The controller of the personal data we collect through the App is: Transcovo SAS (referred to in this Notice as “FREE NOW”). FREE NOW’s principal office is located at 120 rue Jean Jaurès 92300, Levallois-Perret, France. You can contact us by letter to this address.

FREE NOW has a data protection officer. You can reach our data protection officer most easily via the support page on our website available at: support.free-now.com/hc/fr/requests/new. Alternatively, you can write to the address above, addressing your letter for the attention of “The Data Protection Officer.”

"Personal data” means all information which relates to an identified or identifiable living person. This means that "personal data" includes information that identifies you directly (such as your name, postal address, e-mail address and telephone number) as well as information that allows you to be identified when it is combined with other information (such as an IP address).

“Processing“ means any operation performed on personal data, whether or not those operations are automated – e.g. collecting, organising, saving and deleting personal data are all types of processing (as well as a number of other types of activity).

“Journey” is a tour requested by a passenger through the App.

A "controller" of personal data is the organisation or person that decides how and why personal data will be processed – either alone or jointly with others.

A "processor" of personal data acts on behalf of, and on the instructions of, the data controller in relation to the personal data processing. 

The personal data that we collect, and how we use that data, will vary depending on how you interact with our App. In this section, we have set out the various purposes for which we use personal data collected through our App. 

If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, including how we balance our legitimate interests against your rights and freedoms where applicable, please contact us using the contact details provided under section 1 above.

1. To register you as a user of the App. 

Where you register as a user of the App, we will ask you to provide basic personal information to set up your account and verify your account details via SMS.

Categories of personal data used for this purpose:

• Identity data: Name
• Contact details: E-mail address; phone number 
• Optional: Profile picture; home and work address

Our lawful basis for processing this personal data: It is necessary to perform a contract with you (Art. 6 1 lit. b) GDPR). If you do not provide this information, we will not be able to register you as an App user. Where you have chosen to provide the information listed above as 'optional', we process this on the basis of your consent (Art. 6 1 lit. a) GDPR) – you can delete this information from the App at any time.

You can also choose to log in or register with the App via your account on a third party website (such as Meta or Google). Where you choose to do this, you will be transferred to the third party website, where you can provide your account details and consent to relevant permissions. When you do this, your third party account and your App account will be linked and we will receive some of your personal information from the third-party account. 

Categories of personal data used for this purpose:

• Identity data: Name; profile picture 
• Contact details: E-mail address

Our lawful basis for processing this personal data: We process this personal data on the basis of your consent (Art. 6 1 lit. a) GDPR). If you do not wish to link your App account with your Facebook or Google account, you can choose to instead create an account directly via the App. If you have logged into the App using a third party account in the past and wish to unlink your accounts, you can do so via the settings on the relevant third-party webpage. 

2. To procure and manage journeys you request through the App. 

We will need to process information about you in order to arrange and manage the journeys that you order through the App (whether you travel by taxi, private hire vehicle, e-scooter, e-bike or another mode of transport). 

This includes allowing you to interact with maps using Google Maps (which is integrated into the App) so that you can pin the pick-up and drop off locations for your journey on the map or (where you have chosen to activate GPS settings) to identify your location via GPS. We use Google Maps in order to calculate the anticipated cost of your journey and to interactively show you the distance to the vehicle which will be carrying out your journey. 

Where you choose to hire an e-scooter, e-moped or rent a car, some of our mobility partners require us to verify your driver's licence. In this case, you will only be able to hire the e-scooter, e-moped or car once the verification is complete. Verification is valid for 36 months, after which point our mobility partners require us to re-verify the validity of your driver's licence before you carry out any more hires.

After you have procured a journey, your driver may phone you about your journey (for example, to inform you about delays or ask your to clarify the pick-up location) – however, we use a phone masking service that means the driver will not be able to see your phone number at any time. 

