Effective date: November 22, 2019
WE ARE COMMITTED TO PROTECTING YOUR PERSONAL DATA.
FIFTEEN, a Simplified Joint Stock Company (Société par Actions Simplifiée) with a share capital of €152,207, whose registered office is located at 8 Rue Henri Mayer, 92130 Issy-les-Moulineaux, registered with the Nanterre Trade and Companies Register under number 830 590 659 (“we”, “us”, or “our”), is committed to respecting privacy as well as applicable data protection laws with regard to users (“you”, “your”) of its service (the “Service”, as more precisely defined in the “Definitions” section).
This privacy policy (the “Policy”) describes our method of collecting and using personal data in the context of your use of the Service, our website (the “Website”), and your interactions with us, who act as the data controller within the meaning of European data protection legislation concerning the processing of personal data.
Software on your device may have access to your information. Our products or services may contain links to other companies’ websites that have their own privacy notices. We therefore recommend that you carefully read their privacy policies.
This Policy applies only in the context of the Service and our Website.
You are not required to provide us with your personal data. However, if you choose not to provide your personal data, we may not be able to provide you with our products or services, or all of their features, or respond to your inquiries.
Definitions
“We”, “us”, or “our”: refers to the company FIFTEEN as identified at the beginning of this Policy and/or your employer/school/university, if the Service is provided to you through them.
“Service”: refers to the electric bike sharing service offered by FIFTEEN, as defined in the General Terms of Use of the Ti-Vélo Service, to which the service is subject and which form an indivisible whole with this Policy.
“Ti-Vélo”: commercial brand operated by FIFTEEN.
“Application”: refers to the free downloadable software application that runs on a smartphone or tablet operating system (iOS or Android). It allows any Service user to find a nearby bicycle, unlock it, follow a cyclist-friendly route, check the number of kilometers traveled, subscribe to the Service, contact customer support, and report an incident.
What information do we collect?
We collect your personal data and other information when you fill out various online forms as part of your use of the Service and the Website, or when you respond to questions communicated by email, by phone, via the Ti-Vélo application (“the Application”), or through any other means of communication, and when you take part in a campaign, survey, or interact with us. This includes the following cases:
Our applications may regularly contact our servers, for example to check whether updates are available, or to send us information about your use of our services. In addition, we may invite you to voluntarily join service improvement or research programs, in which we collect detailed information such as your socio-professional category, gender, or how you use our services.
Information you provide to us: when you create an account, use the Service, request our services, take part in campaigns or surveys, or interact with us, we may ask for information such as your name, email address, phone number, postal address, usernames and passwords, comments, device-related information, age, gender, and language.
We also retain your consents, preferences, and settings related for example to location data, marketing, and personal data sharing.
Your transactions with us: we keep a record of your purchases, downloads, content you have provided to us, your requests, agreements between us, the products and services we have offered you, payment and delivery details, as well as your interactions with us. In accordance with applicable law, we may record your communications with our customer service or any other point of contact.
Location and positioning data: location services determine your position using satellite, mobile network, Wi-Fi, or other network-based methods. These technologies may involve sharing your location data and the unique mobile device identifier, Wi-Fi identifiers, or other network identifiers with us. Our products may operate with different platforms, applications, and services that may also collect your location data. We do not use this information to personally identify you without your consent.
Your email address: we may process your email address if you have provided it via our Website.
We also collect personal data through cookies and tracking technologies on our Website and Application. Please refer to the section “How do we use cookies and web beacons?” for more information.
Why do we process your personal data?
We may process your personal data for several purposes:
Providing the Service: we may use your personal data to provide the Service, maintain it, process your requests, and more generally to perform the contract between you and us, ensure the functionality and security of our products and services, including the Service, identify you in order to provide the Service, and prevent or investigate fraud and other malicious use.
Communicating with you: we may use your personal data to communicate with you, for example to inform you of changes to our services or to send alerts about our products and/or services, and to contact you via our customer service.
