Transcovo SAS, a simplified joint-stock company, with its head office at 4 Place du 8 mai 1945 - Immeuble Le Hub, 92300 Levallois-Perret; registered at the Commercial Registration Office of Nanterre under the number 532 112 315 ("we"), is the data controller of your data
Collected personal data
Personal data you provide us. We collect the personal data that you provide directly to us, including signing up to and modifying your account, as well as when using our Services. The categories of data concerned are as follows:
- Identity data: this information may include your first name, surname, your phone number, email address, or postal address;
- Bank data: this information is processed for the purposes of your journeys and for combating fraud. They are passed on to the payment service providers we work with. Except for the purposes of proof of payment, this data will be retained until the closure of your account and/or the expiry of the validity of the credit card data. The retention of this data relates only to the last four digits of the credit card and its expiry date.
Personal data collected when using our Services. We also collect other types of personal data about you when you use our Services. The categories of data concerned are as follows:
- Location data: in order to provide our Services, we need to collect the satellite location data relating to the mobile device that you use to access the Chaffeur Privé application. Such collection may begin as soon as we have received permission to access this data by the operating system of your mobile device. In any case, we collect the satellite location data relating to the mobile device used by your Driver during the ride you ordered. We may also estimate your location based on the analysis of your IP address (only at the city level where you are located).
- Data of the rides undertaken: we collect certain data relating to the rides that you order via our Services: date, time, addresses of pick-up and destination (which you can provide us directly or which can be inferred from the analysis of your location), price quoted and price paid, order status (completed or cancelled), as well as the rating you have the opportunity to assign and the comments you can leave regarding the ride and your Driver. We also track the total number of journeys completed.
- Transaction data: in addition to information about the payment methods you use, transaction data is collected by the payment service providers we work with. We also collect some of this transaction data, including information about authorisation requests and payments made: amounts, dates & times, and the result returned by our payment service providers.
- Loyalty and sponsorship: as part of our loyalty programme, we will award your account a number of points and a specific status according to your use of our Services (see our terms and conditions for more details). We may also link to your account the names of the people whom you sponsor or who have sponsored you.
- Technical and navigation data: we may collect several types of data relating to the technical terms by which you access our Services, as well as data relating to your use and browsing of our Services: name and version of the operating system of the mobile device used, IP address, date and time of last connection to our Services, settings and preferences, navigation data on the Mobile Application or the "Chauffeur Privé" Website. These different data can be collected, namely, by means of cookies and other similar techniques. For more details, please check our Cookies Policy.
- Personal data as a Driver: if you also use our Services as a Driver, we may associate the personal data that we have collected in this context with personal data relating to your use of our Services as a Client User. It is specified that the collection and processing of personal data relating to your use of our Services as a Driver is governed by our Confidential Policy - Driver.
Personal data disclosed by third parties. If you use our Services as part of our offers to companies, your employer, or more generally the company allowing you to benefit from our Services in this context, may give us certain personal data concerning you.
Use of your personal data
We use the personal data we collect for several purposes:
- Services Operations: firstly, the personal data we collect is necessary for the operation of the Services, particularly in the context of the planning and completion of the rides, the security of our systems, our support services, and lastly in order to communicate with you or to allow you to communicate with your driver;
- Services improvement: the data that we collect, in particular when using the Services, may be by Transcovo SAS for the purposes of the legitimate interests of commercial development and improvement of its knowledge of the Users, the security of our systems, as well as to offer new services or features
- Internal Management Services: we may use your personal data in the context of the legitimate interest of Transcovo SAS in combating fraud, or in order to prevent and remedy any malfunctions affecting our Services. Also as part of a legitimate interest in improving our Services, we may also use your personal data whether it be anonymous or not, in the context of analysis, statistics, or for the purpose of research and development operations;
- Commercial Communication & Promotional Operations: subject to your right to object, we may, in accordance with the legitimate interest of Transcovo SAS, use your personal data to notify you of offers, promotions, or any other commercial information relating to our Services or the services offered by our partners (in case you have agreed to share your data for this purpose). We may also use your data in the context of contests and other promotional activities, in particular to promote your participation (in case you have agreed to receive this type of communications from us) and to monitor and manage your participation (where applicable);
- Customization: subject in particular to the required consent regarding cookies and similar techniques contained in our Cookies Policy, we may use certain data to offer you, including through advertising, customized services and offers.
