FRED SAS (whose head office is located at 9 rue Gubernatis, 06000 Nice, France), attaches great importance to the protection and respect of your privacy. The purpose of this policy is to inform you of our practices regarding the collection, use and sharing of information that you may provide to us through our SITES www.fredapp.site and www.fredapp.fr or our Mobile APPLICATIONS known under the brand name “FRED”.
1. The information we collect
We may collect and process the following information:
2. The information you send us directly
By using our PLATFORMS, you are required to send us information, some of which is likely to identify you (“Personal Data”). This is notably the case when you fill out forms (such as the registration form) and when you contact us, whether by telephone, e-mail or any other means of communication
- Your first and last names, e-mail address, date of birth, gender, telephone number and password. This information is mandatory. Without which, the COMPANY will not be able to provide you with the services offered via THE SITE and THE APPLICATION and you will not be authorized to create an account;
- A photograph ;
- A mailing address ;
- Information about your vehicle ;
- Your mini-biography ;
- A copy of all exchanges between you and the COMPANY ;
- A copy of all reservations or publications made through the SITE and/or THE APPLICATION ;
- The details of financial or accounting operations carried out via the WEBSITE and/or the APPLICATION or by any other means, containing in particular information relating to your payment card, your bank details, information relating to the journeys booked via the WEBSITE and/or the APPLICATION;
- Details of your visits to the WEBSITE and/or APPLICATION and the contents you have accessed ;
- Where applicable, your answers to our surveys and questionnaires and the opinions you have left to evaluate a journey made, this information being particularly likely to be used in the context of research and analysis of PASSENGER, DRIVER and PARTNER behaviour;
- The data we may ask you to provide when you report a problem with our services, such as the purpose of your support request;
- The data related to your location when you have agreed that we collect and process this data ;
- A copy of your passport, driver’s license, identity card or any other similar document that you have agreed to provide us ;
- Data relating to your insurance subscriptions and waivers, if any, and a copy of the declarations made and forms completed for the purposes of subscriptions or contract management or claims reporting.
3. The data we automatically collect
- In the event that you connect to our services using the social network functionalities made available to you, the COMPANY will have access to some of the data (in particular, your first name, surname, photograph, e-mail address and number of friends) of your account on the said social network concerned. We may also collect some of your Personal Data when you interact with features of these social networks, such as “Like” features;
- FRED collects location data from DRIVERS mobile device when the APPLICATION is running in the foreground (app open and on-screen) or background (app open but not on-screen). Location data helps improve our services, including PASSENGER pickups, navigation, and customer support.
- We also collect information about your use of our SITE and APPLICATION (your registration date, average number of notices received, etc.) which may be displayed on your public profile ;
- Finally, we collect technical information about the model of your vehicle when you send us your license plate number in order to facilitate the completion of the form describing your vehicle. This information is collected by querying the database produced by the company DataNeo (dataneo.fr) from information transmitted by the Ministry of the Interior under a license to reuse data from the Vehicle Registration System in application of Article L.330-5 of the French Highway Code ;
Upon proof of your identity and if the conditions for exercising these rights are met, you may exercise your rights of access, right of rectification, right of deletion, right to limit processing, right of opposition, right to file a complaint with the CNIL and your right to determine the fate of your data after your death by writing to DataNeo firstname.lastname@example.org or DataNeo – 6-8-10, rue Troyon – 92310 Sèvres) or by contacting us directly (see article 14.12 below).
4. How long your data will be kept
- With the exception of the categories of Personal Data referred to in articles 4.2. and 4.3. below, your Personal Data are archived at the end of the following periods :
- 5 years after your last use of our SITE and/or APPLICATION, if you have not closed your account ;
- 1 year after the closure of your account, unless you have received a negative notice or a report, in which case your data will be kept for 2 years following the last negative notice or report received, whichever is longer.
- Financial data (e.g. payments, reimbursements, etc.) are kept for the duration required by applicable tax and accounting laws ;
- The data collected within the framework of the subscription to insurance products are kept for the duration of the subscribed insurance contract and the duration necessary for the management of your claims if necessary;
- Contents created by you on our SITE and/or APPLICATION (such as ratings) are made anonymous after the deadlines mentioned in 14.5.1. but remain visible on our SITE and/or APPLICATION.
