CONFIDENTIALITY POLICY

Bikeway app and website: ttp://www.mybikeway.fr
  1. ARTICLE 1: PREAMBLE
    This privacy policy applies to the site: http://www.mybikeway.fr. and the Bikeway application available on Appstore and Googleplay
    The purpose of this privacy policy is to expose users of the site : 
    How their personal data are collected and processed. All data that may identify a user must be considered personal data. This includes the telephone number, the location of the user; 
    What are the rights of users regarding this data; 
    Who is responsible for the processing of personal data collected and processed; 
    To whom these data are transmitted;  
    Possibly, the policy of the site regarding "cookies" files.
     
    This Privacy Policy supplements the legal notices and General Conditions of Use that users can consult at the following address: 
    http://www.mybikeway.fr/the-confidentiality-policy.html 



    ARTICLE 2: GENERAL PRINCIPLES FOR DATA COLLECTION AND PROCESSING

    In accordance with the provisions of Article 5 of the European Regulation 2016/679, the collection and processing of data from users of the site comply with the following principles:
    Lawfulness, fairness and transparency: data can only be collected and processed with the consent of the user who owns the data. Whenever personal data will be collected, the user will be informed that his data is collected, and for what reasons his data is collected; 
    Limited purposes: the collection and processing of data are carried out to meet one or more objectives determined in these general conditions of use; 
    Minimisation of data collection and processing: only data necessary for the proper execution of the objectives pursued by the site are collected; 
    Data retention reduced over time: the data are retained for a limited period of time, of which the user is informed. Where this information cannot be communicated, the user shall be informed of the criteria used to determine the retention period;
    Integrity and confidentiality of the data collected and processed: the data controller undertakes to guarantee the integrity and confidentiality of the data collected.

    In order to be lawful, in accordance with the requirements of Article 6 of the European Regulation 2016/679, the collection and processing of personal data may only take place if they comply with at least one of the following conditions:after listed: 

    The user has expressly consented to the treatment;  
    The treatment is necessary for the proper performance of a contract;
    The treatment meets a legal obligation; 
    The processing is based on a need to safeguard the vital interests of the data subject or another natural person;
    The treatment may be due to a need related to the performance of a public interest mission or that falls within the scope of the exercise of public authority; 
    The processing and collection of personal data is necessary for the purposes of legitimate and private interests pursued by the controller or by a third party. 


    Article 3. PERSONAL DATA COLLECTED AND PROCESSED IN THE CONTEXT OF NAVIGATION

    A. DATA COLLECTED AND PROCESSED AND MODE OF COLLECTION
    The personal data collected on the website mybikeway.fr To you the cyclette life! are the following:
    Mobile number and geolocation
    This data is collected when the user performs one of the following operations on the site:
    When the user first launches the Bikeway app and synchronizes his phone with the Gps device
    Moreover, when a payment is made on the site, a proof of the transaction including the purchase order and the invoice will be kept in the computer systems of the site publisher.
    The controller shall keep in his on-site computer systems and under reasonable security conditions all the data collected for a period of: 1 year renewable.
    Data collection and processing serves the following purposes:

    L'éditeur collecte et utilise les données de L'utilisateur pour le bon fonctionnement de L’application.

    B. TRANSMISSION OF THIRD-PARTY DATA
    The personal data collected by the site are not transmitted to any third party, and are only processed by the website publisher.

    C. HOSTING OF DATA
    The website mybikeway.fr A vous la vie cyclette!" and the app Bikeway are hosted by: OVH, whose headquarters is located at the following address:
    2 rue Kellermann Roubaix  France
    The webhost can be contacted at the following telephone number: +33 1007
    The data collected and processed by the site are exclusively hosted and processed in France.



    ARTICLE 4: DATA CONTROLLER

    A. THE DATA CONTROLLER
    The person responsible for processing personal data is: Morin Yves. He can be contacted as follows:
    Editor’s Publishing Directorate, open from Monday to Friday from 10 am to 12 pm and from 3 pm to 5 pm
    The data controller is responsible for determining the purposes and means of processing personal data.


    B. OBLIGATIONS OF THE DATA CONTROLLER
    The controller undertakes to protect the personal data collected, not to transmit them to third parties without the user having been informed and to respect the purposes for which these data were collected.
    The site has an SSL certificate to ensure that information and data transfer through the site is secure.
    A SSL ("Secure Socket Layer" Certificate) certificate is intended to secure the data exchanged between the user and the site.
    In addition, the data controller undertakes to notify the user in the event of rectification or deletion of the data, unless this entails for him disproportionate formalities, costs and procedures.
    In the event that the integrity, confidentiality or security of the personal data of the user is compromised, the controller undertakes to inform the user by any means.



    ARTICLE 5: USER RIGHTS

    In accordance with the rules on the processing of personal data, the user has the rights listed below.
    In order for the data controller to grant his request, the user is obliged to communicate to him: his first and last name as well as his e-mail address.
    The person responsible for processing the data must reply to the user within a maximum of 30 (thirty) days.



    A. PRESENTATION OF USER RIGHTS IN DATA COLLECTION AND PROCESSING

    a. Right of access, rectification and right to erasure
    The user may review, update, modify or request the deletion of his data, following the procedure set out below:
    The user must send an email from the Bikeway application or on the mybikeway.fr site specifying his request
    b. Right to data portability
    The user has the right to request the portability of his personal data, held by the site, to another site, following the procedure below :
    The user must send an email from the Bikeway application or on the mybikeway.fr site specifying his request

    c. Right to limitation and opposition of data processing
    The user has the right to request the limitation or to oppose the processing of his data by the site, without the site being able to refuse, except to demonstrate the existence of legitimate and compelling reasons, may prevail over the interests and rights and freedoms of the user.
    In order to request the limitation of the processing of its data or to object to the processing of its data, the user must follow the following procedure::
    The user must send an email from the Bikeway application or on the mybikeway.fr site specifying his request

    d. Right not to be the subject of a decision based solely on an automated process
    d. Right not to be the subject of a decision based solely on an automated processd. Right not to be the subject of a decision based solely on an automated process.

    e. Right to determine the fate of data after death
    The user is reminded that he can organize the future of his data collected and processed if he dies, in accordance with Law No. 2016-1321 of 7 October 2016.

    f. Right to refer to the competent supervisory authority
    In the event that the data controller decides not to respond to the user’s request, and that the user wishes to challenge this decision, or if he believes that one of the rights listed above is infringedabove, it is entitled to refer the matter to the CNIL (Commission Nationale de l'Informatique et des Libertés, https://www.cnil.fr) or any competent judge.



    ARTICLE 6: CONDITIONS FOR AMENDING THE PRIVACY POLICY

    This Privacy Policy is available at any time at the following address:
    http://www.mybikeway.fr/the-confidentiality-policy.html
    The publisher of the site reserves the right to modify it in order to guarantee its compliance with the law in force..
    Therefore, the user is invited to consult this privacy policy regularly in order to keep informed of the latest changes that will be made.
    However, in the event of a substantial change to this policy, the user will be informed of this in the following manner:
    Notifications on the App Bikeway
    It is brought to the knowledge of the user that the last update of this privacy policy took place on: 1/ 10/ 2019.

    ARTICLE 7 : USER ACCEPTANCE OF THE PRIVACY POLICY


    By browsing the site, the user certifies that he has read and understood this Privacy Policy and accepts its terms, with particular regard to the collection and processing of his personal data.