In an effort to make accessible to all, the possibility of using a coach or psychologist for our well-being in general, to try to contribute to the development of each one by identifying ways to improve our personal and professional relationships, the Upfeel Platform calls on the participation of companies/employers to facilitate access to these services.
In this sense, the respect and strict protection of privacy have always been at the heart of the thinking that motivated the creation of the Upfeel Platform.
That is why the Upfeel Platform has been designed to strictly guarantee the security and confidentiality of exchanges made through it by offering a simple solution that can be quickly implemented while ensuring reliability and transparency in terms of confidentiality and processing of any data allowing the identification of Users of the Platform.
Indeed, when registering and creating a user account (Beneficiary, Practitioner or Company), then in the context of the use of services offered, the Platform Upfeel collects personal data, whose processing methods are the subject of this policy.
The person responsible for the processing of the Platform Upfeel is the company Upfeel Services, SAS, with a share capital of 1,000 Euros, registered in the Paris Trade and Companies Register under number 894966142 and having its headquarters at 9, rue Louis David - 75116 Paris.
Upfeel Services (hereinafter "the Company") is represented by Jonathan Ferrebeuf.
The data collected by the Upfeel Platform fall into the following categories:
The collection of this information is required for the proper functioning of the Platform Upfeel and services offered. These data are essential to enable the connection of Users of the Platform, to respond to requests for information or incidents and send content.
This data is collected for the purpose of :
The details of the processing of personal data collected, as well as the processing reserved and its purpose, are presented in the lines below:
Functioning of the services Purpose of the processing
Creation and management of the personal account
Management of consultation requests
Incident management (requests on the Platform, incidents, cancellations, complaints and/or disputes)
Invoicing, payment
Legal basis
Performance of pre-contractual measures or the contract
Compliance with legal and regulatory obligations
Shelf life
For the duration of the opening of the personal account, increased in case of closure of the account by the legal prescription period applicable to legal actions
During the applicable statutory limitation period
Improving services Purpose of the processing
Statistical analyses to improve services (for marketing, customer relations and customer experience purposes)
Legal basis
Legitimate interest: to analyse the use of the services offered in order to i) improve our knowledge of the needs and interests of Beneficiaries, Practitioners and Companies ii) adapt the services / products offered accordingly
Shelf life
During the time the personal account is open
Internal management Purpose of the processing
Prevention of money laundering and terrorist financing and the fight against corruption
Accounting / tax obligations
Legal basis
Compliance with legal and regulatory obligations
Shelf life
During the applicable statutory limitation period
Commercial communication Purpose of the processing
Management of participation in advertising campaigns
Legal basis
Legitimate interest: to develop the business and the services/products offered, to offer new services
Shelf life
Three years from the last unanswered communication
Data transmission Purpose of the processing
Transmission to partner practitioners and competent authorities, if necessary (in case of legal action)
Legal basis
Transmission to Partner Practitioners, competent authorities, if necessary (in case of legal action)
Compliance with legal and regulatory obligations
Shelf life
For the duration of the opening of the personal account, increased in case of closure of the account by the legal prescription period applicable to legal actions
During the applicable statutory limitation period
Failure to provide the personal data requested, the User may not have access to services of the Platform Upfeel.
In the event of a dispute, personal data will be kept until the end of the dispute procedure plus five years.
The personal data processed are intended for the internal services of the Platform Upfeel and its partner practitioners (responsible for processing).
In addition, the personal data processed may be transmitted to the competent authorities, at their request, in particular in the context of legal proceedings, legal investigations, requests for information from the authorities and/or in order to comply with other legal obligations.
In any event, the Company undertakes to preserve the anonymity of Beneficiary Users and never to communicate their identity to Companies or third parties and to use all possible means to preserve this anonymity, except for compelling reasons and in the event of legal obligations.
Your personal data will not be passed on to international organisations.
Where is my data stored?
Your personal data is stored on the servers of AWS (Amazon Web Services) in Oregon, USA.
The Company specifies on the basis of the latest decisions of the European Union (CJEU ruling of 16 July 2020 - Schrems II case), it is up to the Company to ensure that the proposed data protection regime is "adequate", in the sense of the European requirements in this area.
In this respect, the Company acknowledges that it uses an alternative means for data transfers to the United States that is considered valid by the European Commission and that allows the secure transfer of data.
In addition, the Company reminds you that it remains responsible for the processing of personal data collected and that as such it has concluded a contract governing the transfer of your data outside the European Union, including standard contractual clauses approved by the European Commission.
What are my rights?
At any time, you have the right to :
The Platform Upfeel reserves the right to maintain the processing of personal data whose treatment would have been the subject of an objection in the event that such maintenance would be necessary for legitimate reasons or the defense of legal rights.
How can I exercise my rights?
To exercise your rights or if you have any questions about the processing of your personal data you can contact us at contact@upfeel.com
Contact address: Upfeel - Upfeel Services - 9 rue Louis David - 75116 Paris
If, after contacting the dedicated service, you feel that your rights have not been respected, you can submit a complaint to the CNIL.
In compliance with the applicable legal provisions, this Privacy and Personal Data Processing Policy may be modified by the Company at any time.
These changes will apply as of the effective date of the updated version. You are therefore advised to consult the latest updated version of the policy regularly.
Policy updated to 11 May 2021