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Last update4/25/2023

Ulule Privacy Policy 

When you browse the Ulule platform ("the Platform") and use its offered Services your personal data may be required and processed by our services.

The purpose of this data protection policy is to inform you regarding the Ulule platform’s processing of your personal data in order to operate its services. 

Who is the data controller?

The controller is the person who determines the purposes and means of a processing operation, i.e. the objective and the way in which it is carried out.

Ulule SAS: data controller for the use of the Platform and the Services offered on it

Ulule SAS, a simplified joint stock company with a share capital of 293,478 euros, registered under number 794 710 830 in the Paris Trade and Companies Register, having its registered office at 10 rue Penthièvre 75008 Paris, France, publishes the Platform. 

In this context, we collect and process your personal data as data controller when you browse the Platform and use its offered Services.

Ulule SAS and the Project Developers: co-responsible for the management of your Contributions on crowdfunding campaigns

Your personal data, collected for the purpose of making your Financial Contributions to the crowdfunding campaigns carried out on the Ulule Platform, are processed jointly by Ulule SAS, the company operating the Platform, and by each Project Sponsor to whom you contribute funds. 

Ulule SAS and the Merchants are jointly responsible for the processing of your Orders made in the store

Your personal data, collected for the purpose of fulfilling your Orders placed on Ulule Boutique, are processed jointly by Ulule SAS, the company operating the Platform, and by each Merchant with whom you place an Order.

Why do we process your data and on what legal basis?

According to the regulation, any processing of personal data must, in order to be lawful, be based on one of the legal grounds set out in Article 6 of the GDPR or in Article 9.2 of the GDPR if it concerns so-called sensitive data.

The table below sets out the different purposes for which we may process your data and the legal basis for doing so.

Goals

Legal basis

Access and navigation on Ulule

Pre-contractual measures 

Legitimate interests of visitors and users to have the Ulule.com site displayed in good conditions

Goals

Legal basis

Manage registered users of the Ulule.com site

Execution of the contract

Goals

Legal basis

Manage project proposals and fundraising pages on Ulule.com

Execution of contracts with project leaders (project management)

Ulule's legitimate interests (management of project proposals) and compliance with its legal obligations (reporting of projects)

For sensitive data communicated by project leaders or contributors: the processing is justified because it is data that are clearly made public by the data subjects (Article 9.2 e) of the GDPR)

Goals

Legal basis

Manage contributions and fund transfers related to fundraising activities on Ulule.com

Execution of contracts concluded with Contributors and Project Creators 

Ulule's legitimate interests (management of contributions) and compliance with its legal obligations (reporting of contributions)

For sensitive data communicated by contributors or revealed by the simple fact of contributing to a project: the processing is justified because it is data manifestly made public by the data subjects (Article 9.2 e) of the GDPR)

Goals

Legal basis

Combating money laundering and the financing of terrorism 

Compliance with Ulule's legal obligations

Goals

Legal basis

Retention of data related to account creation, connections to the Ulule platform, content creation, and payments made, in view of possible legal requests

Compliance with Ulule's legal obligations 

Goals

Legal basis

Management of your Orders placed through Ulule Boutique (contact with Merchants, delivery, customer service, after-sales service, etc.)

Execution of sales contracts

Goals

Legal basis

Realization of the training courses subscribed with the Ulule training organization

Execution of contract 

Goals

Legal basis

Manage the discussion forum

Legitimate interests of users to have a space dedicated to exchange and assistance

Legitimate interests of Ulule (relationship management and user support)

Compliance with legal obligations (moderation and management of content reports)

Goals

Legal basis

Detect, prevent and combat fraudulent and illegal activities on the Platform

Legitimate interest of Ulule SAS

Goals

Legal basis

Recording and processing of exchanges between customer service and the User by email and/or social networks and/or chat and/or telephone, in order to respond to customer requests, improve our Services and train our teams

Performance of the contract and Ulule's legitimate interest 

Goals

Legal basis

Analysis of your navigation within the Platform to improve our services

Legitimate interest of Ulule SAS

Goals

Legal basis

To carry out statistical studies on the use of our Platform and our services

Legitimate interest of Ulule SAS

Goals

Legal basis

Collection and management of feedback on products, services and customer service performance

Legitimate interest of Ulule SAS

Goals

Legal basis

Conducting surveys and polls to improve our Platform and Services

Legitimate interest of Ulule SAS

Goals

Legal basis

Commercial prospecting by email and/or SMS and/or other use of other channels

Legitimate interest of Ulule SAS

Goals

Legal basis

Personalized advertising based on your browsing experience, profile and on the information you provide us

