Privacy Policy
PRIVACY POLICY
We at UpGradelle CS (“UpGradelle CS,” “the company,” “we,” “us,” “our,” “I,” or “the Publisher”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how the information that you provide to us is used and shared. This Privacy Policy applies to our information collection and use practices in connection with: (i) our websites, including, without limitation, upgradellecs.com and nesrinebeldi.com (the “Websites,” the “website”); and (ii) the information you provide to us offline, including, without limitation, via phone and email.
We specialize in consulting and training services in businesses, careers, strategy, and management, as well as the dissemination of information related to the development of professional activities and projects. Our website is intended to provide Internet users (that is to say, any natural or legal person who visits or uses the websites, hereinafter the “users” or “you”) with information allowing them to discover the activities and services offered by the company (advisory services, courses, workshops, seminars, etc.) or its news (events, publications, testimonials, etc.).
We may also offer through our Website features allowing users to contact our company (contact requests, in particular), to subscribe to the newsletter, or to download certain content for free (download forms). The company can also market its products/services via the websites and may offer users, under certain conditions, the ability to create a reserved space. During your browsing and interactions with the websites or with the company, the latter may collect and process personal data concerning you, as the data controller.
Description of Users and Acceptance of Terms
Our Websites, their content, and services are intended to be accessible and fully functional with the latest versions of the following operating systems: Microsoft Windows, Android, Mac OS, and Linux, and the following browsers: Internet Explorer, Google Chrome, Mozilla Firefox, and Safari. In the event of malfunction(s) of the websites caused by an outdated version of the operating system or browser used, the User is encouraged to perform updates.
All Users agree to use our Websites for strictly personal purposes and to comply with all applicable legal and regulatory provisions, both French and European, as well as the General Conditions of Sale and Terms of Use of our Websites. The User acknowledges that the information communicated to us is personal and does not pertain to any third party who has not expressly consented to the use and communication of their personal data.
This Privacy Policy applies to visitors to our Websites, who view only publicly-available content (“Visitors”), and users who register with us (“Registered Users”) and wish to purchase a product or service through our Websites.
By visiting our Websites, Visitors agree to the terms of this Privacy Policy and the accompanying Terms of Use.
By registering with us and purchasing a product or service through our Websites, each Registered User agrees to the terms of this Privacy Policy and the accompanying Terms of Use.
By providing us information offline, you are also agreeing to the terms of this Privacy Policy.
Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use and the Terms and Conditions of Purchase.
GDPR Privacy Notice
UpGradelle CS undertakes that the collection and processing of data will be done in a lawful, fair, and transparent manner in accordance with Regulation No. 2016/679, known as the General Data Protection Regulation (GDPR), and the applicable French provisions in this area.
Natural persons located in the European Economic Area (“EEA”) should review the General Data Protection Regulation (“GDPR”) and GDPR Privacy Notice here.
The Information We Collect/or Receive; the Purpose of Collection and Use
In accordance with Law n° 78-17 of January 6, 1978, any User has the right to query, access, rectify, delete, exercise the right to be forgotten, limit processing, request data portability, and object to the processing of their personal data by contacting the Websites by post at the following address:
Headquarters:
34, Avenue des Champs Élysées
75008, Paris
France
Or by writing to us at:
contact@upgradellecs.com
Any User also has the right to lodge a complaint with the CNIL, located at 3 Place Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07.
Personal information collected on our Websites is retained for the duration of an account’s activation. After a period of 3 years without account activity, the User will receive an email inviting them to confirm their desire to keep their account active. Failing this, personal data is archived, with the exception of data related to the User’s login information. Archived data is kept for a period of 24 months. After this period, the retained information will only be used for statistical purposes and will be anonymized. In any case, the User has the option to request the deletion of their account, upon which their data will be permanently deleted.
The Websites use information security techniques, such as access control procedures, cryptographic mechanisms, and firewalls, to protect Users’ data and ensure its confidentiality. However, no security measure is infallible, and the Websites cannot guarantee absolute and total security for the User.
Purposes and legal grounds for data processing
Any processing of personal data must be based on a legal basis set out in Articles 6 and 9.2 of the GDPR to be lawful. Personal data may be processed for the purposes of managing and developing registration on the Websites, sending information relating to offers and emails, and responding to requests for access, modification, cancellation, and opposition, as well as addressing questions and complaints. The data collected is used to process orders and manage them appropriately to achieve the desired objectives, such as creating an enterprise and establishing standard documents offered on the Websites. Therefore, the legal foundations for processing and retaining this data include the legitimate interests of the Websites (ensuring proper functionality, processing orders, improving services and offers, and user assistance), fulfilling obligations, and complying with the Websites’ legal responsibilities.
