Preamble :
This privacy policy (hereinafter, the “Privacy Policy”) describes the terms of collection and processing of personal data relating to corporate clients (hereinafter, the “Clients”) and users of the AYRUU online service. mobile business travel aggregator (hereinafter, the “Service”).
The Service is accessible via the AYRUU mobile application (hereinafter, the “Mobile Application” or the “Application”) and the administration or back-office platform of the Service accessible in SaaS mode, (hereinafter , the platform “).
TRIGONE TECH is thus required to collect and process, as part of the provision of the Service, certain personal data concerning its Customers subscribing to the Service, and users of the Service (hereinafter, the “Users”).
TRIGONE TECH also publishes a Website accessible at the address https://ayruu.com (hereinafter, the “Site”), accessible to the public, the consultation of which allows in particular to become aware of the nature of the services offered by TRIGONE TECH, and to obtain a description and a presentation by demonstration of said services.
On this occasion, the personal data that may be collected by TRIGONE TECH are subject to processing as defined in the “Privacy and Cookies Policy” made available by TRIGONE TECH.
The processing of personal data is implemented by the company TRIGONE TECH SAS, a simplified joint stock company with capital of €41,930, registered in the Paris Trade and Companies Register under number 812 944 387, whose head office is located 38 rue de Berri, 75008 Paris (hereinafter, “TRIGONE TECH”).
For its Customers who have subscribed to the Service, TRIGONE TECH acts as data processing manager and as such, collects, uses and discloses personal information, and is responsible for respecting the confidentiality of the information concerned.
With Users of the Service, made up of employees and agents of the Clients, and concerning the information to be provided by the Clients as part of their registration necessary to benefit from the Service, TRIGONE TECH intervenes depending on the nature of the data as data controller or subcontractor under the responsibility of the Clients, and processes the data concerned in accordance with legal requirements and the provisions set out in this Privacy Policy.
As a subcontractor and data processing manager, TRIGONE TECH is keen to protect the privacy of its Customers and Users as best as possible, and does everything possible in this context.
Furthermore and in its capacity as a professional, TRIGONE TECH has the possibility, for the purposes of carrying out the Service provided, to share with commercial partners and travel service providers (hereinafter “Connector”), as well as Third parties, certain information relating to planned travel and business trips. It is indicated here that this Privacy Policy does not apply to Third Party websites, services and applications, for which a separate Privacy Policy is provided by the latter.
TRIGONE TECH undertakes in particular to ensure a level of protection of Users’ personal data in compliance with the General Data Protection Regulations, including all French legislation and regulations implementing, supplementing or replacing the Regulations where applicable (hereinafter: -after, the “GDPR”).
This Privacy Policy allows Customers and Users to find out more about the origin and use of the information concerning them processed when subscribing to the Service provided and its use, as well as their rights. This Privacy Policy is therefore important for Customers and Users, who wish to have a positive experience of the Service and to be able to use it in complete security, and for TRIGONE TECH, who wishes to respond precisely and completely to the questions of Customers and Users and take their wishes into account.
This is the reason why TRIGONE TECH makes this Privacy Policy available on the Platform and the Mobile Application, so that it is easily visible and accessible by Customers and Users, and in particular so as to so that they can consult it before subscribing to the Service, and use the functionalities deployed for this purpose.
The User is deemed to have read the Privacy Policy and to be informed of the methods of collection and processing of his personal data when he accesses the Service.
3.1 Definition of personal data
Personal data consists of information allowing identification as an individual, or relating to an identifiable person.
The nature and purpose of this personal data collected and processed by TRIGONE TECH vary depending on the interactions occurring with Customers and Users of the Service.
3.2 Creation of the Customer Account and administrator profile:
In order for its Clients to benefit, for their Users, from the Service provided accessible by the Application as well as the Platform, TRIGONE TECH collects the following information necessary for the creation of a Client account:
The Customer is informed that TRIGONE TECH transmits the personal data referred to above, to a partner insurance company, for the purposes of determining the scoring of the customer concerned with a view to determining the amount of the security deposit. collected by TRIGONE TECH when subscribing to the Service, according to the terms and conditions referred to in the General Conditions of Services made available by TRIGONE TECH.
The Client must also provide TRIGONE TECH with the following information necessary for the creation of the administrator account, for the purposes of identifying the Client’s representative or employee attached to the Client:
3.3 User Data:
TRIGONE TECH indirectly collects from the Client the following information necessary for the creation of User profiles, and for the purposes of providing the Service:
The information collected by TRIGONE TECH relating to identity documents (National Identity Card, passport) and driving documents (if applicable) of Users provided by the Client during the creation of User profiles is subject to processing. on the occasion of the reservation by the User, on the Mobile Application, of a transport ticket or a car rental service with a Third Party, and may be transmitted by TRIGONE TECH for the needs of the travel reservation and desired mode of transport.
