Privacy and personal data processing policy

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.io 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.io Platform.

That is why the Upfeel.io 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.io collects personal data, whose processing methods are the subject of this policy.

1. Who is responsible for the processing of my personal data?

The person responsible for the processing of the Platform Upfeel.io 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.

2. For what purposes are my personal data collected?

The data collected by the Upfeel.io Platform fall into the following categories:

  • Identification data: Last name, first name, personal and/or professional contact email address and telephone number

The collection of this information is required for the proper functioning of the Platform Upfeel.io 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.

  • Connection data (e.g. IP address, logs)

This data is collected for the purpose of :

  • Build a file of clients, partners and prospects;

  • Responding to all requests for information and incidents;

  • To send newsletters, content and other information in the context of the Platform's services.

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.io.

In the event of a dispute, personal data will be kept until the end of the dispute procedure plus five years.

3. Who are the recipients of my personal data?

The personal data processed are intended for the internal services of the Platform Upfeel.io 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.

4. will my personal data be passed on or to international organisations?

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 :

  • Request access to your personal data and be informed about their processing;

  • Requesting the rectification of inaccurate, incomplete or outdated data;

  • To object to the processing of your personal data;

  • Request the restriction of their processing in accordance with the cases defined in Article 18 of the GDPR;

  • Demand that your personal data be deleted, and prohibit any future collection;

  • Make a complaint to the CNIL (the competent supervisory authority in France), if you consider that the processing of your personal data does not comply with the applicable texts;

  • Define guidelines for the retention, deletion and disclosure of your personal data after your death;

  • Request the portability of your personal data in a standard machine-readable format and demand their transfer to the recipient of your choice.

The Platform Upfeel.io 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.io

Contact address: Upfeel.io - 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.

8. update

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