Personal data

Privacy policy

Last updated : 27 September 2026

This policy explains how HUPSKALE processes the personal data collected on www.hupskale.com, in accordance with Regulation (EU) 2016/679 (GDPR) and French Law no. 78-17 of 6 January 1978 on data processing, data files and individual liberties.

Data controller

HUPSKALE, SASU with a share capital of 10,000 euros, 46 rue de Terssac, 81000 Albi, France, RCS Albi 980 185 938, represented by Emmanuel Rey, President. Contact: contact@hupskale.com.

HUPSKALE has not appointed a data protection officer, as this is not mandatory for its activity.

Data processed

• Contact form: first name, last name, email address and, if you provide them, phone number, company, profile (company, employee or individual, other) and the content of your request.
• Direct exchanges (email, phone): the information you choose to share.
• Technical connection data (IP address, browser type, connection logs), processed by the host to run and secure the site.

Purposes and legal bases

• Responding to your request and, where relevant, preparing a proposal: pre-contractual steps taken at your request (GDPR article 6.1.b) or, for a simple enquiry, HUPSKALE's legitimate interest in responding to requests addressed to it (article 6.1.f).
• Managing the relationship with prospects and clients: legitimate interest (article 6.1.f).
• Protecting the site and the form against abuse and automated submissions: legitimate interest (article 6.1.f).
• Meeting accounting and tax obligations once an engagement is agreed: legal obligation (article 6.1.c).

Your data is never sold, rented or transferred to third parties.

Recipients and processors

Only Emmanuel Rey, on behalf of HUPSKALE, has access to your requests. HUPSKALE uses the following processors, who act on its instructions and are bound by security and confidentiality obligations:

• Wix.com Ltd.: site hosting, receipt and storage of requests sent through the form, contact management;
• Google Ireland Limited: business email (Google Workspace), for exchanges by email.

Transfers outside the European Union

Wix.com Ltd. is established in Israel, which benefits from an adequacy decision of the European Commission (Decision 2011/61/EU of 31 January 2011). Service providers of Wix and Google may process some data in the United States; these transfers are covered by the safeguards provided for by the GDPR, namely the EU-US Data Privacy Framework for certified companies, or the standard contractual clauses adopted by the European Commission.

Retention periods

• Requests that do not lead to an engagement: three years from your last contact.
• Clients: for the duration of the engagement, then archived for the applicable limitation period (five years in civil and commercial matters); accounting records are kept for ten years (French Commercial Code, article L. 123-22).
• Technical connection data: period set by the host, limited to what is necessary for the security of the site and for its legal obligations.

Your rights

You have the right to access, rectify and erase your data, to restrict or object to its processing, and to data portability (GDPR articles 15 to 22), as well as the right to give instructions on what happens to your data after your death (article 85 of French Law no. 78-17 of 6 January 1978).

To exercise these rights, write to contact@hupskale.com or to HUPSKALE, 46 rue de Terssac, 81000 Albi, France. You will receive a reply within one month (GDPR article 12).

If, after contacting us, you believe your rights have not been respected, you may lodge a complaint with the French data protection authority, the CNIL: www.cnil.fr, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France.

Cookies and trackers

The site sets no advertising cookies and uses no tracker-based audience measurement. Only strictly necessary elements are used:

• technical session cookies set by the host (client-session-bind, server-session-bind), which keep browsing working and secure;
• when you use the contact form, a technical visitor identifier stored in your browser's local storage, which allows your request to be sent.

These elements are exempt from consent under article 82 of French Law no. 78-17 of 6 January 1978.

Security

The site is only accessible over an encrypted connection (HTTPS). Access to the requests received is restricted and protected by authentication.

Changes to this policy

This policy may be updated to reflect changes to the site or to regulations. The date of the last update appears at the top of the page.