and cancellation and answer service-related requests. The legal basis is performance of the contract or steps requested by you before entering it. A request made outside a subscription is handled on the basis appropriate to that request, including a legal obligation for a statutory privacy request.

Accounting records and information required to comply with applicable law are processed on the basis of legal obligations. Connection and security records used to protect accounts, investigate fraud or misuse, maintain service reliability and defend legal claims are processed on the basis of legitimate interests in protecting the service and exercising legal rights, subject to necessity, proportionality and your rights.

Visit dates and the time zone are used to display your own personal activity calendar. We rely on our legitimate interest in providing account holders with a limited record of their visits to the service, subject to necessity, proportionality and your rights. Recording is limited to one visit date per day, the recording start date and a time zone, without an IP address or a list of pages in the calendar. This calendar is not used to adapt investment publications to your financial circumstances, build an advertising profile or monitor your investment orders. You may object to this processing at contact@gallia.me. Related browser storage supports authentication, preferences and consultation of this personal account function, as explained in P4; accepting the Terms is not consent to optional tracking.

We keep Terms acceptance evidence on the basis of our legitimate interest in establishing the contract and defending legal rights. Information required to answer statutory requests is retained on the basis of the applicable legal obligation. Retention is limited as described in P7.

If an optional purpose requiring consent is offered, such as promotional messages or optional tracking, we request that consent separately and explain the purpose before activation. Refusing an optional purpose does not prevent use of the paid information service. You may withdraw consent for future processing without affecting the lawfulness of processing before withdrawal.

The confirmed registration sharing described in P11 for the previous arrangement relies on the separate consent given at the time. Gallia keeps the records needed to demonstrate that consent and honor any withdrawal. Sections P7 and P11 describe retention.

The subscription status controls access to the same publications available to subscribers. We do not collect an investment suitability profile or use account information to decide what investments you personally should make.

Arrival counters are used to compare aggregate traffic from campaign links, solely for Gallia. They are not individually matched with accounts. Statistics on new registrations, trials and first payments rely on our legitimate interest in measuring the results of our campaigns in a limited way and directing our expenditure. We have limited this processing to generic labels available at registration and service milestones, without recognising the visitor beforehand, creating an advertising profile or sharing data with advertising networks. You may object to account-related statistics under P4 and P8 without affecting your account, price or access. Accepting the Terms is not consent to these statistics. Results remain partial: a later return without a campaign link, a change of device or an error may leave the origin unknown.

## P4 Browser storage and tracking signals

Gallia uses browser storage for authentication sessions, account recovery, language and display choices, cached subscriber activity information and continuity when returning from payment or subscription management. Authentication, preferences and activity caches use local storage. Recovery and payment-return information may use session storage. The activity cache contains the current visit date, recording start date and time zone; it supports consultation of your personal calendar and is cleared on sign-out and relevant account-state changes. It is not an advertising tracker. Payment-return records can contain an account reference, the action taken, a timestamp and the previous subscription status so that the account can check the resulting billing state.

You can clear or restrict browser storage in browser settings. Doing so may sign you out, remove saved preferences or impair functions. Clearing this storage does not by itself cancel a subscription or delete records held by Gallia or its providers. Provider interfaces, including payment pages, may use their own cookies or storage under their applicable notices. The rules governing browser storage depend on its purpose; this notice does not claim that every use is exempt from consent. A purpose requiring consent must have its own prior choice, separate from acceptance of the Terms.

Gallia's website does not currently change its operation in response to a browser's Do Not Track signal. Its current configuration does not include advertising trackers intended to follow visitors across unrelated websites. Service providers nevertheless receive the technical requests needed to provide their services. jsDelivr's published policy states that its CDN and delivery providers do not track individual users. When you use the payment interfaces, Stripe may collect information about your online activities over time and across different websites, including device and usage information for fraud prevention and security, as explained in its [Privacy Policy](https://stripe.com/privacy). This is distinct from promising that no third party receives technical information or uses any browser storage. A legally applicable opt-out signal, including Global Privacy Control where required, retains the effect given to it by law; Do Not Track is not the same signal.

**Statistics without visitor identifiers.** The campaign feature does not create a cookie or a measurement identifier in local or session storage. It does not preserve a first origin for 30 days. Only generic campaign labels may accompany internal links until registration; individual advertising identifiers and account confirmation or recovery links do not feed these statistics. This feature displays no banner and adds no consent checkbox. Earlier local measurement keys are removed when the new version loads, without reusing them for attribution. Storage needed for the other functions described above remains separate.

