Transparency and data protection

Privacy Policy

This policy explains the limited information processed through the public UpSkillCorp website and the internal UpSkillCorp Analytics tool, which UpSkillCorp uses to report on and publish content to its own Pinterest business account.

Effective date: 28 September 2026

1. Who is responsible for processing

The data controller is Laszlo Feher, operator of UpSkillCorp in France.

Designated public contact and privacy-rights address: info@upskillcorp.fr.

2. Scope of this policy

This policy covers:

3. Information processed

Public website

The website does not provide user accounts or a contact form and does not include advertising pixels, third-party audience analytics, embedded social widgets or remote fonts. The hosting infrastructure may create technical server logs containing information such as an IP address, date and time, requested path, response status, browser user-agent and diagnostic security events.

Direct email

If a person chooses to send an email, the controller receives the sender's email address and whatever identity, message content or attachments the sender voluntarily provides. Providing information beyond what is needed for the request is discouraged.

Internal own-account tool

The internal app processes data available through authorised Pinterest API access for the UpSkillCorp account only, with the operator's authorisation via Pinterest OAuth. This includes Board and Pin identifiers, content metadata, publication dates and aggregate performance metrics such as impressions, saves and outbound clicks. The app also creates Pins on UpSkillCorp's own account: each Pin draft (image, title, description, link and board) is reviewed and approved individually by the operator before it is published, and each approval decision is logged with its date. The app does not access other users' Pins, Boards or accounts, does not manage advertisements and never collects account passwords.

4. Purposes and legal basis

Processing is limited to the purposes below and is based on the operator's legitimate interests:

These interests are pursued with a deliberately limited website, minimum API permissions, no public user accounts and no access to other users' Pins or Boards. The public website does not use consent as a basis because it does not set non-essential cookies or operate a consent-based collection feature.

5. Retention

Information is deleted or anonymised when it is no longer required, unless a longer period is required by law or needed for the establishment, exercise or defence of legal claims.

6. Recipients and service providers

Access is limited to the UpSkillCorp operator and service providers that are necessary to run the website and app. The public site is hosted by OVH SAS. Pinterest provides the external account and API services used by the internal app. Information is not sold and API information is not shared with advertising services or unrelated third parties.

Providers may process limited information under their own terms and privacy notices. Their role, location and contractual safeguards must be reviewed whenever the service configuration changes.

7. International transfers

The public website does not transmit visitor information to Pinterest. The internal app may communicate with Pinterest systems under Pinterest's terms and privacy documentation. If a service provider processes information outside the European Economic Area, the processing must be covered by the safeguards required by applicable data-protection law. The operator will review this notice if the providers or actual data flows change.

8. Security

Reasonable technical and organisational measures are used to protect information, including encrypted HTTPS transport for the public site, restricted server access, minimum API permissions, private credential storage, access tokens stored with restricted file permissions on a private server, security updates and access logging. No internet transmission or storage system can be guaranteed to be completely secure.

9. Rights

Subject to applicable law, individuals may have rights of access, rectification, erasure, restriction, objection and data portability. Because the processing described here relies on legitimate interests, individuals may also object to it. The designated request address is info@upskillcorp.fr. Additional information may be requested only where reasonably necessary to verify identity.

Individuals may also lodge a complaint with their competent data-protection authority. In France, this is the CNIL.

10. Cookies and similar technologies

The current public website does not set cookies or use browser storage, advertising tags or third-party analytics. It therefore does not display a cookie-consent banner. If non-essential cookies or similar technologies are added later, this policy and the consent mechanism must be updated before those technologies are enabled.

11. Changes to this policy

This policy may be updated to reflect changes in the website, the app, providers or applicable requirements. The effective date at the top of the page will be updated when a material revision is published.