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Translation pending review. The French version prevails.

PRIVACY POLICY OF VALORIZE UP

Version 1.0 of 5 October 2026

1. Who is responsible for your data

Valorize Solutions SRL, Rue de Huppaye 40, 1315 Incourt, Belgium, company number 0546.967.261 (“Valorize”, “we”), is the controller of the personal data collected on valorizeup.com and in the Valorize Up platform. For any question about your data: contact@valorizeup.com. Valorize has not appointed a data protection officer.

2. What data we process

Do not enter in the exercises the names of the people you deal with (replace them with their job title), or any sensitive data.

3. Why, on what basis, and for how long

PurposeLegal basis (GDPR, Art. 6)Retention period
Creating your account, giving you access to the Course, correcting your exercises, issuing the certificatePerformance of the contractAccess Period, then [12] months to allow you to retrieve your certificate; then deletion or anonymisation
Invoicing and keeping the accountsLegal obligationStatutory retention period for accounting and tax documents [to be confirmed with the accountant]
Showing your progress to the company that paid for your licencePerformance of the contract with that company and legitimate interestAccess Period
Keeping evidence of acceptances, choices and withdrawalsLegal obligation and legitimate interest (defending ourselves in the event of a dispute)[Period to be set with the lawyer]
Responding to your requests and complaintsLegitimate interest, or performance of the contract[3] years after the last request
Organising individual coachingPerformance of the contract[12] months after the last session
Improving the Courses on the basis of anonymous statisticsLegitimate interestAnonymised data
Sending you information about our training coursesConsent, which you may withdraw at any timeUntil consent is withdrawn
Securing the site and the platformLegitimate interest[6] months for technical logs

4. The AI Coach

To correct your exercises, your answers are sent to the provider of the artificial intelligence model [Anthropic, United States (Claude models)], which acts as a processor for Valorize. [This provider has undertaken by contract not to use your data to train its models.] [Vincent's voice is produced from the text of the feedback by ElevenLabs, United States.] The AI Coach provides training feedback; it takes no decision that produces legal effects concerning you or that significantly affects you.

5. Who receives your data

We do not sell your data.

6. Transfers outside the European Union

[Some processors are established in the United States: Vercel, Supabase, Anthropic, ElevenLabs, Resend, Stripe, Inc. (for Stripe Payments Europe).] These transfers are based on the adequacy decision of the European Commission for companies certified under the EU-U.S. Data Privacy Framework, or on standard contractual clauses adopted by the Commission. You can obtain a copy of them at contact@valorizeup.com.

7. Your rights

You may request access to your data, its rectification, its erasure, the restriction of its processing, and its portability. You may object to processing based on our legitimate interest, and withdraw at any time any consent given, without affecting what was done before. Write to contact@valorizeup.com. We respond within one month, which may be extended in the cases provided for by law. We may ask you to prove your identity.

8. Complaint

If you consider that your rights are not being respected, you may lodge a complaint with the Data Protection Authority, Rue de la Presse 35, 1000 Bruxelles, www.autoriteprotectiondonnees.be.

9. Security

We take appropriate technical and organisational measures to protect your data: encrypted connections, access limited to the people who need it, processors chosen for their guarantees.

10. Changes

We may update this policy. The date of the version in force is shown at the top of the page. In the event of a significant change, we will inform you by e-mail.