**Objecting to account-related statistics.** You can use the objection control on this page while signed in, or write to **contact@gallia.me**. Objecting removes your account's statistical attribution and associated conversions, then prevents later payment events from recreating them. It does not delete your account, Terms acceptance evidence or information required to manage or account for the subscription. Arrival counters contain no identifier that could locate or remove a person from those totals; they remain independent aggregates.

## P5 Recipients and service providers

Gallia's operator and authorised persons may access information needed for their tasks. Suppliers involved in providing the service currently include:

- **Supabase**, for authentication, database services and storage, including encrypted archives of files backed up from the Gallia server;
- **Scaleway**, for the server hosting the website, operating its services and holding encrypted database backup archives;
- **Stripe**, for payment and subscription processing;
- **OVHcloud**, for domain and email services, including account confirmation and recovery emails and correspondence addressed to Gallia;
- **jsDelivr**, for delivering the Supabase browser library used by the website, including on public pages. Its delivery network providers also receive the technical requests used to load that library.

Providers receive the information needed for their functions. Some act for Gallia under processing arrangements; payment and other providers may also process information independently for their own security, regulatory or other legally permitted purposes. Additional information submitted directly in a provider's interface is governed by the relevant arrangements and that provider's notice. Locations and international transfer safeguards are described in section P6. [jsDelivr's privacy policy](https://www.jsdelivr.com/terms/privacy-policy) and its [delivery providers](https://github.com/jsdelivr/jsdelivr/blob/master/Sub-Processors.md) describe its CDN processing.

We may disclose relevant information when legally required, to address abuse or protect rights. Gallia does not sell customer contact lists. The previous sharing arrangement with Meta is described in P11.

## P6 Locations and international transfers

Gallia operates the service from France. The Supabase project used for account authentication, the database and storage is hosted in **Ohio, United States (us-east-2)**. This region has been checked in the project configuration; the [Supabase regions documentation](https://supabase.com/docs/guides/platform/regions) identifies the associated primary data storage location.

Scaleway hosts the website server and its encrypted database backup archives. Its [regions and availability documentation](https://www.scaleway.com/en/product-availability-by-region/) describes the locations offered, but does not by itself establish where Gallia’s server is located. We do not state a specific country for this server until its own location has been confirmed.

OVHcloud provides domain and email services. The location of mailboxes, their backups and related processing depends on the subscribed service and applicable contractual documents. The [public information on OVHcloud email services](https://www.ovhcloud.com/fr/mail/) does not by itself establish the exact location of Gallia’s services. We do not state that all email processing takes place exclusively in France or the European Union.

Operating Gallia from France does not mean that all hosting, support access, email processing or content delivery takes place in France. The primary storage location does not determine every location from which providers process or access data.

Some provider operations involve international access or transfers. Stripe's published [Privacy Policy](https://stripe.com/privacy) identifies transfers to countries including the **United States and India**. Supabase's contractual data importer is based in **Singapore**, and its published arrangements describe internationally distributed support. jsDelivr uses a global delivery network; its [delivery provider list](https://github.com/jsdelivr/jsdelivr/blob/master/Sub-Processors.md) describes the organisations involved. The location of a database alone does not determine every location from which information may be accessed.

For transfers outside the European Economic Area, the applicable provider arrangements must supply the safeguards required by law. Supabase's published [Data Processing Addendum](https://supabase.com/legal/customer-resources/data-processing-addendum) incorporates standard contractual clauses for covered transfers under its conditions. Stripe's policy describes adequacy mechanisms, standard contractual clauses and the EU–US Data Privacy Framework for transfers within their respective scope. jsDelivr's published [Data Processing Agreement](https://www.jsdelivr.com/documents/data-processing-agreement.pdf) sets out standard contractual clauses for relevant transfers. These are the providers' published arrangements; they are not a certification that every individual processing operation or transfer has undergone an independent audit. Contact **contact@gallia.me** for information on the arrangements relevant to your data and how to obtain a copy of the applicable safeguards.

## P7 Retention deletion and backups

The existing retention rules continue to apply. The new offer does not restart existing retention periods. Gallia applies the earlier rules through monthly reviews and any required manual closure, deletion or restricted archiving. Daily statistics cleanup and the log and regular backup rotations operate separately. Retention of the previous Meta sharing choice and technical transmission records is described in P11.

- **Campaign statistics:** daily arrival counters are kept for 13 months from the relevant day. Statistics relating to a new account and their conversions are kept for no more than 13 months from registration; campaign expenditure is kept for 13 months from its date. Daily cleanup removes expired records. Individual identifiers from the earlier measurement and its temporary attribution references are deleted from active systems during the transition; only daily totals and, for accounts previously attributed with agreement, useful generic labels may remain, without extending their earlier expiry. Objecting under P4 removes account statistics and associated conversions before that deadline. These deletions do not affect invoices, contractual information or accounting records subject to their own rules. Older copies in backups follow the rotation and restrictions described below.
- **Account information and personal visit history:** kept while you use the account, with deletion on a valid request subject to applicable exceptions. If there is no active subscription, we close the account and delete these records after **three years without an interaction from you, a sign-in or a paid customer relationship**. Ending subscriber access stops further calendar recording but does not itself delete earlier visit days. Records separately required for accounting or legal evidence follow the rules below.
- **Terms acceptance evidence:** kept during the account's life, then for **five years after closure** to establish the contract and defend legal rights. After closure, the separate evidence register is limited to the account identifier, actual acceptance time, language, version and integrity reference of the accepted text, without a name or email address. The protected document copy remains available as part of that evidence.
- **Support correspondence and requests:** kept for **five years after the request or case is closed**, with access limited to handling requests and establishing or defending rights. A record relevant to an ongoing dispute or legal preservation obligation is retained until that matter and the applicable obligation end, then deleted when no other retention requirement applies.
- **Invoices and accounting records:** kept for **ten years from the end of the financial year concerned**, including records archived through Stripe, to meet accounting obligations. Other customer, payment and security information processed independently by Stripe follows its own applicable legal and retention requirements; this does not extend the retention period for the Gallia account or visit history.
- **Connection and security records on Gallia's server:** the system journal is configured for a maximum of **seven days**, also subject to a storage limit. Text system logs and failed-login logs rotate daily with **seven archived files**, in addition to the current file; this is not a universal seven-day deadline for every log. Records necessary for a specific security incident or legal claim may be preserved separately while that matter remains open.

Providers may retain their own technical records under the applicable service terms and privacy notices, according to their security, operational and legal purposes. These periods are separate from the Gallia server settings. Relevant information is available in the notices of [Supabase](https://supabase.com/privacy), [Scaleway](https://www.scaleway.com/en/privacy-policy/), [Stripe](https://stripe.com/privacy), [OVHcloud](https://www.ovhcloud.com/fr/terms-and-conditions/privacy-policy/) and [jsDelivr](https://www.jsdelivr.com/terms/privacy-policy). You can ask **contact@gallia.me** about the records relevant to your request and applicable retention or deletion arrangements.

Self-service account deletion removes the authentication account and related Gallia account and visit records, subject to the checks described in A3. It does not automatically delete the separately retained acceptance evidence or customer, payment and invoice records held by Stripe. A request under P8 is assessed for each category according to its purpose and lawful retention requirements. Only the information needed for an applicable exception is retained, with restricted access.

Regular backup processing is configured to retain the latest **30 successfully completed backup copies**. The database, including account and authentication records, is backed up in encrypted archives on the Gallia server; server files are backed up in encrypted archives in private Supabase storage. Manual copies and incomplete backup sets are not necessarily included in the regular rotation. Thirty copies is not a guarantee that every copy is deleted after 30 calendar days or after 30 successful runs.

Backups may temporarily contain information removed from active systems. They are used for recovery with access restrictions. Such information remains in a regular backup until that copy is removed through the rotation described above. Manual copies and incomplete backup sets are reviewed monthly and deleted as soon as their recovery or verification purpose ends, with a maximum retention of **90 days from their creation**, unless a specific legal preservation obligation requires restricted retention for longer. If a backup is restored, applicable deletion requests are reapplied before restored information is put back into ordinary use.

## P8 Your choices and rights

Under the GDPR, subject to applicable conditions and exceptions, you may request access, correction, deletion, restriction and portability, or object to processing based on legitimate interests. You may withdraw consent for a purpose relying on consent. You may complain to the French supervisory authority, the **CNIL**, at [cnil.fr](https://www.cnil.fr), or another competent supervisory authority.

