PRIVACY POLICY - USERS

Once you register and use our services, either via the Website or the "Chauffeur Privé" Mobile Application (hereinafter together referred to as the "Services"), we collect and process certain personal data about you. This Privacy Policy explains what personal data we collect from you and for what purposes, as well as providing information about how such data is used and the rights you are entitled to with respect to the data processing we carry out.

In accordance with this Privacy Policy, "Personal Data" means any information relating to an identified or identifiable natural person, as defined by the relevant applicable law. For all due purposes, an "identifiable natural person" is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person

This "Client Privacy Policy" applies to the collection and processing of the personal data of the Client Users of our Services ("you"). It does not apply to personal data relating to the Chauffeurs, transport companies or other partners, who fall under the "Confidential Policy - Chauffeurs".

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:

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:

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:

Sharing of personal data

We may share your personal data with:

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.

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:

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: partenaires@chauffeur-prive.com 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).

Changes to the Privacy Policy

We may change this Privacy Policy from time to time. Therefore, we recommend that you visit this page periodically. In the event of a significant change in the conditions of collection and processing of your personal data, we will notify you directly by email or via a specific note within our Mobile Application or on our Website.

Contact

In order to exercise your above mentioned rights and for any other question, you may contact us through the following ways: