Personal data protection policy
Conditions valid until 8 February 2022
Freshmile SAS (hereafter “Freshmile”) takes the protection of your personal data seriously. The procedures applied by Freshmile guarantee your rights in this respect.
The personal data protection measures concern all websites, web applications and mobile applications made available to users by Freshmile (hereinafter the “Sites”). Websites and services offered by third parties, to which links may be provided, are explicitly uncovered. Freshmile is not responsible for any personal data breaches that may result from visiting third party sites or using third party services.
The purpose of this policy is to explain how Freshmile collects and processes your personal data. It may be modified at any time, particularly to take into account the evolution of the technologies used, the release of new services and new regulations, in which case the new version will be published on the Sites.
Article 1 – General
In the context of its activities,
Tel: +33 3 69 24 67 32
Email : firstname.lastname@example.org
Freshmile must collect and process your personal data, as a data controller, in accordance with the General Data Protection Regulation.
Freshmile is committed to respect the provisions of the French law n°78-17 of 6 January 1978 relating to data processing, files, and freedoms, as well as the General Data Protection Regulation of the European Union (GDPR).
Article 2 – Data relating to browsing on the Sites
It is possible to navigate on the Sites without having to give access to personal data. However, all products and services offered by Freshmile (hereinafter the “Products and Services”) may be unavailable without prior transmission of personal data.
General browsing data are recorded, such as IP address, web browser and operating system, date, and time of visit. Personal data such as name, address or email address are only recorded and processed if the user contacts Freshmile to use the Products and Services, and the use of such data are necessary.
The login information is anonymized and is used for statistical purposes and to improve the Products and Services. It is not possible to use login data to identify a specific user.
Article 3 – Contact form
The Freshmile website includes contact forms. When using a contact form, the information communicated by the user is recorded for the purpose of processing the request and is necessary to manage user’s request.
This information is intended for Freshmile and will only be accessible to the persons in charge of processing this request. This information will be kept for 12 months and then archived.
Article 4 – Personal data collected and purposes of processing
The use of the Sites, Products and Services offered by Freshmile may require the processing of users’ personal data, such as identification data (e.g. name, address, email address), usage data (e.g. consumption, billing) and correspondence data. This data are necessary for the proper performance of the Products and Services, except for data expressly indicated as not required (e.g., certain fields in registration forms).
Freshmile uses your personal data for the following purposes
- Creation and management of the User account
- Commercial relationship: management of the customer relationship (complaint, support…), management of the payment methods, use of the recharging service;
- Communication: sending newsletters about the Products and Services;
Your data relating to charging sessions is also collected and kept for anonymous statistical purposes and to improve services. This data are stored and processed anonymously, i.e., without any link with the identity of the users.
Creation of a user account: in the context of the user account’s creation based on your consent, the following personal data are processed: email address (mandatory), first and last name (optional) and postal address (optional).
This data may subsequently be processed in the context of the execution of contracts which you may subscribe for the use of the Products and Services. This data will be kept until the deletion of your account and will only be accessible to Freshmile employees, when necessary, for the performance of their duties as well as to the call centre teams, in the context of the support service.
Article 5 – Usage data of mobile applications
In the case of mobile applications, information is transmitted during the download to the third party managing the application catalogue (e.g., Apple, Google). Freshmile has no influence on the data transmitted to the application catalogue managers and is not responsible for the use made by these third parties.
When using mobile applications, the geographical position of the user can be collected to propose a relevant display. This availability of the geographical position can be deactivated by the user in the phone settings. This makes the use of mobile applications less efficient.
Users can also use mobile applications anonymously, i.e., without prior registration or transmission of identifying information.
The available online payment systems are provided by third parties, which have their own personal data policies.
Some of your data relating to the use of the mobile applications are collected for statistical purposes and to improve the Products and Services. This data are stored anonymously, i.e., not linked to the users’ identity.
Article 6 – Evolution of products and services
Freshmile also uses some data related to the use of the service in an anonymised form for statistical purposes to assist in the development of new Products and Services.
Article 7 – Newsletters
Users have the possibility to subscribe to newsletters. Personal data related to this, such as name and address entered in the registration form, may be used for the purpose of sending newsletters.
The newsletters may contain tracking devices such as web beacons. This may be used to compile statistics about online marketing campaigns and to improve the newsletters. This data are anonymous and do not identify individual users.
Article 8 – Recipients and categories of recipients of personal data
In order to carry out their missions, only Freshmile staff needs to have access to personal data.
Some external service providers to Freshmile may also have access to data to carry out the tasks that Freshmile entrusted to them, such as: IT service providers, billing service providers, printers, consultants, installers, or maintainers.
In addition, Freshmile may have to reveal information about users by law, as a result of an external request for information or as necessary for the performance of products and services. In these circumstances, recipients of personal information may include, for example, electricity distribution network operators, energy suppliers, auditors, public authorities, courts, lawyers, or notaries.
In all cases and to fulfil their missions, Freshmile ensures that only those third parties, which need access to personal data, have access to it.
Freshmile will never sell personal data to third parties.
Article 9 – Retention and destruction of data
Usage of Sites as well as Products and Services provided by Freshmile may require the processing of personal data from users, such as identification data (ex: name, address, email address), usage data (ex: consumption, billing) as well as data related to correspondence. These data are necessary to the proper execution of Products and Services, exception made for data explicitly indicated as non mandatory (ex: as found in some registration forms).
Data are also collected for statistical purpose and improvement of services. These data are stored and processed in an anonymous manner, i.e. without link to the identity of users.