When the User contacts TRIGONE TECH in order to obtain assistance in the use of the Service provided, TRIGONE TECH collects on this occasion personal information necessary to verify the identity of the User concerned, in order to remedy the situation or the difficulty encountered.
The Client undertakes to comply with applicable data protection legislation and in particular the GDPR and guarantees TRIGONE TECH that the collection and processing of Users’ personal data within the framework of the Platform, and in particular the communication of this data personal to TRIGONE TECH, is legal and compliant.
It is the Customer’s responsibility to inform its employees of the processing it carries out of their personal data and the recipients of this personal data. It is also the responsibility of the Client to alert Users of the need for them to correct their personal data entered during the use of the Services in the event that they prove to be obsolete or no longer up to date.
The Client undertakes to identify, guarantee and compensate TRIGONE TECH for any consequences linked to non-compliance with its obligations under this paragraph, in the event that TRIGONE TECH is concerned about this.
3.4 Data collected automatically:
In addition to the personal information collected in order to create the Customer account, the profiles of the Users of the Service provided, and to enable the use of the Service, TRIGONE TECH automatically collects other information intended to provide information on the terms of access to the Platform and the Mobile Application, which may relate to:
Information regarding the browser and device used (IP address, computer type, operating system name and version, internet browser type, version and name of the Site and application used);
Log data (online activity, search terms used, pages viewed, date and times of access, etc.). TRIGONE TECH may also consult, when using the Service, the trips made by the User, the reservations made, and other actions relating to said Service;
Cookies: TRIGONE TECH uses various cookies intended to collect information on the use of the Service. The terms of processing and collection of Cookies can be consulted in the “Cookies Policy (EU)” made available by TRIGONE TECH;
Geolocation: certain features available via the Service (such as weather) may require geolocation to be activated via the User’s terminal. The User must activate geolocation via their mobile terminal. Geolocation data is collected as such by TRIGONE TECH for the purposes of providing the Service.
3.5 Data relating to virtual bank cards
In order to proceed with the reservation of a trip by the User, the latter is informed that TRIGONE TECH collects and processes the bank card data provided by the Client during the creation of the Client account, which are transmitted to a virtual card payment service provider (such as Edenred, Stripe), which creates, for the purposes of the Service provided, a virtual card for the customer concerned.
The creation and hosting of the virtual card used as part of the reservation of a trip by the User, is carried out directly by the virtual card payment service provider, TRIGONE TECH having access only, for the needs of travel reservations made by the User, to the UUD (“Universally Unique Identifier”) number serving as the identifier of the user concerned by the Service provided, which is kept within the TRIGONE TECH database, and used by this for the purposes of providing said service.
The data collected on this occasion are kept for the duration of the transaction. The Customer is invited to consult the General Conditions of Use applied by the virtual card payment service provider.
Who has access to Users’ personal data ?
The User who completes his profile through the Service accepts that his personal data will be shared with other Users of the Service, employees of the same Client, unless this functionality is deactivated by the User.
The personal data of Users is thus shared exclusively between Users of the Service, and within the framework of use of the Service in connected mode only.
TRIGONE TECH does not transmit Users’ personal data to Third Parties, except to the following recipients:
Why and on what basis does TRIGONE TECH collect personal data from Customers and Users ?
The Client and the User are informed that personal data is collected for the sole purpose of execution of the contract binding them to TRIGONE TECH within the framework of the General Conditions of Services and Use.
Thus, TRIGONE TECH collects data in order to:
What are the rights of Customers and Users regarding personal data collected by TRIGONE TECH ?
In accordance with the provisions of the GDPR, the Customer and the User have the right of access, opposition, rectification, limitation and erasure of their data.
Where applicable and depending on the type of data concerned, the Customer and the User also have a right to portability in accordance with the GDPR.
Finally, the Client and the User also have the right to define guidelines relating to the conservation, erasure and communication of their personal data after their death under the conditions provided for by applicable law.
Both the Customer and the User can exercise all of their rights with TRIGONE TECH by proving their identity:
TRIGONE TECH will verify the request made, using the information and personal data associated with the Customer account in question.
If the User considers that his rights have not been respected, he may lodge a complaint with the National Commission for Information Technology and Liberties (CNIL) or with any other competent authority.
What are the methods of storing and hosting Users’ personal data?
Customer and User data are kept by TRIGONE TECH for a period which does not exceed the duration of subscription to the Service. At the end of this subscription, TRIGONE TECH retains the User’s personal data for the period necessary to comply with its accounting and legal obligations.
Customer and User data is hosted in the European Union under data security and confidentiality conditions required by regulations.
What are the procedures for transferring the personal data of Users outside the European Union?
No transfer of personal data of Customers and Users outside the European Union is planned as part of the Service. In particular, the personal data of Customers and Users are hosted within the European Union.
Changes to the Privacy Policy:
TRIGONE TECH reserves the right to modify and/or update this Privacy Policy, in which case the Client and the User will be duly informed. The revised Privacy Policy will be posted online on the Platform and the Mobile Application with an indication of the last update date.
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