In the course of operating the Websites and interacting with you, we will collect (and/or receive) the following types of information:
1. Contact Information
When you sign up for newsletters, respond to a survey, register for a class, purchase a product or service, or become an affiliate partner, you may provide personal information, such as your name, address, email, social media information, and phone number. Contact Information is used to provide the requested product, service, or information and to contact you for direct marketing of current and future products and services.
If you access one of our pages through an affiliate partner link and provide Contact Information (e.g., to request information or make a purchase), we may share your name and email address with that affiliate partner to confirm the referral. If the affiliate partner offers bonuses or rewards, we are not responsible for fulfilling them. Please review their privacy policies and terms of use for more details on how they manage your information.
2. Order Information
When you place an order, you provide information about the products or services you wish to purchase. This information is collectively referred to as “Order Information” and is used to fulfill your order.
3. Billing Information
When purchasing a product or service, you may need to provide additional information, such as debit or credit card details, expiration dates, billing addresses, and activation codes. This “Billing Information” is processed by our third-party payment processor as our agent (see Onward Transfers to Third Parties). UpGradelle CS does not directly obtain or process any Billing Information.
4. Other Information
In addition to the above, we may collect additional information (“Other Information”):
a. From You: Additional details you voluntarily provide, such as household income, gender, product and service preferences, and other non-personal information.
b. From Your Activity: Information automatically collected when you use the Websites, including:
- IP Addresses: Static or dynamic IP addresses sometimes tied to identifiable devices.
- Browser and Device Data: Browser type, language, referring/exit pages, date and time, duration on pages, sections visited, device type, UUID, operating system, carrier, and hardware specifications.
c. From Cookies: Information collected via cookies, which are small data packets stored on your device. Cookies enhance user experience and collect Other Information. Users can disable cookies via browser settings, but this may affect website functionality. Refer to our cookie policy for details.
d. Third-Party Analytics: We use services like Google Analytics to evaluate website usage, compile reports, collect demographic data, and analyze performance metrics. These providers use cookies and other technologies to gather data. By using the Websites, you consent to this data processing. Opting out may limit functionality. Learn more about Google Analytics at https://www.google.com/analytics.
e. From Other Sources: Information from third parties, such as Facebook, YouTube, and other social media platforms.
Information Collected by or Through Third-Party Advertisers/Remarketers
We may share Other Information about you with third parties, including, but not limited to, advertising and remarketing providers or other brand partners, to personalize or better understand how you engage with ads or other content. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), or other technologies to collect Other Information for these purposes. This may include tailoring, targeting (e.g., behavioral, contextual, retargeting, and remarketing), analyzing, reporting on, and/or managing advertising campaigns or other initiatives. For example, when a browser visits a site, pixel tags enable us and these third parties to recognize certain cookies stored within the browser, helping to determine which ads or other content brought a user to a specific site. Additionally, we may receive Other Information from these third parties, including through their service providers, such as advertising identifiers, IP addresses, and post-conversion data.
Below is a list of advertising/remarketing providers we use. However, this list is subject to change based on the campaigns we run, and we will update it diligently. You may use the accompanying links to learn more about these providers and, if available, how to opt out of their targeted ads or personalization features. Please note that opting out does not necessarily mean you will avoid all advertising or content; you may still receive generic ads or content.
- Facebook: http://www.facebook.com/about/privacy
- Twitter: https://twitter.com/en/privacy
- Google: https://support.google.com/ads/answer/2662922?hl=en
In addition, you may opt out of interest-based advertising from participating providers by visiting:
Information Collected Through the Websites that is Not Covered by this Privacy Policy
You may post and/or share information, including but not limited to, comments using forums and other similar features available through the Website. NONE of the information you provide using these features is protected by this Privacy Policy. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE USING ANY SUCH FEATURES. ALL SUCH INFORMATION IS PUBLIC INFORMATION AND MAY BE SEEN, COLLECTED, OR USED BY ANY USER OF THE WEBSITE.
Please note that if you post and/or share information on our Website through your Facebook account, such information will be subject to Facebook’s privacy policy.