Categories of personal data used for this purpose:

• Identity data: Name; photo of face (if required by our third-party mobility provider from which you are renting a vehicle (e-moped or car)); photo of driver's licence; driver's licence expiration data; address; e-mail address; date of birth; passenger/user ID; profile picture; Miles&More card number; blocked user accounts, gender
• Contact details: E-mail address; phone number
• Journey data:
  • such as the time of the booking and the start/end location of your journey – Your start location may be collected by you placing a pin on a map or through your GPS coordinates, depending on the settings you have enabled. Enabling collection of GPS coordinates is optional. Where you have permitted access to GPS coordinates, we will only ever be able to see these where you are logged into and actively using the App on your device,
  • live location - if your turned on location sharing, we will also collect your live location from the moment you order a ride until it starts. You can change it at any time in the App settings.
  • vehicle ID; trip information (like usage of minutes, distance, start and endpoint of tour); price paid and voucher amount; reservation and vehicle state; the areas in which journeys are available for booking; location of hire; date of last trip; energy level of vehicle; number of journeys and revenue in last 90 days;
• Technical data: Information about your device (device ID); IP address; country code; trip ID; app version; error codes; app download date
• Financial data: Last four digits of credit card; payment transaction data; non-authorised transactions and payment rejection reasons
• Optional: Home and work address – If you provide your addresses, we will use these to save your favourite journey routes on the App.

Our lawful basis for processing this personal data: It is necessary to perform a contract with you (or to take steps at your request prior to entering into a contract) (Art. 6 1 lit. b) GDPR). If you do not provide this information, we will not be able to procure the journey or hire that you request or allow you to interact with maps via the App.

Where you have chosen to provide the information listed as 'optional', we process this on the basis of your consent (Art. 6 1 lit. a) GDPR) – you can delete this information from the App at any time.

Alternatively we process this personal data as it is necessary for our legitimate interest (Art. 6 1 lit. f) GDPR) to ensure a high quality experience for you.

3. To better locate your driver via GPS location (Live Location).

We can share your GPS information live with your driver, to expedite the process of locating your driver. This particular option can be turned on or off at any time by using the respective toggle within the in app Privacy settings.

Categories of personal data used for this purpose:

• Journey data

Our lawful basis for processing this personal data: We process this personal data on the basis of your consent (Art. 6 1 lit. a) GDPR).

4. To use GPS information to enhance user experience and support other processing activities.

You can book a ride without the need of using GPS location. However, where you choose to turn on this option within your device settings, we can rely on it to provide a better user experience throughout the journey. For example, you will not need to insert your pick up location as this will be automatically filled in.

We can use GPS information to support additional processing activities such as bug fixing, fraud prevention, and communication of offers and news. This Notice clearly sets out for which processing activity GPS information can be used, once users consent.

Categories of personal data used for this purpose:

• Journey data

Our lawful basis for processing this personal data: We process this personal data on the basis of your consent (Art. 6 1 lit. a) GDPR).

5. To respond to your enquiries and send you service-related communications. 

You can contact FREE NOW in several ways, such as our online contact form (support.free-now.com/hc/fr/requests/new), by letter or by phone (where possible). Whenever you get in touch with FREE NOW, we process your personal data so that we can manage and respond to your enquiry or comment. We will also contact you from time to time with service communications (e.g., to provide a receipt for a journey you have taken or to notify you of updates to our Terms & Conditions). 

Categories of personal data used for this purpose: Depending on how you choose to contact FREE NOW, we will process the following types of personal data:

• Identity data: Name
• Contact details: E-mail address; postal address; phone number
• Location and related data: Language; country and city 
• Communications data: Recordings of phone conversations between you and FREE NOW (where applicable); content of your messages (including any attachments you provide)
• Journey data: Relevant information about your journey or booking 
• Technical data: Usage data e.g., log-in time and log-out times

Our lawful basis for processing this personal data: Where you contact us to enter into or enforce a contract between you and FREE NOW, our lawful basis will be that the processing is necessary to perform a contract with you and/or to take steps at your request prior to entering into a contract (Art. 6 1 lit. b) GDPR). 

In all other cases, we process this personal data as it is necessary for our legitimate interest (Art. 6 1 lit. f) GDPR) in responding to passenger enquiries and in managing our relationship with customers and potential customers. Where you contact FREE NOW by phone call, you will be notified that your phone conversation with FREE NOW is being recorded for the purposes of training and evaluating our customer care agents and improving our services. However, you will be given the option to refuse to the recording at the start of your call. Call recordings will be automatically deleted after 30 days. We do not record all calls received by our customer care agents. We do so on the basis of our legitimate interest in improving our customer care service.

