Your privacy is important to us.
Citybike Normandie, a simplified joint stock company with a capital of 1.000 €, whose registered office is located at 37 boulevard Charles de Gaulle 76140 LE PETIT QUEVILLY, registered with the Registre duCommerce et des Sociétés under number 951 939 396 («we», «us» or «our»), undertakes to respect the privacy and applicable data protection laws of the users («you», «your» or «yours») of the service (the «Service», as more precisely defined in the article «Definitions»).
This privacy statement (the «Statement») describes our method of collecting and using personal data in connection with your use of the Service, the website (the «Website») and your dealings with us, who are the joint data controller with Métropole Rouen Normandie within the meaning of European legislation on the processing of personal data.
Your terminal software may have access to your information. Our products or services may contain links to other company websites which have their own privacy notices. We therefore recommend that you read their privacy notices carefully. This statement applies only to the Service and the Website. You are under no obligation to provide us with your personal data. However, if you choose not to provide us with your personal information, we may not be able to provide you with our products or services or their full functionality, or to respond to your inquiries.
- «We», «us» or «our» refers to the company Citybike Normandie as designated at the head of the Declaration.
- «Service» means the self-service electrically-assisted bicycle service offered by Métropole Rouen Normandie, as defined in the General Conditions of Use of the LOVELO Self-Service Service to which said service is subject and which form an indivisible whole with the Declaration.
- «LOVELO libre-service» commercial brand name of Métropole Rouen Normandie.
- The "Application" refers to the program that can be downloaded free of charge and executed from the operating system (iOS or Android) of a smartphone or tablet. They enable any User of the Service to subscribe to or unsubscribe from the Service, find a nearby bike, unlock it, get hints on directions and ride status, report an issue with the bike, manage personal profile and contact Customer Support.
What information do we collect?
We collect your personal data and other information when you complete the various online questionnaires as part of your use of the Service, and the Website or when you answer questions that will be communicated by email, telephone, via the lovelo self-service application («the Application») or by any other means of communication and when you take part in a campaign, or survey or interact with us. This includes the following cases:
- Positioning and location data: location services establish the latter using satellite, mobile, Wi-Fi or other network positioning methods. These technologies may involve sharing your location data and unique mobile identification number, Wi-Fi or other network identifiers with us. Our products may work with different platforms, applications and services which may in turn collect your location data. We do not use this information to identify you personally without your consent.
Why do we process your personal data?
We may process your personal data for various purposes:
- Providing the Service: we may use your personal data to provide you with the Service, to maintain it, to process your requests and more generally to perform the contract between us and you, to ensure the functionality and security of our products and services and in particular the Service, to identify you in order to provide the Service as well as to prevent or investigate fraud and other malicious uses.
- Communicating with you: we may use your personal data to communicate with you, for example to inform you that our services have changed or to send you alerts about our products and/or services, to conduct surveys and to contact you via our customer service department.
- Marketing, advertising and referrals: we may contact you to inform you of new products or services, promotions that may be offered to you, after obtaining your consent, or if we are permitted to do so.
- Anonymized statistics: we may aggregate the GPS data of all users to provide statistics on travel habits, which will be made available to our partners. This aggregated data will be anonymized in accordance with the conditions laid down by current regulations on the protection of personal data.
We use your personal data with your consent or if necessary for the proper performance of the contractual relationship between us. We may also use your personal data when required by law or in our legitimate interest, for example to protect our customers, to safeguard the security of our products and services, or to 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 mentioned below:
- Your consent and social networking 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 invite you to be vigilant and to consult the personal data protection policies of these social networks in order to be fully aware of the information that is collected by these sites as well as the purposes for which your data is used, in particular for advertising purposes.
- Inurba group companies (Citybike Global) and authorized third parties: we may share your personal data with other Inurba group companies or authorized third parties, processing personal data for Citybike Normandie as set out in this Statement. This may include, for example, billing your network operator, or delivering personal batteries, providing services such as customer service, consumer data management and analysis, surveys, commercial management or other.
- We may conduct marketing campaigns and other communication methods in collaboration with our authorized third-party partners. In order to avoid duplicate and unnecessary communications, and to send you a message tailored to your needs, we may need to match data collected by Citybike Normandie with data collected by the partner where permitted by law.
- These third parties authorized by Inurba are not permitted to use your personal data for any purpose. We require them to act in accordance with this Statement and applicable data protection regulations and to employ appropriate security measures to protect your personal data.
- International transfers of personal data: our products and services may be provided using resources and servers located in various countries around the world. Your personal data may therefore be transferred beyond the borders of the country where you use our services, including countries outside the European Community which do not have laws providing specific protection for personal data, or which have different data protection laws. In such cases, we will take steps to ensure adequate protection for your personal data, in accordance with applicable law, by using agreements approved by the relevant authorities (e.g. the European Commission) and by requiring the use of technical and organizational information security measures.
- Compulsory disclosures: we may be required by law to disclose your personal data to certain authorities or other third parties, for example to law enforcement agencies 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 defend our legitimate interests, for example in the event of civil or criminal legal proceedings.
- Mergers and acquisitions: if we decide to sell, buy, merge or reorganize our activities in certain countries, this may involve us disclosing personal data to prospective or actual buyers and their advisors, or receiving personal data from sellers and their advisors.
How do we approach data quality?
We take all reasonable steps 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 only retain your personal data for as long as is necessary to fulfil the purposes described in this Statement or otherwise communicated to you, unless a longer period is required by law.
We encourage you to access your account to review your personal data from time to time to help us keep it up to date.
What measures are taken to protect your personal data?
Privacy and security are crucial to the way we create 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 selection of appropriate activities, including proactive and reactive risk management, security and privacy engineering, training and assessment. We take appropriate measures to address the risk of online security, physical security, data loss and other risks, taking into account the risk represented by the processing and the nature of the data being protected. We also restrict access to our databases containing personal data to authorized personnel with a justified need to access this information.
How can you manage/delete these cookies?
All major Internet browsers allow you to manage cookies installed on your computer or mobile device.
If you do not want our website to place cookies on your computer or mobile device, you can restrict or delete them easily by adjusting the settings on your browser or mobile device. In addition, you can arrange for your computer or mobile device to send you a notification each time you receive a cookie on your computer or mobile device, so that you can decide whether or not to accept it.
We alert all new users with a specific banner that cookies are used on our website. You can accept or reject them at any time. You can reset your choice at any time by clicking here. The cookie authorization banner will be displayed again the next time you log on.
What are your rights?
You have the following rights concerning the personal data we use about you:
- Access: you have the right to know what personal data we hold about you and to obtain a copy.
- Data portability: subject to the law, you have the right to obtain in machine-readable format the personal data you have provided to us.
- Rectification: you have the right to request that any incomplete, erroneous or out-of-date personal data concerning you be rectified.
- Erasure: you have the right to request the erasure of your personal data if it is no longer required to fulfil the purpose for which it was collected, if you have withdrawn your consent to the processing, if you have objected to the processing in accordance with the regulations on the protection of personal data, if the processing is unlawful or if there is a legal obligation to do so.
- Withdrawal of consent: you have the right to withdraw the authorization you have given us to use your personal data.
- Objection: you have the right to object to the processing of your 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 a legitimate interest pursued by us, on grounds relating to your particular situation. You may also object at any time to processing carried out for the purposes of commercial canvassing.
- Limitation: you have the right to request the limitation of the processing of personal data when you dispute the accuracy of your personal data subject to processing, if the processing is unlawful and you object to the erasure of your personal data, if you consider it useful or if you have objected to the processing, during our verification of the legitimacy of our interests.
- Post-mortem directives: you also have the right to define instructions concerning the conservation, erasure and communication of your personal data after your death.
If you wish to exercise any of your rights, you can let us know by contacting us at our contact e-mail address. If you are still not satisfied, you also have the right to lodge a complaint with a competent supervisory authority, namely, in France, the Commission Nationale de l'Informatique et des Libertés.
How long do we keep your personal data?
Your data will be kept for no longer than is necessary for the purposes set out in this Statement.
If your data is no longer required for the purposes set out in this Declaration, it will be regularly deleted or anonymized unless it is necessary to keep it longer:
- to ensure compliance with legal, accounting and tax retention obligations, i.e. 10 years ;
- to preserve evidence during applicable limitation periods, i.e. 5 years;
- for commercial prospecting purposes, i.e. 3 years from the end of our contractual relationship with you or from our last contact with you.
Furthermore, if we find that your user account has not been used for more than 2 years, we will delete your personal data.
What access authorizations does the Application require?
You are required to give the following authorizations to the Application to enable us to collect the data necessary for your registration and use of the levelo Service.
- Camera: authorization required to scan the QR Code identifying the bike.
- Location: authorization required to locate you on the map, to show you the position of nearby bikes and how to access them.
Modification of the Declaration
We reserve the right to modify this Declaration at any time, with or without notice. However, if our Declaration is modified, you will be notified by email, so that you can read it.
If you have any questions or requests concerning this Statement or in general concerning the way in which we process your data, you can contact us at the following e-mail address: email@example.com