It's not clear to me why "actual freedom of speech" should be equal to what is guaranteed by the US constitution. That would be like me saying "The US doesn't have the 'Right to Life'" because I'm exclusively applying the European definition of that term.
Freedom of expression/freedom of speech is guaranteed in some way in all Western nations, the difference – as you correctly point out – is the degree to which other rights are also taken into account when applying the Right to freedom of speech. But that's an extremely important distinction and it cannot be said that France doesn't have Freedom of speech.
Freedom of expression/freedom of speech is guaranteed in some way in all Western nations, the difference – as you correctly point out – is the degree to which other rights are also taken into account when applying the Right to freedom of speech. But that's an extremely important distinction and it cannot be said that France doesn't have Freedom of speech.