We use Agentic AI to help respond to your queries quickly and effectively through our in-app support chat. It operates within our secure cloud environment and follows strict, predefined instructions created by us. The AI does not make any independent decisions about you or your requests. Agentic AI only uses the information necessary to support your query, such as the message you send in the chat and relevant booking details from your FREE NOW account. This data is processed securely and temporarily to enable a seamless support experience and is automatically deleted after 30 days. Your data is not used to train the AI or improve third-party models. All data is stored securely within the European Union and handled in accordance with applicable data protection laws. We process this data on the basis of our legitimate interest in efficiently managing customer service interactions and ensuring a high-quality user experience. If you prefer not to use Agentic AI, you will be given clear options to contact us through other customer care channels.

6. To take payment for your journey. 

Where you pay for your journey directly via the App, we will process payment-related information about you. Alternatively, you can also choose to connect your App account with a travel expense tool (such as Cytric or Concur). This will automatically transfer your journey invoices to an external service provider, who will process them to provide you/your employer with a detailed overview of travel expenses. 

Categories of personal data used for this purpose:

• Identity data: Name
• Contact details: E-mail address; phone number
• Journey data: Start/end location of your journey; type of service; time and date of the booking/journey; distance; duration
• Location and related data: Language; country
• Financial data: 
  • Currency
  • If you have provided a credit card as a means of payment: the first name and surname of the credit card owner, the issuer of the credit card; the first six and last four digits of the credit card number and the expiration date of the credit card.
  • If you pay via PayPal: the e-mail address of your PayPal account.
  • If you pay with Apple or Google Pay: the e-mail address of your account.

• Technical data: Information about your device (such as device ID)
• Employment data: If your journey is linked to a FREE NOW for Business account or a mobility budget that is provided by your employer, we will process information about who your employer is
• Communications data: Content of any optional comments you provide (where relevant) 

Our lawful basis for processing this personal data: Where you choose to connect your account with a travel expense tool, we process this personal data based on your consent (Art. 6 1 lit. a) GDPR). Your use of a travel expense tool is entirely voluntary and you can withdraw your consent at any time in the App menu. 

In all other cases, we process this personal information on the basis that it is necessary to perform a contract with you (Art. 6 1 lit. b) GDPR).

7. To manage ratings of our drivers and passengers. 

On the App, you can provide ratings of drivers and vehicles used to provide your journey: your rating will be aggregated with ratings from other passengers and used to display the driver's average rating on the App. FREE NOW will be able to view your rating (from one to five stars) as well as the specific journey to which the rating is associated. However, your specific rating will not be shown to the driver you have rated and your associated journey details and individual rating will not be shown publicly via the App.

In addition, your driver can provide a rating for you as a passenger (for instance, to provide positive feedback or to inform us of problems). FREE NOW will use these ratings to create an average passenger rating score for you. Only you will be able to view this in your FREE NOW passenger profile. Your rating will not be displayed to drivers during the procurement of any journeys and your rating will not be used as the basis for any journey procurement or other decision about you. We urge our drivers to choose the passenger rating on the basis of the politeness and behaviour of the passenger. 

Categories of personal data used for this purpose:

• Rating data: Ratings you have given; ratings you have received
• Journey data: Information about the journey to which the rating relates (such as start/end location and duration)

Our lawful basis for processing this personal data: We process this data on the basis of our legitimate interest (Art. 6 1 lit. f) GDPR) in further developing and improving the quality of our services.

8. To manage fraud prevention and non-payment risks. 

When you create an account with the App, FREE NOW will evaluate the risk of non-payment and/or fraud for each new means of payment linked with your account and for each booked journey. We do this using either of the following two methods in order to make a decision about whether or not you will be able to access the "Pay By App" functionality: 

• our specially-trained employees review your information for irregularities and determine, based on their experience and discretion, whether or not you will be offered the Pay By App functionality. If one of our employees decides that you should not be offered the Pay By App functionality because, for example, they have identified a risk of fraudulent activity, they may contact your driver during your journey to let the driver know that your Pay By App functionality should not be accepted; and 
• using an automated decision-making process carried out by our European fraud prevention service provider. The provider will calculate a statistical likelihood of non-payment based on information connected with your account and the relevant payment method (and they will not use your personal data for any other purpose). On the basis of this, we will generate a fully automated decision as to whether you will be offered the "Pay By App" function in the App. 

If the outcome of our review is that you cannot use the Pay By App functionality then you will be notified of this by e-mail. You will still be able to use the App to procure journeys and pay by other means (such as cash). If you wish to contest a decision that you will not be offered Pay By App, please contact us via support.free-now.com/hc/fr/requests/new. You will also be able to contest a decision that has been made by fully automated means. One of our trained employees will then review and reconsider the decision, taking your viewpoint into account when doing so.