Send requests to **contact@gallia.me**. We may request proportionate information to verify identity where necessary; do not send identity documents unless requested. GDPR requests are normally answered within one month. Where the law permits an extension, we explain it and the reasons within that first month. You can make a privacy request while a subscription remains active even if the self-service account deletion control is unavailable. Subscription cancellation, statutory withdrawal and deletion of personal information are separate actions.

US state privacy rights depend on residence, the law's scope and applicable exceptions. We assess requests under the laws that apply to Gallia and do not retaliate for exercising an applicable right. Use the contact above for concerns or requests, including any applicable rights concerning the optional sharing described in P11.

## P9 Security and incident handling

Gallia uses account access controls, encrypted connections and encrypted backup archives. Access is limited according to operational needs. No system can promise absolute security. Use a unique password and contact us promptly if you suspect misuse. We assess security incidents and provide legally required notifications to competent authorities and affected individuals. We will not ask for your brokerage password, complete card number or authentication code in an unsolicited message.

## P10 Updates and contact

We publish the applicable notice with its version and effective date. For a material change, we notify account holders by email or a prominent account notice before the change applies where required. A revised notice does not replace a fresh consent where the law requires one. Privacy contact for **Gallia**: **contact@gallia.me**.

## P11 Previous sharing of confirmed registrations with Meta

Gallia does not request Meta sharing consent from new users or send their registrations to Meta. Under the previous arrangement, Gallia could send at most one confirmed registration event per account via Meta’s Conversions API, with separate consent, to measure its campaigns and improve delivery of its ads on Facebook and Instagram. This section describes that arrangement and the rights of people affected by it. The internal analytics described in sections P2 through P4 are separate.

The event could include the action type, its actual date and time, an opaque technical conversion identifier, the relevant page address without personal parameters, standard browser information (the User-Agent), and a SHA-256 hash of the account email address. Meta may use the hash to match the event to a Facebook or Instagram account. This data is not anonymous. Gallia does not send a clear-text email address, visitor IP address, first or last name, browsing history, trial starts, payment information, projection amounts or portfolio information through this feature. This feature does not add a Meta pixel or advertising cookies.

The recipient is Meta Platforms Ireland Limited in Ireland. Under the [Meta Business Tools Terms](https://www.facebook.com/legal/technology_terms), Meta acts as a processor for certain matching, measurement and analytics operations; responsibilities may be joint for collection and transmission for targeting and personalisation, after which Meta processes the received data under its own responsibility. The allocation of responsibilities is described in the [Controller Addendum](https://www.facebook.com/legal/controller_addendum). Meta may also use event data to personalise its advertising, content and products under its [Privacy Policy](https://www.facebook.com/privacy/policy/).

Gallia keeps a record of the choice made under the previous arrangement, separate from your acceptance of the Terms. That record includes your account identifier, choice, notice version and language, the date and time of the choice and, if applicable, the date and time of withdrawal. It remains while your account exists and is deleted from active systems when the account is deleted. Restricted backup copies follow P7.

Gallia can use the technical information needed for transmission for 72 hours from collection. Gallia deletes it after processing or when it clears expired data. The limited technical log, which contains no email address, email hash, User-Agent or page address, is scheduled for deletion after 30 days. Meta applies its own retention rules under the terms and policy linked above.

Meta’s processing may involve the United States and other countries. Its [European Data Transfer Addendum](https://www.facebook.com/legal/EU_data_transfer_addendum/update) describes reliance on the EU–US Data Privacy Framework and other recognised mechanisms for operations within its scope. This information does not mean that all processing takes place in Ireland or that Gallia has independently audited each transfer.

You can withdraw your consent at any time in the Sharing with Meta section of your Gallia account. Withdrawal stops future transmission. It does not affect the lawfulness of processing that took place before withdrawal, or recall information already sent to Meta. You keep any 30-day trial already awarded without an accelerated charge. The rights and contact methods in P8 remain available, and you can also exercise applicable rights directly with Meta.

## P12 Potential use of Meta Pixel

If Gallia activates Meta Pixel on its site, this tool from Meta may collect information about your browsing, your actions on the site, and your device identifiers. This information may be used to measure the effectiveness of our advertising campaigns, improve our services, and personalize the ads you see on Facebook and Instagram.

Meta processes the data it receives in accordance with its [Privacy Policy](https://www.facebook.com/about/privacy/). Meta Pixel is not active on Gallia as of the publication date of this notice.