Privacy Policy

Data controller

The controller of the personal data collected on the selfupgrade.fr website is:

• UPGRADE (UPGRADE ACADEMY)
• Represented by Jérémy François
• Email: contact@selfupgrade.fr

Data collected

UPGRADE ACADEMY collects the following personal data depending on the context of use:

Company form (B2B quote)

• First and last name
• Company name
• Business email address
• Phone number
• Number of employees
• Message (description of the need)

Complaint form (Qualiopi ind. 31)

• First and last name
• Email address
• Program concerned
• Approximate date
• Subject of the complaint
• Detailed description

Free program enrollment (Systeme.io funnel)

• First name
• Email address
• Answers to the positioning questionnaire

Cookies and trackers

Cookies may be placed on your browser. Please consult our cookie policy for details.

Purposes of processing

The data collected is processed for the following purposes:

• Enrollment management: processing enrollment requests, access to the learner area, educational follow-up
• Complaint management: processing and following up on complaints in accordance with the Qualiopi framework (indicator 31)
• Commercial prospecting: sending newsletters and training offers (only with your consent)
• Audience analysis: measuring website traffic and improving the user experience (only with your consent)
• Service improvement: analyzing feedback to improve the training programs

Legal basis

Data processing is based on the following legal bases:

• Performance of a contract: enrollment management and educational follow-up (article 6.1.b of the RGPD)
• Legal obligation: Qualiopi compliance, invoicing, retention of accounting documents (article 6.1.c of the RGPD)
• Legitimate interest: improvement of services and training programs (article 6.1.f of the RGPD)
• Consent: analytics cookies, advertising pixels, commercial prospecting (article 6.1.a of the RGPD)

Retention period

• Contractual data: 5 years after the end of the training course (legal obligation to retain training documents)
• Prospecting data: 3 years after the last active contact
• Cookie consent: 6 months maximum (then re-solicitation)
• Connection logs: 1 year (legal obligation)

User rights

In accordance with the RGPD, you have the following rights over your personal data:

• Right of access: obtain confirmation that your data is being processed and obtain a copy of it
• Right to rectification: correct your inaccurate or incomplete data
• Right to erasure: request the deletion of your data (subject to legal retention obligations)
• Right to object: object to the processing of your data, in particular for commercial prospecting
• Right to portability: receive your data in a structured, machine-readable format
• Right to restriction: request the suspension of the processing of your data in certain cases

To exercise your rights, contact us at: contact@selfupgrade.fr

We undertake to respond to your request within 30 days.

You also have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL): www.cnil.fr

Processors

UPGRADE ACADEMY uses the following processors for the processing of personal data:

Transfers outside the EU

Some of our processors are located outside the European Union, mainly in the United States.

These transfers are governed by:

• The EU-US Data Privacy Framework for certified companies (Google, Meta, Cloudflare)
• The Standard Contractual Clauses (SCC) approved by the European Commission for the other processors (Circle.so, TikTok)

Security

UPGRADE ACADEMY implements the appropriate technical and organizational measures to protect your personal data:

• HTTPS: all communications are encrypted via TLS
• Restricted access: only authorized personnel access personal data
• Data minimization: only strictly necessary data is collected

Amendment of the policy

This privacy policy may be updated at any time to reflect regulatory developments or changes in our practices.

The date of last amendment is indicated at the top of this page. We invite you to consult it regularly.