Privacy Policy

V1.0

Privacy policy related to products and services purchased or subscribed to as from 01/03/19

INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA

Who is responsible for the processing of your personal data?

The person responsible for the processing of your personal data is our company (hereinafter referred to as “We”): VEL’CO, a simplified joint-stock company registered with the Nantes Trade and Companies Register under number 819 556 168, having its registered office at 168, route de Saint Joseph in Nantes (44300). We manufacture and publish mobility solutions consisting of a product (hereinafter referred to as the “Product”) associated with an application accessible on the web, on Android, and iOS mobile devices (hereinafter referred to as the “Application”). Our navigation solutions collect and process personal data about you. We explain in this document what personal data we collect, for what reasons, and what we do with it. We also explain what your rights are regarding your personal data, and how you can exercise them.

What personal data do we collect?

When you create an account on our Application (hereinafter referred to as the “Account”), we collect the following personal data, which we absolutely need: surname, first name, gender, date of birth and email address. We also collect the following personal data if you provide it to us voluntarily in order to enable us to optimise our quality of service: telephone number and country code, postal address. We also collect at least one, and up to three, phone numbers if you choose the accident alert service. (Hereinafter referred to together as the “Administrative Data”).

Your Account is automatically associated with the serial number of your Product when it is initialised via the Bluetooth connection with your mobile phone, but the administrative data is held separately from the data emanating from the Application and the Product, as detailed below, said data being on two different servers in order to ensure security. We also collect the following data via the App: nickname (name given to your bike), location, status (stopped, on the move, stolen etc.) and speed. If you subscribe to a paid service (with or without a free trial period) in addition to the basic services, the following data is also obtained via your Product: Product serial number, location, status (stopped, on the move, stolen, etc.), speed, orientation (normal, on its side, upside down etc.), brightness, temperature, battery level and MAC address of the handlebar Bluetooth module. (Hereinafter referred to together as the “Technical Data”). Such Technical Data is not strictly personal data. However, we consider it personal data because some data may be used to identify you or because it is associated with your Account to the extent that you use the services for which it is needed. We also collect the following data about your bike, if you give the information voluntarily in your Account: make, model, serial number, colour, bicycode and photograph of your bike (hereinafter referred to as the “Bike Data”). This is not personal data insofar as, in principle, it does not allow you to identify yourself. However, we also consider it personal data as long as it concerns your bike.

Why do we collect your personal data (purpose of the processing)?

We collect your Administrative Data to manage the contractual relationship with you, in particular to ensure the performance of the contract entered into with you, to manage your Account, to provide you the functionalities of the Application, to communicate with you within the framework of the provision of these features and basic or additional services, to inform you about our products or services similar to your Product, our Application or the services you use, and to invoice for paid services and to monitor the payment of our invoices. Basic services include call and SMS notification, navigation, lighting, alarm, trip statistics, and bike identification sheet. Additional services are geolocation in case of theft, the alert of relatives in case of accident, and connected guided tours. We also collect your Technical Data and Bike Data to manage the contractual relationship with you, in particular to encure the performance of the contract entered into with you and to provide you with the functionality of the Application, as well as the basic services and additional services you have chosen, and to optimise the safety of your bike. We also collect certain Technical Data to perform completely anonymous statistics for our own specific needs, or which we provide to our contractors.

What authorises us to collect your personal data (basis of processing)?

The processing of your personal data is based on the fact that it is necessary for the performance of the contract entered into with you, in particular to provide you with the Account, the functionalities of the Application, and the basic and complementary services. The processing of certain personal data (date of birth) is based on the fact that it is necessary for compliance with our legal obligations. The processing of certain Technical Data for the purposes of anonymous statistics is based on our legitimate interest in compiling and using these anonymous statistics.

Who are the recipients of your personal data?

The recipients of your personal data are the employees of our support service, who are in charge of managing the contract entered into with you. Employees of our department in charge of the management of our Application and its operating environment are also likely to access your personal data indirectly as part of their administration and maintenance operations, as well as employees of our hosting provider, in exceptional cases. Your basic administrative data may be communicated to our insurance partners, if you subscribe to our connection service with them. In addition, anonymous statistics compiled from certain Technical Data are provided to our departments, which analyse them, and to our contractors.

How long will we keep your personal data?

We keep your personal data for the duration of our contractual relationship and, for your Administrative Data, for three years from the end of our contractual relationship. Beyond these terms, we keep, in intermediate archives under a pseudonym (not nominative), the data which is necessary to carry out and prove our rights and obligations, during the term of the applicable limitation periods, or according to the legal obligations to which we are subject. In all other cases, the data will be deleted or anonymised for statistical purposes for certain Technical Data.

Where is your personal data stored?

We store your personal data on the servers of our hosting provider, OVH FRANCE, whose servers are located in France, so that your personal data benefits from the level of protection existing within the territory of the European Union.

How is your personal data protected?

We are committed to protecting your personal data. This is why we have implemented ways to ensure its security and confidentiality, including the following:

Administrative Data and Technical Data is stored on different servers;

Communications between our Application and our servers are encrypted;

Communications between your Product and our servers are also encrypted;

Access to your personal data is restricted to the employees of our support service, and is made via our intranet with access control;

The employees of our support service are subject to a contractual obligation of confidentiality;

Our databases are backed up daily.

What are your rights regarding your personal data?

In accordance with the legislation applicable in France to the protection of personal data, namely the law of 6 January 1978 relating to data, files and freedoms, as amended by subsequent laws, and the Regulation of 27 April 2016 on the protection of individuals with regard to processing of personal data and the free movement of such data, you may:

Request communication and, where appropriate, rectification or erasure of your personal data;

Request the limitation of the processing of your personal data;

Oppose the processing of your data;

Obtain a copy of your personal data in a structured and current format for transmission to another data controller;

To inform us of your specific instructions on the fate of your personal data in the event of death; otherwise, your heirs may assert their rights under applicable law.

You may have access to and correct or delete your Administrative Data and Bike Data in your Account, with the exception of mandatory Administrative Data which is not erasable. You may exercise any of the above rights by logging onto https://www.velco.bike/support, after providing proof of your identity.

The above rights are not applicable in all cases. We therefore invite you, before any request, to consult the applicable legislation to find out in which cases you can exercise one or the other of these rights. In particular, you may consult the information available on the website of the Commission Nationale Informatique et Libertés (CNIL – Commission for Information Technology and Civil Liberties), or any other competent supervisory authority. We will be entitled to charge you fees related to the exercising of these rights, including performing a retrieval or a copy of your personal data, in case of unjustified or excessive request.

In addition, we may suspend or terminate your Account, or terminate the contract with you in the event that we no longer have the personal data necessary for its performance as a result of the exercising of these rights. You also have the right to lodge a complaint with the Commission Nationale Informatique et Libertés (CNIL) or any other competent supervisory authority in case of a dispute concerning the above processing of your personal data.

Short version for posting to account creation

We collect various personal data about you, including your surname, first name and email address, to manage the contractual relationship with you, in particular to ensure the performance of the contract entered into with you, to manage your account, to provide you with the functionalities of our application, to communicate with you in connection with the framework of the provision of these features and basic or additional services, to inform you about our products or services similar to the product you purchased, our application or the services you use and to invoice for paid services and to monitor the payment of our invoices.

In accordance with the applicable legislation, you can:

Request communication and, where appropriate, rectification or erasure of your personal data;

Request the limitation of the processing of your personal data;

Oppose the processing of your data;

Obtain a copy of your personal data in a structured and current format for transmission to another data controller.

You may exercise any of the above rights by logging onto https://www.velco.bike/support, after providing proof of your identity.

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