Purpose of the Privacy Policy
From its unified telephone number, Île-de-France Mobilités, the organising authority for mobility in the Ile-de-France region, in its capacity as data controller, may be required to collect and process information identifying you (for example: your name, your personal contact details). 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 on the protection of Personal Data — the General Data Protection Regulation 2016/679 of 27 April 2016 and the Data Protection Act 78-17 of 6 January 1978 as amended — 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.
Who are we?
We are responsible for the processing of Personal Data about you:
Île-de-France Mobilités
39b-41 rue de Châteaudun 75009 Paris
How to contact us?
If you have any questions about this Privacy Policy and how we use your Personal Data, you can contact us:
- By email: [email protected]
- By postal address: 39b-41 rue de Châteaudun 75009 Paris
Privacy Policy Update
This Privacy Policy may be updated regularly. In the event of significant changes, we will keep you informed via our usual communication channels (websites and social networks). Otherwise, please consult our website regularly.
As a reminder, this privacy policy came into force on 06/09/2024.
Who are the people whose Data is collected?
Users who call the number 0 800 10 20 20 which is managed by Île-de-France Mobilités.
What data does Île-de-France Mobilités use and where does it come from?
During your call, the questions you are asked are strictly intended to deal with your request. We recommend that you only provide the data that is strictly necessary. If additional data is provided, it will not be considered.
Personal data processed (general regime)
- Identification data (surname, first name, address, email, telephone number, Navigo pass number, etc.) : Audio and data retrieved by the Interactive Voice Response (free speech of the caller which is transcribed in the conversation between the callbot and the caller): first and last name, address, email, Navigo pass number, telephone number of the caller.
- Data relating to professional life (CV, diplomas, etc.) : Audio and data retrieved by the Interactive Voice Response (free speech of the caller which is transcribed in the conversation between the callbot and the caller).
- Personal life data (family situation, lifestyle habits, etc.) : Audio and data retrieved by the Interactive Voice Response (free speech of the caller which is transcribed in the conversation between the callbot and the caller).
- Economic and financial data (income, tax or financial situation, bank details, etc.) : Audio and data retrieved by the Interactive Voice Response (free speech of the caller which is transcribed in the conversation between the callbot and the caller).
- Location data (movements, GPS data, mobile phone, etc.) : Audio and data retrieved by the Interactive Voice Response (free speech of the caller which is transcribed in the conversation between the callbot and the caller).
How is the data collected?
The caller's phone number is collected by the Interactive Voice Response system while all other data collected will be provided by the callers if stated. To ensure the processing of requests and complaints that arrive on the unified number and that will be transferred to the dedicated interlocutors (transport operators or Comutitres S.A.S), the following list of data will be transferred to them:
- The intention
- The transcription of the conversation between the callbot and the caller which is based on free speech, so all the data previously mentioned is likely to be processed
- The caller's number
- The Public Service Delegation concerned corresponding to the territory operated by the transport operator
- The transport operator
- The transmission line
- The city
- The Navigo pass number
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Cookies and similar technologies
There is no cookie in the unified number.
For what purposes and on what grounds is your Data collected and used?
Purpose of processing
- Unified number : By calling 0800 10 20 20, your request will be directed to the right person who can answer it (e.g. Comutitres SAS or transport operator).
- Audience measurement : In order to adapt the callbot to the requests of callers, we measure: the number of calls received, the number of calls handled, the number of callers, the number of calls hung up, the number of abandoned calls, the duration of calls, the time it takes to take up a call, the number of repeated calls
- Satisfaction survey : Surveys may be sent to you at the end of your call in order to get your feedback on the process and processing of your request. Depending on the answers or scores collected, Île-de-France Mobilités may update and/or improve the proposed route.
Legal bases
This section describes the purposes for which we use your Data and the legal bases provided by law for processing your Data.
Depending on the missions and activities concerned, the processing of personal data is based on:
- The performance of the service or contract to which the data subject is a party for the processing of requests or complaints. This is the case, for example, for the processing of a request for a refund of a Navigo pass or a request for information on the timetables of a bus line.
- Obtaining the consent of the person concerned when this is required. That is the case with regard to the recording of the telephone conversation. By calling 0800 10 20 20, you consent to Île-de-France Mobilités collecting and processing your Data.
Who has access to your Data?
Île-de-France Mobilités takes all the necessary technical and organisational measures to guarantee the security of the Data it has collected but also its confidentiality, i.e. to ensure that only authorised persons have access to it.
Only persons authorised by virtue of their activities within the competent services of Île-de-France Mobilités and in charge of the corresponding processing, have access to your Data within the limits of their authorisations. These people are in charge of passenger relations, monitoring operating contracts and quality of service.
The partner (Comutitres S.A.S or transport operator) concerned by your request has access to your data: your call from the unified number will be forwarded to them. The partner then manages, processes and follows up on user complaints.
Similarly, our service providers may have access to your Data if necessary. This access will be secure as part of the performance of their service.
Certain authorities will also receive your Data in accordance with applicable laws and regulations.
How long is your Data stored?
Your Data is kept according to the legal deadlines in force.
The data will be kept for the time necessary to process the request and until the expiry of the archiving (2 years) and limitation periods (5 years). Beyond 5 years from the end of the processing of the request, all data will be permanently and automatically deleted.
Is the Data transferred outside the European Union?
Data concerning the holder is communicated for management purposes to Île-de-France Mobilités ' subcontractors established outside the European Union (Côte d'Ivoire). In this regard, only data relating to identification, personal contact details and the subscription contract will be transferred.
These transfers are governed by cross-border flow agreements established in accordance with the standard contractual clauses issued by the European Commission or Binding Corporate Rules (BCRs).
The data transmitted to operators, Comutitres S.A.S and Orange Business Services is hosted in France.
What are your rights over your Data?
You have rights in relation to the use of your Data. These rights vary depending on the legal basis used to justify the processing of your Data and certain processing purposes.
You can exercise your rights through the various communication channels made available to you in SECTION I – How to contact us?
Right to be informed about the use of your Data
You have the right to obtain clear information about the use of your Data (e.g. the purposes of the processing, the categories of data concerned, the recipients or categories of recipients of the data, etc.) and about the exercise of your rights.
Right to access or receive a copy of your Data
You can read and obtain from the data controller a complete, legible and understandable copy of the Data concerning you, as well as the following information:
- The purposes for which your Data is processed
- The recipients to whom it is communicated and how we obtained your Data
- The Data retention period
This right has exceptions and is exercised subject to respect for the rights and freedoms of third parties.
Right to obtain rectification of your Data
In the event that your Data is incomplete, inaccurate or no longer up-to-date, you have the right to request its rectification.
Right to obtain erasure of your Data
You may request the deletion of your Data when it is no longer necessary in relation to the purposes for which it is processed.
However, we may refuse to do so where we need to continue to process your Data, in particular where it is necessary to comply with our legal obligations or for evidentiary purposes.
Right to limit the processing of your Data
You have the right to request that the processing of your Data be restricted in certain specific cases. If you exercise this right, we must refrain from carrying out any other processing on the personal data in question, for the time necessary to exercise your right. Unless such disclosure is impossible or requires disproportionate effort, we will notify each recipient to whom the Data has been disclosed.
Right to object to the processing of your Data
You have the right to object to the processing of your Data in certain cases. You have the right to object to the processing of your Data where it is based on our legitimate interest. It is not a right to simply and permanently delete all your Data. We may refuse this request in the case of legitimate and compelling reasons or in cases where the processing of the Data would be necessary for the establishment, exercise or defense of legal claims.
Right to withdraw your consent at any time
When the processing of your Data is based on your consent, it is possible to withdraw it at any time. You can specify this to the call center agent who will answer you as part of the handling of your call. If you wish to withdraw your consent after the call, please contact the Data Protection Officer by post or email.
Right to data portability
You have the right to the portability of your Data, for processing based on your consent or the performance of a contract concluded or to be concluded. If it is technically impossible to transfer the data directly to a data controller, we will provide you with a copy of your Data in a complete, legible and understandable format.
Right to lodge a complaint with the supervisory authority
You have the right to lodge a complaint with a competent supervisory authority, i.e. 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 has been committed (in France, the CNIL).
Post-mortem directives
In addition, you have the option of providing us with instructions relating to the retention, deletion and disclosure 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.
How to exercise your rights?
To exercise your rights, please contact our Data Protection Officer by email or post indicating your surname, first name, contact details and providing a copy of your proof of identity.
Data Protection Officer
Postal address: Île-de-France Mobilités, 41 rue de Châteaudun, 75009 Paris
Email: [email protected]