Personal data - Privacy policy

From its websites, Île-de-France Mobilités, in its capacity as data controller, may collect and process information that identifies you (for example: your name, your personal contact details, your IP address). This information is hereinafter referred to as "Personal Data" or "Data".

Data protection is essential to build a relationship of trust. To this end, Île-de-France Mobilités constantly ensures compliance with the legal rules — the General Data Protection Regulation 2016/679 of 27 April 2016 and the Data Protection Act 78-17 of 6 January 1978 as amended — on the protection of Personal Data and intends to ensure responsible governance of its IT files as well as the greatest transparency on the Data processing it operates. As such, Île-de-France Mobilités has appointed a Personal Data Protection Officer (or DPO). It ensures that the processing of Personal Data implemented by Île-de-France Mobilités complies with the applicable regulations.

This information notice explains why Île-de-France Mobilités may collect your Data, how your Data will be used and protected, how long it will be kept and the rights you have.

Data processed within the framework of the Ile-de-France Mobilités Account and the Ile-de-France Mobilités Connect service

In the context of the use of the Ile-de-France Mobilités Customer Account, in its capacity as data controller, Ile-de-France Mobilités is required to collect and process personal data concerning you. In addition, the Navigo services marketed by GIE Comutitres and accessible from the Ile-de-France Mobilités website on the "My Navigo" page also collect personal data about you.

This processing is carried out in accordance with the regulations in force and has been entered in the processing register held by the data protection officer appointed by Ile-de-France Mobilités and the GIE Comutitres.

Who are the people whose Data is collected?

The data collected and stored in the context of the customer account and Navigo services are those of users and customers who create a customer account allowing them to access a secure customer area that offers them dedicated services.

What data is collected by Ile-de-France Mobilités?

Origin of collection

Ile-de-France Mobilités collects Personal Data directly from the user via a registration form.

GIE COMUTITREScollects the user's personal data when it completes:

• The subscription and order form for the provision of the Services and products marketed by the GIE COMUTITRES,
• The contact forms on the "My Navigo" page,
• The survey(s) and/or satisfaction surveys conducted by the GIE COMUTITRES.
• The refund request form
• The contact forms on the "dedommagement.iledefrance-mobilites.fr

Ile-de-France Mobilités account data

The data collected and stored in the context of the customer account are:

• Name
• Forename
• Date of birth

Data from the Ile-de-France Mobilités Connect Service

The data collected and stored are as follows:

• Email address
• Password

As part of the management of the services offered by GIE COMUTITRES through the "My Navigo" and "Compensation" pages, the data collected belong to the following categories of personal data:

• Identification data: surname, first name, postal address, email address, telephone number, gender, age/date of birth;
• Personal and professional life: schooling, training;
• Login data: cookies;
• Economic and financial information: bank card number, SEPA direct debit, bank account details.
• As part of the provision of the Services, the GIE COMUTITRES collects the data provided in the General Terms and Conditions of Sale and Use of the passes/contract and Navigo Pass.
• Additional supporting documents necessary for the eligibility of a refund

Why is the data collected?

The personal data collected when using the Ile-de-France Mobilités account is intended for (with its legal basis):

• Identify the user to secure access to data
  Legal basis: Execution of the General Terms and Conditions of Use of the Ile-de-France Mobilités account
• Synchronize information between systems
  Legal basis: Execution of the General Terms and Conditions of Use of the Ile-de-France Mobilités account

As part of the processing carried out by GIE COMUTITRES on behalf of Ile-de-France Mobilités:

