Personal data protection policy
Conditions valid on 28 January 2022
Article 1 - General
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 "websites"). Websites and services offered by third parties, to which links may be provided, are explicitly not covered. 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 we collect and process your personal data. It may be modified at any time, in particular to take into account the evolution of the technologies used, the publication of new services and new regulations, in which case the new version will be published on our websites.
Article 2 - Data controller
As part of its activities,
Tel: 03 69 24 67 32
Email : email@example.com
Freshmile is required to collect and process, as a data controller, personal data concerning you, in accordance with the General Data Protection Regulation.
Freshmile undertakes to respect the provisions of the 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 3 - Data relating to navigation on the websites
It is possible to browse the websites without giving access to personal data. However, all products and services offered by Freshmile (hereinafter the "Products and Services") may not be available without the prior transmission of personal data.
General browsing data is 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 is necessary.
The login information is anonymised and is used for statistical purposes and to improve the Products and Services. It is impossible to use the connection data to identify a specific Internet user.
Article 4 - Contact form
The websites offer 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 your 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 5 – Cookies
When users use the websites, some information may be stored in the form of a file on the user's machine, called a cookie. Cookies allow users to be recognised on a subsequent visit, to save their password for faster browsing or to adapt the websites to their interests.
Article 6 - Personal data collected and purposes of processing
The use of the websites, products and services offered by Freshmile may require the processing of personal data of the users, such as identification data (e.g. name, address, email address), usage data (e.g. consumption, billing) and correspondence data. This data is necessary for the proper performance of the products and services, except for data explicitly indicated as not required (e.g. certain fields in registration forms).
Freshmile uses your personal data for the following purposes
- Creating and managing a user account
- Commercial relationship: management of the customer relationship (complaint, support...); management of the payment means, use of the top-up service
- Communication : sending newsletters about our products and services
Your data relating to charging sessions is also collected and kept for anonymous statistical purposes and to improve our services. This data is stored and processed anonymously, i.e. without any link with the identity of the users.
Article 7 - Personal data collected and purposes of processing in the context of partnerships
In the context of the processing of personal data carried out by Freshmile in the framework of a partnership with a partner company, Freshmile and the company concerned act as non-joint data controllers.
The use of the websites, products and services offered by Freshmile in the framework of this partnership requires the processing of the personal data of the beneficiaries as presented in article 6.
In the context of the use of Freshmile services for business purposes, some personal data may be shared with the partner company for service monitoring and billing purposes.
For more information on how their data is processed, the beneficiaries of these partnerships can refer to the information notice they received upon registration.
Article 8 - Mobile application usage data
In the particular case of mobile applications, information is transmitted during the download to the third party entity 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 in order to propose a relevant display. This provision of the geographical position can be deactivated by the user in the settings of his phone. 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 online payment systems made available are provided by third parties, who apply their own personal data policy.
Article 9 - Evolution of products and services
Freshmile also uses some data related to the use of the service in an anonymised form for statistical purposes in order to assist in the development of new Products and Services.
Article 10 – Newsletters
Users have the possibility to subscribe to newsletters. The personal data linked to this, such as the name and address entered in the registration form, may thus be used for the purpose of sending newsletters.
The newsletters may contain tracking devices such as web beacons or web beacons. These may be used to compile statistics about online marketing campaigns and to improve the newsletters. These data are anonymous and do not allow the identification of Internet users.
Article 11 - Recipients and categories of recipients of personal data
Only Freshmile's staff who need to have access to personal data to perform their tasks have access to them.
Some external service providers to Freshmile may also have access to data in order to carry out the tasks entrusted to them by Freshmile, such as: IT service providers, billing service providers, printers, consultants, installers or maintainers.
In addition, Freshmile may be required to disclose user information by law, as a result of an external request for information, or as necessary to perform the products and services. In these circumstances, recipients of personal information may include, for example, electricity distribution network operators, energy suppliers, accountants, auditors, public administrations, courts, lawyers or notaries.
In all cases, Freshmile ensures that only those third parties who need access to personal data to fulfil their missions have access to it.
Freshmile will never sell personal data to third parties.
Article 12 - Retention and destruction of data
Personal data are deleted as soon as they are no longer necessary for the purposes for which they were collected and processed, there is no pending claim, there is no legal obligation to retain them or any other legal provision requiring retention.
Data that has been previously anonymised for statistical and service improvement purposes is stored for as long as it is required for these purposes.
Article 13 - Data transmission security
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 14 - Precautionary measures
Freshmile advises users to keep their login details carefully and not to reveal them to third parties. Where a personal computer or other machine is used by more than one person, users are advised to log off after using the websites 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.
For more informations : https://www.cnil.fr/fr/generer-un-mot-de-passe-solide
Article 15 - 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 and 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 then stored in cookies on users' machines.
Users are informed that they are solely 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 and Google Maps
Users have the option to prevent the storage of cookies in their web browser settings. In this case, the full functionality of the websites may not be available.
The Sites use Google Analytics reports for demographic analysis. The corresponding data cannot be directly linked to a person's identity. 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, in order for the revocation to be 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 is processed and stored by Twitter. This data may include 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 16 - Questions relating to the protection of personal data
You have the following rights:
- Right of access: you have the right to know what personal data we hold about you and to request a copy of it, as well as to request information about the purpose of the processing;
- Right of rectification: you have the right to obtain the rectification of personal data concerning you which are inaccurate, and in certain cases the erasure or restriction of their processing;
- Right to object: you may object to the processing of your personal data for the purposes of prospecting;
- Right to limit processing: you have the right to ask us to limit our use of your personal data in certain cases;
- Right to erasure: you can ask us to erase 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 required.
- Post-mortem right: you have the right to define directives concerning the conservation, deletion and communication of your personal data after your death.
To exercise the above rights or to obtain further information about these rights, you can contact Freshmile's Data Protection Officer by post:
Data Protection Officer
Or by email : firstname.lastname@example.org
Users may also address any complaints regarding 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