Privacy Policy | Startup Académie

Article 1: Data Controller

The controller of the personal data collected via the Startup Académie site and services is:

Company: Adminmarketplus LLC (trade name: STARTUP ACADEMIE)
Legal form: Limited Liability Company (LLC), New Mexico, USA
Address: 1209 Mountain Rd Pl NE, Ste R, Albuquerque, NM 87110, USA
Entity ID (New Mexico): 0008070475
Contact e-mail: contact@startupacademie.com

For any question relating to your personal data or to exercise your rights, you can contact Adminmarketplus LLC at the e-mail address contact@startupacademie.com or by post at the address above.

Article 2: Data Collected

2.1: Data collected directly from you

Identification data: surname and first name of the learner and of the legal representative, date of birth
Contact data: e-mail address, telephone number, postal address
Location data: country of residence, city, time zone
Payment data: billing details (banking data is processed exclusively by our secure payment provider and is never stored by Adminmarketplus LLC)
Educational data: learner's level, exercise results, progress through the modules, session history
Communication data: messages exchanged via our customer service or the class platforms

2.2: Data collected automatically

Connection data: IP address, browser type, operating system, pages visited, length of visits
Cookies and trackers: see Article 8 below

2.3: Data we never collect

Adminmarketplus LLC never collects so-called "sensitive" data within the meaning of the GDPR (ethnic origin, political opinions, health data, biometric data, etc.), except with explicit consent and where absolutely necessary in a specific educational context.

Article 3: Purposes of Processing

Your personal data is collected and processed for the following purposes:

Managing enrollments and creating user accounts on the Startup Académie platform
Delivering online and in-person courses, and monitoring the learner's educational progress
Managing payments, invoicing and accounting
Communicating with the Client regarding the performance of the contract (confirmations, reminders, class information, schedule changes)
Continuously improving our services, our platform and our educational content
Sending commercial communications and information about our new courses (only with your prior consent)
Handling support requests, complaints and disputes
Complying with our legal and regulatory obligations (accounting retention, responding to requests from authorities, etc.)
Securing our platform and preventing fraud

Article 4: Legal Bases for Processing

Each processing of your data is based on a specific legal basis, in accordance with Article 6 of the GDPR:

Performance of the contract (Art. 6.1.b GDPR): processing necessary for delivering the courses, managing your account and payment
Legitimate interest of Adminmarketplus LLC (Art. 6.1.f GDPR): improving our services, platform security, fraud prevention, internal statistics
Consent (Art. 6.1.a GDPR): sending commercial communications, placing non-essential cookies, processing the data of minors under 16
Legal obligation (Art. 6.1.c GDPR): retaining billing data for 10 years, responding to requisitions from authorities

Article 5: Retention Periods

Your data is kept for set periods depending on its nature and purpose:

Data category	Retention period
Account and course data	Duration of the contractual relationship + 5 years
Billing and accounting data	10 years (legal obligation)
Connection data and technical logs	12 months maximum
Cookies and browsing data	13 months maximum
Marketing prospecting data	3 years from the last contact
Support and complaints data	5 years from closure

At the end of these periods, your data is deleted or anonymized permanently and irreversibly.

Article 6: Recipients of the Data

Your personal data is processed internally by the authorized teams of Adminmarketplus LLC. It may also be transmitted to the following categories of recipients, to the extent strictly necessary:

Startup Académie instructors and educational staff, for the purpose of delivering the classes
Technical service providers (hosting, video call tool for live classes, communication tools), bound by GDPR-compliant data processing agreements
Secure payment provider (only the data necessary for the transaction)
E-mail and communications delivery provider
Competent authorities (CNIL, judicial authorities, tax authorities) where required by law

Adminmarketplus LLC never sells your personal data to third parties for commercial purposes.

Article 7: International Data Transfers

As part of its worldwide activity, Startup Académie may transfer your personal data to countries located outside the European Economic Area (EEA), in particular to host the class platforms or to manage international instructors.

These transfers are subject to appropriate safeguards, in accordance with Chapter V of the GDPR, in particular:

Standard Contractual Clauses (SCC) approved by the European Commission
The use of countries covered by an adequacy decision of the European Commission
Binding Corporate Rules where applicable

You can obtain information about these safeguards by contacting Adminmarketplus LLC at: contact@startupacademie.com

Article 8: Cookie Policy

8.1: What is a cookie?

A cookie is a small text file placed on your device (computer, tablet, smartphone) when you browse our Site. It allows our Site to remember your preferences, measure its audience and improve your user experience.

