Privacy Policy
This policy explains which personal data Upflo processes, for which purposes, on which legal basis, for how long, with which recipients and under which safeguards.
Controller
The entity operating Upflo and identified in the Legal Notice
Privacy contact
contact@upflo.fr
Main area
France / EEA, subject to the technical providers in use
Supervisory authority
CNIL
1. Controller and scope
The controller is the entity operating the Upflo platform, as identified in the Legal Notice. When a platform user enters information about another person, that user may also act as a separate or joint controller depending on the context; this policy describes the processing carried out by Upflo as operator of the service.
This policy applies to personal data processing carried out on public pages, the authenticated product area, payment flows, admin interfaces, support requests, cookies and technical services associated with Upflo.
2. Data subjects
- Website visitors and viewers of public pages.
- Sales talents, applicants, account holders and premium subscribers.
- Startup representatives, members, admins and invited teammates.
- Prospects and third parties whose information is entered in relation to a funded appointment or dispute.
- Users sending feedback, reviews or support interactions.
- Admin staff authorised to handle disputes, operations and support requests.
3. Categories of personal data
- Identity and contact data: display name, email address, language, avatar, role and active organisation context.
- Talent profile data: biography, headline, experience, location, preferences, skills, LinkedIn URL and onboarding progress.
- Organisation and mission data: startup name, description, website, logo, missions, applications, contracts, signatures and related evidence.
- Messaging and notification data: conversations, messages, notification events, anti-bypass blocking and related logs.
- Appointment and prospect data: date, status, amounts, dispute reason, notes, email, phone number, meeting link, LinkedIn URL and sensitive context notes.
- Payment and subscription data: Stripe identifiers, payment status, refunds, transfers, payout batches, internal ledger entries and premium status.
- Technical and security data: session cookies, context identifiers, IP addresses or user-agent details whenever required for evidence, signatures, fraud prevention or security.
- Support and quality data: feedback titles, messages, page URL, user-agent, locale, active role, error logs and internal product events.
4. Data sources
Data mainly comes from information provided directly by users when registering, creating a profile, publishing a mission, sending a message, submitting an appointment or contacting support.
Some data comes from third-party providers chosen by the user or used by Upflo to operate the service, such as authentication providers, payment processors, security services, hosting providers and monitoring tools.
Upflo may also receive data indirectly when a user enters the email address of an invited teammate or the contact details of a prospect in relation to a funded appointment.
5. Purposes and legal bases
| Purpose | Examples of data | Main legal basis |
|---|---|---|
| Account creation, authentication, session management and login security | Email address, user identifier, session cookies, OAuth provider, technical logs | Performance of a contract and legitimate interest in security |
| Managing startup and talent profiles | Display name, avatar, biography, location, logo, website, preferences, experience | Performance of a contract |
| Publishing missions, applications and contractualisation | Mission details, application messages, status, signatures, IP and user-agent evidence | Performance of a contract and legitimate interest in evidence |
| In-app messaging, notifications and anti-bypass prevention | Messages, conversation identifiers, contact-detail blocking rules, notifications | Performance of a contract and legitimate interest in protecting the business model |
| Funded appointments, payments, refunds, disputes and transfers | Amounts, statuses, prospect details, Stripe identifiers, dispute reasons, audit logs | Performance of a contract, legal accounting obligations and legitimate interest in fraud prevention |
| Managing the talent premium subscription | Customer and subscription identifiers, billing periods, premium status | Performance of a contract and accounting obligations |
| Support, feedback and service improvement | Feedback titles, messages, page URL, user-agent, error logs | Legitimate interest and, where relevant, performance of a contract |
| Administration, audit, security and abuse prevention | Logs, product events, webhook failure logs, internal traces | Legitimate interest, legal obligations and defence of rights |
| Compliance with legal, tax, accounting obligations and litigation handling | Invoices, consent evidence, payment history, audit logs | Legal obligations and legitimate interest in legal defence |
Important
Where several legal bases apply to a given workflow, the basis listed above is the one that primarily justifies the relevant operation.
6. Mandatory or optional fields
Data strictly required to open an account, authenticate, publish a mission, manage a profile, fund an appointment, receive a payout or secure the service is mandatory. Without it, Upflo may be unable to provide all or part of the service.
Some data is optional or enrichment-oriented, for example certain profile presentation fields, some visuals, some feedback fields or certain preferences. Missing optional data may nevertheless reduce the quality of the experience or the visibility of a profile.
7. Data recipients
Data is accessible, on a need-to-know basis, to authorised Upflo personnel involved in support, operations, moderation, billing, security and administration.
Data may also be shared with subprocessors and technical partners used for hosting, authentication, database and realtime services, payment processing, anti-bot protection, monitoring, rate limiting and technical operation of the service.
- Application hosting and deployment providers.
- Database, authentication and realtime service providers.
- Payment and subscription processors.
- OAuth providers chosen by the user, such as Google or LinkedIn.
- Anti-bot or captcha providers when the feature is enabled.
- Error tracking, observability and rate-limiting services depending on the environment.
- Advisers, auditors, insurers, public authorities and courts when necessary.
8. International transfers
Depending on the selected hosting region and the activated technical providers, some data may be processed outside the European Economic Area, especially when global providers are used for hosting, payments, authentication, anti-bot protection, error monitoring or support.
Whenever a transfer outside the EEA occurs, Upflo relies on an appropriate legal mechanism such as an adequacy decision, the European Commission's Standard Contractual Clauses or another recognised safeguard, supplemented where necessary by reasonable additional measures.
9. Retention periods
| Category | Active retention | Archiving / deletion |
|---|---|---|
| Account, profile and user-context data | For the duration of the contractual relationship and until closure or deletion | Deletion or anonymisation after a reasonable period, with evidential archiving when needed |
| Organisation invites | Until expiry, acceptance or withdrawal | Periodic deletion or purge unless evidence must be retained for a dispute |
| Missions, applications, contracts, signatures and messaging | While the service is being performed | Evidential archiving for up to 5 years from the last useful operation unless a longer period is required |
| Appointments, disputes, reviews and related audit logs | For operational handling during the relationship | Archiving up to 5 years after closure, and longer if litigation requires it |
| Payments, invoices, refunds, transfers and accounting entries | During performance and financial follow-up | Accounting and tax retention up to 10 years where required by law |
| Support feedback and internal requests | For handling and a reasonable history afterwards | Deletion or anonymisation no later than 3 years after closure unless litigation requires otherwise |
| Security logs, technical errors and raw product events | As long as needed for supervision and analysis | Rotation, deletion or aggregation depending on the log, generally within no more than 12 to 13 months for raw traces not needed longer |
| Cookies and trackers | Depending on purpose and type | Detailed in the Cookie Policy; 13 months maximum when a CNIL-like framework applies |
Important
These periods may be extended when necessary to defend a right, comply with a legal obligation or handle a dispute, audit or regulatory review.
10. Public visibility and access controls
Not all data is intended to be public. Upflo applies role-based and workflow-based access controls. Prospect data is separated from the core appointment record to reduce the risk of premature exposure.
Direct contact details of users or prospects are not freely exposed on public pages. Some information may be masked, redacted or delayed until payment or verification conditions are met.
11. Third-party data entered by a user
When a user enters the email address of an invited teammate, prospect contact details, a meeting link or any other information about a third party, that user warrants that an appropriate legal basis exists and that the required information has been provided to the third party where the law so requires.
Upflo processes such data in order to perform the service, preserve evidence, prevent fraud, resolve disputes and comply with legal obligations. Where collection is indirect, this policy serves as the general GDPR information notice, subject to the practical individual notice requirements imposed by law.
12. Data subject rights
Subject to the conditions and limits laid down by applicable law, data subjects have a right of access, rectification, erasure, restriction, objection, portability where applicable and, where consent is the legal basis, a right to withdraw that consent.
Requests may be sent to the privacy contact indicated in this policy. Upflo may request reasonable evidence of identity where necessary to protect the data and rights of third parties.
- Primary contact: contact@upflo.fr
- Support contact: contact@upflo.fr
- Supervisory authority in France: CNIL.
13. Automated decisions and scoring
As of the update date of this policy, Upflo does not organise decision-making based solely on automated processing that produces legal effects or similarly significant effects within the meaning of Article 22 GDPR.
Where internal indicators, quotas, scores or automatic product rules are used, they mainly serve as operational support, security guardrails or feature-access parameters, combined with human-defined rules and/or administrative review where appropriate.
14. Security
Upflo implements reasonable and proportionate technical and organisational measures to protect the confidentiality, integrity and availability of data. These measures may include secure authentication, role-based segregation, access limitation, audit logs, separation of sensitive data, secure protocols and administrative controls.
Because no security measure can eliminate all risk, users are also invited to protect their devices, passwords, usage environments and communication channels.
16. Policy updates
This policy may be updated to reflect changes to the service, providers, processing activities or legal framework. The last update date appears at the top of the document.
In the event of a material change, Upflo may inform users through the website, by email, by notification or by any other appropriate means.