• Managing your authentication and controlling your access to the site and your personal space;
  Legal basis: Execution of the General Terms and Conditions of Use of the Ile-de-France Mobilités account
• Customer relationship management and monitoring;
  Legal basis: Legitimate interest in managing and monitoring the customer relationship
• The management and follow-up of ticket orders;
  Legal basis: Execution of the General Terms and Conditions of Sale and Use of the Title
• Online subscription to a ticket;
  Legal basis: Execution of the General Terms and Conditions of Sale and Use of the Title
• Management and prevention of theft and loss of cards or tickets;
  Legal basis: Execution of the General Terms and Conditions of Sale and Use of the Title
• Displaying or modifying data relating to customers' tickets;
  Legal basis: Execution of the General Terms and Conditions of Sale and Use of the Title
• The management and monitoring of online payments;
  Legal basis: Execution of the General Terms and Conditions of Sale and Use of the Title
• Sales and marketing management;
  Legal basis: Execution of the General Terms and Conditions of Sale and Use of the Title
• Measuring the quality of satisfaction;
  Legal basis: Legitimate interest in combating fraud and chargebacks in connection with the provision of the Services.
• Commercial prospecting and personalization of offers;
  Legal basis: When commercial prospecting is addressed for services similar to those offered under the GTCSU, the legal basis for the processing is the legitimate interest of offering similar and similar services to its customers. When the commercial prospecting is addressed for services not similar to those offered under the GTCSU or by other advertisers, the legal basis for the processing is your consent
• Carrying out statistical analyses and studies;
  Legal basis: Legitimate interest in combating fraud and chargebacks in connection with the provision of the Services.
• The fight against fraud and the prevention and management of unpaid invoices;
  Legal basis: Legitimate interest in combating fraud and chargebacks in connection with the provision of the Services.
• News from Ile de France Mobilités;
  Legal basis: Ile France Mobilités' public service mission to send information to transport users in Ile de France
• Transport news in Ile de France;
  Legal basis: Legitimate interest of Ile France Mobilités and carriers to send information to Ile de France transport users
• Information on transport and mobility projects and new services in the Ile de France region;
  Legal basis: Public service mission of Ile France Mobilités, transporters to send information to transport users in Ile de France.
  Where the information is commercial, the legal basis for processing is your consent
• Claims management;
  Legal basis: Legitimate interest in managing and monitoring the customer relationship
• To process requests and questions using the compensation contact form.
  Legal basis: Legitimate interest in managing and monitoring the customer relationship

How long does Île-de-France Mobilités keep this data?

The personal data collected for the use of the Ile-de-France Mobilités account, the services of the "jegeremacartenavigo.iledefrance-mobilites.fr" and "dedommagement.iledefrance-mobilites.fr" websites are kept until the closure of your account, which may occur upon a simple request to delete the user's account.

The request for closure will give rise to an eligibility check. The deletion of the account and its data will only be possible if all the services are not in use.

Some of this data may be archived in order to establish proof of a right or contract or when legal or regulatory obligations require it. This data may only be archived for the time necessary to comply with these legal or regulatory obligations or for a period not exceeding the legal limitation period.

The Ile-de-France Mobilités account will be closed automatically after two years of inactivity on all the user's services, including access to products and services on the "jegeremacartenavigo.iledefrance-mobilites.fr" and "dedommagement.iledefrance-mobilites.fr" sites.

The personal data collected in the context of the products and services offered by GIE Comutitres within the "jegeremacartenavigo.iledefrance-mobilites.fr", "dedommagement.iledefrance-mobilites.fr" websites are kept for the duration of the contractual relationship that binds you to GIE COMUTITRES under the GTCSU and are then kept for a period of three (3) years from the last commercial activity.

Data relating to prospects is kept for three (3) years after the last contact with the data subject.

Holders of a Discovery Pass as part of a refund request will have to open an Ile-de-France Mobilités account. Data specific to Discovery Passes will be deleted within a reasonable period of time at the end of the redemption transaction.

Who can have access to the data?

The data collected directly or indirectly by Ile-de-France Mobilités is necessary for this processing and is intended for the relevant departments of Ile-de-France Mobilités and its service providers in the exercise of their missions.

The data is transmitted to the GIE Comutitres, the data controller for the management of certain Comutitres products and services offered from the "jegeremacartenavigo.iledefrance-mobilites.fr" and "dedommagement.iledefrance-mobilites.fr" websites.

The data is also transmitted:

• To service providers and contractual partners of GIE COMUTITRES and Ile-de-France Mobilités acting under their instructions and on their behalf;
• To public transport companies in the Ile-de-France region that are members of the GIE COMUTITRES (Optile, RATP, SNCF) within the limits of the scope of responsibility for each processing;
• To institutional funders within the limits of the framework of responsibility for each processing.

Is your data transferred outside the European Union?

Ile-de-France Mobilités may share the personal data of data subjects in order to carry out the activities specified in this privacy policy. This data may be transferred to a country outside the European Union after having given rise to risk analyses and the implementation of contractual and organisational arrangements. The level of control is acceptability of a transfer will follow the geographical division proposed by the CNIL.

