Personal data protection policy

Our company has set up the Personal Data Protection Policy in order to inform individuals who use our “ARTYBOT” application and resort to the associated services, about the personal data concerning them that our company is likely to collect and process in this context.

This Policy is in line with the provisions of Regulation (EU) 2016/670 of the European Parliament and of the Council of 27 April 2016 (“General Data Protection Regulation” or “GDPR”) and Law N°78-17 of 16 January 1978, as amended, relating to information, files and freedoms (Loi Informatique et Libertés “) and its implementing texts.

1. What data do we collect?

In the course of operating our application and providing the associated services, we may collect and process personal data about users, which includes information about:

  • The precise geolocation of the mobile device used by the User.

2. On what legal grounds do we process your data?

We collect and process personal data as follows:

  • For needs of execution of the services to which the users resort via our application.
  • For the purposes of our legitimate interests, such as prospecting and animation, as well as managing the relationship with our prospects and users of our application.
  • To comply with our legal and regulatory obligations and to ensure the defence of our rights; and/or
  • On the basis of the consent of the natural persons concerned (e.g. for the geolocation of users).

3. For what purposes do we process your data?

We collect and process personal data for the following purposes:

  • For geolocation: the classification of the routes according to the initial position of the user and to guide him/her on the paths of the route that the user chooses to select.

4. Who we share your data with

No data is stored by the company Up culture SAS. All the data collected via geolocation is only transmitted to the Google Maps service in order to guide the user in the spaces. No data is stored over time.

We do not transfer any personal data collected outside the European Union.

5. How long do we keep your data?

We only keep the personal data collected for the time necessary for the purposes for which they were collected in compliance with the regulations in force and without prejudice to the legal obligations of conservation and limitation periods.

6. How do we ensure the security of your data?

Our company implements appropriate technical and organizational measures to ensure the security of the data collected and compliance with its obligations under the applicable regulation. In particular, our company implements means to ensure the confidentiality, integrity, availability and ongoing resilience of processing systems and services.

7. What are the rights of the persons concerned?

All natural persons whose personal data are processed by us have the following rights, as recognized by the applicable regulation:

  • A right of access to his data as well as to information relating to the processing of his data (Art. 15 of the RGPD; Art. 49 of the Data Protection Act).
  • A right to rectify inaccurate or incomplete data (Art. 16 of the RGPD; Art. 50 of the Data Protection Act).
  • A right to erasure of data (Art. 17 of the RGPD; Art. 51 of the French Data Protection Act).
  • A right to limit the processing of one’s data (Art. 18 of the RGPD; Art. 53 of the Loi Informatique et Libertés).
  • A right to data portability (Art. 20 of the RGPD; Art. 55 of the Loi Informatique et Libertés).
  • A right to object to the processing of his data (Art. 21 of the RGPD; Art. 56 of the Data Protection Act).
  • Where data processing is based on consent, the right to withdraw consent at any time (Art. 7.3 GDPR)
  • The right to define directives relating to the conservation, deletion and communication of personal data after one’s death (art. 85 of the Loi Informatique et Libertés).

Any person concerned may, by proving his or her identity, exercise his or her rights at any time by sending an e-mail to

The person concerned has the right to lodge a complaint with the National Commission for Information and Liberties (CNIL) concerning the processing of his/her personal data(

8. Identity of the data controller

The person in charge of processing is the company Up culture SAS, a simplified joint stock company with a share capital of 8000 €, whose head office is located at 62 boulevard Gambetta 10000 Troyes, registered in the TROYES trade and companies register under the number: 884 018 391

President: Caroline Rosnet

Telephone: 06 11 01 04 25

Offices : 62 boulevard Gambetta 10000 Troyes

E-mail address: