Privacy Policy

Effective Date: January 2025

WayUp SAS (hereinafter, « the Company », « We », « Us ») is deeply committed to ensuring compliance with applicable laws and to the protection and privacy of personal data. This Privacy Policy (hereinafter, « this Policy ») explains how we handle your personal information as a user of the SmartCleaner app (hereinafter, « the app » or « our app »). If you do not agree with this Policy, we ask that you refrain from using the app.

We may update this Policy to comply with new legal requirements or business changes. Any updates or modifications to this Privacy Policy will take effect once published in the app. Therefore, we encourage you to review this Policy regularly. This Policy will always be accessible within the app for users to refer to at any time.

The purpose of this policy is to inform you about how we process this data in compliance with Regulation (EU) 2016/679 of April 27, 2016, relating to the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “GDPR”).

Who is the data controller?

The data controller is WayUp, SAS with a capital of €1500, registered at the RNE under the SIREN number 977 878 743 and headquartered in Champs-sur-Marne (hereinafter “We”).

What data do we collect?

Personal data is any information that can identify an individual directly or through cross-referencing with other data.

We collect data falling under the following categories:

Identification data (your email address)
Any information you wish to share with us as part of your contact request;
Internet data (e.g., IP address);
The Service requests access to Gmail API to allow you to delete unwanted emails, mark emails as read or unread, categorise messages according to your preferences, and enable you to manage email filters and unsubscribe from unwanted mailing lists directly from within the app. Access to Gmail data is granted through Google’s OAuth 2.0 authentication process. The Service does not collect, store, or transmit any Gmail data to external servers. All data processing related to email management occurs locally on your device. You can review or revoke access to your Gmail account by managing connected applications within your Google account.

Google API Services Usage Disclosure

Notwithstanding anything else in this Privacy Policy, if you provide us with access to your Google data, our use of that data is subject to these additional restrictions:

1. we will only use access to read or control Gmail message metadata (including information about attachments), headers and message content to provide a web extension that allows users to process (delete/move/archive/unsubscribe from) emails and will not transfer this Gmail data to others unless doing so is necessary to comply with applicable law.
2. we will not use this Gmail data for serving advertisements.
3. we will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, or to comply with applicable law.

We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Data Protection and Security

We implement security measures to protect the confidentiality and integrity of Google user data.

Access Controls: Only authorized personnel can access user data, following strict access management policies.
Secure Data Transmission: We use secure protocols to transmit data and prevent unauthorized access.
Data Confidentiality: We do not share user information with unauthorized third parties and take measures to prevent misuse.
Regulatory Compliance: Our practices comply with applicable regulations, including GDPR and CCPA.
Data Retention and Deletion: Data is retained only as long as necessary, and users can request its deletion at any time.

Mandatory data is indicated when you provide your information to us. They are marked with an asterisk and are necessary for us to provide our services to you.

On what legal bases, for what purposes, and for how long do we keep your personal data?

Purposes

Legal Bases

Retention Periods

Providing you with a

demonstration of our

products and services,

responding to your

information requests

Execution of

pre-contractual measures taken at your request

Your data is kept for 3 years from the last contact from you.

Building a database of

customers and prospects

Our legitimate interest in developing and promoting our business

For customers: data is kept for the duration of the contractual relationship.

For prospects: data is kept for a period of 3 years from your last contact, for prospecting purposes.

Sending newsletters,

solicitations, and

promotional messages to

our prospects

BtoC prospects: Your

consent

BtoB prospects: Our

legitimate interest in

retaining and informing our prospects of our latest

updates

Data is kept for 3 years from your last contact with Us or until your consent is withdrawn.

Managing rights requests

Our legitimate interest in responding to your

requests and keeping

track of them

If we request proof of identity: we keep it only for the time necessary for

identity verification. Once the

verification is completed, the proof is deleted. If you exercise your right to object to receiving marketing: we keep this information for 3 years.

Who are the recipients of your data?

Your personal data may be accessed by:

Our company staff;
Our subcontractors: hosting providers, emailing services, CRM tools; 3. Where applicable: public and private entities, solely to comply with our legal obligations.

Is your data likely to be transferred outside the European Union? Your data is stored and retained throughout the duration of processing on the servers of WayUp located at 2 bis rue Alfred Nobel in Champs-sur-Marne.

In the context of the tools we use (see the section on recipients regarding our subcontractors), your data may be transferred outside the European Union. The transfer of your data in this context is secured by the following means:

Either the data is transferred to a country that has been subject to an adequacy decision by the European Commission, in accordance with Article 45 of the GDPR: in this case, the country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR;
Or the data is transferred to a country whose level of data protection has not been recognized as adequate under the GDPR: in this case, these transfers are based on appropriate safeguards mentioned in Article 46 of the GDPR, tailored to each provider, including, but not limited to, the conclusion of standard contractual clauses approved by the European Commission, the application of binding corporate rules, or under an approved certification mechanism.
Or the data is transferred based on one of the appropriate safeguards described in Chapter V of the GDPR.

What are your rights concerning your data?

You have the following rights concerning your personal data:

Right to information: this is precisely why we have drafted this policy. This right is provided for by Articles 13 and 14 of the GDPR.
Right of access: you have the right to access all of your personal data at any time, pursuant to Article 15 of the GDPR.
Right to rectification: you have the right to rectify your inaccurate, incomplete, or outdated personal data at any time in accordance with Article 16 of the GDPR.
Right to restriction: you have the right to obtain the restriction of the processing of your personal data in certain cases defined by Article 18 of the GDPR.
Right to erasure: you have the right to demand that your personal data be erased, and to prohibit any future collection thereof on the grounds set out in Article 17 of the GDPR.
Right to lodge a complaint with a supervisory authority: you have the right to contact a supervisory authority (such as the CNIL in France) to file a complaint regarding our personal data protection practices in accordance with Article 77 of the GDPR.
Right to define directives related to the storage, deletion, and communication of your personal data after your death.
Right to withdraw your consent at any time: for purposes requiring your consent to

the processing of your data, Article 7 of the GDPR allows you to withdraw your consent at any time. We will then cease processing your personal data for these purposes.

Right to portability: under certain conditions specified in Article 20 of the GDPR, you have the right to receive the personal data you provided to us in a standard machine-readable format, and to request its transfer to the recipient of your choice.

You may exercise these rights by writing to us at: contact@wayupapp.com.

Note that we may require proof of your identity to fulfill your request. This proof will be deleted once the request has been processed.

Amendments

We may modify this policy at any time, particularly to comply with regulatory, jurisprudential, editorial, or technical developments. These modifications will apply as of the publication of the new version. Therefore, it is advisable to refer to the most recent version of this policy before browsing.

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