Marketing, advertising, and recommendations: we may contact you to inform you about new products or services, promotions that may be offered to you, or conduct surveys after obtaining your consent where required or permitted. We may use your personal data to personalize our offers and provide more relevant services, for example by making recommendations and displaying personalized content and advertisements within our services. This may include content from FIFTEEN or third parties.
Anonymous statistics: we may aggregate GPS data from all users to provide statistics on mobility patterns, which may be shared with our partners. These aggregated data will be anonymized in accordance with applicable data protection regulations.
We use your personal data with your consent or when necessary for the proper performance of our contractual relationship. We may also use your personal data when required by law or based on our legitimate interests, for example to protect our customers, ensure the security of our products and services, and protect our rights and property.
Do we share your personal data?
We do not sell, rent, or disclose your personal data to third parties except in the cases described below.
Your consent and social media buttons: we may share your personal data if you have given your consent. Some of our products and services may allow you to share your personal data with social networks. We encourage you to be careful and review the privacy policies of these social networks to understand exactly what information is collected and how it is used, particularly for advertising purposes.
FIFTEEN group companies and authorized third parties: we may share your personal data with other companies in the FIFTEEN group or authorized third parties processing personal data on behalf of FIFTEEN, in accordance with this Policy. This may include, for example, billing by your network operator, delivery of personal batteries, or services such as customer support, consumer data management and analysis, surveys, commercial management, or other services.
We may carry out marketing campaigns and other communication activities in collaboration with our authorized third-party partners. To avoid duplicate or unnecessary communications and to send you more relevant messages, we may need to match data collected by FIFTEEN with data collected by partners where permitted by law.
These authorized third parties are not permitted to use your personal data for any other purpose. We require them to comply with this Policy and applicable data protection regulations, and to implement appropriate security measures to protect your personal data.
International data transfers: our products and services may be provided using resources and servers located in various countries worldwide. Your personal data may therefore be transferred across borders, including to countries outside the European Union that may not have specific data protection laws or may have different ones. In such cases, we take measures to ensure adequate protection of your personal data in accordance with applicable law, using agreements approved by relevant authorities (e.g., the European Commission) and requiring technical and organizational security measures.
Mandatory disclosures: we may be required by law to disclose your personal data to certain authorities or third parties, for example law enforcement authorities in countries where we or third parties acting on our behalf operate. We may also disclose and process your personal data in accordance with applicable law to protect our legitimate interests, for example in civil or criminal proceedings.
Mergers and acquisitions: if we decide to sell, purchase, merge, or reorganize our business in certain countries, this may involve disclosing personal data to potential or actual buyers and their advisors, or receiving personal data from sellers and their advisors.
How do we address children’s privacy?
FIFTEEN products and services are generally intended for general audiences. We do not knowingly collect information from children under the age of 15 without prior consent from their parents or legal guardians.
How do we ensure data quality?
We take all reasonable measures to ensure that the personal data we hold is up to date and to delete personal data that is found to be inaccurate or unnecessary. We will retain your personal data only for as long as necessary to fulfill the purposes described in this Policy or as otherwise communicated to you, unless a longer retention period is required by law.
We encourage you to access your account from time to time to review your personal data and help us keep it up to date.
What measures are taken to protect your personal data?
Confidentiality and security are of crucial importance in the way we design and deliver our products and services. We have assigned specific responsibilities to address security and privacy issues. We enforce our internal policies and guidelines through a range of appropriate activities, including proactive and reactive risk management, security and privacy engineering, training, and assessments.
We take appropriate measures to address online security risks, physical security risks, data loss risks, and other risks, taking into account the nature of the data being processed and the associated risk level. We also restrict access to databases containing personal data to authorized personnel who have a legitimate need to access such information.
How do we use cookies and web beacons?
A “cookie” is a small text file containing data that is stored on a device (computer, tablet, smartphone, etc.) when you browse a website. We use cookies, web beacons, and similar technologies to operate and improve our Website and Application. We also use cookies to personalize and display advertisements. Some FIFTEEN websites use third-party advertising technologies to display ads.