Legitimate interest of Ulule SAS

Goals

Legal basis

Display of personalized content on the Platform based on your browsing, your profile and the information you have provided

Legitimate interest of Ulule SAS

Goals

Legal basis

Manage claims, pre-litigation and litigation

Legitimate interest or legal obligations of Ulule SAS, as the case may be

Goals

Legal basis

Management of requests for access, rectification and opposition rights

Legal obligation

The collection of payments made directly on the Ulule site is managed by our payment service providers (MANGOPAY and STRIPE), which are approved by the French banking regulator, theAutorité de Contrôle Prudentiel et de Résolution (ACPR). MANGOPAY or STRIPE process personal data for which they are responsible, as described in MANGOPAY's privacy policy and in Stripe's privacy policy

As part of their legal obligations to combat fraud, money laundering and the financing of terrorism, Ulule and MANGOPAY perform processing, including data combination, to help their employees determine the level of fraud risk associated with a payment or fundraising. Such processing may be used to support Ulule's or MANGOPAY's or STRIPE's decision to decline a payment. 

Which parts of your personal data do we process?

We collect and process:

  • the personal data you have entered on our Platform, in particular when creating your User Account (email, name, first name, address, password, telephone, etc.);

  • For users who participate in crowdfunding activities on the Platform: 

    • personal data related to fundraising that you organize via the platform (presentation of your project, identity information, banking information, etc.).

    • data relating to the contributions you make on a crowdfunding campaign presented on the platform (consideration chosen, amount paid, transaction number, delivery address, etc.);

  • For users who place an order on the Platform's shop area: 

    • order data (product purchased, transaction number, delivery address, etc.);

  • For the users of the Training area of the platform : 

    • the data that will allow us to examine the applications for the training courses offered by our training organization: motivation to join the program, professional project, updated CV, Pôle Emploi certificate (for job seekers) and the highest diploma. 

    • data allowing us to track course participants and their training activities within  our training programs: data relative to the courses followed, the exercises, the completed chapters, etc. 

    • data relating to your professional project, your qualifications, your financing preferences, your desire for long-term training, the obstacles in relation to the proposed solution, the estimated starting date, as well as, depending on your situation, the reason for rejection during telephone exchanges when you give us your contact details. This data is used for registration, consultation, use, completion, extraction and transmission to promote the career paths of our students.

    • feedback given regarding the training courses you have taken with us (in the context of satisfaction surveys). 

  • when you make a payment on the Platform, the data relating to your means of payment (credit card number, expiry date of the credit card, visual cryptogram) through a secure payment provider, which has sole access to these data;

  • data allowing us to respect our obligations in the fight against fraud, money laundering and the financing of terrorism as well as the management of your rights, pre-litigation and litigation. In this context, we are led to collect documents proving your identity; 

  • the data you send us when you contact the customer service via the Platform (content of the exchanges, nature of the complaint, etc.);

  • your connection and navigation data within the Platform (IP address, the value in euros and the composition of your basket, the products and pages you have consulted or searched for), the URL of the destination page and the URL of the website from which you arrived;

  • data relating to the consultation of emails that we send you for statistical purposes and commercial prospecting;

  • the information you provide when you leave a review on the Platform;

  • information about our advertisements that you see;

  • information you provide when you participate in promotions, contests or events that we organize.

All this data can be communicated to us by the user when he/she fills out our forms or during our exchanges. It may also be collected through computer tools such as cookies. For more information on the use we make of these tools, we invite you to read the cookie policy available on the following link Cookie Policy.

For the purposes described above and below, any personal data obtained with your consent may be combined with other personal data obtained previously.

Is the collection and processing of your data mandatory?

When you browse our Ulule.com website, access to certain features requires the creation of an account and therefore the communication of certain data. By creating an account, you become a user of the Ulule site, thus allowing you to become a project creator or contributor.

In order to create an account on the Ulule.com site, you must provide a first and last name or a username, your email address and a password. Otherwise, you will not be able to register.

As a simple visitor on Ulule.com, you will be able to consult certain sections of the site, but not to create a project or fundraiser, or contribute to existing projects and fundraisers. 

To create a project on the Ulule.com website, in addition to the information you must provide when creating your account, you must provide your first and last name, the name of your project, the category in which it falls, its description, your country of residence, your shipping address, your billing address, your goal, the amount and its currency, your bank account information, and any proof of identity necessary for identification, depending on whether you are an individual or a corporation.

In order to contribute to a fundraiser on the Ulule.com website, in addition to the information you must provide when creating your account, you must provide your first and last name, your nationality, your country of residence, your date of birth, your delivery and/or billing address (if the project creator has made this information mandatory in order to deliver the chosen rewards), your credit card payment information and any proof of identity necessary to identify you, depending on whether you are an individual or a corporation.

In order to make a purchase on the Ulule shop, you must enter your first and last name, your shipping address and your credit card payment information.

In order to complete a training course through the Ulule training organization, you must provide information about your identity, your motivations, your academic and professional background, your professional situation, your degree level, etc. 

If you do not provide this information, you will not be able to publish your fundraising campaign on Ulule.com, or to contribute to the projects on the Ulule.com website, to purchase items from boutique.ulule.com, or to subscribe to a training program offered by the Ulule training organization. 

These data supply requirements are contractual and/or regulatory in nature (especially for your proof of identity).

In order to exercise your rights as outlined in Section 8 of this Privacy Policy, proof of identity will be required. Failure to do so may prevent us from responding to your requests.

This requirement to provide data is regulatory in nature.

The collection of other data may be mandatory. For all data whose collection is mandatory, the contractual or regulatory nature of this obligation to provide, as well as the consequences of not providing the data concerned will be brought to your attention directly at the time of collection.

Sensitive and third party data - Important

Sensitive data

Using the platform to make comments, present your project, your user profile, etc., could make you reveal private and sometimes sensitive or very personal information about yourself (religious or philosophical beliefs, sexual orientation, political opinions, health status, etc.). 

We therefore advise you to be careful when using the platform in order to protect your privacy. 

  • User profile: the following fields in your user profile are optional and are intended to allow you to personalize your public user profile on Ulule: last name, first name, city, description, full description, social networks and websites.  Completing this information could make you reveal private and sometimes sensitive or very personal information about yourself (religious or philosophical beliefs, sexual orientation, political opinions, health status, etc.). Once the form is validated, this information will become public and accessible to all. We therefore advise you to protect your privacy and to be careful when completing your user profile. 

  • Project presentation and/or news related to the latter: when describing a project or publishing a news on your project page, you could reveal private and sometimes sensitive or very personal information about yourself (religious or philosophical beliefs, sexual orientation, political opinions, health status, etc.). If your project and/or news is published online, this sensitive information will become public and accessible to everyone. Ulule therefore urges you to protect your privacy by carefully selecting the information used when describing your project and/or when writing news on your project page.

  • Contributions to back a project: by default, contributions are made publicly visible via the list of contributors that is available on each project and via each contributor’s user profile. Contributing to a project could reveal private and sometimes sensitive or very personal information about yourself (religious or philosophical beliefs, sexual orientation, political opinions, health status, etc.). For example, contributing to a project that has a political dimension could indirectly reveal your political opinion. If you don't want your contribution to be publicly visible, Ulule allows you to make your contribution "anonymous" by going to your user profile / "my contributions" / "change address and preferences". Once you’ve made your contribution "anonymous" your identity will only be known by Ulule and by the project creator.) To make all your contributions "anonymous", go to your user profile / "preferences" / "privacy". 

  • Comments published on projects or any type of content published on the Ulule forum: if you choose to write a comment on a project, on a news published on a project, or if you decide to post any type of content on the forum, doing so could reveal private and sometimes sensitive or very personal information about yourself (religious or philosophical beliefs, sexual orientation, political opinions, health status, etc.). Once the comment or forum post form is validated, this sensitive information will become publicly visible to everyone. Ulule therefore urges you to protect your privacy by carefully selecting the information used when publishing any comments or posts on project pages, news and/or on our forum.

Third party data

When writing a project presentation or a news item, you may have to communicate to us and to the public information concerning third parties (your collaborators, a person whom your project aims to help, etc.). 

The processing of these data must be done in compliance with the regulations. 

You must verify that you have the right to communicate this data to Ulule and to the public (for example, by having the written consent of any third parties) and you must also communicate to them the information regarding Ulule's treatment of their data contained in this Privacy Policy.   

How long do we keep your personal data?

Data concerned

Shelf life (with exceptions*)

Data related to the management of visitors and users who have neither contributed to a fundraising event, nor proposed a fundraising event, nor made a purchase from the store, nor subscribed to a training course. 

You are an active user (logging in to your account): for the duration of your account, then 3 months from the request to close your account (except for data required for commercial prospecting which will be kept for 3 years)

You are an inactive user: after 3 years without logging in to your account, we will ask you if you wish to keep your account. If you wish to close your account, your data will be deleted within 3 months of your request. If you do not respond, your data will be deleted within 3 months of our request.

