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Confidentiality policy

Confidentiality policy

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Data protection policy

(EU Regulation 2016/679 of 27 April 2016 (RGPD) and law no. 78-17 of 6 January 1978)

 

Preamble:

This data protection policy is intended to inform Data Subjects about the processing of their personal data in the context of automated and non-automated processing, in accordance with the provisions of Law No. 78-17 of January 6, 1978 and EU Regulation 2016/679 of April 27, 2016 (hereinafter “RGPD”) and other legal and regulatory provisions in force (hereinafter the “Regulations in force”) relating to the protection of personal data.

 

The terms “Personal Data”, “Data Controller”, “Processor”, “Processor”, “Processing”, “Data Subject”, “Personal Data Breach” and “Supervisory Authority” are defined as defined in article 4 of the GDPR.

 

The main categories of personal data that are processed

 

The personal data collected are as follows:

 

1. When ordering (information required to benefit from the provision, maintenance and return of equipment):

a. Identification data (name, first name, gender and size (for the persons benefiting from the provision of the equipment), as well as, where applicable, for company managers (signatory of contracts), as well as the data contained in the copy of an identity document such as the national identity card or another official document attesting to identity),

b. Contact data (postal address, email address, telephone numbers),

c. Where applicable, payment information (IBAN) relating to the user of the equipment in order to ensure the payment of partial support for the provision of the equipment,

 

2. When visiting the website accessible at https://www.zenride.co and https://app.zenride.co:data collected using cookies, trackers or equivalent technical means (for more information on the management of cookies and trackers, consult the information notice relating to the management of cookies).

 

3. During the contractual relationship : Data relating to the contractual and commercial relationship between the Persons Concerned and ZENRIDE (e.g. subscription category, purchase history),

 

Legal information for the persons concerned

 

The purpose of these terms is in particular to provide the Persons Concerned with the required legal information, which is the following:

a) Identity and contact details of the Personal Data Controller

The identity and postal details of the Personal Data Controller are as follows:

- ZENRIDE, a simplified joint stock company registered in the Paris Trade and Companies Register under number 839 209 392, whose head office is 13 rue de Bellefond, 75009 Paris (hereinafter “ZENRIDE”);

b) Contact details of the data protection officer

The contact details of the data protection officer are as follows:

- Maître Pascal Alix, associate lawyer at AARPI VIRTUALEGIS, 5 rue Jean-Baptiste Dumas, 75017 Paris;

 

c) Purposes of Personal Data Processing

 

The purposes of the processing for which personal data are intended are as follows:

- (i) identification of the Persons Concerned and contact with them (Users),

- (ii) provision of equipment for the benefit of Users,

- (iii) connection with partner stores,

- (iv) provision of contractual services (upkeep and maintenance),

- (v) contract and user account administration

- (vi) management of relationships with fleet managers within tenant entities

- (vii) sending information and/or service proposals to the Persons Concerned

- (vii) refinancing of assets

 

d) Legal bases for Treatments

The legal bases for the Treatment are, according to the Treatments:

- (i) the consent of the persons concerned,

- (ii) the need for the execution of pre-contractual measures,

- (iii) the need for the execution of a contract concluded with the tenant entities in order for Users to benefit from the contractual services

- and (iii) the need for ZENRIDE to pursue its legitimate interest, in particular to manage the relationship with the Persons Concerned and in particular to maintain proof of exchanges with them.

 

e) Recipients of personal data

The recipients of the personal data processed are:

- ZENRIDE staff in charge of contractual services,

- ZENRIDE's subcontracting and non-subcontracting service providers participating in the provision of these services, such as, for example, suppliers of the equipment made available and IT service providers.

 

f) Transfer of personal data outside the European Economic Area (E.E.E.)