Below is a list of the cookies we use:
| Name | Purpose | Maximum lifespan | Domain/Service concerned |
| Google Analytics | We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics creates a cookie to evaluate your use of our Website and to produce reports for us on site activity. | 2 years | zoov.eu / forfait-velo.fr |
| HubSpot | We use cookies provided by HubSpot, Inc. to track visitors to our Website. | 13 months | zoov.eu |
| We use cookies provided by Facebook, Inc. via HubSpot for better integration with our Facebook account. | 3 months | zoov.eu | |
| We use cookies provided by LinkedIn, Inc. to track LinkedIn users and improve integration with our LinkedIn account. | 2 years | zoov.eu |
How can you manage/delete these cookies?
All major web browsers allow you to manage cookies stored on your computer or mobile device.
If you do not want our Website to place cookies on your device, you can easily restrict or delete them by configuring your browser or device settings. In addition, you can set your device to notify you each time a cookie is sent, allowing you to decide whether to accept it.
We notify new users with a dedicated banner indicating that cookies are used on our website. You may choose to accept or reject them at that time. You can reset your choice at any time by clicking here. The cookie consent banner will be displayed again at your next login.
What are your rights?
You have the following rights regarding the personal data we process about you:
Access: you have the right to know what personal data we hold about you and to obtain a copy of it.
Data portability: subject to applicable law, you have the right to receive the personal data you have provided to us in a machine-readable format.
Rectification: you have the right to request that any incomplete, inaccurate, or outdated personal data about you be corrected.
Erasure: you have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, when you have withdrawn your consent, when you have objected to the processing in accordance with data protection regulations, when the processing is unlawful, or when a legal obligation requires it.
Withdrawal of consent: you have the right to withdraw any consent you have given for the use of your personal data.
Objection: you have the right to object to the processing of personal data if it is based on the performance of a task carried out in the public interest or in the exercise of official authority, or on legitimate interests pursued by us, for reasons related to your particular situation. You may also object at any time to processing for direct marketing purposes.
Restriction: you have the right to request the restriction of processing of your personal data when you contest the accuracy of the data, when the processing is unlawful and you oppose deletion, when you need the data for legal claims, or when you have objected to the processing while we verify our legitimate grounds.
Post-mortem instructions: you also have the right to set instructions regarding the storage, deletion, and communication of your personal data after your death.
If you wish to exercise any of these rights, you may contact us at landerneau@zoov.eu. If you are still not satisfied, you also have the right to lodge a complaint with a competent supervisory authority, which in France is the Commission Nationale de l’Informatique et des Libertés (CNIL).
How long do we retain your personal data?
Your data will be kept for a period that does not exceed what is necessary to achieve the purposes stated in this Policy.
If your data is no longer needed for those purposes, it will be regularly deleted or anonymized, unless it must be retained longer:
to comply with legal, accounting, and tax obligations: 10 years
for evidence preservation during applicable limitation periods: 5 years
for marketing purposes: 3 years from the end of our contractual relationship with you or from your last contact with us
In addition, if we determine that your user account has not been used for more than 2 years, we will delete your personal data.
What permissions does the Application require?
You must grant the following permissions to the Application to allow us to collect the data necessary for your registration and use of the Ti-Vélo Service:
Camera: required to scan the QR code identifying the bicycle.
Location: required to locate you on the map (MapBox), show the position of nearby bicycles, and guide you to them.
Bluetooth: required to establish and maintain the connection between the user’s phone and the bicycle, enabling proper use of the Ti-Vélo Service.
Modification de la Déclaration
Nous nous réservons le droit de modifier la présente Déclaration à tout moment, avec ou sans préavis. Toutefois, si notre Déclaration devait être modifiée vous en seriez notifié par email, afin que vous puissiez en prendre connaissance.
Contact
Si vous avez des questions ou des demandes concernant cette Déclaration ou de manière générale sur la manière dont nous traitons vos données, vous pouvez nous contacter à l’adresse email suivante : landerneau@zoov.eu.
Comments
0 comments
Please sign in to leave a comment.