Data concerned

Shelf life (with exceptions*)

Data related to project management and fundraising on Ulule.com 

You are an active project owner (logging in to your account): for the duration of your account, then 5 years from the date of the request to close your account (due to the legal prescription)

You are an inactive project owner: after 5 years without logging in to your account, we will ask you if you want to keep your account.

If you wish to close it, your data will be deleted 3 months after your request.

If you do not respond, your data will be deleted 3 months after our request

Data concerned

Shelf life (with exceptions*)

Data related to the management of contributions and fund transfers on Ulule.com 

You are an active contributor: for the duration of your account, then 5 years from the date of your account closure request (to respect the legal prescription)

You are an inactive contributor: after 5 years without logging in to your account, we will ask you if you want to keep your account.

If you wish to close it, your data will be deleted 3 months after your request.

If you do not respond, your data will be deleted 3 months after our request

Data concerned

Shelf life (with exceptions*)

Data relating to orders placed in the shop area 

Retention for 3 years from the end of your commercial relationship with Ulule. The end of your commercial relationship corresponds to your last Order on the Platform or, if this date is later, to your last contact with Ulule (i.e., as of your last connection to your Personal Account/Guest Account or your last phone call/email/chat with Ulule)

Data concerned

Shelf life (with exceptions*)

Data specifically related to training activities 

Data related to the management of applications for training: 3 years from the date of application. 

Data related to billing and analysis of sessions attended by students for billing purposes: 10 years from the close of the current fiscal year

Data concerned

Shelf life (with exceptions*)

Data related to the management of the forum 

You are an active user of the forum: for the duration of your account, then 5 years from the request to close your account (to respect the legal prescription)

You are an inactive user of the forum: after 5 years without logging in to your account, we will ask you if you want to keep your account. If you want to close it, your data will be deleted 3 months after your request. If you do not answer, your data will be deleted 3 months after our request.

Data concerned

Shelf life (with exceptions*)

Banking data

Deletion as soon as the transaction is completed, unless you have given your consent for retention, and 15 months for evidentiary purposes in the event of a dispute about the transaction

Data concerned

Shelf life (with exceptions*)

Content reporting

1 year from the day of creation of the reported content

Data concerned

Shelf life (with exceptions*)

Comments or project descriptions

Deleted upon account closure or anonymized upon request by the User concerned

Data concerned

Shelf life (with exceptions*)

Review published on a product page of the store

Published on the Platform until you request their removal.

Data concerned

Shelf life (with exceptions*)

Commercial prospecting

3 years from the end of our contractual relationship, unless otherwise stated

Data concerned

Shelf life (with exceptions*)

Performance statistics

No duration when our statistics are made on anonymous data

Data concerned

Shelf life (with exceptions*)

Cookies and tracers

13 months after the first deposit in your terminal equipment

Data concerned

Shelf life (with exceptions*)

Data relating to our obligations to combat fraud, money laundering and the financing of terrorism

5 years from the termination of the contractual relationship or the closing of your account with respect to identity data and documents. 

5 years from the execution of the financial operation in question for documents and information relating to the operations carried out.

Data concerned

Shelf life (with exceptions*)

Data related to the management of pre-litigation and litigation

In case of pre-litigation, deletion as soon as the dispute is settled amicably or the legal action is time-barred.

In the event of litigation, removal when appeals are no longer possible against the decision made to enforce it.

Data concerned

Shelf life (with exceptions*)

Information about your instructions concerning the fate of your data after your death

As long as the data concerned by the directives is kept.

Data concerned

Shelf life (with exceptions*)

Data relating to the exercise of your rights (point 5)

5 years from the date you exercise your right.

Data concerned

Shelf life (with exceptions*)

Copy of the proof of identity communicated in the context of the exercise of your rights

1 year from the date of receipt by Ulule.

At the end of the periods listed above, your data will either be deleted or anonymized.

*As an exception to the preceding paragraphs, in the event of litigation, all or some of your data may be stored for a longer period of time if it is useful for the said litigation.

To whom is your personal data transmitted?

To our service providers

Your personal data is transmitted to the service providers we use to subcontract all or part of the processing we carry out with your data, including:

  • for the operation of the Platform and its Services (sending emails and SMS, phone calls, etc.): your data is transmitted to specialized technical service providers;

  • for the payment of your Contributions and your Orders: your data is transmitted to providers specialized in banking transactions (such as banks and payment service providers);

  • for customer service management: your data is transmitted to our partners and technical service providers;

  • for the management of commercial prospecting: we transmit your data to service providers specialized in commercial prospecting.

The subcontractors we use have the guarantees required by the applicable regulations on the protection of personal data. They only have access to the personal data necessary for the performance of their services and are not authorized to process your personal data for other purposes. We have signed agreements with each of them to guarantee the security and integrity of your personal data and its processing in compliance with the applicable regulations.

To Project Creators and their carriers

The data necessary for the management of your Contributions are transmitted to the Project Creators of the projects you have backed so that they can deliver, at the end of the campaign, the promised rewards as part of the crowdfunding campaign.

This same data can also be transmitted to the carrier selected by the Project Creator.

To the merchants of the Platform and their carriers

The data required to manage your Orders made within Ulule Boutique are transmitted to the Merchants from whom you have purchased a Product through the Platform.

Your personal data used to ensure the delivery of your Order is also transmitted to the carrier selected by the Merchant. 

To business partners of operations in which you participate

In cases where you have indicated your willingness to participate in a specific partner operation, for example as a project creator, if you apply for a prize or a partner offer directly managed by Ulule, we must communicate your contact information to the partner so that the partner can award you the promised prize if you are selected as its winner, or provide you with the promised offer if you are eligible. 

To the authorities

Your personal data may be disclosed to authorities pursuant to a law, regulation or decision of a competent regulatory or judicial authority.

In general, we undertake to comply with all legal rules that may prevent, limit or regulate the dissemination of information or data and in particular to comply with the applicable data protection regulations.

To Users

When you complete your user profile, the following fields in your user profile are optional and intended to allow you to customize your public user profile on Ulule: last name, first name, city, description, full description, social networks and websites. The contents of these fields are public and accessible to website visitors. 

When you post a comment on a crowdfunding campaign, the first and last name or username linked to your user account, as well as the content of your comment, are accessible website visitors. 

When you raise funds via Ulule, once published on the platform, all of the project presentation fields and news related to your campaign are public and accessible to website visitors. 

When you contribute to a crowdfunding campaign via Ulule, by default, your contributionsare made publicly visible via the list of contributors that is available on each project and via each contributor’s user profile (username or first and last name of the contributor if entered in his or her public profile, chosen counterparty). This information is accessible to website visitors. 

If you don't want your contribution to be publicly visible, Ulule allows you to make your contribution "anonymous" by going to your user profile / "my contributions" / "change address and preferences". Once you’ve made your contribution "anonymous" your identity will only be known by Ulule and by the project creator.) To make all your contributions "anonymous", go to your user profile / "preferences" / "privacy". 

When you post a review on a product page of the store, the first and last name or the username that you entered and your review are accessible to all website visitors.

What are your rights regarding your personal data and how can you exercise them?

What are your rights?

You have the right to obtain from our services:

  • confirmation that your personal data is or is not being processed, and if necessary, access to it;

  • updating and correcting your personal data if inaccurate or incomplete;

  • under certain conditions, the removal of your personal data;

  • under certain conditions, the limitation of the processing of your personal data;

  • portability of your personal data;

  • to organize the fate of your personal data in case of death (conservation, deletion, or communication to a designated person).

You also have the right to object, under certain conditions, to the processing of your personal data.

You can also, at any time:

  • withdraw your consent to the processing of your data implemented by our services for purposes of behavioral advertising, analysis of navigation and audience measurement by setting your cookies;

  • object to the processing of your data for commercial prospecting purposes :

  • by email, by clicking on the unsubscribe link available in our promotional emails and newsletters;

  • by text message, by sending "STOP" to the number indicated in the text message received.

We also remind you that you have the right to lodge a complaint with the CNIL (National Commission on Informatics and Liberty) if you feel that your rights have not been respected.

For more information on your rights regarding the use and processing of your personnal data, please visit the CNIL website: www.cnil.fr.

How to exercise your rights?

For any requests please contacts us :

  • by email at [email protected] 

  • by postal mail (with an attached copy of your ID) to the following address Ulule  To the attention of the Data Protection Officer (DPO) 10 rue de Penthièvre 75008 Paris FRANCE

Our services will get back to you as soon as possible and at the latest within one month of receiving your request.

Is your personal data transferred outside the European Union?

Some of the processing operations that we entrust to our subcontractors are carried out outside the European Union. Agreements have been signed with each of these service providers to ensure that all personal data transfers are carried out securely and in compliance with the applicable data protection regulations.

Contact the Data Protection Officer

If you have any questions about the processing of your personal data or if you wish to exercise your rights regarding your data, the Data Protection Officer (DPO), appointed by Ulule SAS, can be contacted:

  • by email at [email protected] 

  • by postal mail (with an attached copy of your ID) to the following address Ulule  To the attention of the Data Protection Officer (DPO) 10 rue Penthièvre 75008 Paris France