Privacy policy

Personal data protection charter

This Privacy Policy explains how ComeUp handles the personal data of members and visitors of the Site.

We pledge to only collect the information necessary to provide you with a quality service, to guarantee its confidentiality and security, including when using service providers, and to facilitate the exercise of your rights over your data following applicable data protection laws in all countries where we operate, including the European Union's General Data Protection Regulation 2016/679 (the "GDPR").

Data processing manager: 5EUROS SAS, publisher of the ComeUp.com website

The terms “ComeUp”, “platform” or “we” refer to the company 5EUROS, SAS registered with the RCS of Reims under the number 829285451, whose registered office is located at Centre d'Affaires Reims - Bezannes 7 rue Pierre SALMON 51430 BEZANNES.

5EUROS is responsible for the processing operations described in this Charter.

Data Protection Officer contact details

If you have any questions about the protection of your personal data at ComeUp, or if you wish to exercise your rights, please contact our Data Protection Officer:

by email to: [email protected]

by postal mail to: 5EUROS, Centre d'Affaires Reims - Bezannes 7 rue Pierre SALMON 51430 BEZANNES

Effective date and modification

This Data Protection Policy automatically takes effect for all Users as of 10/01/2024.

We reserve the right to modify this Privacy Policy at any time. The most current version of the Charter will govern the use of your data and will be available at the following address: https://comeup.com/en/privacy

In the event of a substantial modification to the present policy, you will be notified via the ComeUp.com notification center.

If you continue to use the platform after these changes have been made, you will be deemed to have accepted these changes.

1. The data we process, for what purposes, and on what basis

In general, we use your data to offer you our services following our Terms of Service. Some data may be processed based on your consent, for our legitimate interests, or to comply with a legal obligation.

Category of concerned individuals: Sellers

We process various categories of personal data related to you:

Personal information: last name, first name, place and date of birth, nationality, telephone number, email address, location, profile photo, language;

Professional information: structure and legal form, legal documents, VAT number, identity of company's legal representative, list of effective beneficiaries, past professional experience, portfolio, skills, training, services;

Information generated by your use of ComeUp: emails on our support, cookies and browsing data, transaction details, exchanges on the integrated messaging system, information related to services provided.

Verification of legal documents (personal and/or professional identity). Allow a professional or individual seller to sell on ComeUp

Seller profile display

Enable contacts and sales to be made

Optimization of the visibility of services on the platform. Calculation of average response time, sales, cancellation rate before and after order acceptance, and average rating

The use of images and service descriptions for advertising purposes to promote the platform, services, and sellers

Recording and preparation of coaching sessions to help sellers grow their business

Category of concerned individuals: Buyers

We process various categories of personal data related to you:

Personal information: last name, first name, date of birth, email address, profile photo;

Company information: billing details, address, and email address

Information generated by your use of ComeUp: emails sent to our teams, cookies and browsing data, order details, reviews, data relating to the use of the messaging system (conversation content)

To display services adapted to each customer to optimize conversion

Allow to leave a review/comment at the end of an order

Category of concerned individuals: Members

As a reminder, members are the sellers and buyers registered on ComeUp; the table below shows the treatments that concern both sellers and buyers.

In general, to enable the implementation of the Services offered by ComeUp

To provide order-related documents: invoices, payment receipts, refunds…

Payment of orders directly via ComeUp and our partners PayPal/Braintree. Management of financial flows via the platform, including invoicing orders and payments

To send relevant communications and notifications tailored to platform usage

Securing the website and its various domains

Moderation to combat fraud and spam

Platform intervention in the event of a dispute

Providing secure instant messaging, reading of exchanges if necessary to combat fraud and assist Users

Development of services and functionalities, producing statistics on the use of services and monitoring the audience for website pages, as well as tracking commercial activities and user behavior on the platform

To respond to requests to exercise the law

2. The use of AI at ComeUp

The algorithm used to highlight ComeUp services in categories, in search, and on the homepage is based on all sales data from sellers and their activity on the site (response time, connection, cancellation rate, sales, average basket, type of Plus plan, individual or professional status, etc.).

