top of page

privacy policy

Version 01 / 11 /2021

Data protection

 

MOBY LEAF, 17 Avenue Raoul Dufy, 06200 NICE, makes available to all users of the MOBY LEAF mobile application (hereinafter "the application") the following Privacy Policy, in order to provide information on how we process your personal data and protect your privacy.

 

MOBY LEAF recommends that users carefully read its Privacy Policy MOBY LEAF is thus committed to processing your Personal Data in compliance with applicable laws and regulations, and in particular the Law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, and the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

 

introduction

 

This Privacy Policy governs the processing of personal data collected by MOBY LEAF through the App and/or in the course of providing the App services (hereinafter "App services"), as described in the General Terms of Use.

 

The User warrants that the information provided is true, accurate, complete and up to date, being liable for any direct or indirect loss or damage that may occur as a result of failure to comply with this obligation. When the user provides personal data about third parties, he/she guarantees that he/she has informed them of the contents of this Privacy Policy and that he/she has obtained their prior consent to provide us with their personal data, in order to process them for the necessary purposes.

 

With regard to the personal data requested through the forms activated in the application, it is necessary that the user provides, at least, those that are considered obligatory, since otherwise MOBY LEAF will not be able to accept and manage the request.

 

MOBY LEAF may modify this Privacy Policy if necessary. If we change this policy, we will notify you through the Application, our website, or other means of communication to ensure that you are aware of the new privacy terms applicable to the Application's services.

 

If you continue to use the App services after we have informed you of the changes to our Privacy Policy, this will mean that you accept the new terms, except for those purposes for which your express consent is required.

 

 

Data Controller

 

Company name: MOBY LEAF, 17 Avenue Raoul Dufy, 06200 NICE, registered in the Trade and Companies Register of Nice, under number 903 564 706.

Phone number:  (7 days / 7, 24h / 24).

E-mail address: contact@freemob.fr

 

 

data processing

 

The personal data you provide may be processed by MOBY LEAF for any of the purposes below, depending on the type of data provided by the user, as well as the user's interactions with the application:

 

1. Registration of the user in the application and management of the platform supporting the application: the use of the services of the application is conditioned to the prior registration of the user in the application and, for some functionalities, to the submission of the relevant documents, as well as to the acceptance of the Terms of Use of the application and the Privacy Policy.

 

2. Management of the application: the use of the application may involve the processing of certain technical information about the users' mobile or other digital device, in order to enable its operation, as well as for incident management.

 

3. Customer service: MOBY LEAF will provide users with a customer service center regarding the use of the services of the application.

 

4. Fraud prevention: management and development of activities of control and prevention of fraud.

 

5. Prevention or identification of accidents or traffic violations: analysis of driving behavior and speed, detection of accidents or vehicle collisions, and alerting MOBY LEAF and the user in case of driving deemed dangerous.

 

6. Management of promotions: management of promotions and user participation, as well as provision of information on promotion activity to users and compliance with MOBY LEAF's legal obligations arising from promotions.

 

7. Anonymization of data: MOBY LEAF may anonymize the personal data of the users in order to comply with the legal obligations concerning security measures and to establish reports concerning the operation of the car-sharing service, market studies and profitability studies based on anonymous data, in order to increase the knowledge about the use of MOBY LEAF services and to improve the services of the application.

 

8. Data analysis (from internal and external sources): MOBY LEAF may conduct activity analysis and user profiling using internal and external data to improve the quality of the Application's services, including the development of predictive and mobility models.

 

9. Collection of information: carrying out surveys, satisfaction polls, studies or statistics to better evaluate the quality of its service and anticipate the needs of its customers within the framework of MOBY LEAF's legitimate interest to ensure the satisfaction and follow-up of its customers.

 

10. Marketing communications: MOBY LEAF may send communications to users in order to promote the use of the application and to share content related to the application's services.

 

11. Third party marketing communiqués:  MOBY LEAF may send commercial messages to users in order to promote third party products and/or services.

 

12. Profiling using internal sources: in order to provide personalized marketing communications tailored to users' needs, preferences and personal circumstances, MOBY LEAF may collect information about a user's use of its application services solely from internal data, and analyze the user's characteristics or behavioral patterns in order to place them in a certain category or group, and/or to make predictions or assessments about them. Internal data profiling may include operations to enable and improve the quality of application services.

 

13. Geolocation: In order to provide application services and to facilitate the provision of car-sharing services, MOBY LEAF may require users' geolocation data.

 

14. Compliance with legal obligations relevant to MOBY LEAF and related to the application services: compliance with the legal obligations of MOBY LEAF in relation to the application services and which require the use of user data.

 

 

cookies

 

What is a cookie?

 

A cookie is a small text file sent to your browser by the website you are visiting and stored on your terminal equipment. Cookies allow the website to collect information about your visit, such as your path through the site or your preferred language, in order to improve your browsing experience and the content and features of the website.

 

What cookies are present on the Site?

 

● Functional cookies: you are informed that during your visits to the Site,MOBY LEAF may install technical cookies on your terminal, allowing in particular to track your browsing without having to request authentication on each page. These cookies are automatically deleted by the browser when you close it.

 

● Audience measurement cookies: MOBY LEAF uses Google Analytics, statistical tools that may deposit cookies on your terminal, in order to carry out statistics relating 3 in particular to the number of visits, the number of pages viewed, the activity of users of the Site and their frequency of return. We inform you that all data collected through the use of these cookies are used anonymously by MOBY LEAF to improve the quality of the Site.

 

How can I disable the recording of cookies?

 

You have the possibility of refusing the recording of cookies on your terminal via your navigation software.

 

Depending on the browser used, you have the possibility to:

 

● List the cookies used for each site

● Delete the cookies saved

● Refuse the deposit of new cookies

 

MOBY LEAF informs you that functional cookies are necessary for the proper functioning of the site.

 

All major Internet browsers allow you to manage the Cookies installed on your computer or mobile device.

 

If you do not want our Website to place Cookies on your computer or mobile device, limit or delete them easily by setting your browser or mobile device.

 

In addition, you can set 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 to accept it.

 

origins and obtaining of the data processed by MOBY LEAF

 

The personal data processed by MOBY LEAF as a result of users' interactions with the application come from the following sources:

 

● personal data provided by users via the forms made available by MOBY LEAF to enable registration and use of the application and its services or any other form or via MOBY LEAF customer service.

 

● Personal data collected as a result of the use of the application by the user.

 

● Service usage data (type of driving, speed, etc.).

 

In particular, MOBY LEAF may process and receive the following categories of data:

 

● Identification and personal data (such as first and last name, driver's license number, e-mail address, postal address, telephone number, IP direction, etc.).

 

 

● Data related to the use of carsharing services (such as date and time of use of the carsharing service, incidents, etc.).

 

Legitimacy of MOBY LEAF concerning the processing of your personal data

 

MOBY LEAF processes users' personal data in accordance with the following legal basis, depending on the type of personal data provided, as well as the interactions established between the user and MOBY LEAF:

 

● The execution of the contract or the legal relationship established between MOBY LEAF and the users, in particular for the processing of users' geolocation data.

 

● Compliance with legal obligations (such as those provided by tax regulations and the highway code) related to the processing and possible transfer of data to administrations and competent authorities.

 

● The legitimate interest related to fraud prevention, MOBY LEAF marketing releases, profiling using internal sources and data anonymization.

 

● The user's consent, in relation to the performance of advertising and commercial prospecting activities concerning third-party products and services as well as data analysis using internal and external sources.

 

MOBY LEAF hereby informs that it will only process personal data for consent-based processing activities once the user has consented to a specific processing activity, through the means of obtaining consent made available by MOBY LEAF.

communication about your personal data

 

Personal data collected by MOBY LEAF through the application may be communicated to the recipients below, in accordance with the legal basis of the communication:

 

● support teams providing related services, such as billing or customer service.

 

● the competent public administrations, for compliance with tax obligations and for the identification of drivers in accordance with the regulations in force, among others.

 

● acquirers, successors or assignees of our company in connection with a merger, acquisition, debt financing, asset sale or similar transaction, or in the event of insolvency, bankruptcy or receivership in which information is transferred to one or more third parties as one of our business assets.

 

● insurance companies.

 

We also inform you that we may transfer your personal data to service providers providing data processing, some of which are located in countries outside the European Economic Area, whose laws may not provide the same level of data protection.

 

In this event, we will ensure that adequate safeguards are in place to protect your personal data in accordance with our legal obligations. This may include a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for the transfer of personal data to third countries or the service provider's compliance with privacy frameworks, among other things.

 

To learn more about the above transfers and the appropriate safeguards we use to protect them, you may contact us using the contact information provided in this Privacy Policy.

 

How long we use your data

Your personal data will be kept as long as the legal relationship established will be maintained and for the time necessary to meet the legal obligations of MOBY LEAF. With regard to the other purposes of processing, your personal data will always be kept, provided that MOBY LEAF can justify it in a legitimate way and until the user demands its deletion.

 

Your rights regarding your personal data

 

In accordance with the French Data Protection Act and the Regulation, you have the right to access, rectify, delete, limit the processing of your personal data, object to the processing of your personal data for legitimate reasons and to have your data ported. Finally, you have the right to define general and specific directives defining the way in which you intend these rights to be exercised after your death.

 

Under certain circumstances, the user may request the limitation of the processing of his or her data, in which case we will only keep it for the exercise of claims or the defense of such claims.

 

The user may also object to the processing of his/her data on the basis of reasons related to his/her situation, in which case we will stop processing the personal data in question, except for compelling legitimate reasons or for the exercise of claims or the defense thereof.

 

The user may request the right to data portability and obtain for himself or for another service provider certain information from the formalized relationship with MOBY LEAF. The user also has the right not to be subjected to a decision based solely on automated processing, including profiling, likely to have legal effects concerning him or her or to affect him or her significantly in another way.

 

 

 

Finally, the user may withdraw consent at any time, in the event that consent has been granted for a specific purpose, without affecting the lawfulness of the processing of data on the basis of the consent prior to its withdrawal.

 

We remind the user that he/she may object, at any time, to the processing of his/her personal data for commercial or promotional purposes. In order to exercise the above-mentioned rights or to revoke the given consents, the user can contact MOBY LEAF, 17 Avenue Raoul Dufy, 06200 NICE, indicating in reference "Data Protection" or sending an e-mail to the following address: contact@freemob.fr

 

We inform you that in order to make effective the right exercised, we may ask you to provide additional documents to prove your identity (for example, a copy of your identity card or passport).

 

For any further information regarding the processing of personal data, the user may contact MOBY LEAF using the contact details mentioned in this Privacy Policy.

 

You may also exercise your right to file a complaint with the National Data Protection Authority by sending your request to the Commission Nationale de l'Informatique et des Libertés, by mail to the following address: 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07, or on the CNIL website available at the following address: https://www.cnil.frou or by phone at the following number: 01 53 73 22 22.

bottom of page