Applicable as of 25 May 2018:
The present policy defines the information we process for the functioning of the Mobility Work Application.
I. Purpose of the present policy
We comply with all applicable regulations relating to personal data protection, and in particular all provisions defined in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the « General Data Protection Regulation » or « GDPR »).
We hereby wish to inform you how we protect your Personal Data processed through the “Mobility Work” Application, which can be accessed on tablets, mobile and web at the address https://app.mobility-work.com.
II. Identity and contact details of the data controller
The data controller is company Mobility Work, a simplified joint-stock company organized and operating under the laws of France, with a capital of 1.000.000 euros, having its registered office located 44 rue de Lisbonne, 75008 Paris, registered with the Paris Trade and Companies Register under registration number 820 234 599, and represented by its CEO, Mr Marc-Antoine Talva.
III. What type of information do we collect?
In order to provide the Mobility Work Services, we process information concerning you. The type of information we collect is subject to the way you use our Services. You can access all information we collect concerning you, modify them or delete them through the Profile settings of your Mobility Work account.
1. What you and others do and provide.
· Account and Network creation. Upon creation of an account by a User, or by an Administrator or a Client on behalf of a User, in accordance with article 3 of our Terms, we require that be necessarily provided the following information: last name; first name; valid email address; password. Regarding the invoicing which allows to access to the Service, the following information shall also be required to be provide by email: postal address; phone number; Client’s activity; information related to the Company if the Client is acting in the name of the Company: corporate name, head office location, registration number in the concerned Trade and Companies Register or any other national register, VAT, position in the Company; Terms of payment. All Users may also add a profile picture and a phone number.
· Information and content you provide. We collect the content, the communications and other information you provide when using our Services, in particular when you create an account, when you create or share content, by way of survey, or when you communicate with other Users of the Network or send them messages. This could comprise information contained in the content you provide (such as metadata) or concerning such content, such as the location of a photo, GPS coordinates of an Equipment or the date on which an activity has been created or modified.
· Networks and connections. We collect information on the people, the pages of the Application, the accounts and the Networks in which you have contacts, as well as the way you interact with such through our Services, for example, Users with which you communicate most or the Networks you belong to. We collect as well contact details if you choose to import such information (such as those belonging to your Networks’ Users) in order to facilitate the tool’s implementation or its functioning.
· Your use. We collect information relating to the way you use our Services, such as the type of content, activities and tasks you create, view, or with which you interact, schedule planning and other interventions, analysis of the time used per Equipment, activity, task or label, features you use, actions you perform, people with whom or accounts or Networks with which you interact, and the time, frequency and duration of your activities performed. For instance, we record your time of use and last use of our Services, as well as publications, videos and other content you view on our Services. We also collect information regarding the way you use the Mobility Work features.
· Information regarding transactions conducted through our Services. We may, in the event you use our Services to process purchases or other financial transactions, collect information relating to such purchases or transactions. This comprises payment information, such as your credit or debit card number and other information relating to your card, other account and authentication information, as well as invoicing and delivery information and contact details. We may use services from third party providers, in accordance with the terms and conditions herein.
· Other people’s activity and information they provide concerning you. We also receive and analyse content, communications and information other people provide when using our Services. This could include information concerning you, for instance when others share, duplicate or comment a picture, an activity, or a task created or modified by you, or send you a message or assign you to a task.
2. Information relating to devices.
As defined hereunder, we collect information concerning computers, mobile phones and devices, connected televisions, and other devices connected to the Internet that you use to access the Mobility Work Services.
Information we collect from such devices include:
· Device attributes: information such as the operating system, hardware and software versions, signal strength, available storage, type of browser, name and type of applications, files and plugins.
· Operations made on the device: information relating to operations and behaviour on the device, such as when a window is brought to the forefront or backward, or movements made with the mouse (such permitting to differentiate humans from bots).
· Login information: personal login (user name and email address).
· Device signals: Bluetooth signals and information that you authorize us to receive through your device settings which you activate, such as GPS location, your camera or your photos.
· Network and connection: information such as the name of your telephone or your internet provider, your language, your time zone, your mobile phone number, your IP address, your connexion speed, and in certain cases, information concerning other devices located at proximity or on your Network in order for us for example to assist you in broadcasting a video from your mobile, television or any other device.