We may also use artificial intelligence systems to guarantee safety and security of the platform (e.g. robot detection, fraud, and spam prevention).

We also use artificial intelligence (chatGPT) to make an initial reading of the services received to see if they comply with French law and our basic rules and to sort them automatically into our various categories.

To learn more about this subject, please consult the following articles:

How are services ranked in categories, in search, and on the homepage: https://support-en.comeup.com/article/1499-how-are-services-ranked

3. Our Cookie Policy

We use cookies for authentication, security, site integrity, localization cookies, cookies related to site and service functionalities, as well as cookies for analysis, search, and advertising.

When you first connect to the platform, you have the option of accepting, refusing, or customizing your cookie preferences, and you can change these choices at any time.

4. Data recipients and possible transfers

We are the recipients of the personal data collected via the platform and use it only for the purposes explained above. Under no circumstances do we sell this information to third parties.

4.1 With our investors, accountants, and auditors

We may share information about Users to respond to requests for information from our investors, accountants, and auditors, in particular in connection with any fundraising or verification of the use of funds raised, in compliance with applicable regulations.

4.2 With authorized third parties

We may share your information if reasonably necessary to satisfy a legal or regulatory obligation, legal process, or administrative request, to protect the safety of any individual, to address any fraudulent issues, security, or technical issues, or to protect the rights of Users.

4.3 With trusted service providers

All our servers on which your data is stored are located in Europe.

On very rare occasions, some of our service providers whose principal place of business is in a country outside the European Union may need to transfer your data to that country. In such cases, we first check that they comply with their obligations in terms of personal data protection, and implement a “transfer tool” such as standard contractual clauses to guarantee an equivalent level of protection for your personal data as that offered within the European Union.

You will find below a list of ComeUp's service providers, the purpose for which they operate, their location, and the appropriate safeguards adopted where applicable.

Service provider name Purpose Concerned individuals Data localization
Braintree
https://www.paypal.com/fr/webapps/mpp/ua/privacy-full?locale.x=en_FR&_ga=2.89458779.1188845927.1726671913-177565946.1726671913 Platform for payment by credit card, PayPal, Google Pay, Apple Pay.
Verification that financial flows passing through the platform do not originate from money laundering or are not used to finance terrorism. Sellers and Buyers United States (PayPal group)
Hyperwallet https://www.hyperwallet.com/privacy-policy/ A platform for sellers to withdraw their earnings. Verification that financial flows do not originate from money laundering or terrorist financing, and verification of sellers' identity. Sellers United States (PayPal group)
Mailjet https://www.mailjet.com/legal/privacy-policy/ Platform to send emails Sellers and Buyers Sweden
Calendly https://calendly.com/legal/privacy-notice Schedule appointments for sales coaching Sellers France
Helpscout https://www.helpscout.com/company/legal/privacy/ Managing customer service Sellers, Buyers, and visitors United States
Plausible https://plausible.io/privacy Visits and conversions statistics Sellers, Buyers, and visitors Estonia
Standard facile https://aircall.io/privacy/ Telephone call tool Sellers France
Looker https://looker.com/trust-center/privacy/policy/ Data analysis Sellers, Buyers, and visitors Netherlands
Trustpilot https://legal.trustpilot.com/for-reviewers/end-user-privacy-terms Collecting feedback from platform users Sellers, Buyers, and visitors Denmark
Amazon AWS https://aws.amazon.com/privacy/ Data hosting Sellers, Buyers, and visitors United States
OneSignal https://onesignal.com/ Mobile notification management Vendeurs et Clients United States
OVH https://www.ovhcloud.com/en-gb/personal-data-protection/ Website and database hosting Sellers, Buyers, and visitors France
Google tag manager https://policies.google.com/privacy?hl=en Managing Google tracking tags Sellers, Buyers, and visitors United States
Facebook https://www.facebook.com/policies_center Advertising tracking Sellers, Buyers, and visitors United States
Cookies yes https://www.cookieyes.com/privacy-policy/ RGPD cookies consent banner Sellers, Buyers, and visitors United kingdom
Twillio https://www.twilio.com/en-us/legal/privacy Audio, video and screen-sharing communication between sellers and buyers Sellers and Buyers United States
Facturation.pro https://www.facturation.pro/a-propos/privacy Billing tool Sellers and Buyers France

5. Data security

We attach the utmost importance to the security and confidentiality of our Users' data.

