Introduction

("we", "our" or "Up2Victory") is committed to protecting the privacy of users of its website and services. This privacy policy explains how we collect, use, and protect your personal data in accordance with the General Data Protection Regulation (GDPR).

Data Controller

The data controller is:

Data Collected

We collect the following data:

Identification Data

• First and last name
• Email address
• Phone number
• Business address

Connection Data

• IP address
• Browser type
• Connection dates and times
• Pages visited

Payment Data

• Billing information (processed by Stripe)
• Transaction history

Player Data (our customers' clients)

• Email address
• Game participation and winnings
• Newsletter consent

Processing Purposes

Your data is collected for:

• Managing your account and providing our services
• Processing your payments and billing
• Sending you account-related communications
• Improving our services and your user experience
• Complying with our legal and regulatory obligations
• Sending you marketing communications (with your consent)

Legal Basis for Processing

• Contract performance: to provide our services
• Consent: for marketing communications and cookies
• Legitimate interest: to improve our services and prevent fraud
• Legal obligation: to comply with tax and accounting obligations

Data Retention Period

We retain your personal data for the duration of your subscription and:

• 3 years after the end of the business relationship for prospecting data
• 10 years for billing data (legal requirement)
• 1 year for connection logs

Data Sharing

Your data may be shared with:

• Stripe: for payment processing
• Our hosting provider: for secure data storage
• Email services: for sending communications

We never sell your data to third parties.

Your Rights

In accordance with the GDPR, you have the following rights:

• Right of access: obtain a copy of your data
• Right to rectification: correct your inaccurate data
• Right to erasure: request the deletion of your data
• Right to data portability: receive your data in a structured format
• Right to object: object to the processing of your data
• Right to restriction: request the restriction of processing

To exercise these rights, contact us at: dpo@up2victory.com

Cookies

Our website uses cookies for:

• Essential cookies: necessary for the website to function
• Session cookies: to maintain your session
• Analytics cookies: to measure audience (Google Analytics)

You can configure your browser to refuse cookies or be notified when a cookie is sent.

Security

We implement appropriate technical and organizational measures to protect your data against loss, unauthorized access, disclosure, or destruction. These measures include SSL encryption, access restrictions, and staff training.

Modifications

We may modify this privacy policy at any time. In case of a substantial modification, we will notify you by email or via a notification on our website.

Contact and Complaints

For any questions regarding this policy or your personal data:

• Email: dpo@up2victory.com

You may also file a complaint with the relevant data protection authority: www.cnil.fr