· Information from cookies: data from cookies saved on your device, in particular login information and cookie settings.
IV. How do we use this information?
1. Offer, personalize, and improve our Services.
We use the information at our disposal to provide our Services, in particular account creation, establishing of your rights depending on your profile, to personalize functionalities and content (in particular your news feed, your analytics dashboard, your schedule) and to make suggestions (such as late tasks to be address promptly). To create personalized Services which are both unique and relevant, we use your connections, preferences, and activities from the data we collect, information that you or third parties furnish and other information; we also use data relating to the way you use and interact with our Services; as well as data concerning people, location or elements with which you have connected or which interest you on our Services.
· Information on all Mobility Work Services and devices: we link all information concerning your activity on the different Mobility Work Services and devices in order to provide you with a more personal and consistent experience of all Mobility Work Services you use, whichever medium you use. By way of example, we could suggest you to request for assistance or visit our online help center, to view or duplicate our Services or official services, to join a Mobility Work group to which belong members of your Network, of your line of business or with which you communicate with through our integrated instant messaging service.
· Geographic information: we use geographic information (such as your current location) in order to offer, personalize and improve our Services for you and other Users. Such geographic information may in particular derive from device location (if you have authorized us to collect them), ID addresses and information relating to your use (and of others’).
· Research and development of Services: we use all information at our disposal to develop, test and improve our Services, in particular through surveys and research, and by testing and correcting new Services and new functionalities.
2. Provide measures, analysis and other professional services.
We use the information at our disposal (in particular relating to your activity) to enhance decision-making, maintenance management, assist you, your management and your company, for example to plan schedules, to address difficulties you may encounter, to determine axes for improvement or to put in place preventive actions.
We use such information to provide an analytics dashboard which allows for instance to follow in detail time spent per Equipment, per type of task, or associated costs.
3. Improve safety, integrity and security.
4. Communicate with you.
We use the information at our disposal to send you commercial communications, inform you of our Services and of our different terms and conditions. We also use your information to address your enquiries when you contact us.
V. How do we share information?
Your information is shared with others as follows:
1. Data sharing on Mobility Work.
a. People and accounts with which you communicate and share content.
When you share and communicate through our Services, you have the possibility to choose the authorized audience of what you share. For example, when you create an Equipment, you choose the audience of your publication by selecting between private visibility (limited to the members of your Network) or public (accessible to all web users). Similarly, when you use the integrated instant messaging service to communicate with individuals or businesses, said individuals or businesses may view the content you send. Your Network may equally see all actions you made on our Services, in particular all interactions with other Users or tasks and activities you have created or modified.
Public information can be seen by everyone, on our Services or outside, even from persons who do not have an account. This includes all information you share publicly with everyone on Mobility Work, including your first name and the first letter of your last name on the tasks you have created or modified. You, other Users of Mobility Work, and us may grant access to public information or send to anyone within our Services or outside, through search results, or through tools or APIs. It is also possible to view, re-share and download public information through third party services, in particular through search engines, APIs and through specific applications, websites and other services integrated to our Services.
Your last name, email address and profile picture shall only be seen by members of your Network.
b. Content concerning you or re-shared by others.
You should consider with whom you choose to share content, as persons who can see your activity on our Services may then share such information with other people on our Services and outside, including with persons and companies who do not belong to the audience with which you share your content. For example, when you share a publication with Users who are members of your Network, these Users can download this content, make a screen capture or re-share this content with other persons on Mobility Work or outside.
c. Information relating to your active status or your presence on our Services.
Members of your Network may see signals which indicate you are active or not on our Services, in particular if you are currently active on the integrated instant messaging service, or when you have created or modified an Equipment, an activity or a task for the last time.
2. Applications, websites and third-party services integrated to our Services or using our Services.
When you choose to use applications, websites or other third-party services which are integrated to Mobility Work, such applications, websites or third-party services can receive information relating to what you publish or share. For example, when you exchange messages on the integrated instant messaging service or when you edit activities or task in the analytics tool, the developer of the third-party tool may receive information related to your messages or activity.
