Privacy policy

Last update : July 2023

This Personal Data Protection Policy reflects UPCITI's commitment to transparency.

This document outlines UPCITI's practices regarding the collection, use, and confidentiality of your personal data gathered through the website, which it operates. Its purpose is to inform you about the conditions under which UPCITI, as the data controller, processes your data.

This Personal Data Protection Policy supplements the information provided when you submit your data by filling out the forms on our website

If you have any questions about this document or how UPCITI processes and protects your data, you can contact UPCITI by email at or by mail at 20 rue Voltaire, 93100 Montreuil, France.

  2. According to the General Data Protection Regulation, "personal data" refers to any information related to an identified or identifiable natural person. An "identifiable natural person" is considered to be a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more specific elements unique to their physical, physiological, genetic, mental, economic, cultural, or social identity.

  4. UPCITI, whose contact details are provided here, is responsible for processing the personal data of users of the website.

    • Purpose: Handling Contact Requests
    ObjectivesUPCITI processes the personal data you send to respond to requests received electronically (web forms, email).
    Legal BasisLegitimate interest of UPCITI to respond to received requests.
    Categories of Processed DataProfile, identity, telephone and email contacts, subject of the request, provided response.
    Data SourceProvided by the individual on the website.
    Mandatory Nature of Data CollectionFailure to provide all the data mentioned as mandatory in the web form will result in the request not being processed.
    Automated Decision-MakingThe processing does not involve automated decision-making.
    Concerned IndividualsIndividuals contacting UPCITI via the website, email, or postal mail.
    Categories of RecipientsUPCITI personnel responsible for responses.
    Data Transfer Outside the EUYES - via hosting provider NETLIFY.
    Data Retention Period3 years from the last contact initiated by the prospect.
    • You have various rights concerning your data, which can be exercised by sending a letter with proof of identity to:

      If UPCITI has reasonable doubts about the identity of the person making the request under the rights described below, UPCITI may request additional information necessary to confirm the person's identity (such as a copy of the ID card).

      Please note that no payment is required to exercise your rights as described below. However, when a person's requests are manifestly unfounded or excessive, especially due to their repetitive nature, UPCITI may:

      • Demand payment of reasonable fees taking into account administrative costs for providing information, making communications, or taking requested actions; or
      • Refuse to comply with such requests.

      We will respond to your request within one month from the receipt of your request. Given the complexity and number of requests, this period may be extended by two months. UPCITI will inform you of this extension and the reasons for the delay within one month from receiving the request.

    • Right to Object to Data Processing
    • In the case of commercial prospecting, you can object without reason to the processing of your data. If you have agreed to receive direct prospecting messages from UPCITI and/or its partners, you can change your mind later and object to receiving future messages, free of charge and without giving a reason. If you have accepted the deposit of non-mandatory cookies for the site's operation on your device, you can also object later, again free of charge and without giving a reason. In the case of exercising your right to object, UPCITI will no longer process your data for commercial prospecting purposes.

      You are also informed that you can register for free on the BLOCTEL telephone canvassing opposition list. For more information, you can visit the website

      Apart from the processing of your data for commercial prospecting purposes, you can also object, for legitimate reasons, to the processing of your personal data by UPCITI. In case of exercising this right of objection, UPCITI will then no longer process your personal data unless there are compelling legitimate grounds for the processing that override your interests, rights, and freedoms (examples: retaining your data for establishing, exercising, or defending legal claims).

    • Right to Access Your Data
    • You can directly request information from UPCITI about the processing related to you and the data held about you. To exercise your right of access, you must justify your identity by providing proof.

      Exercising your right of access cannot infringe on the rights and freedoms of others.

    • Right to Rectify Your Data
    • You can request the rectification of information about you if the data held by UPCITI is inaccurate. You also have the right to obtain incomplete personal data to be completed, including by providing a supplementary statement.

      In the case of exercising this right, UPCITI will notify each recipient to whom your data has been communicated of any rectification of data, unless such communication proves impossible or requires disproportionate effort.

    • Right to Erasure of Your Data (Right to be Forgotten)
    • You have the right to obtain from UPCITI the erasure of your data when there is a legal ground, such as, for example: the uselessness of the data or the withdrawal of your consent for processing based on it, if you object to processing for prospecting, or if you object to processing for another purpose and there is no compelling legitimate reason for the processing.

      In the case of exercising this right, UPCITI will notify each recipient to whom your data has been communicated of any erasure of data, unless such communication proves impossible or requires disproportionate effort.

      However, UPCITI may retain some of your data in the form of intermediate archives for the time necessary to meet its legal, accounting, and tax obligations.

    • Right to Restrict Processing of Your Data
    • You have the right to obtain the restriction of processing by UPCITI when one of the following elements applies:

      • If you dispute the accuracy of your data, for a duration allowing us to verify it.
      • If the processing is unlawful and you oppose the erasure and instead request the restriction of their use.
      • If UPCITI no longer needs your data for processing purposes, but you still need them for establishing, exercising, or defending legal claims.
      • If you have objected to processing based on the legitimate interest of the data controller, during the verification as to whether the legitimate grounds pursued by the data controller override yours.

      In the case of exercising this right, UPCITI will notify each recipient to whom your data has been communicated of any restriction of processing, unless such communication proves impossible or requires disproportionate effort.

    • Right to Data Portability
    • You have the right to request data portability. This allows you to receive data in a digital format. This right only applies when processing is carried out using automated means and based on your consent or the performance of a contract.

    • Automated Decisions and Profiling
    • UPCITI does not make any decisions about you based solely on automated processing that produces legal effects concerning you or significantly affects you.

    • Right to Provide Instructions on the Fate of Your Data After Death
    • You have the right to establish general or specific directives concerning the storage, erasure, and communication of your data after your death, specifying how you want these rights to be exercised. These directives may designate a person responsible for their execution, or else, your heirs will be designated. You can communicate specific directives to UPCITI. In the absence of any directives, your heirs can contact UPCITI.

      These directives, when they are general and concern all personal data concerning you, can be recorded with a digital trust service certified by the National Commission for Information Technology and Civil Liberties (CNIL).

    • Right to Lodge a Complaint with a Supervisory Authority
    • You have the right to lodge a complaint with a supervisory authority, such as the National Commission for Information Technology and Civil Liberties (CNIL) in France.

  8. The term "Cookie" broadly refers to any tracker deposited and/or read during the consultation of a website or an email. A cookie may contain information such as the name of the server that deposited it, an identifier in the form of a unique number, an expiration date.

    Cookies are essential, particularly to enable you to benefit from certain functionalities of our website. If you have chosen to disable cookies via your internet browser, access to the site may then be impaired.

    For more information on the use of cookies by UPCITI, please refer to our Cookie Policy.

  10. UPCITI implements appropriate technical and organizational measures, taking into account the state of knowledge, implementation costs, and the nature, scope, context, and purposes of the processing, as well as the degree of probability and severity of the risks to the rights and freedoms of individuals.

    UPCITI also takes measures to ensure that its staff, subcontractors, and their staff, who have access to your data, do not process them unless instructed by the data controller, except when required by Union law or the law of a Member State.

    UPCITI ensures that its subcontractors provide sufficient guarantees regarding the implementation of appropriate technical and organizational measures so that the processing best complies with the protection of the rights of the data subject.

  12. We regularly review our Personal Data Protection Policy and will publish any updates on this web page.