In the event of data transfer outside the European Union, Ile-de-France Mobilités will put in place measures to ensure that the data benefits from equivalent protection, and more particularly by putting in place appropriate contractual provisions such as the standard contractual clauses approved by the European Commission concluded with its service providers, or binding corporate rules known as "BCRs".

In addition, GIE COMUTITRES may be required to share the personal data of the persons concerned by the products and services it sells on the "jegeremacartenavigo.iledefrance-mobilites.fr" and "dedommagement.iledefrance-mobilites.fr" sites, in order to carry out the activities specified in this privacy policy. This data may be transferred to a country outside the European Union (Morocco and/or Madagascar and/or Ivory Coast). These countries do not have an adequacy decision.

However, GIE COMUTITRES ensures that the transfer of personal data is carried out in accordance with the Data Protection Regulations.

GIE COMUTITRES puts in place measures to ensure that data benefits from equivalent protection, and more particularly by putting in place appropriate contractual provisions such as the standard contractual clauses approved by the European Commission concluded with its service providers or binding corporate rules known as "BCRs".

Data processed outside the Ile-de-France Mobilités Connect account and Ile-de-France Mobilités Connect service

Who are the people whose Data is collected?

Visitors to websites managed by Île-de-France Mobilités.

Users who wish to subscribe to products or services marketed by GIE Comutitres through the "jegeremacartenavigo.iledefrance-mobilites.fr" and "dedommagement.iledefrance-mobilites.fr" websites.

What data does Île-de-France Mobilités use and where does it come from?

Only identification, contact and connection data will be collected by Île-de-France Mobilités as part of the services offered on the sites managed by Île-de-France Mobilités. All Data collected will be provided by visitors to the site.

For what purposes and on what grounds is your Data collected and used?

Contact form

By filling in our contact forms, you consent to Île-de-France Mobilités collecting and processing your Data in order to be able to identify you and respond to your request.

Subscribe to project information

By subscribing to project information, you consent to Île-de-France Mobilités collecting and processing your Data in order to be able to identify you and send you information relating to this project.

Subscription to Île-de-France Mobilités alerts (emails)

By subscribing to our alerts, you consent to receive information by email related to Île-de-France Mobilités. You can unsubscribe at any time by clicking on the link provided for this purpose in each of our communications.

Recruitment

The "Join us" section allows you to apply online for our job offers and gives you information about our recruitment process.

Who has access to your Data?

Île-de-France Mobilités takes all necessary measures to guarantee the security of the Data it has collected but also its confidentiality, i.e. to ensure that only authorised persons access it.

Only persons authorised by virtue of their activities within the competent services of Île-de-FranceFrance Mobilités, in charge of the corresponding processing, have access to your Data within the limits of their authorisations.

Similarly, our service providers may have access to your Data as necessary and in a secure manner in the context of the performance of their service.

Certain authorities will also receive your Data in accordance with applicable laws and regulations.

Is your data transferred outside the European Union?

Your personal data is not transferred outside the European Union.

What are the rights of Users over their data?

Within the limits and conditions permitted by the regulations in force, you may:

• Access all of your Data;
• Rectify, update and delete your Data, subject to legitimate reasons;
• Object to the processing of your Data for legitimate reasons and to the processing of your Data for prospecting purposes without any reason;
• Request the portability of your Data, for processing based on your consent or on the performance of a contract concluded or to be concluded;
• Request a limitation of the processing we carry out in relation to your Data;
• Withdraw your consent at any time (for any processing subject to your consent);
• Lodge a complaint with a competent supervisory authority, i.e. that of the country of the European Economic Area in which your habitual residence is located, or your place of work or the place where the alleged violation of the regulations would have been located in France (in France, the CNIL).

In addition, you have the option of providing us with instructions relating to the retention, deletion and communication of your Data after your death, which instructions may also be registered with a "certified digital trusted third party". These directives may designate a person responsible for their implementation. Otherwise, your heirs will be designated.

If you are a minor under the age of 15 or an adult under curatorship or guardianship, your legal representative will be able to exercise all the rights listed. Proof of the legal representation of the minor or protected adult will be requested.

How to exercise your GDPR rights?

To exercise your rights, please contact our Data Protection Officer by e-mail or post indicating your surname, first name, contact details and providing a copy of your application document.

Ile-de-France Mobilités and the GIE Comutitres are combining their efforts to ensure that all users can exercise their GDPR rights as simply as possible.

