FINACIUS SAS, with a capital of 5000 euros, whose head office is located 13 rue Proudhon 93210 La Plaine Saint-Denis, France, as well as its subsidiaries, here after jointly referred to as "Upperise" as a commercial name, is a SaaS platform that operates in the startup/scaleup ecosystem and support their hyper growth and valuation.
Upperise complies with the amended "Computer and Freedoms" Act No. 78 of January 6, 1978, the "Confidence and the Digital Economy" No. 2004 - 575 of June 21, 2004 and the General Data Protection Regulations 2016/679 of April 27, 2016 ("GDPR").
Upperise has a Data Protection Officer in charge of ensuring the proper application of the law and respect for the rights of access, rectification, opposition, erasure, limitation and portability that you have in accordance with the aforementioned texts (dpo [at] upperise.com).
2. WHICH PERSONAL DATA ARE COLLECTED ON OUR SITES AND WHY?
As a processing manager within the meaning of the so-called "Computer and Freedoms" act and the GDPR, Upperise is responsible for the personal data it collects.
The data is collected in order to allow you, as a customer, prospect or simple user of our services, to receive personalized information, to manage your orders, but also to offer you suitable commercial offers, and if necessary to make you benefit from offers from our partners. This data also enables our services to administer and improve our marketing and services activities for our customers.
When collecting your personal data, you are notified of the mandatory nature of the requested information, in order to be able to benefit from a service, or its optional nature, as well as the consequences of not disclosing a data. You are also informed of the use that Upperise will make of your data and your right of access,rectification, opposition, erasure, portability of data, limitation of treatments, and to know the fate of your data after death.
Declarative data : Upperise collects the data needed to use the service of your choice, or to manage your order. The data collected on this occasion may be: your name(s) and first name(s), your postal address, your email address, your phone number, your date of birth. They can be supplemented by information about your home (number and age of children, interests).
You may be offered commercial offers from Upperise or its partners. In accordance with the "Confidence in the Digital Economy" Act, you must clearly express your consent by checking a box that confirms your agreement, if any. You will of course have the option to withdraw your consent at any time by exercising your rights of objection, erasure or limitation. However, you will not be able to question the legality of the treatment performed before the withdrawal.
All of these data are stored in our customer database, so that you can communicate with you and offer you offers tailored to your needs.
Behavioural data : You may be required to respond to online surveys offered by Upperise as a customer and/or user of products or services. These investigations are anonymous. However, we may ask for your consent to retain, associate with your customer account, declarative behavioral data. You are then notified of your rights of access, rectification, erasure and opposition, and the means to exercise them.
Navigation data : We are also likely to collect data about the events of interactions between you and Upperise's services (page loads, clicks buttons, click rates on newsletters, banners, etc.). in order to offer you offers tailored to your wishes, and generally improve our services according to the expectations of our customers. In this case,with your consent, we collect and process this data. You are then informed of your rights of access,rectification, opposition and erasure, to the portability of data, to the limitation of treatments and the means to exercise them.
This data is then collected by tracers and/or cookies. A cookie is a text file, recorded on your computer's hard drive at the request of the server managing the site visited. It contains information about browsing the pages of this site and makes it easier to use the site later on your next visit. The information collected by a cookie can only be read by the cookie's transmitter. You may object to the introduction of cookies, but in this case you may have degraded access to the services offered (see Article VII).
Data not collected directly from you : In certain assumptions, your personal data may have been collected from third parties. Thus, Upperise may be required to collect personal data from its partners. These sources are non-public. If so,we will not fail to provide you with all the information about the treatment as well as any useful information regarding the exercise of your rights of opposition, erasure, limitation, access, rectification and portability.
3. WHAT USES UPPERISE MAKES OF YOUR PERSONAL DETAILS?
1. Declarative data
Declarative data is required to register and manage your orders or to use the services offered by Upperise's sites. Data about your preferences can help you make proposals tailored to your needs.
Your email address can be used under the following conditions :
- - If you are a customer of an Upperise company, the same company may send you offers of products similar to those you have already ordered.