Article 9 – Data related to the use of mobile applications
Personal data shall be deleted as soon as they are no longer necessary for the purposes they were collected and processed, there are no pending claims, there is no legal obligation to store them or any other legal provision requiring storage.
Data that has been previously anonymised for statistical and service improvement purposes is stored for as long as it is needed for these purposes.
Article 10 – Security of data transmissions
Freshmile implements technical and organisational measures in order to protect its information and communication systems, to adapt them to the risks you are exposed to and to prevent any loss, unauthorised access, misuse, or unauthorised modification of your personal data. Nevertheless, the security and confidentiality of personal data also depends on good practice, and it is your responsibility to be vigilant, by keeping confidential the password you use to access to the Sites, Products and Services.
Freshmile will never contact you to ask for your password, except in the normal process of logging into your account.
Data transmission is protected by the use of secure servers using encryption technologies such as SSL (Secure Sockets Layer). This protects the data from loss, destruction, manipulation, or unauthorised access by third parties.
The security measures taken evolve as technology improves. Browsers themselves display information proving that encryption technologies are correctly implemented on the Sites.
Although Freshmile makes its best efforts to protect personal data, Freshmile cannot guarantee the security of the data during its transmission from the user to Freshmile.
Article 11 – Caution
Freshmile recommends that users keep their login details carefully and not to reveal them to third parties. When a personal computer or other machine is used by several people, users are advised to log out after using the Sites, in order to ensure that communication with Freshmile has been completed.
Freshmile advises to follow the best practices recommended by the CNIL for the creation of passwords.
More information: https://www.cnil.fr/fr/generer-un-mot-de-passe-solide
Article 12 – Cookies
When Internet users browse sites, some information may be stored in the form of a file on the user’s machine. This information is called a cookie.
What is a “cookie»?
A “cookie” is a piece of information, usually small and identified by a name, that may be sent to your browser by a website you are visiting. Your web browser will store it for a certain period of time and send it back to the web server each time you log on again. Cookies have many uses: they can be used to memorise your customer ID on a commercial site, the current contents of your shopping basket, an ID that allows your browsing to be tracked for statistical or advertising purposes, etc.
Learn more about cookies and how they work
When you access the Freshmile website, strictly necessary cookies are stored (choice of language, connection etc.). These cookies allow the main services of the site to function in a best way. You can technically block them by using your browser settings but your experience on the site may be degraded.
The Freshmile website does not set any cookies to track users for audience analysis or advertising targeting.
Article 13 – Use of external analysis tools and links to third party services and content
Freshmile uses services and content provided by third parties within its Sites, Products and Services. Freshmile’s interest is to improve the services offered to users.
Third party content providers may use users’ IP addresses to send information to their browsers. This use of IP addresses is necessary for the display of third-party content. For statistical or marketing purposes, third parties may use tracking devices, information about which is stored in cookies on users’ machines.
Users are advised that they are entirely responsible for disabling tracking features on the Sites. Centralized control of users’ tracking preferences is not possible. An explanation is given below for each tracking feature.
Google Analytics et Google Maps
Users can prevent the storage of cookies in the settings of their web browser. In this case, the full functionality of the Sites may not be available.
The Sites use Google Analytics reports for demographic analysis. The corresponding data cannot be directly linked to the identity of an individual. They can be deactivated at any time in the browser settings.
The collection and storage of data can be revoked at any time with immediate effect. However, to make the revocation permanent, the browser must accept cookies. Another method is to use the browser add-on for deactivating Google Analytics.
The Sites use elements provided by Twitter Inc, 795 Folsom St., Suite 600, San Francisco, CA 94107 USA (“Twitter”).
When users “tweet” Freshmile content, their personal data are processed and stored by Twitter. This data may include the IP address, browser type, operating system, address of the originating web page, date, and time of the visit, as well as data otherwise transmitted by the user to Twitter. Freshmile has no influence on the processing and storage of data by Twitter. Users can control the use of their data in their Twitter account settings and in their phone settings.
For more information: https://twitter.com/fr/privacy
Freshmile uses maps from the OpenStreetMap Foundation, 132 Maney Hill Road, Sutton Coldfield, West Midlands, B72 1JU, UK. The data processed may include the user’s IP address and geographical location provided the user has given permission for this to be done.
For more information: https://wiki.openstreetmap.org/wiki/Privacy_Policy
Article 14 – How to exercise your rights
You have the following rights:
- Right of access: you have the right to know what personal data about you is held by Freshmile and to request a copy of it, as well as to request information about the purpose of this processing;
- Right to rectification: you have the right to obtain the rectification of personal data concerning which are inaccurate, and in certain cases the deletion or limitation of their processing;
- Right to object: you may object to the processing of your personal data for the purpose of prospecting;
- Right to restrict processing: you have the right to request the restriction, in certain cases, of the use of your personal data;
- Right to erasure: you can request the erasure of your personal data (under certain conditions);
- Right to data portability: where applicable, you have the right to receive a copy of the personal data you have provided to us (in a machine-readable format) or to have that data transferred to another company;
- Right to withdraw your consent: you may at any time withdraw the consent you have given for the use of your personal data where consent is needed.
- “Post-mortem” right: you have the right to define directives concerning the conservation, erasure, and communication of your personal data after your death.
To exercise the above rights or to obtain further information on these rights, you can contact Freshmile’s Data Protection Officer by post:
Data Protection Officer
Or by email to : email@example.com
Users may also address any complaints about the way Freshmile collects and processes your data to the competent authority. :
Commission Nationale de l’Informatique et des Libertés
3 Place de Fontenoy
75334 Paris Cedex 07