Sharing of personal data
We may share your personal data with:
- The drivers: in order to take care of you and undertake the ride you requested, the drivers will have access to your name, your surname, the characteristics of the requested ride (addresses, etc.), as well as your location if you have allowed us to collect this type of data. We have also put in place a mechanism allowing the drivers to call you at the number you have given us, without showing your respective phone numbers, in accordance with the principle of anonymization of calls. This mechanism thus exclusively makes it easier to take care of you and to keep you informed of any problem or incident, whenever necessary;
- Your employer (and similar): as part of our offers reserved for companies, we may be required to communicate certain data about you to your employer or more broadly to the company allowing you to benefit from our Services;
- Our group companies: we may share your data with the companies to which we are affiliated (parent companies, sister companies, or daughter companies), as part of the operation of the Services or for logistical purposes.
We may also share your personal data with other companies particularly in the context of merger, acquisition, sale of assets, or restructuring operations, subject to your prior notification and absence of opposition, in accordance with the applicable law.
More generally, we may share your data with any other third party, subject to your prior notification and to your absence of opposition or explicit consent, in accordance with the applicable law.
- Public authorities: we may be required to communicate your personal data in response to a specific request made by a competent administrative or judicial authority, and more generally in all situations where the law, the regulations, or an administrative or judicial decision requires it;
- Other third parties: in the context 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 proposed by us, subject to your prior consent
Fight against fraud
In order to guarantee, under a legitimate interest of Transcovo SAS, the quality and the security of our Services, we use two mechanisms to fight credit card fraud: (i) an internal system of suspicious behaviour detection by evolutionary algorithm, based on a profile drawn from the combination of your habits, so as to identify abnormal or unusual expenses in relation to your typical use of our Services. In such a case, you will be invited to contact the Chauffeur Privé client service electronically to discuss your situation together and, if necessary, to proceed with its correction. Your lack of response exposes you to the risk of no longer benefiting from our Services; and, (ii) the use of anti-fraud systems offered by our payment service providers.
This data will only be kept for the time necessary to eliminate the risk of credit card fraud.
In this context, we can carry out checks on the information you provide us (e.g. name, surname, email address, etc.) and may also ask the Drivers to verify your identity during the ride (by asking you to present an ID).
Authorisation mechanisms for mobile terminals
The operating systems of the most popular mobile terminals have a specific authorisation mechanism relating to certain data: location sharing, notifications, access to contacts, camera, etc. When you use our Services via a mobile device, you will be asked to give us your permission in this context, in particular regarding your location data.
For more information, we recommend that you consult the documentation made available by the operating system publisher of your mobile device.
Specifically, in what location is concerned, please not that if you turn off the satellite location sharing of your mobile device, you will no longer be able to use our Services as a User. In fact, access to this information is considered critical to the operation of our Services.
Storage period for your personal data
Your personal data will be stored in active files or systems only during the period of time necessary to fulfil the purposes for which they were collected, in accordance with the applicable law. That is:
- As a rule, for all your data: until the removal of your Driver Client account from our Services;
- Exceptionally,Specifically for purposes of electronic marketing, we may keep your email address, as well as your first and last name for a maximum period of three yearsone year after the last contact maintained with youcancellation of your Driver account on our Services, subject without prejudice to the possibility of the exercisinge of your right to objection at any time.
If you later decide to oppose the processing of your data for such communicationspurpose, we may retain your data for the period of time required up to three years in order to comply with your decision (and to provide evidence of such compliance), upon which your data will be deleted, unless it is necessary for any other purposes (e.g., the use of our Services).
For any other type of processing, we keep the personal data collected throughout our entire business relationship and, upon termination, for thea maximum periods permitted by law of three years for promotional purposes, as well as for proof fiscal and accounting purposes. In any case, your data may be archived for the duration of the applicable requirements.
Your rights regarding your data
In accordance with the applicable law, you have, if necessary after providing a valid identity document, a right of access, to data portability, to rectification, restriction of processing, and erasure of data concerning you and a right of objection to the processing of such data, although possibly subject to legitimate and compelling reasons that may require such processing of the data, You may also set the rules regarding the destination to be given to your personal data in the event of death. These rights may be exercised directly with Transcovo SAS by email at the following address: firstname.lastname@example.org or by simple letter to the following address: 4 Place du 8 mai 1945 – Immeuble Le Hub, 92300 Levallois-Perret.
Finally, you have the right to file a complaint with CNPD (Comissão Nacional de Proteção de Dados, the Portuguese Data Protection Authority).
In order to exercise your above mentioned rights and for any other question, you may contact us through the following ways: