At Upskyld, protecting your personal data is our priority.
When you use the platform Upskyld (hereinafter the "Platform"), we may collect personal data about you.
The purpose of this policy is to inform you about how we process your personal data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR").
1. Who is the data controller?
The data controller is EGLS – Everybody’s Gonna Learn Sometime, French “société par actions simplifiée” (simplified joint-stock company), registered under the number RCS 920 109 139 with the Registry of Trade and Companies of Paris and whose head office is located at 15 rue des Halles, 75001 Paris, France (hereinafter “Us” or “We”).
2. What personal data we collect?
Personal data is a data that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name.
We may collect the following personal data:
- Identification data (e.g. full name, email and postal addresses, telephone number, your photo);
- Data relating to your listening;
- Login data (e.g. logs, IP address).
We inform you, when collecting your personal data, whether some of these data are mandatory or optional. Mandatory data are indicated with an asterisk.
3. On what legal basis, for what purposes and for how long do we keep your personal data?
Data retention period
To provide you with our services available on our Platform (give you access to podcasts)
Performance of a contract to which you are party and/or taking steps at your request prior to entering into a contract
When you have created your account: personal data are retained for the duration of your account. Your connection logs are kept for 1 year. If your account is inactive for a period of 2 years, it will be deleted if you do not respond to our reactivation email. When you have not created your account: your data are retained for 3 years for direct marketing purposes. In addition, personal data may be archived for probationary purposes for a period of 5 years.
To perform operations related to contracts, orders, invoices and customer relationship management
Performance of a contract to which you are part
Personal data is retained for the duration of our business relationship. The data are archived for probationary purposes for a period of 5 years.
To create a database of customers and prospects
Our legitimate interest in developing and promoting our business
For our customers: their personal data are retained for the duration of our business relationship. For our prospects: their personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action). In addition, personal data may be archived for probationary purposes for a period of 5 years.
To send newsletters, requests and direct marketing mailings
For our customers: our legitimate interest in winning customer loyalty and informing our customers of our latest news. For our prospects: your consent
Personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action) or until you withdraw your consent.
To answer to your information request and other inquiries
Our legitimate interest in responding to your inquiries
Personal data is retained during the processing of your request and is deleted once the request has been processed.
To elaborate analytics of navigation of Upskyld.com
The personal data are retained for Upskyld internal analytics only.
To process data subjects’ requests to exercise their rights
Our legitimate interest in responding to your requests and keeping records of them
If we ask you for proof of identity: we only retain it for the necessary time to verify your identity. Once the verification has been carried out, the proof is deleted.
4. Who are the recipients of your personal data?
Will have access to your personal data:
i. The staff of our company;
ii. Our processors: hosting provider, CRM tool, mailing provider, database, tracking tools;
iii. If applicable: public and private organizations, exclusively to comply with our legal obligations.
5. Are your personal data likely to be transferred outside the European Union?
Your personal data is hosted for the duration of the processing on the servers of the companies Supabase and Vercel, located in the European Union.
As part of the tools we use (see article on the recipients of your personal data, especially our processors), your personal data may be transferred outside the European Union. The transfer of your personal data in this context is secured with the use of following safeguards:
- Either personal data are transferred to a country that has been recognized as ensuring an adequate level of protection by a decision of the European Commission, in accordance with article 45 of the GDPR : in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR; or
- The personal data are transferred to a country whose level of data protection has not been recognized as adequate to the GDPR : in this case these transfers are based on appropriate safeguards indicated in article 46 of the GDPR, adapted to each provider, including but not limited to the execution of Standard Contractual Clauses approved by the European Commission, the application of Binding Corporate Rules or under an approved certification mechanism; or
- The personal data are transferred under any appropriate safeguards described in Chapter V of the GDPR.
6. What rights do you have regarding your personal data?
You have the following rights with regard to your personal data:
- Right of access: you have the right to access all your personal data at any time as defined by article 15 of the GDPR.
- Right to rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time as defined by article 16 of the GDPR.
- Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases defined in article 18 of the GDPR.
- Right to erasure (“right to be forgotten”): you have the right to request that your personal data be deleted and to prohibit any future collection as defined by article 17 of the GDPR.
- Right to file a complaint to a competent supervisory authority (in France, the CNIL), under GDPR article 77, if you consider that the processing of your personal data constitutes a breach of applicable regulations.
- Right to define instructions related to the retention, deletion and communication of your personal data after your death.
- Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.
- Right to data portability: under specific conditions defined in article 20 of the GDPR, you have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.
- Right to object: You have the right to object to the processing of your personal data as defined by article 21 of the GDPR. Please note that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.
You can exercise these rights by writing to us using the contact details below. For this matter we may ask you to provide us with additional information or documents to prove your identity.
7. What cookies do we use?
For more information on cookies management, please consult our Cookies Policy.
8. Contact information for data privacy matters
Contact email: email@example.com
Contact address: Everybody’s Gonna Learn Sometime (Upskyld), 15 rue des Halles, 75001 Paris, France
Entry into force: October 2022