We ensure the protection of your personal data. Fifteen, a simplified joint-stock company (SAS) with a share capital of €1,815,772, whose registered office is located at 8 Rue Henri Mayer, 92130 Issy-les-Moulineaux, France (“we,” “our,” or “us”), is committed to respecting privacy as well as applicable data protection laws regarding users (“you,” “your”) of the service (the “Service,” as defined in more detail in the “Definitions” section).
This privacy notice (the “Notice”) describes our methods for collecting and using personal data in connection with your use of the Service, the website (the “Website”), and your interactions with us and with the Operator, Fifteen, a simplified joint-stock company with a share capital of €1,815,772, whose registered office is located at 8 Rue Henri Mayer, 92130 Issy-les-Moulineaux, France, registered with the Lyon Trade and Companies Register under number 505 280 727, to which we outsource the processing of personal data within the meaning of European legislation.
Software on your device may have access to your information. Our products or services may contain links to other websites belonging to companies that have their own privacy notices. We therefore recommend that you carefully read their privacy policies. This notice applies only within the context of the Service and the Website.
You are not required to provide us with your personal data. However, if you choose not to provide it, we may not be able to offer you our products or services, or all of their features, or respond to your requests.
Definitions
“We,” “our,” or “us”: Refers to the Communauté d’agglomération de l’Auxerrois and Fifteen as designated at the top of the Notice.
“Service”: Refers to the electric bike sharing service provided by Fifteen, as defined in the General Terms of Use of the Vélo Modalis Service, which form an integral part of this Notice.
“Vélo Modalis”: Commercial brand operated by Fifteen SAS.
“Application”: Refers to the free downloadable application compatible with a smartphone or tablet operating system (iOS or Android). It allows any Service user to find a nearby bike, unlock it, follow a cycling route, view kilometers traveled, subscribe to the Service, contact customer support, and report an incident.
What information do we collect?
We collect your personal data and other information when you complete online forms as part of your use of the Service and Website, or when you respond to questions sent by email, phone, via the Vélo Modalis application (“the Application”), or by any other communication channel, and when you participate in campaigns, surveys, or interact with us. This includes the following:
Our applications may regularly contact our servers, for example to check for updates or to send us information about your use of our services. We may also invite you to voluntarily participate in service improvement or research programs, in which we collect detailed information such as your socio-professional category, gender, or usage patterns of our services.
Information you provide to us: when you create an account, use the Service, request our services, participate in campaigns or surveys, or interact with us, we may request information such as your name, email address, phone number, postal address, usernames and passwords, comments, device-related information, age, gender, and language. We also retain your consents, preferences, and settings, such as those related to location data, marketing, and data sharing.
Your transactions with us: we keep records of your purchases, downloads, content you provide, requests, agreements between you and us, the products and services offered, payment and delivery details, and your interactions with us. We may also record communications with customer service or other contact points, in accordance with applicable law.
Location data: location services determine your position using satellite, mobile network, Wi-Fi, or other technologies. These may involve sharing your location data and unique mobile identifiers, Wi-Fi identifiers, or other network identifiers with us. Our products may operate with platforms and services that may also collect location data. We do not use this information to personally identify you without your consent.
Your email address: we may process your email address if you have provided it via our Website.
We also collect personal data through cookies and trackers on our Website and Application. Please refer to the section “How do we use cookies?” for more information.
Why do we process your personal data?
We may process your personal data for several purposes:
Providing the Service: to deliver, maintain, and manage the Service, handle your requests, execute the contract between you and us, ensure functionality and security, identify users, prevent fraud or misuse, and investigate such cases.
Communicating with you: to inform you of changes to our services, send alerts, conduct surveys, and contact you via customer support.
Marketing, advertising, and recommendations: to inform you about new products, services, or promotions, where permitted or with your consent.
Anonymized statistics: to aggregate GPS data from users in order to produce usage statistics for partners. These data are anonymized in accordance with data protection regulations.
We use your personal data with your consent or when necessary for the performance of our contractual relationship. We may also use it when required by law or for legitimate interests, such as protecting customers, ensuring the security of our services, and protecting our rights and property.
Do we share your personal data?
We do not sell, rent, or disclose your personal data to third parties except in the cases described below.
Your consent and social media buttons: we may share your personal data if you have given your consent. Some of our products and services may allow you to share your personal data with social networks. We encourage you to be cautious and to consult the privacy policies of these social networks in order to understand precisely what information is collected and how it is used, including for advertising purposes.
Authorized third parties: we may share your personal data with authorized third parties processing personal data for Vélo Modalis in accordance with the provisions set out in this Notice. This may include, for example, billing by your network operator, or the delivery of personal batteries, or services such as customer support, consumer data management and analysis, surveys, commercial management, or other services.
We may conduct marketing campaigns and other communication methods in collaboration with our authorized third-party partners. In order to avoid duplicate or unnecessary communications, and to send you messages tailored to your needs, we may need to combine data collected by Vélo Modalis with data collected by the partner, where permitted by law.
These third parties authorized by the Communauté d’agglomération de l’Auxerrois are not permitted to use your personal data for any other purpose. We require them to act in accordance with this Notice and applicable data protection regulations, and to implement appropriate security measures to protect your personal data.