We also carry out fraud prevention checks for your journey by using your profile picture (where you have uploaded one) to identify you. The driver who carries out your journey will temporarily be shown your profile picture to check that it matches the passenger taking the journey.

In addition, we carry out checks of the activity on users of our App to prevent ad-related fraud activity via AppsFlyer for more information see section 3.1. We also process technical information, usage data and location related data, to identify devices, for the purposes of fraud prevention.

Categories of personal data used for this purpose:

• Identity data: Name; profile picture (where provided); address details (if provided); advertising and related IDs connected with your device
• Contact details: The address you provide when registering your account; e-mail address; phone number
• Journey data: Start/end location of your journey, GPS coordinates
• Location and related data: Language; country
• Finance data: Invoice address (if provided)
  • If you have provided a credit card as a means of payment: Credit card issuer and the last four digits of your credit card number, the expiration date of your credit card, the name of the credit card owner
  • If you pay via PayPal: the e-mail address of your PayPal account

• Technical information: Information regarding your end user device (device ID, operating system, version); IP address; the version of the App you are using
• Usage data: Information about how you have interacted with the App, including features you have installed and links you have clicked

Our lawful basis for processing this personal data: We process this data on the basis of our legitimate interest (Art. 6 1 lit. f) GDPR) in fraud prevention and reducing the risks of non-payment by our customers.

In order to protect you against overpaying for journeys, your driver's mobile phone will transmit GPS coordinates to us at intervals throughout your journey. This helps us to ensure that the driver does not intentionally prolong your journey in order to obtain a higher fee. This means that, if you think you may have paid too much for a journey, you can request that we share information about the route of your journey. 

Categories of personal data used for this purpose:

• Location data: GPS coordinates from your journey
• Journey data: such as the time of the booking and the start/end location of your journey

Our lawful basis for processing this personal data: We process this data on the basis of your and our legitimate interests (Art. 6 1 lit. f) GDPR) in protection against overpayment and fraud prevention. 

9. To fix bugs and improve the functionality of the App. 

In order to fix issues, improve App functionality, and adjust the App to suit the needs of our passengers, we carry out technical analysis of how users interact with our App. Where possible, we will anonymise the personal data we use in order to carry out this activity. 

Categories of personal data used for this purpose:

• Identity data: Name; profile photo (where provided)
• Contact details: E-mail address; phone number; workplace and home address (where provided)
• Location and related data: Country; language; time zone; GPS coordinates at the time of booking (where provided)
• Journey data: Start/end location 
• Technical information: Information about your device (Device ID; advertising ID)
• Usage data: Information about your usage of our App

Our lawful basis for processing this personal data: It is necessary for our legitimate interests (Art. 6 1 lit. f) GDPR) in improving the functionality and features of our App.

10. To send you news and personalised offers (marketing). 

Where we are permitted to do so, we will send you news and personalised offers relating to products and services offered by FREE NOW and/or our third-party partners that we think may be of interest to you. Depending on the settings you have enabled in your App, we will send these to you by e-mail, text or through in-app or push notifications. You can withdraw your consent to receiving these marketing messages at any time (see section 7 (Your privacy rights) to find out how you can object to marketing messages). You can also withdraw your consent to marketing communications via the “Data Protection Settings" of the FREE NOW passenger App (under your “Profile”), by turning off the toggle relating to “News and personalised offers”.

We rely on Braze Inc., 63 Madison Building, 28 E. 28th St., Floor 12, New York, NY 10016, USA (“Braze”) for sending you news and personalised offers relating to products and services offered by FREE NOW and/or our third-party partners.

Categories of personal data used for this purpose: 

• Identity data: Name; passenger ID; App profile type (business or privacy customer); registration status
• Contact details: E-mail address; phone number; home address or business address (where provided)
• Financial data: Method of payment; incentives
• Journey data: Type of journey; journey status; GPS location data at the time of the booking and at the time of the end of the journey (where you have provided access) or pickup and destination locations
• Technical information: Information about your device including the version of the App you are using; device ID, GAID (Google Advertising Identifier), IP address; usage data (usage frequency, information relating to the download of the App); login information
• Location and related data: Language; time zone; city 

Our lawful basis for processing this personal data: We process this personal data on the basis of your consent (Art. 6 1 lit. a) GDPR).