5. Use of your personal data
We use the personal data we collect for several purposes:
- Operation of the Services: first of all, the personal data that we collect is essential to the operation of the Services, in particular in the context of the planning and execution of the rides, the security of our systems, our assistance services or in order to communicate with you or to allow you to communicate with the DRIVERS and/or PASSENGERS ;
- Improvement of the Services: the analysis of the data we collect, in particular during the use of the services, may be used to improve the services, the security of our systems, and to propose new services or new functionalities;
- Internal management of the Services: we may use your personal data in the context of our anti-fraud operations, or to prevent and repair malfunctions affecting our services. We may also use your personal data, anonymously or not, for analysis, statistics or research and development;
- Commercial communication & promotional operations: we may use your personal data in order to send you offers, promotions or any other commercial information relating to our services or the services of our partners if you have agreed to the sharing of your data for this purpose. We may also use your data for contests and promotions, including to offer you the opportunity to participate in them (if you have agreed to receive such communications from us) and to track and manage your participation where appropriate;
- Personalization: subject in particular to the provisions relating to cookies and similar techniques contained in our policy on cookies and similar techniques, we may use certain data in order to offer you, in particular through advertising, personalized services and offers;
- Compliance with the legislation in force: we are required to keep certain information about you in application of the laws and regulations relating to the road transport of persons. This concerns in particular your driver’s license number as well as information concerning your VTC professional card or concerning the insurances that you take out.
6. Sharing of personal data
We may share your personal information with :
- PASSENGERS: PASSENGERS will have access to your first and last name, your photograph, as well as data relating to the category of vehicle you are driving, the average grade assigned to you by all your previous passengers, your satellite location, and characteristics relating to the vehicle you are driving (in particular the license plate). This information will be communicated to the PASSENGERS when their order has been validated, during the duration of the ride, and then within the summary invoice of the ride, sent by e-mail to the PASSENGERS. The PASSENGERS also have a mechanism that allows them to call you at the number you have communicated to us in order exclusively to facilitate the handling of your order and to keep you informed of any problem or incident if necessary;
- The COMPANIES of our GROUP: we may share your data with the COMPANIES to which we are affiliated (parent companies, sister companies or daughter companies), within the framework of the operation of the services or in particular for logistical purposes;
- Public authorities: we may be obliged to communicate your personal data in response to a specific request made by a competent administrative or judicial authority, as well as more generally in all situations where the law, regulation or an administrative or judicial decision requires it;
- Other third parties: as part of specific offers and services to which you have specifically subscribed, as part of other applications or websites connecting to our services through an API offered by us, subject to your agreement. More generally, we may share your data with any other third party after informing you and subject to your absence of opposition or your prior consent in accordance with the applicable rules.
7. Transfer of personal data outside the European Economic Area
We may transfer your personal data outside the European Economic Area for storage and/or processing. Some of these countries may have data protection laws that are less protective than those in force in the European Economic Area. Where this is the case, we will take all necessary measures in accordance with the applicable legislation.
8. Authorization mechanisms for mobile terminals
The operating systems of the most widespread mobile terminals have a specific authorization mechanism for certain data: sharing of location, notifications, access to contacts, camera, etc. When you use our services via a mobile device, you will be asked to give us your authorization in this context, in particular with regard to your location data. For more information, we recommend that you consult the documentation provided by the publisher of the operating system of your mobile device.
Regarding location in particular, please note that if you disable the sharing of satellite location on your mobile device, you will no longer be able to use our services as a DRIVER. Indeed, access to this information is essential to the operation of our services.
9. Your Rights
You have the right to access, rectify and delete your personal data. You also have the right to oppose their processing for legitimate reasons.
Finally, in accordance with Law No. 2016-1321 of October 7, 2016, you may define guidelines for the storage, deletion and communication of your personal data after your death.
You may exercise all of these rights by referring to the “Contact” section below. You can also modify your personal information at any time within the parameters of your account on our services.
To exercise your rights as mentioned above, and for any other question, you can contact us at the following addresses:
E-mail : email@example.com
Postal address : FRED – 9 rue Gubernatis, 06000 Nice, France