That is why we implement appropriate technical and organizational measures to ensure the constant security, confidentiality, integrity, availability, and resilience of our information system and your data, in order to protect them against destruction, loss, alteration, unauthorized disclosure, or unauthorized access.

In particular:

6. Your rights

You can find a description of each of your rights and how to exercise them in the “Your rights” section of this Data Protection Center.

Under data protection regulations, you have the following rights:

6.1 Right of access - article 15 of the RGPD

You have the right to access the data that ComeUp processes about you. This enables you to know what information we hold about you and, if you wish, to request a copy, subject to respect for the rights of third parties whose personal data may appear in the information concerning you.

6.2 Right to rectification - Article 16 of the RGPD

You may ask ComeUp to correct your personal data if it is inaccurate, obsolete or incomplete. This request must be justified.

To facilitate the exercise of this right, we invite you to modify your information directly from your Account.

If you believe that other data concerning you requires correction or completion and you are unable to do so yourself, please inform us by writing to [email protected].

6.3 Right to erasure

You have the right to request the deletion of your personal data as soon as possible unless a legitimate interest or legal obligation requires us to retain it.

For security reasons and to avoid unintentional deletion of your account, we invite you to carry out this procedure yourself by logging into your account using the following link: https://comeup.com/en/settings/my-account.

Please note that search engines and other third parties may continue to retain copies of your public information, even after you have removed your data from the ComeUp site or deleted your account. ComeUp cannot be held responsible for such processing by third parties.

6.4 Right to restriction of processing - Article 18 of the RGPD

You can ask ComeUp to restrict the processing of your data (make your profile temporarily invisible on the site, for example) in the following cases:

If we decide to lift the restriction on the processing of your personal data, we will inform you accordingly.

6.5 Right to object - article 21 of the RGPD

You have the right to object to the use of your data if both of the following conditions are met: (i) you can justify reasons relating to your particular situation and (ii) the legal basis for our use is the pursuit of a legitimate interest.

ComeUp will then cease processing your data unless there are compelling legitimate grounds for further processing, or if this is necessary to establish, exercise, or defend legal claims.

For example, you can opt-out of receiving communications, including commercial communications, from ComeUp. To do so, an unsubscribe link is included in every e-mail we send, and you can also manage your notification preferences here: https://comeup.com/en/settings/notifications.

6.6 Right to data portability - article 20 of the RGPD

You have the right to request the portability of your data at any time. This means that we undertake to provide you, within a reasonable time and in a machine-readable format, with the data you have provided to us, whether directly shared by you or generated by your activity on the platform.

6.7 Right to withdraw consent - Article 7 of the RGPD

When the processing of your personal data is based on your consent, you may withdraw this consent at any time. This will not affect the lawfulness of any processing carried out prior to such withdrawal.

6.8 Right to decide what happens to your data after your death - article 85 of the French Data Protection Act (Loi informatique et libertés)

You have the possibility of giving us instructions on how your personal data should be stored, deleted, or communicated after your death.

6.9 Right to lodge a complaint with a supervisory authority

In the event of an unresolved dispute, you can contact the relevant data protection authority to lodge a complaint.

The competent supervisory authority for matters related to ComeUp, including a user complaint, is the Commission Nationale de l'Informatique et des Libertés (CNIL).

Website: https://www.cnil.fr/en

You can also contact the data protection authority in your country of residence, employment, or nationality, which will forward your request to the CNIL.

Directory of EU data protection authorities: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.