Privacy policy

1. Data controller

2. What data do we process?

2.1 “Add the agent to my app” form. When you send us a request, we collect:

• the name of your company or application, your email address and the description of the task you would like to make simpler (required);
• your name, role, application website, telephone number and the deployment mode you have in mind (optional);
• the language and the page from which the request is sent (technical context, no personal data).

2.2 Technical data. The Site keeps server logs (IP address, user agent, page requested, date and time) for security and proper operation. If you accept audience measurement, pages viewed and referral source are added, with a truncated IP address. No advertising tool is deployed.

2.3 Agent trial. The trial takes place in BANANA-CONTENT, a STARTUP-UP IP application separate from the Site: the data you enter there is governed by its own privacy policy, presented at sign-up.

3. Why, and on what legal basis?

No automated decision with legal effect is made from this data. No data is used for marketing without your consent.

4. Who can access your data?

Your data is never sold or shared with third parties for commercial purposes. It is accessible, strictly within their duties:

• to the directors and team of STARTUP-UP IP in charge of reviewing your request and preparing the conversation;
• to our technical processors (infrastructure hosting), strictly as necessary and under confidentiality obligations;
• if you accepted audience measurement: to Google, acting as a processor, for the browsing data described on the Cookies page only.

5. Where is your data hosted?

Form data is stored on our infrastructure located in the European Union — in France, with failover in Germany — and encrypted in transit and at rest.

If you accept audience measurement, the corresponding data is processed by Google, which may involve a transfer outside the European Union covered by the European Commission’s standard contractual clauses. Declining audience measurement rules out any transfer: the Site performs no other.

The measures protecting our production platforms — including encryption with keys we hold — are described on the Trust page.

6. How long do we keep your data?

• Contact requests: 12 months from the request, then deletion, unless a contractual relationship is entered into — data is then kept for its duration and archived in accordance with Luxembourg legal obligations.
• Technical logs: 13 months at most, for security purposes.

7. Security

We implement appropriate technical and organisational measures to protect your data against loss, alteration, disclosure or unauthorised access:

• hosting in the European Union, encryption of data in transit and at rest, backups included;
• master encryption keys of production databases held by us, in a hardware security module separate from the data platform;
• strict access control and traceability of actions;
• confidentiality obligations for staff and partners.

8. Your rights

Under the GDPR you have the following rights:

• Right of access: confirmation that your data is processed and a copy of it.
• Right to rectification: correction of inaccurate or incomplete data.
• Right to erasure: deletion of your data.
• Right to restriction: freezing the use of your data.
• Right to object: to processing based on our legitimate interest.
• Right to portability: receiving your data in a structured format.
• Right to lodge a complaint: with the Commission nationale pour la protection des données (CNPD) of Luxembourg.

To exercise your rights, write to guillaume@startup-up.io, stating the nature of your request and attaching proof of identity. We respond within one month at most.

9. Cookies and audience measurement

The Site sets no cookies without your consent. With your consent, audience measurement (Google Analytics) tells us which pages are viewed, with a truncated IP address and no advertising features; the legal basis is then your consent (art. 6.1.a), which you can withdraw at any time through the “Manage cookies” link in the footer. Details on the Cookies page.

10. Changes

This policy may be amended to reflect legal, technical or organisational changes. The date of the last update appears at the top of the page.

11. Contact

For any question about this policy or your personal data: guillaume@startup-up.io.