Data privacy notice

ARTICLE 1
Preamble

The purpose of this privacy policy is to inform users of the site:  

• How their personal data is collected. Personal data is defined as any information that can be used to identify a user. This may include: their first and last names, age, postal or email address, location or IP address (non-exhaustive list);
• Their rights regarding this data;  
• The person responsible for processing the personal data collected and processed;  
• The recipients of this personal data;  
• The website’s policy on cookies.  

This policy supplements the legal notices and General Terms and Conditions of Use, which users can consult at the following address: www.upside.paris

ARTICLE 2
PRINCIPLES RELATING TO THE COLLECTION AND PROCESSING OF PERSONAL DATA

In accordance with Article 5 of European Regulation 2016/679, personal data shall be:   

• Processed lawfully, fairly and transparently in relation to the data subject;
• Collected for specified, explicit and legitimate purposes (see Article 3.1 hereof) and not further processed in a manner incompatible with those purposes;
• Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;  
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
• Processed in a manner that ensures appropriate security of the data collected, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.  

Processing is lawful only if, and to the extent that, at least one of the following conditions is met:

• The data subject has given consent to the processing of his or her personal data for one or more specific purposes;
• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which the controller is subject;
• Processing is necessary to protect the vital interests of the data subject or another natural person;
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

ARTICLE 3
PERSONAL DATA COLLECTED AND PROCESSED WHEN BROWSING THE WEBSITE  

Article 3.1: Data collected  

The personal data collected in the course of our business are as follows:  

• First name, surname and email address in the event of a request for a call back or subscription to our newsletter

The collection and processing of this data serves the following purpose(s):  

• Request for a callback or subscription to the Upside newsletter

Article 3.2: Method of data collection

When you use our website, the following data is automatically collected:  None

Other personal data is collected when you perform the following operations on the platform:  None

It is stored by the data controller under reasonable security conditions for a period of: 12 months.

The company may retain certain personal data beyond the periods specified above in order to fulfil its legal or regulatory obligations.

Article 3.3: Data hosting

The website www.upside.paris is hosted by:  

OVHcloud, located at 19 place François Dorin 75017 Paris

contact@ovhcloud.com

ARTICLE 4
DATA CONTROLLER AND DATA PROTECTION OFFICER

Article 4.1: Data controller  

Personal data is collected by UPSIDE Conseil & Transactions SAS, with capital of €10,000, registered with the Paris Trade and Companies Register under number 887735561, whose registered office is located at 28, rue de Berri, 75008 Paris  

The data controller can be contacted as follows: By post at the following address: 28 rue de Berri, 75008 Paris;

• • By telephone on +33 (0)6 74 88 83 61;
  • By email: contact@upside.paris.  

Article 4.2: Data Protection Officer

The data protection officer for the company or controller is: Guillaume Savard, partner, gsavard@upside.paris

If, after contacting us, you feel that your “Data Protection” rights have not been respected, you can send a report to the CNIL.

ARTICLE 5
USER RIGHTS REGARDING DATA COLLECTION AND PROCESSING

Any user concerned by the processing of their personal data may exercise the following rights, in accordance with European Regulation 2016/679 and the Data Protection Act (Law 78-17 of 6 January 1978):   

• Right of access, rectification and erasure of data (set out in Articles 15, 16 and 17 of the GDPR respectively);
• Right to data portability (Article 20 of the GDPR);
• Right to restriction (Article 18 of the GDPR) and to object to data processing (Article 21 of the GDPR);
• Right not to be subject to a decision based solely on automated processing;
• Right to determine the fate of data after death;
• Right to lodge a complaint with the competent supervisory authority (Article 77 of the GDPR).  

To exercise your rights, please send your letter to Upside Conseil & Transactions, 28 rue de Berri 75008 Paris or by email to gsavard@upside.paris.

In order for the data controller to comply with the request, the user may be required to provide certain information such as their full name, email address and account, personal space or subscriber number.  

Visit cnil.fr for more information about your rights.

ARTICLE 6
CONDITIONS FOR MODIFYING THE PRIVACY POLICY

The publisher of the www.upside.paris website reserves the right to modify this Policy at any time in order to ensure that it complies with the law in force.  

Any changes shall not affect purchases previously made on the website, which remain subject to the Policy in force at the time of purchase and as accepted by the user when confirming the purchase.  

Users are invited to read this Policy each time they use our services, without the need for formal notification.  

This policy, published on 1 June 2023, was updated on 1 December 2025.