Your data,
Our major concern.

Privacy Policy

Datafolio Mobiplat

April 2024

Datafolio, a Simplified Joint Stock Company registered under the RCS number of Lille with number 877 629 493, whose head office is located at 165, avenue de Bretagne - 59000 Lille (hereinafter "Datafolio" or "we"), offers various types of "Mobility" insurance services (vehicle and/or driver insurance) through mobility platforms (hereinafter "Datafolio Mobility Services" or "the Services").

In this context, and for the needs of providing the Services, Datafolio may process personal data (the "Data") of the users benefiting from the Services (the "Users" or "the User"), whether the subscription is initiated by the provider of the mobility solution used or at the initiative (usually optional) of the user.

Datafolio places the protection of Data at the heart of its concerns, and this Privacy Policy aims to inform Users about the processing implemented in the context of providing Datafolio Mobility Services and Datafolio's commitments under European and French regulations on the protection of personal data and privacy, especially the General Data Protection Regulation No. 2016/679 of April 27, 2016 ("GDPR") and the Law No. 78-17 of January 6, 1978 relating to data processing, files, and freedoms, as amended.

By using the Services, Users agree to read and accept this Privacy Policy, subject to their rights under the GDPR as mentioned below.

Datafolio may need to evolve and modify this Privacy Policy, especially to adapt its content to the processing implemented in the context of providing the Services. Datafolio would then promptly inform the Users and, if necessary, request their consent.

1. Nature of the Data Processed, Purposes, and Legal Bases of the Processing

In the context of providing Datafolio Mobility Services, Datafolio processes the following data:

- User identification data: name, first name, date and place of birth, social security number (depending on the country of subscription), tax code, email address, telephone number, username, and password created by the User; any other information requested locally by the insurer to allow the User to subscribe to the insurance;

- Data collected during the use of the Services: Name, first name, age, address, nationality, identification document, journey data including the duration of the journey, distance traveled, "GPS" start and end positions, vehicle identifier (via geolocation, data from mobile phone sensors (accelerometer, compass, magnetometer, gyroscope) and/or vehicles, technical logs, movement and mobile phone usage data);

- Data collected in the event of a claim: Name, first name, information related to the claim, identity information of the insured's beneficiary(ies).

The data is provided directly by the User; in some cases, it is transmitted by the mobility solution provider with the User's agreement.

Datafolio processes the data for the following purposes:

- To respond to questions and requests from the User, notably via the contact form on Datafolio's website;

- To enable the subscription and execution of insurance contracts;

- To determine the price of the insurance;

- To analyze the risk(s);

- To manage claims;

- To manage customer relations.

We process your Data (i) with your consent, which you may withdraw at any time; (ii) when they are necessary for the execution and provision of the Services and to respond to your requests; (iii) when they must be processed in order to comply with a legal obligation to which we are subject; and in some cases (iv) to protect our legitimate interests (for example, sending communications via email).

In the event that Datafolio is required to process personal data of minors under 18 years, the processing of such Data in accordance with this Privacy Policy will be subject to prior authorization from the representatives of said minor. In the absence of such authorization, Datafolio would not be in a position to provide the Services and declines all liability in this regard.

2. Recipient of the Data

The data is stored on secure servers of Amazon Web Services (AWS) and Datadog, in the European Union and the United States, under conditions compliant with the GDPR.

Datafolio commits to limiting and framing the transfers of Data outside the European Union and to obtaining from its partners or service providers all the necessary guarantees for data protection and for the compliance of processing in view of the GDPR.

We only transmit your Data to our partners and subcontractors when necessary for achieving one of the purposes mentioned above. In this regard, Datafolio may transfer all or part of the Data to the mobility platform, the insurer, possibly another broker representing the insurer, and the claim(s) manager(s).

Your Data may be transmitted to third parties legally authorized to access it upon specific request, in certain cases provided by law: judicial authority, administrative authority, etc.

Your Data may also be communicated to third parties if necessary to protect and/or defend our rights and to enforce these provisions.

3. Data Retention Periods

The data that you share with Datafolio as a User of the Services are kept in active database for the duration of the contractual relationship with Datafolio and then in an intermediary database for the legally applicable limitation periods in terms of insurance and claim management.

Data related to your registration expires 3 years after your last use. You can decide at any time to delete your account by sending a written request via email to the following address: dpo@datafolio.io.

We keep the data collected through cookies for a maximum of 25 months.

We retain your data as a prospect for a maximum period of 3 years from our last contact, and you have the right at any time to exercise your right to deletion.

However, your data may be kept longer if a longer retention period is allowed or imposed under a legal, contractual, tax, or social obligation.

4. Your rights

Datafolio commits to respecting the rights of Users and, more broadly, of individuals concerned, under the GDPR.

Datafolio has appointed an external Data Protection Officer (DPO), registered with the CNIL under number 115797, who can be contacted at the following email address: dpo@datafolio.io, or by writing to: Datafolio – DPO, 165, avenue de Bretagne - 59000 Lille (France).

In accordance with the applicable regulations on personal data protection (notably articles 15 to 22 of the GDPR), you have the following rights regarding the processing of your Data by Datafolio:

- Right of access: to obtain information about your Data and a copy of your Data;

- Right to be informed: to obtain information about the conditions of processing (recipients, purposes, categories of data, etc.);

- Right to rectification: to correct or update your Data when they are inaccurate or incomplete;

- Right to object: to object to the processing for reasons related to your particular situation, or to withdraw your consent for processing based on this legal basis;

- Right to withdraw consent, when consent is the legal basis for processing;

- Right to restriction: to request that your Data not be processed, in whole or in part, temporarily, without requesting their deletion;

- Right to erasure: to request the deletion of all or part of your Data, subject to Datafolio's obligations to retain such data;

- Right to data portability: to obtain your Data in a structured, commonly used and machine-readable format and to transmit them easily to a third party;

- Right to set specific directives for the processing of your Data after death.

You can exercise your rights by writing to: dpo@datafolio.io. In case of doubt about your identity or qualification to make the request, proof may be requested. We may reject any request that is abusive or unfounded in relation to the necessity of the concerned processing and applicable laws and regulations.

When you exercise your rights, we commit to responding as promptly as possible and, in any case, within the time limits set by the GDPR.

You can decide at any time to stop receiving newsletters and information bulletins from Datafolio by clicking on the link provided in the concerned messages or by writing to: dpo@datafolio.io.

5. Contact

To contact us and ask questions about the processing of your Data, send us an email at dpo@datafolio.io.

If you do not receive a satisfactory response, you can contact the supervisory authority, the National Commission on Informatics and Liberty (CNIL), located at 3 Place de Fontenoy - TSA 80715, 75334 PARIS CEDEX 07.

‍