The information collected by these third-party services is subject to their respective general terms and conditions, and not the present policy.
The list of these third-party services may be provided to you following request by you by registered letter with acknowledgment of receipt at the following address: Mobility Work, 44 rue de Lisbonne, 75008 Paris, or by email at: [email protected].
a. Sharing with third-party partners.
We collaborate with third-party partners who assist us in furnishing and improving our Services or who use Mobility Work to develop their activity. We do not sell any of your private information to these third parties. We equally impose strict limitations in relation to the way partners may use and disclose data we share with them.
We provide advertisers with reports relating to the type of persons and login information (first name and first letter of last name) of Users who view their advertisements, and relating to advertising performance, but we do not share information which permits to identify you personally (information such as your name or your email address, which can in itself be used to contact you directly or to identify you), unless you authorize us to such. For instance, we provide advertisers general information concerning the demographic and centres of interest (for example, an advertisement has been viewed by a certain Marie, who is between 25 and 34, who lives in Madrid, and who is interested in IT engineering) to permit them to comprehend their audience better. We permit them as well (as for any other User) to contact you directly through the integrated instant messaging service by clicking on your login on a task.
c. Partners relating to analytics and measurement.
We share information concerning you with companies who aggregate and compile such information to provide analysis and measurement reports for your use and said third-party advertisers.
d.Suppliers and service providers.
We provide information and content, including Personal Data, to our suppliers and service providers, who are located within and outside of the territory of the European Union, and who support our business, including by offering services pertaining to technical infrastructure, providing customer service, and facilitating payment process or by conducting surveys.
3. Non-commercial use of Personal Data.
We undertake not to commercialise the Users’ Personal Data that we collect.
VI. Duration of Personal Data conservation
We retain Users’ Personal Data for the strict duration required in light of the pursued objectives, and in particular the proper functioning of the Application and the Services, in compliance with all applicable regulations.
VII.Under which legal grounds do we process data?
We collect, use and share data in our possession as per the following:
· Under your consent, which you can revoke at any time through your Profile Settings in the Mobility Work Application;
· In compliance with our legal obligations;
· For the purposes of our (or others’) legitimate interests, in particular our interests in providing an innovative, personalized, secure and profitable Service for our Users and partners, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Data.
VIII. How can you exercise your rights under the General Data Protection Regulation?
In accordance with the General Data Protection Regulation, you have the following rights:
- Right to access, and notably the right to obtain copy of all your Personal Data, as well as all essential information regarding the way such Personal Data is used;
- Right to have rectified Personal Data, in prompt delays, and the right to have completed all incomplete, incorrect, ambiguous or obsolete information;
- Right to erasure of your Personal Data;
- Right to restriction of their processing; and
- Right of Personal Data portability.
In the event you wish to oppose the processing of your Personal Data or wish to delete your account, you may delete your account through your Profile Settings, or address your request by registered letter with acknowledgment of receipt to: Mobility Work, 44 rue de Lisbonne, 75008 Paris, or by email at [email protected], and we shall delete your account and all Personal Data within a period of 30 days.
For all other queries pertaining to Mobility Work’s use of your Personal Data, or for all requests for rectification, for the restriction on processing, or for the copy of your Personal Data, please address your request by registered letter with acknowledgment of receipt or by email respectively at the above mentioned addresses. We shall treat your request within a period of 30 days.
Finally, you may also make any inquiry or request before the control authorities, and in particular before the CNIL (https://cnil.fr/fr/plaintes).
IX. Data retainment, account deactivation and deletion
We retain data until deletion of your account. At any time, to delete your account, please visit the User profile settings.
When you delete your account, you can:
- Choose to delete immediately all your Personal Data from the Application. We shall immediately anonymise all content you have published (your first and last name being replaced by “Anonymous User”) and you will no longer be able to retrieve your information following such;
-Choose to download all your Personal Data. Such will then be sent to you by email (under the Excel or .jpg formats) within 24 hours.
Your data will however be retained for a period of 60 days in our database after deletion of your account for security purposes (in case of request from any competent authority, in case of breach of our Terms, or to facilitate the creation of a new account, in case of error for example).