11. To analyse the success of our marketing campaigns and advertise our services online. 

We place non-targeted adverts for our services on third-party websites. We also evaluate and analyse the performance of our marketing campaigns and channels to understand how users become aware of our App, how they respond to specific ad campaigns and how they use the App. To do this, we collect and process certain information about the devices used by our users, their online behaviour and the content of websites they visit. The personal data we collect for this purpose are aggregated by our advertising partner and anonymised shortly after collection. Our service providers therefore cannot identify an individual from the personal data they receive. More information on how FREE NOW uses cookies and tracking technologies can be found in our Cookie Notice.

Categories of personal data used for this purpose: 

• Technical data: IP address; user agent; advertising IDs; operating system of the device; device model; information about your journey; device information and settings; applications; downloads; website hits; information about how you use your device and your in-App behaviour; network carrier; as well as original device and attributed media sources 
• Location and related data: City; language
• Preference data: Opt outs for advertising measures

Our lawful basis for processing this personal data: We process this personal data on the basis of your consent (Art. 6 1 lit. a) GDPR).

12. To provide personalised ads. 

We use ‘custom audience’ and ‘lookalike’ targeting provided by third parties so that we can display targeted advertisements about our services on third party websites and apps to a specific audience (e.g., depending on the characteristics of the audience). We do this so that ads can be tailored to the likely interests of the relevant individual. 

Categories of personal data used for this purpose: 

• Contact details: E-mail address (more specifically, we provide your email address to third party platforms, such as social media, to show you ads about FREE NOW on these platforms. This will only be possible if you registered on these platforms ('custom audience' ads). We also provide the email addresses of some of our users to third party platforms where we want to display FREE NOW ads to the registered users of these platforms who share similar characteristics as our own users (e.g., usage patterns, demographics, etc.) but are not yet FREE NOW users.
• Technical information: Information about your device, such as device ID; Android ID; device type; operating system; IMEI or IP address; advertising identifiers; browser information; information on how you have interacted with the App (such as app downloads, in-app purchases, app calls); measurement data such as interactions with advertisements
• Journey data: use of promotions; journeys taken; cost of journeys
• Location data: City; country; language
• Information about users of third party platforms (in order to identify users that are likely to be interested in FREE NOW's services to show them appropriate ads, and/or to provide FREE NOW with information on the success of its advertising campaigns)

Our lawful basis for processing this personal data: The legal basis we rely on for this processing activity is that you have provided your consent (Art. 6 1 lit. a) GDPR).

You can also withdraw your consent to this via the “Data Protection Settings" of the FREE NOW passenger App (under your “Profile”), by turning off the toggle relating to “Personalised Advertising”. Alternatively, you can send us a message via https://support.free-now.com/hc/fr/requests/new or by letter to the address set out in section 1 of this Privacy Notice.

Where you withdraw your consent, this will not affect the lawfulness of any processing that we carried out prior to your withdrawal. We will implement your changes as soon as possible (due to technical reasons, this will be no later than 48 hours - working days - from the withdrawal).

You can turn off this use of your advertising identifier:

• on an iOS device: under “Settings” – “Data Protection” – “Advertising”, by selecting the option “no ad tracking” or
• on an Android device: under “Settings” – “Google” – “Advertising”, by selecting the option “deactivate personalised advertising”.

You can also reset your advertising identifier at any time in the device settings (iOS: “Reset Ad-ID”; Android: “Reset Advertising-ID”). Where you do this, a new identification number will be generated for your device, which will not be linked with the data collected for your previous advertising identifier.

12.1 Appsflyer

Where you have consented to the Personalised Ads toggle, we use AppsFlyer to evaluate and analyse the performance of our marketing measures.

Categories of personal data used for this purpose: 

• Individual user identifiers: such as IP address, user agent, IDFA (Identifier For Advertisers), Android ID (in Android devices), Google Advertiser ID and appsflyer_id.
• Technical data: such as Android ID, information regarding the operating system of the used device, user agent identification, device model, browser language, TourID, eventName, eventValue, events_api, city, device information and settings, applications, opt out declarations regarding advertising measures, downloads, website hits, clicks and installations of apps, in-app behaviour, device motion parameters, network carrier, events that occur outside of the mobile app.

On the basis of the collected data which are aggregated in the course of the process, AppsFlyer can identify for us if certain actions relating to our app (e.g. download or installation) were caused by manipulation.

Our lawful basis for processing this personal data: The legal basis we rely on for this processing activity is that you have provided your consent (Art. 6 1 lit. a) GDPR).

If you do not wish for the use of AppsFlyer technology, you can withdraw your consent at any time in the “Data Protection Settings” of the FREE NOW passenger App (under your “Profile”), by turning off the toggle relating to “Personalised Advertising”. Alternatively, you can send us a message via https://support.free-now.com/hc/fr/requests/new or by letter to the address set out in section 1 of this Privacy Notice. We will implement your changes as soon as possible (due to technical reasons, this will be no later than 48 hours - working days - from the withdrawal)."

13. Marketing to potential business customers. 

FREE NOW collects information about potential business customer contacts from public sources (such as LinkedIn) so that we can send them marketing materials about our services where we think these may be relevant to their business. 

Categories of personal data used for this purpose: 

• Identity data: Name
• Employment data: Job role; employer
• Contact details: Business contact details

Our lawful basis for processing this personal data: It is necessary for the purpose of our legitimate interest (Art. 6 1 lit. f) GDPR) in identifying potential B2B customers and advertising our services.

14. To conduct market research and surveys. 

If you have agreed to receive market research and surveys from us (e.g., during registration of your account on the App or by activating the relevant toggle in the App's privacy settings), we will send these to you from time to time. The surveys we send you will be personalised to you. Depending on the settings you have enabled, we will send these to you by e-mail, text or through in-app or push notifications. We do this so we can understand how you use our App and how we can improve our services. 

Categories of personal data used for this purpose: 

• Identity data: Name; passenger ID; profile picture (if provided); app profile (business or privacy customer); login details (username)
• Contact details: E-mail address; residential and/or business address (if provided); phone number
• Finance data: Payment method; invoice address on record (yes/no); tip value preference
• Journey data: Registration date; type of journey (booking, try-out ride); registration/journey status; information about vouchers redeemed; information about favourite drivers and number of journeys taken/cancelled; journey rates and values; ratings.
• Location and related data: Language; GPS coordinates at the start/end of journey (if provided) or start/end location of journey 
• Technical data: App version; usage data (usage frequency; information about the download of the App; date of the last login; push tokens)

Our lawful basis for processing this data: We process this personal data on the basis of your consent (Art. 6 1 lit. a) GDPR). If you have provided your consent to this activity and you subsequently do not wish to receive these messages, you can easily withdraw your consent by de-activating the relevant toggle in your “Data Protection Settings" of the FREE NOW passenger App (under your “Profile”). See also section 7 (Your privacy rights) on other ways you can withdraw consent and how we will implement your withdrawal. 

15. To run our loyalty, referral and partnership programs. 

If you take part in one of FREE NOW's loyalty or referral programs or partnership schemes, we will use your personal data as necessary to provide you with the relevant loyalty or partnership rewards and to confirm your participation in the program. The terms and conditions of the relevant program will be provided to you at the time you sign up to it. In particular, we run a referral scheme for business accounts, by offering rewards when the new referred customer signs up and takes a certain number of journeys. If you are a B2B passenger that is referred through this scheme, we will contact you to ask if you would like to sign up to our services, and we will collect and share information with the person who referred you about your sign-up activity and the number of journeys you take.

Categories of personal data used for this purpose:

• Identity data: Name 
• Journey data: App usage information such as the number of journeys taken; the cost of journeys; distance travelled
• If you wish to collect miles from our frequent flyer program partners by using the Pay By App function (insofar as this is available), your respective program number (e.g. Miles&More number)

Our lawful basis for processing this data: Where participation in the program involves users signing up to a contract, we process this personal data on the basis that it is necessary for the performance of a contract with you (or to take steps at your request prior to entering into such a contract) (Art. 6 1 lit. b) GDPR).

Otherwise, we process this personal data on the basis that it is necessary for our legitimate interest (Art. 6 1 lit. f) GDPR) in conducting the loyalty or partnership program. However, your participation in any loyalty or partnership program is voluntary and you can choose not to participate and/or end your participation in accordance with the terms of the relevant program.

Lastly, the legal basis we rely on for the B2B referral scheme is the consent of the referred passenger. You have a right to withdraw it at any time and please see section 7 (Your privacy rights) on how you can withdraw consent and how we will implement your withdrawal.