Information Collected Through the Facebook Community Group
You may post and/or share information through our Discord Community Groups. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE USING THE DISCORD COMMUNITY GROUP. USE OF THE DISCORD COMMUNITY GROUP IS GOVERNED BY DISCORD’S PRIVACY POLICY. ALL SUCH INFORMATION IS PUBLIC INFORMATION AND MAY BE SEEN, COLLECTED, OR USED BY ANY USER OF OUR DISCORD COMMUNITY GROUP.
Aggregate Data
In an ongoing effort to better understand our visitors, customers, and our products and services, we may analyze the Order Information and Other Information in aggregate form to operate, maintain, manage, and improve the Website and/or our products and services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics to describe our products and services to current and prospective business partners and other third parties for other lawful purposes.
Additional Uses
We also use information collected pursuant to this Privacy Policy to provide our services; to process Orders; to administer our rewards and promotional programs; to maintain and improve our Website and services to you; to solicit your feedback; and to inform you about our products and services and those of our third-party marketing partners.
Sharing with Third Parties
Like many businesses, we contract with other companies to perform certain business-related services. We may disclose your information, including personal information in some cases, to certain types of third-party companies, but only to the extent needed to enable them to provide such services, including, without limitation, technical assistance, order fulfillment, customer service, marketing assistance, payment processing, survey collection, promotional and marketing assistance, and business operations.
These other companies will have access to your information, including personal information in some cases, only as necessary to perform their functions and to the extent permitted by law. We may also disclose your information, including any personal information, to any of our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control with us in order to support delivery of our products and services.
We apply in our Website the French and European legislation on prospecting for partners according to which any transmission of personal data from a User to partners is systematically subject to obtaining the said User’s agreement.
Business Transfer
In the event of a merger, dissolution, or similar corporate event or the sale of all or substantially all of our assets, we expect that the Information that we have collected and/or received, including personal information, would be transferred to the surviving entity in a merger or to the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy.
Disclosures to Public Authorities
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Opt-Out for Direct Marketing
You may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to this email address: contact@upgradelle.com. Please allow us a reasonable time to process your request.
Accessing and Modifying Personal Information and Communication Preferences
Upon request to contact@upgradelle.com, we will provide you with confirmation as to whether we are processing your personal information, and have the data communicated to you within a reasonable time. You have the right to correct, amend, or delete your personal information where it is inaccurate or has been processed in violation of this Privacy Policy. We may require payment of a non-excessive fee to defray our expenses in this regard. Please allow us a reasonable time to respond to your inquiries and requests.
In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any UpGradelle CS marketing email. Customers cannot opt out of receiving transactional e-mails related to their account or their Orders. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.
Information You Share on Public Forums
We feature or may in the future feature public forums such as message boards or web logs, webinars, classes, telephone conferences, or coaching calls, user comments, chat rooms, and similar activities (collectively, “Public Forums”). You may voluntarily post and share information through such Public Forums. NONE of the information you provide to through the Public Forums or through use of these features are protected by this Privacy Policy including any personal information. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE USING ANY SUCH FEATURES. ALL SUCH INFORMATION IS PUBLIC INFORMATION AND MAY BE VIEWED, COLLECTED, USED, MODIFIED AND/OR DISCLOSED FOR ANY PURPOSE BY US, ANY USER OF THE PUBLIC FORUM, AND THE PUBLIC.
You should think carefully before disclosing any information in any Public Forum.
How We Protect the Information
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in processing and the nature of such data, and in compliance with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, email sent to or from the Websites may not be secure, and you should therefore take special care in deciding what information you send to us via email.
Retention of Personal Information
We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, subsequently authorized, or as allowed under applicable law.
Important Notice to Non-E.U. Residents
It is important to note that the Website and their servers are operated in the European Economic Area, more precisely in France. If you are located outside of the E.U and France, please be aware that any information provided to or collected by us, including personal information, will be transferred from your country of origin to France. Except in the case of data transfers under the EU-U.S. Privacy Shield, your decision to provide such data to us, or allow us to collect such data through our Website, constitutes your consent to this data transfer.
Children
We do not knowingly collect personal information from children under the age of 13 through the Websites. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information through the Website without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.
External Websites
The Website may contain links to third-party websites. We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.
Changes to This Privacy Policy
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. By accessing the Website and/or using our services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.
How to Contact Us
If you have questions about this Privacy Policy, please contact us via:
Email:
contact@upgradelle.com
Or write to us at:
UpGradelle CS
34, Avenue des Champs Elysées
Paris, 75008
France