Privacy Policy

Privacy Policy

As of 1st July 2018

Article 1 – Preamble

Freshmile Services SAS (hereinafter “Freshmile”) takes privacy seriously. Procedures applied by Freshmile guarantee that your rights are respected.

This Privacy Policy covers all web sites, web applications and mobile applications provided by Freshmile (hereinafter the “Sites”). Sites and services provided by third parties are not covered by this Privacy Policy, including links referring to such third parties. Freshmile is not responsible for any harm to personal data that would result from the visit of such third-party sites or third-party services.

Article 2 – Data processing responsible

The responsible for data processing is:

Freshmile Services SAS
Aéroport Strasbourg
Bâtiment Blériot
67960 Entzheim
France
Tel: +33 3 88 25 70 58
Email : web@freshmile.com

Freshmile commits to respect the French laws and regulations as well as the General Data Protection Regulation of the European Union.

Freshmile reported the appointment of a Data Protection Officer to French agency CNIL (declaration n°DPO-1449).

Article 3 – Data related to use of Sites

It is possible to use the Sites without granting access to personal data. However the whole products and services provided by Freshmile (hereinafter the “Products and Services”) may not be available without prior transmission of personal data.

Browsing activity data such as IP address, web browser, operating system, date and time of visit are recorded. Personal data such as name, address or email address are registered and processed only if the user contacts Freshmile to use the Products and Services and if such data is required.

Connection information are anonymised and are used for statistical purpose and improvement of Products and Services. It is impossible to use connection information to identify a user in particular.

Article 4 – Contact form

The Sites include contact forms. When using a contact form, the data provided by the users are recorded in order to process the demands.

Article 5 – Data transmission security

Transmission of data is protected by the use of secured servers using encryption technologies such as SSL. Data are thus protected against loss, destruction, manipulation or unauthorized access by third parties.

Security measures evolve with technological evolutions. Web browsers display information proving that encryption technologies are correctly put in place on the Sites.

Although Freshmile makes its best efforts to protect personal data, Freshmile is not able to guarantee the security of data during transmission from the users to Freshmile.

Article 6 – Care

Freshmile recommends to take care of credentials and to not disclose them to other people. When a personal computer or any other device is used by more than one person, it is recommended to disconnect after use of Sites, as to make sure that any communication with Freshmile has been terminated.

Freshmile recommends to follow best practices for a safe password: 12 characters, including lower case, upper case, figures and symbols.

Article 7 – Cookies

When using Sites, some information may be stored in the form of a file in users’ computers, called cookie. Cookies allow to recognize users for following visits, in order to record their credentials for quicker navigation or adaptation of Sites to their interests.

Users can refuse cookies by setting up their web browser accordingly or by erasing cookies stored in their machines.

Article 8 – Goals of personal data processing

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

In the particular case of mobile applications, data are transmitted when downloading the applications to the third-party entities managing the applications catalogues (ex: Apple, Google).

Freshmile has no influence on data transmitted to these applications catalogues managers and is not responsible of the use made of data by these third parties.

When using mobile applications, the users locations can be retrieved in order to offer an adapted display of information. Access to this data can be denied by users by adapting the settings of their mobile phones. The performance of mobile applications may decrease as a result.

Users can also use the mobile applications in anonymous mode, i.e. without prior registration nor transmission of identification data.

Online payment systems are run by third parties, which apply their own privacy policies.

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 10 – Advertisement and evolution of products and services

Personal data can be used to advertise Products and Services, only in relation with electric mobility. In order to offer adapted Products and Services, Freshmile may complete data sets with other data at its disposal.

Freshmile also uses data in an anonymised way for statistical purposes, for instance in order to develop new Products and Services.

Article 11 – Newsletters

Users can subscribe to newsletters. Personal data linked to newsletters, such as name and address given in the subscription form can thus be used to send newsletters.

Newsletters may contain tracking mechanisms such as web beacons. These mechanisms help build statistics linked to online marketing campaigns and newsletters improvement. These data are anonymous and cannot lead to the identification of users.

Article 12 – Recipients and categories of recipients of personal data

Only Freshmile staff needing access to personal data to perform their duties have access to personal data.

Some external contractors may have access to data in order to carry out the tasks given to them by Freshmile, such as: IT providers, billing providers, printers, consultants, installers and maintainers.