In order to ensure the security of your data, we offer you the opportunity to carry out legal exercises in connected mode via the forms on the websites and applications to ensure that it is the right user who makes the request.

You have the terms and conditions of practice explained in the frequently asked questions.

You have the possibility to contact the DPOs of Ile-de-France Mobilités (dpo@iledefrance-mobilités.fr ) and the DPO of the GIE Comutitres ([email protected] ) to make your requests for rights.

To ensure that your requests are processed quickly, we advise you to indicate at the beginning of the message the type of request (information, portability, deletion, modification, opposition) and the scope of your request (the products for which you want the operation to be carried out (Navigo monthly, Navigo liberté +, etc.).

To avoid any errors, we indicate the DPO to contact per product/support/service:

Scope of applications to be made to the DPO Ile-de-France Mobilités:

Ile-de-France Mobilités Account / Preferences Getting Around / Compensation Service

Scope of requests to be made to the DPO DPO Comutitres:

On contactless support (Navigo pass, telephone):

• Navigo Day pass on contactless support
• Navigo pass for months and weeks
• Navigo Youth Weekend pass on contactless support
• Navigo Liberté + contract
• t+ ticket on contactless media
• Orlybus and Roissybus tickets on contactless and contactless bank card
• Imagine R School and Junior Annual Package
• Annual package imagine R student
• Annual Navigo Pass
• Amethyst Package
• On-board ticket by SMS
• Contactless anti-pollution package on a medium

On cardboard (magnetic ticket):

• t+ ticket
• School card regular buses
• Paris Region Pass
• Boarding ticket

Anti-pollution package

On the Solidarity Transport Pricing:

The Solidarité ransport pricing applies to the following packages: Navigo Forfait Gratuité / Forfait Navigo Solidarité 75% Month / Forfait Navigo Solidarité 75% Semaine / Discount 50%

On the title carriers:

• Navigo Pass
• Navigo Easy Pass
• Telephone as a ticket holder
• Navigo Discovery Pass

Cookie management

Cookies and other trackers

A "cookie" is a series of information, usually small and identified by a name, that can be transmitted to your browser by a website to which you connect. Your web browser will keep it for a certain amount of time, and will send it back to the web server every time you reconnect to it. Cookies have multiple uses: they can be used to memorize your customer ID with a merchant site, the current contents of your shopping cart, an identifier to track your browsing for statistical or advertising purposes, etc.

Audience measurement cookies

In order to adapt the site to the requests of its visitors, we measure the number of visits, the number of pages viewed as well as the activity of visitors on the site and their frequency of return. This data collected is anonymised.

Third-party cookies to improve the interactivity of the site

Île-de-France Mobilités' websites rely on certain services offered by third-party websites. These include:

• Share buttons (twitter, Facebook, LinkedIn)
• Lists of tweets (Twitter)
• Videos broadcast on the site (youtube, dailymotion)

These features use third-party cookies directly placed by these services. When you first visit the Île-de-France Mobilités websites, a banner informs you of the presence of these cookies and invites you to indicate your choice. They are only deposited if you accept them or if you continue browsing the site by going to a second page of the website visited. You can find out more and configure your cookies to accept them at any time by visiting the "personal data" page for the iledefrance-mobilites.fr site and the legal notice pages for all the other sites managed by Île-de-France Mobilités. You will be able to indicate your preference either overall for the site or service by service.

With regard to the cookies used on the "jegeremacartenavigo.iledefrance-mobilites.fr" website, the GIE COMUTITRES must be able to prove that the consent of the Data Subjects has been obtained.

In this regard, a system for collecting your consent to the deposit of cookies is implemented by GIE COMUTITRES.

What cookies are used on the Site

The cookies used in the context of the Site are the following:

• Browsing cookies
• Functional cookies
• Performance and audience measurement cookies

By learning about the behaviour of Internet users on the jegeremacartenavigo.iledefrance-mobilites.fr and dedommagement.iledefrance-mobilites.fr sites, the GIE COMUTITRES will be able to:

• Establish reliable statistics on traffic and the volumes of traffic and use of the various elements that make up the sites (sections and content visited, paths, etc.), thus enabling it to improve the interest and ergonomics of the services,
• To adapt the presentation of the sites to the display preferences of the web or mobile terminal (display resolution, operating system used, etc.) of the user during his visits,
• To allow the user to access reserved and personal areas of the site if necessary,
• Memorize information relating to forms (registration or access to an account),
• Implement security measures.