X. How do we proceed to address all legal enquiries and to avoid all risks of damages?
We access, retain and share your information with all regulatory bodies and authorities:
· To answer any legal request, if we believe in good faith that we are required by law. We can also answer all legal requests if we believe in good faith that we are required by the law of such jurisdiction, that it affects Users of this jurisdiction, or under internationally accepted standards.
· When we have reasons to believe in good faith that such is necessary in order to detect, avoid or contain any fraud, unauthorized use of the Services, breach of our terms and conditions, or any other illegal or dangerous activities; to protect ourselves (in particular our rights, property or Services), you and others, including in the context of investigations or regulatory demands. For example, we provide content to third-party partners and receive information from such partners regarding the safety of your account to avoid all frauds, abuse or all other activities which could be damaging to our Service.
XI. How do we manage and transfer data in the context of international services?
We share information internationally, with our Users, collaborators, partners and suppliers, and with all people with whom you interact and share content throughout the world, in accordance with the principles defined under the present policy, our Terms, and the provisions of the GRPD.
We may use the services of third-party providers, or processors, which may have in particular as a consequence data processing outside of the European Union, and such in pursuance of our obligations under the Terms, and especially the provision of our Services.
In the case certain processors would be located in a country which does not present the necessary guarantees with regards to Personal Data protection outside of the European Union or in the case their own processors would be established in such countries, we execute with said processors specific agreements, in order to ensure all necessary and required guarantees to protect and secure data transfers in compliance with the provisions of the GDPR.
The list of said processors may be provided to you upon request by registered letter with acknowledgment of receipt at the following address: Mobility Work, 44 rue de Lisbonne, 75008 Paris, or at: [email protected]
2. Data storage
XII.How do we proceed to notify you of modifications brought to the present policy?
We shall notify you at least 15 days in advance of all substantial changes brought to the present policy and shall permit you access the revised version before continuing to use our Services.
XIII. Cookies and other storage technologies
You can in particular deactivate functionalities of Google Analytics, including through advertisement settings, advertisement settings for mobile applications and all other means available (for example, through the NAI - Network Advertising Initiative). You will find here the additional deactivation module of Google Analytics for the web.
XIV. How do we ensure data protection and security?
We take all technical and organisational measures in order to ensure security of processing of Personal Data and their confidentiality, in particular to avoid their accidental or unlawful destruction or loss, alteration, disclosure or unauthorised access, taking into account the state of the art and implementation cost, at the appropriate security level, and in light of the nature of the data and the risks presented by their processing.
- Our staff is duly qualified and has received the appropriate training (GDPR, Security, Architecture…);
- Our data is stored with AWS (Amazon Web Service) in Frankfurt, Germany;
- We use various services to perform automated tests et regular analysis of our code;
- We use services of specialized firms (Synacktiv) to undertake intrusion tests and security audits of our applications;
- We use pseudonymisation, anonymisation and encryption processes, in particular regarding personal and private data;
- We ensure that all necessary and required measures and guarantees are taken with our third-party partners to ensure a safe and secure transfer of your data, in compliance with the provisions of the GDPR;
- We perform an automatic save of the data stored in the Application every 24 hours;
- We have subscribed to cyber risks insurance coverage;
- We hold an internal record of processing activities.
XV. Personal Data and minors
The Application is addresses to adults in capacity to contract obligations pursuant to the laws of their country.
Pursuant to the General Data Protection Regulation, the User who is a minor and whose age is below the age of 16 or not in capacity to contract obligations must obtain the prior consent of its legal representative prior to the entering of any personal on the Application. Unless legal confidentiality obligation, we shall directly inform such legal representative (i) of the type of Personal Data which is collected from said minor, and (ii) of the right to oppose to the collection, use or conservation of such Personal Data.
In accordance with the provisions of the General Data Protection Regulation, the age of 16 years old may be reduced down to the age of 13 years old under the law of the place of the habitual residence of the User.
XVI. How to address your enquiries to Mobility Work?
For any queries regarding the present policy, you can contact us either:
- By email at the following address: [email protected]
- By post by registered letter with acknowledgement of receipt at:
44 rue de Lisbonne