Moreover, Freshmile may be required to communicate information linked to users by law, on external request from information or for any reason related to the execution of Products and Services. In these conditions, recipients of personal data may be for instance electrical grid network operators, energy providers, accountants, auditors, public authorities, courts, lawyers or notaries.

In any case, Freshmile ensures that only third parties needing access to personal data to perform their duties have access to personal data.

Freshmile does not commercialise any personal data to any third party.

Article 13 – Recording and destructing data

Personal data are erased as soon as (i) they are no longer necessary to the purpose for which they have been collected or processed, (ii) there is no ongoing claim, (iii) there is no legal obligation to keep the records.

Data which have been previously anonymised for statistical purposes or for the purpose of improving services can be stored as long as they are necessary to these ends.

Article 14 – Opposition right

Users may oppose at any time to the usage of their data or cancel at any time any prior autorisation they would have given to the use of their data. The contact details are given in Article 2.

Cancellation of authorisations does not apply retroactively. Hence data processed before cancellation are not concerned. The information collected before the cancellation are kept according to Article 13.

Article 15 – Modification right

Users are entitled to ask for modification of their personal data. The contact details are given in Article 2.

Article 16 – Data portability

Users are entitled to ask for an extract of their data, which are provided as an electronic file sent by email. The contact details are given in Article 18.

Freshmile answers requests for data portability within 90 days.

Article 17 – Use of external analytical tools and links with third-party services and contents

Freshmile uses services and contents provided by third parties within its Sites and Products and Services. Freshmile’s goal is to improve services offered to clients.

Providers of external content may use IP addresses of users to send information on their web browsers. This use of IP addresses is requested to display external content. Third parties may use tracking mechanisms for statistical or marketing purposes and store information in cookies stored in the users’ machines.

Users are informed that they are sole responsible for the de-activation of tracking mechanisms on the Sites. A centralised control of users’ preference in this matter is not possible. Further explications are given hereunder for each tracking mechanism.

Google Analytics

Sites use Google Analytics, a service provided by Google LLC (hereinafter “Google”).

Google Analytics uses cookies stored on users’ computers, allowing the analysis of Sites usage. Through cookies, usage information are generally transmitted to Google’s servers in the United States, where they are processed and stored. Tracking codes use the “_anonymizeIp()” function, so that IP addresses located in the European Union and in the European Economic Area are shortened, in order to prevent any direct identification of users. Exceptionally, addresses may be transferred in full before being shortened by Google in the United States. Freshmile authorizes Google to use this information to build activity reports. Information related to IP addresses within Google Analytics are not reconciled with any other data collected by Google.

Users can prevent the storage of cookies when setting up their web browser. In this case, all features of Sites might not be available.

Sites use reports from Google Analytics for demographic analyses. Corresponding data cannot be directly linked to a person’s identity. This data can be de-activated at any moment in the browser parameters.

Data collection and storage can be cancelled at any moment with immediate effect. However, for the cancellation to be permanent, the web browser must accept cookies. Another method is to use the complementary module for de-activation in web browsers of Google Analytics.

Twitter

Sites use components provided by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107 USA (hereinafter “Twitter”).

When users “tweet” contents from Freshmile, their personal data are processed and stored by Twitter. These data main include IP address, browser, operating system, web page address, date and time of visit, as well as data transmitted by any other means by users to Twitter. Freshmile has no influence on data processing and storage performed by Twitter. Users can control how Twitter uses their data in the parameters of their Twitter account and of their phone.

More information on https://twitter.com/fr/privacy

OpenStreetMap

Freshmile uses maps provided by the OpenStreetMap Foundation, 132 Maney Hill Road, Sutton Coldfield, West Midlands, B72 1JU, UK. Data processed may include IP address and location of users, as long as users gave their authorisation to this end.

More information on https://wiki.openstreetmap.org/wiki/Privacy_Policy

Article 18 – Questions related to privacy

For any question or claim related to privacy, users can contact the Data Protection Officer at Freshmile.

Freshmile Services SAS
Data Protection Officer
Aéroport Strasbourg
Bâtiment Blériot
67960 Entzheim
France

Users can also contact the relevant French agency:

Commission Nationale de l’Informatique et des Libertés
3 Place de Fontenoy
TSA 80715
75334 Paris Cedex 07
France