Privacy Policy

Introduction

This privacy policy aims to inform users and professional clients of the Upsellr SaaS solution of the conditions under which their personal data is collected, used and protected, in accordance with Regulation (EU) 2016/679 (GDPR) and the French Data Protection Act. This policy complements the Terms of Use (TOU) and General Terms and Conditions of Sale (GTCS).

1. Data Controller

The data controller is Upsellr company. Legal form: SAS Registered office: 200 chemin de Meayne, 06550 La Roquette Sur Siagne GDPR contact email: contact@upsellr.io Upsellr processes personal data exclusively in a professional context (B2B).

2. Categories of Data Processed

Upsellr may process the following categories of data: – identification data (name, first name, function, company), – professional contact details (email, phone), – connection and usage data (logs, IP address, timestamps), – billing data (address, payment information), – Client Data voluntarily integrated by the Client into the platform, – content generated by Services when they allow identification of a natural person. Upsellr does not process any sensitive data within the meaning of Article 9 of GDPR, unless specific legal obligation.

3. Purposes and Legal Bases

Personal data is processed for the following purposes: – provision and operation of Services → contract execution, – management of Client and user accounts → contract execution, – billing, accounting and legal obligations → legal obligation, – platform security and fraud prevention → legitimate interest, – Service improvement and internal statistics → legitimate interest, – operational communication related to service → contract execution. No data is used for commercial prospecting without appropriate legal basis.

4. Upsellr’s Role and Subcontracting

In providing Services, Upsellr acts: – as data controller for data related to commercial, contractual and technical management of the Client, – as processor for Client Data processed on behalf of the Client via the platform. Respective obligations of the parties are specified in the data protection annex (DPA).

5. Data Recipients

Personal data is intended exclusively for: – authorized internal Upsellr teams, – technical providers necessary for Service operation (hosting, payment, support), – administrative or judicial authorities when required by law. Upsellr does not sell or transfer personal data to third parties.

6. Transfers Outside European Union

Some Upsellr providers may be located outside the European Union. In this case, Upsellr ensures that transfers are governed by appropriate safeguards, including standard contractual clauses approved by the European Commission.

7. Retention Periods

Personal data is retained for periods proportionate to the purposes pursued: – account data: duration of contractual relationship plus five (5) years, – billing data: ten (10) years (legal obligation), – connection data: twelve (12) months maximum, – Client Data: contract duration, then deletion or return according to TOU.

8. Data Security

Upsellr implements appropriate technical and organizational measures to ensure security, integrity and confidentiality of personal data. These measures take into account state of the art, nature of data and risks incurred.

9. Data Subject Rights

In accordance with regulations, data subjects have the following rights: – right of access, – right of rectification, – right to erasure, – right to restriction of processing, – right to object, – right to data portability. When Upsellr acts as processor, requests must be addressed directly to the Client data controller. Requests may be sent to: contact@upsellr.io

10. Complaints

Any data subject has the right to lodge a complaint with the CNIL (www.cnil.fr).

11. Policy Evolution

Upsellr reserves the right to modify this privacy policy. Any substantial modification will be subject to prior information to Clients.

12. Applicable Law

This privacy policy is governed by French law.

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