The Data Subjects are informed that the Data Controller may, where appropriate, in particular when a service provider is located outside the EEA, transfer personal data to a third country subject to an adequacy decision issued by the European Commission; if the recipient country is not the subject of an adequacy decision, the transfer can only be carried out provided that appropriate guarantees are in place and that Persons Concerned by Data Processing at Personal persons have enforceable rights and effective remedies, under the conditions of the Regulations in force and in particular articles 46 to 49 of the RGPD.

 

g) Retention period of personal data

The retention periods of the personal data of the Data Subjects vary according to the purpose of the Treatments and according to the nature of the relationship (prospect who has never contracted, customer, or interlocutor with a subcontractor or a non-subcontracting partner).

The table below specifies the main retention periods for personal data relating to Data Subjects:

 

h) Rights of Data Subjects that can be exercised with the Data Controller

With regard to the legal basis for Processing, including in particular that of consent, the person concerned has the following rights, under the conditions provided for by the Regulations in force:

- access to their personal data;

- the correction of personal data when they are inaccurate or incomplete;

- the deletion of these, in particular when these data are no longer necessary for the purpose of the Processing or when the person concerned has withdrawn their consent or when the Processing is unlawful, subject to legal retention obligations;

- a limitation of the Processing of their personal data when the accuracy of the data is being verified following a dispute by the person concerned, when the Processing is unlawful and the data subject objects to the deletion of the data and instead requires the limitation of their use or when the Data Controller no longer needs the personal data for the purposes of the processing, but they are still necessary for the person concerned to establish, exercise or defense of rights in justice;

- the opposition of the person concerned to the Processing of his personal data for reasons relating to his particular situation;

- the opposition of the Data Subjects at any time to the Processing of their personal data for prospecting purposes, including profiling;

- the portability of their personal data under the conditions of the Regulations in force, which provides in particular that Persons Concerned by Personal Data Processing have the right to receive the personal data concerning them that they are provided to the Data Controller, in a structured, commonly used and machine-readable format, in a structured, commonly used and machine-readable format, and have the right to have this data transmitted to another Data Controller;

- the withdrawal by the data subject, at any time, of his consent to the processing of his personal data (without affecting the legality of the processing based on the consent carried out before the withdrawal of the consent);

- the right to define instructions relating to the fate of his personal data after his death;

The exercise of the rights identified in this (h) is carried out by the Data Subject to the Data Controller (as identified above) by means of a request made by him or by a duly authorized person, sent to Zenride at the following address (or to the contact details identified in point (b) above): help@zenride.co

i) Complaint to the CNIL

Data Subjects may, in particular if they consider that the answers provided by the Data Controller to their questions concerning the processing of their personal data are not satisfactory, file a complaint with the supervisory authority, namely the Commission Nationale de l'Informatique et des Libertés (CNIL) (CNIL): 3 Place de Fontenoy - TSA 80715 - 75334 Paris 07.

j) Mandatory nature of the provision of certain personal data

The exercise by a data subject, when placing an order, of his right to object to the processing of his personal data (and in particular contact data) for reasons relating to his particular situation constitutes an obstacle to the conclusion of the contract. The subsequent exercise of the same right may, where appropriate, prevent access to additional contractual services.

k) Automated decision making

Using the personal data collected, no automated decision-making is carried out within the meaning of the Regulations in force.

l) Possible further processing of personal data

In principle, ZENRIDE does not carry out any further processing of personal data for a purpose other than that for which the personal data was collected. But in the event that a treatment is carried out for one or more purposes other than those initially determined, the Data Controller provides the Data Subjects in advance with the information required about this/these purposes and, if necessary, will obtain their prior consent.

M) Mobile application: Bike trip

The Trajet Vélo mobile application uses geolocation services, including geolocation in the background, in order to function properly. This authorization is necessary to detect your trips, calculate their duration and distance, and count the number of trips made via the application, even when it is not open in the foreground.

Protecting your data is a priority. Precise location data is never stored or maintained by the app. Only the information that is strictly necessary for the operation of the service, namely the distance travelled and the duration of the trip, is recorded.