8.2: Cookies used by Startup Académie

Strictly necessary cookies: essential for the Site to function (session management, security, remembering the cart). These cookies cannot be disabled. No consent is required.
Performance and audience measurement cookies: used to analyze traffic to and use of the Site in order to improve it (e.g. Google Analytics or equivalent). Subject to your prior consent.
Functionality and preference cookies: used to remember your browsing preferences (language, region, display settings). Subject to your consent.
Targeting and advertising cookies: used to display personalized content. Subject to your explicit consent.

8.3: Cookie lifespan

Cookies have a maximum lifespan of 13 months from the time they are placed on your device, in accordance with the recommendations of the CNIL.

8.4: Managing your cookie preferences

You can manage your cookie preferences at any time via the cookie management banner available on our Site, or via your browser settings. Refusing certain cookies may affect the proper functioning of some features of the Site.

Article 9: Enhanced Protection of Minors' Data

Since Startup Académie is aimed at children and young learners, Adminmarketplus LLC applies enhanced measures to protect their personal data:

The consent of the legal representative is strictly required before any collection of data concerning a minor under 16 (or the age set by the national legislation applicable in the country of residence)
Minors' data is never used for commercial or advertising profiling
Access to the educational data of a minor learner is limited to authorized instructors and the legal representative
No minor's data is transmitted to third parties for commercial purposes
Instructors have no access to families' personal contact details outside the official Startup Académie platform

These measures apply in addition to the provisions of the GDPR, and in compliance with the specific national legislation applicable in each country where Startup Académie operates (in particular COPPA in the USA, the Age Appropriate Design Code in the United Kingdom, etc.).

Article 10: Your Rights over your Personal Data

In accordance with the GDPR and the amended French Data Protection Act (loi Informatique et Libertés), you have the following rights over your personal data:

Right of access (Art. 15 GDPR): obtain confirmation that data concerning you is being processed, and receive a copy of it
Right to rectification (Art. 16 GDPR): have inaccurate or incomplete data concerning you corrected
Right to erasure / right to be forgotten (Art. 17 GDPR): request the deletion of your data, subject to legal retention obligations
Right to restriction of processing (Art. 18 GDPR): request the temporary suspension of the processing of your data
Right to data portability (Art. 20 GDPR): receive your data in a structured, commonly used and machine-readable format
Right to object (Art. 21 GDPR): object to the processing of your data on grounds relating to your particular situation, or object to its use for marketing purposes
Right not to be subject to an automated decision (Art. 22 GDPR): not to be subject to a decision based solely on automated processing
Right to withdraw your consent at any time, without affecting the lawfulness of processing carried out before such withdrawal

To exercise any of these rights, send your request by e-mail to: contact@startupacademie.com, or by post to: Adminmarketplus LLC, 1209 Mountain Rd Pl NE, Ste R, Albuquerque, NM 87110, USA.

We will respond to your request within one (1) month of its receipt. This period may be extended by two further months in the case of complex or numerous requests, in which case you will be informed in advance.

If you believe that your rights have not been respected after contacting us, you have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), 3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07: www.cnil.fr

Article 11: Data Security

Adminmarketplus LLC implements all appropriate technical and organizational measures to ensure the security, confidentiality and integrity of your personal data, in accordance with Article 32 of the GDPR. These measures include in particular:

Encryption of data in transit (HTTPS/TLS protocol) and at rest
Strict control of access to data by internal teams (principle of least privilege)
Secure authentication for access to the platforms
Regular backups and a business continuity plan
GDPR-compliant data processing agreements with all our technical service providers
Regular training and awareness-raising of teams on data protection

In the event of a personal data breach likely to result in a high risk to your rights and freedoms, Adminmarketplus LLC undertakes to notify you as soon as possible, in accordance with Article 34 of the GDPR.

Article 12: Changes to the Privacy Policy

Adminmarketplus LLC reserves the right to amend this Privacy Policy at any time, in particular to take account of legal, regulatory or technological developments. The version in force is always accessible on the Site.

In the event of a substantial change affecting your rights, you will be informed by e-mail at the address provided at enrollment, with reasonable notice before the changes take effect. Continued use of the services after this period constitutes acceptance of the new policy.

Article 13: Contact and Data Protection Officer

For any question relating to this Privacy Policy, to the protection of your personal data or to exercise your rights, you can contact Adminmarketplus LLC:

By e-mail: contact@startupacademie.com
By post: Adminmarketplus LLC, 1209 Mountain Rd Pl NE, Ste R, Albuquerque, NM 87110, USA

Adminmarketplus LLC is not legally required to appoint a Data Protection Officer (DPO) within the meaning of Article 37 of the GDPR, given the size and nature of its activities. However, any request relating to data protection will be handled with the utmost diligence by the data controller.