International data transfers: our products and services may be provided using resources and servers located in various countries around the world. Your personal data may therefore be transferred across borders, including to countries outside the European Union that may not have specific data protection laws or may have different legal protections for personal data. In such cases, we take measures to ensure adequate protection of your personal data in accordance with applicable law, including the use of agreements approved by relevant authorities (e.g., the European Commission) and requiring appropriate technical and organizational security measures.
Mandatory disclosures: we may be required by law to disclose your personal data to certain authorities or third parties, for example law enforcement agencies in countries where we or third parties acting on our behalf operate. We may also disclose and process your personal data in accordance with applicable law to defend our legitimate interests, for example in civil or criminal legal proceedings.
Mergers and acquisitions: if we decide to sell, buy, merge, or reorganize our business in certain countries, this may involve disclosing personal data to potential or actual buyers and their advisors, or receiving personal data from sellers and their advisors.
How do we ensure data quality?
We take all reasonable steps to ensure that the personal data we hold is kept up to date and to delete personal data that is inaccurate or no longer necessary. We will retain your personal data only for as long as necessary to fulfill the purposes described in this Notice or as otherwise communicated to you, unless a longer retention period is required by law.
We encourage you to log into your account from time to time to review your personal data and help us keep it up to date.
What measures are taken to protect your personal data?
Privacy and security are of crucial importance in how we design and deliver our products and services. We assign specific responsibilities for addressing security and privacy issues. We enforce our internal policies and guidelines through a range of appropriate activities, including proactive and reactive risk management, security and privacy engineering, training, and assessments.
We take appropriate measures to address online security risks, physical security risks, data loss, and other risks, taking into account the nature of the data being protected and the risks involved in processing it. We also restrict access to our databases containing personal data to authorized personnel only who have a legitimate need to access such information.
How do we use cookies?
A “cookie” is a small text file containing data that is stored on a device (computer, tablet, smartphone, etc.) when you browse a website. We use cookies, web beacons, and other similar technologies to operate and improve our Website and Application.
Below is a list of the cookies we use:
| Name | Purpose | Lifetime | Domain / service concerned |
|---|---|---|---|
| Session | Keeps the user logged into their account to ensure secure authenticated browsing | 7 days | www.velomodalis.fr |
| Locale | Manages the visitor’s language preference | 12 months | www.velomodalis.fr |
| Stripe | Fraud prevention | 12 months | www.velomodalis.fr |
How can you manage/delete these cookies?
All major internet browsers allow you to manage cookies stored on your computer or mobile device.
If you do not want our Website to place cookies on your device, you can easily restrict or delete them by adjusting your browser or device settings. You can also set your device to notify you each time a cookie is sent, so you can decide whether to accept it or not.
We notify new users with a banner indicating that cookies are used on our website. You can accept or refuse cookies at that time. You can also reset your choice at any time by clicking here. The cookie consent banner will be displayed again at your next login.
What are your rights?
You have the following rights regarding your personal data:
- Access: you have the right to know what personal data we hold about you and obtain a copy.
- Data portability: you have the right to receive the personal data you have provided to us in a machine-readable format, subject to legal requirements.
- Rectification: you have the right to request correction of any incomplete, inaccurate, or outdated data.
- Erasure (right to be forgotten): you may request deletion of your personal data when it is no longer necessary, when you withdraw consent, when you object to processing, when processing is unlawful, or when required by law.
- Withdrawal of consent: you have the right to withdraw consent for the use of your personal data.
- Objection: you may object to processing based on public interest, official authority, or legitimate interest, for reasons related to your situation. You may also object at any time to direct marketing.
- Restriction: you may request restriction of processing if you contest data accuracy, if processing is unlawful, if you object to deletion, or while we verify legitimate grounds.
- Post-mortem instructions: you have the right to define instructions regarding the retention, deletion, and communication of your personal data after your death.
To exercise your rights, you may contact us via our email address. If you are still not satisfied, you also have the right to file a complaint with the competent supervisory authority, in France this is the CNIL (Commission Nationale de l’Informatique et des Libertés).
How long do we keep your personal data?
Your data is retained only for as long as necessary to fulfill the purposes described in this Notice.
If no longer needed, it will be deleted or anonymized unless retention is required:
- To comply with legal, accounting, and tax obligations: 10 years
- To preserve evidence within legal limitation periods: 5 years
- For marketing purposes: 3 years after the end of the contractual relationship or last contact
In addition, if your user account has been inactive for more than 2 years, we will delete your personal data.
What permissions does the Application require?
The following permissions are required to allow data collection necessary for registration and use of the Vélo Modalis Service:
- Camera: required to scan the QR code identifying the bicycle
- Location: required to locate you on the map (MapBox), show nearby bikes, and guide you to them
- Bluetooth: required to establish and maintain the connection between the user’s phone and the bicycle, enabling proper use of the Service
Changes to this Notice
We reserve the right to modify this Notice at any time, with or without prior notice. However, if changes are made, you will be notified by email so you can review them.
Contact
If you have any questions or requests regarding this Notice or how we process your data, you can contact us at: 📧 contact@fifteen.eu
or contact our Data Protection Officer at: 📧 dpo@mobivia.com