- - When collecting your email address, or later, you may be asked to check a box confirming your agreement to receive commercial offers from Upperise. If you agree by checking this box, Upperise will be able to email you offers of the products it sells.
- - Similarly, you may be offered offers from Upperise's partners by checking the box provided for this purpose. If you agree, Upperise's partners will be able to send you business offers by email.
In any case, you can ask to no longer receive commercial offers at your email address:
- - Either using the opt-out link you'll find at the bottom of all Upperise's commercial e-mailings.
- - Either by sending a letter to: Upperise STATION F, 5 Parvis Alan Turing 75013 Paris, France.
- - Either by writing an email to our DPO at: dpo [at] upperise.com.
In addition, in accordance with Consumer Regulation 2014-344 of March 17, 2014, you can object to telephone canvassing by registering on the French national opposition list "Bloctel": https://conso.bloctel.fr.
Upperise informs you, however, that there are exceptions. Indeed, the law allows you to be called if :
- - You are our customer ;
- - You gave your number unequivocally ;
- - The telephone call consists of offering you the provision of newspapers, periodicals or magazines or contributing to a charitable action carried out by a non-profit association.
In the event that Upperise is informed of your death, this information will be shown on our files so that no more prospecting is sent. Your data will then be deleted from our database.
2. Navigation data
During your visits to Upperise's sites, cookies can be implanted in your computer. Upperise complies with Section 82 of the "Computer and Freedoms" Act No. 78-17 of January 6, 1978 amended, the GDPR and the recommendation(s) of the CNIL regarding tracers and cookies.
- - The following tracers and cookies are not affected and may be filed without your consent in accordance with CNIL's recommendations:
- - Tracers to keep your choice on the repository of tracers (or your willingness not to express a choice) ;
- - Trackers to identify you with a service you requested ;
- - Tracers designed to store the contents of a shopping cart on a merchant site ;
- - User interface customization tracers (for example, for choosing the language or presentation of a service), when such customization is an intrinsic element expected by the user of the service ;
- - Tracers that balance the load of equipment that contributes to a communication service ;
- - Tracers allowing paid sites to limit free access to their content to a pre-defined quantity and/or a limited period ;
- - hearing measure tracers who benefit from the consent exemption under the framework specified by Article 5 of the July 4, 2019 Cookie and Other Tracer Guidelines.
Once your consent is transmitted, it will be kept thirteen (13) months by Upperise. At the end of this period, or before if you add purposes or partners, you may be asked for a new consent.
You can change your choices at any time by clicking on the "Cookie Management" link at the bottom of our sites (if applicable).
In accordance with current regulations, navigation data can be passed on to the relevant authorities on request.
3. Personal data security
Upperise implements all the technical means to guarantee the security of your personal data, and to prevent any risk of loss, deterioration or misuse of it.
4. WHO ARE THE RECIPIENTS OF YOUR PERSONAL DETAILS ?
The personal data collected is intended for Upperise and its subsidiaries. Your other personal data is not disclosed to third parties, except in the following cases :
- - Where you have given your prior consent for the sharing and/or disclosure of your personal data, including through the features offered by Upperise's websites ;
- - When Upperise must share your personal data with its subcontractors, service provider and/or technical providers for the purpose of providing the requested services, including shipping and delivery of your subscriptions and orders and managing your subscriptions, as well as solving service operating problems, processing payments, data analysis, processing mailing campaigns, managing subscription and re-subscription information flows, hosting services, handling certain marketing aspects of services ;
- - Under a law, regulation or a decision of a competent regulatory or judicial authority or, if necessary,for the purpose of preserving its rights and interests, Upperise will be able to disclose your data ;
- - In the event of a change of control of Upperise and its subsidiaries or the sale of all or part of its assets, Upperise will be allowed to transfer your Personal Data ;
You are also informed that Upperise will be able to pass on your name and postal address to its business partners so that they can offer their services to you. You have the opportunity to oppose it.
Upperise will also be able to forward your email address to its business partners, provided you have consented to this transmission via a checkbox.
Upperise does not transmit your other Personal Data to third-party advertisers for targeted marketing purposes unless you have previously consented to it. It should be noted, however, that advertisers can obtain your personal data from other public sources. Upperise cannot in the same way see its liability incurred in this regard.
On the other hand, Upperise may use and share with third parties certain non-personal technical or aggregated data relating to your browsing on Upperise's sites. The collection, processing and disclosure of such anonymized data cannot be subject to the restrictions set out here.
5. HOW LONG DO YOU KEEP YOUR PERSONAL DATA ?
The shelf life of your personal data may vary depending on the purpose of the collection.
Legal obligations may impose on Upperise a minimum term of preservation. In other cases, the data about you will only be kept within the limit of the realization of the purpose pursued (in this case for the duration strictly necessary to manage the commercial relationship i.e. seven years from the end of your last subscription contract with Upperise, or if you are not a customer, three years after the last contact on your part), or in compliance with the applicable regulations in this matter.
Information stored in your device (e.g. cookies) or any other items used to identify you and allow them to be traceable, as well as raw attendance data with an identifier,will not be kept formore than thirteen months.
6. ARE YOUR PERSONAL DATA BEING TRANSFERRED ABROAD?
In order to ensure the execution of its services, including the management of subscription and re-subscription information flows, Upperise will be able to transfer your personal data to subcontractors outside the European Union for these purposes. In order to ensure that your privacy and personal data are respected, the subcontractors concerned are signatories to the standard contractual clauses established by the European Commission.
A. COOKIE MANAGEMENT
A cookie is a text file that records information about your browsing on the internet. This file placed during a consultation, by the serversite, on the user's hard drive, cannot contain viruses or be run. It is not active. In addition, you can read it, destroy it or modify it. A cookie cannot be used to retrieve data or personal information from your hard drive, read your email address.
How to express your choices ?
There are several ways to manage, accept or reject Cookies. You can :
- - Use the Consent Management Platform (CMP) (a) ;
- - Show your choice by setting up your internet browser (b) ;
- - In the case of advertising cookies, use a tool edited by digital advertising professionals (c);
- - show your choice directly to the cookie issuer for analytical cookies or social media (d).
a) Use the consent management platform you are offered when you first log on to the site
On the first page of the consent management platform, you have a global information on the purposes of the different cookies used on the site. You can either:
- - Accept all cookies and continue browsing ;
- - Set up your choices :
- - On the second page of the consent platform, you can exercise your choices based on each purpose of collecting data by the cookies deposited by the site. You can click on "Accept Everything" or "Refuse Everything" and continue browsing, or set up your partner choices.
- - On the third page, you can set your choices by partner.
- - Warning: your choice can only be saved if you use the same browser and you haven't erased your browsing history and/or cleaned your cookies in the meantime.
- - You will be asked again every time you delete your history and/or cleaned your cookies or every thirteen (13) months.
b) Set up your browser
Most browsers accept cookies by default. However, you can decide to block these cookies or ask your browser to notify you when a site tries to implement a cookie on your device. In this context,we inform you that you can set up your browser to refuse the implementation of cookies. For managing cookies and your choices,the configuration of each browser is different. It is described in your browser's help menu, which will let you know how to change your cookie wishes.
c) Express your online choices to interprofessional platforms to opt out of advertising cookies only
The "Youronlinechoices" platform, proposed by digital advertising professionals grouped within the European Digital Advertising Alliance (EDAA) and managed in France by the Interactive Advertising Bureau France, offers you the opportunity to refuse or accept cookies used by its member companies to adapt to your browsing information the advertisements that may be displayed on your device (french link): http://www.youronlinechoices.com/fr/controler-ses-cookies/.
Beware, your choice will not prevent the display of advertisements but will block technologies that allow you to adapt ads to your interests.
d) By objecting directly to the issuer of this cookie regarding analytical cookies or issued by social networks
Upperise uses a tool to measure the audience of its sites: Google Analytics.
If you don't want this tool to collect or use your information, you can opt out from the following page: http://tools.google.com/dlpage/gaoptout?hl=None
You can also turn off Google Analytics' advertising features, via the Network Advertising Initiative's deactivation page by clicking on the following link: http://www.networkadvertising.org/choices/
Social Media Cookie
To learn about the purpose and extent of data collection, the processing and use of data by the social network(x) towhich(s) you belong, as well as your rights and opportunities to change the parameters for the protection of your privacy,we invite you to read their policy of managing Cookies on their sites.
In order to allow you to measure the usefulness of a particular cookie, a presentation of the different types of cookies follows this paragraph.
B. COOKIES – GLOSSARY
Feature cookies and cookies needed to run Upperise's websites.
These cookies are exclusively deposited by Upperise and are necessary for the proper functioning of the sites you use as well as to access the features of the sites designed to ensure your browsing comfort: navigating as a subscriber to one of our press titles without having to identify from one navigation to another for example. They can still allow the display of our sites to be adapted to your terminal's preferences and the visualization software installed on your device.
Our sites include analytical cookies whose purpose is to know the attendance, use and performance of our sites, and to improve their operation and ergonomics (for example, the pages most often visited, visitor searches, etc.). Upperise uses Google Analytics which collects the information needed for the above analysis described.
Sharing cookies (social links)
To allow you to share articles and content with your loved ones or comment on them, our sites contain sharing links to social networks (Facebook, Twitter). When you use these sharing buttons, a third-party cookie is installed. If you are connected to the social network while browsing our site, the sharing buttons allow you to link the content viewed to your user account.
Our advertising agency markets the advertising spaces of our sites. The commercialization of the advertising spaces of our sites allows Upperise to finance the free provision of quality services for users and subscribers of its sites.
Advertisements on our sites may contain :
- - Cookies issued by the advertiser (i.e.,the one on which the advertisement is shown) or by a third party concerned by this advertisement (e.g. audience measurement), and allow, among other things, to calculate the amounts liability liabilities by advertisers but also to limit the number of times you see an ad ;
- - Cookies issued by our management: these are cookies used to offer you advertisements tailored to your interests on our sites. In particular, they are used to limit the number of times you see an ad.
In addition, some cookies can be issued by advertising market intermediaries (Trading Desk, Google Adsens, SSP) and follow you from one site visit to another for advertising display.
8. HOW CAN YOU EXERCISE YOUR RIGHTS OF ACCESS, RECTIFICATION, OPPOSITION, ERASURE, PORTABILITY AND THE LIMITATION OF YOUR PERSONAL BELONGINGS ?
In accord with the provisions of the Computer and Freedoms Act and the GDPR, you can request the disclosure of your Personal Data and require that, depending on the case, be, corrected, completed, updates, locked or deleted your Personal Data, which are inaccurate, incomplete, equivocal, outdated, or whose collection, use, communication or retention is prohibited.
In accordance with Article 18 of the GDPR, if necessary, you may also request to limit access to the processing (for example, when the accuracy of your personal data is disputed by you - for a period of time allowing Upperise to verify the accuracy of your Personal Data or when Upperise no longer needs your Personal Data for processing purposes but is still required for the recognition, exercise or advocacy of your rights).
In accordance with Article 20 of the GDPR, it is also possible for you, within the limits of the technical processes used by Upperise, to request to receive your personal data, in a structured format, commonly used and readable by machine, and that they be transmitted to another processing manager for processing carried out using automated processes for which you have given your consent.
For all of these requests, simply send an email or a letter to:
Upperise Data Protection Officer
5 Parvis Alan Turing
75013 Paris, France
dpo [at] upperise.com
In accordance with Decree No. 2007-451 of March 25, 2007 for the application of the Computer and Freedoms Act, your applications must be submitted in writing and must be signed and accompanied by a photocopy of an identity document bearing your signature. The request should specify the address to which the response will have to be sent. Upperise will have one (1) month to respond after receiving your request.
For your full information, you have the ability to refer your request to the (French) National Commission for Information Technology and Freedoms (whose contact information is listed at https://www.cnil.fr/fr/vous-souhaitez-contacter-la-cnil) in the event that Upperise has not followed up on your request within one month of your request. If necessary, this period may be extended by two (2) months, given the complexity and number of requests.