16. To use the FREE NOW mobility benefits card.

If you accept your employer's invitation to use the FREE NOW Mobility Benefits Card and activate and use your card, we process personal data in order to manage your budget, the mobility services used and the entitlements granted to you and to be able to assist you with any questions or problems. We also provide your employer with (possibly aggregated) information about the status of the budget or budget consumption, so that, for example, further credits can be loaded onto cards in good time or statistical evaluations of budget developments in user groups can be made.

Categories of personal data processed for this purpose:

• Identity data: Name, if applicable title, user ID
• Contact information: E-mail address
• Tour information: If you use mobility services via FREE NOW, data will be processed in accordance with "Arrangement and management of tours".
• Location and location-related data: language; country, time zone
• Payment information: 
  • Date of payment acceptance/refusal, reason for payment refusal, payment ID, payment status (recorded/booked/expired) payment type, currency, payment amount (original amount/requested amount);
  • Card budget, budget used (for FREE NOW bookings each by type of mobility used), date of (regular) budget renewal;
  • Merchant ID, merchant category code, merchant name, city, zip code, country of merchant;
  • Card type (virtual/physical), card number, card security code (CVV / CVC), expiration date, and country of issue of credit card; first six and last four digits of PAN (Primary Account Number), card status (active/inactive), country of bill recipient.
• Technical data: Information about your terminal device (e.g. device ID, last login).
• Work-related data: Information about your employer, if applicable your function/role in the company, 
• Communication data: Content of your optional comments/statements (if required). 

Our legal basis for the processing of personal data: Processing for the purpose of creating and activating the Card in our App and in connection with the use of the Card for individual transactions is necessary to fulfill a contract concluded with you (Art. 6 1 lit. b) GDPR).

Insofar as personal data is transferred to your employer (if applicable also in aggregated form), this either also serves to execute a contract (Art. 6 1 lit. b) GDPR) concluded with you or to safeguard our legitimate interests (Art. 6 1 lit. f) GDPR) or those of your employer in the orderly administration of the mobility budgets granted.

If you are a Business Account Holder (employer), we collect and/or transmit personal data of holders, partners, beneficial owners and/or authorised representatives for the purpose of conducting so-called KYC (Know Your Customer) checks by the card-issuing partner company.   

Categories of personal data processed for this purpose:

• Identity data: Name, function/role in the company, value of shares held in the company, if applicable, customer ID, account holder ID.
• Company data: Company name, registered office, excerpt from the commercial register, commercial register number, tax number, VAT identification number, IBAN, bank information 

Our legal basis for the processing of personal data: The collection and transfer of personal data for the performance of KYC checks by the card issuing company is carried out in order to safeguard the legitimate interests to comply with obligations of payment service providers to cooperate in the fight against money laundering, fraud and the financing of terrorism.

17. To handle accident reporting. 

Unfortunately, accidents sometimes happen. If you or your driver is involved in an accident during a journey, we will use some of your personal information in order to carry out internal reporting, provide information to our insurers, mobility service providers, public authorities and other relevant third parties, and comply with our legal obligations. 

Categories of personal data used for this purpose:

• Identity data: Name
• Contact details: E-mail address; phone number
• Journey data: Details of the accident, including information your journey location, vehicle type, and journey time
• Health data: if anyone has been injured during the accident

Our lawful basis for processing this data: It is necessary for the purpose of our legitimate interests (Art. 6 1 lit. f) GDPR) in maintaining internal records about accidents that take place, notifying our mobility service providers of incidents in accordance with our contractual obligations, and processing insurance claims.

We will also process your personal information on the basis that it is necessary for compliance with a legal obligation (Art. 6 1 lit. c) GDPR) to which we are subject, where this is the case.

In limited instances, we will process this information to protect the vital interests (Art. 6 1 lit. d) GDPR) of you or someone else. 

18. To comply with our legal obligations. 

We may use your personal data to provide information to competent authorities where we are required to do so by applicable laws or regulations (e.g., to our transport licensing authority or insurers) based on Art. 6 1 lit. c) GDPR.

The types of personal data we share for this purpose will vary depending on the nature of the legal obligation. However, common categories of personal data used for this purpose are:

• Identity data: Name, details about your FREE NOW account.
• Contact details: E-mail address; phone number.
• Journey data: Information about your journeys, such as the start/end point.
• Usage data: Information about your usage of our App.

19. Links to third-party websites. 

Where you access a third party's website – for example, by following a link to our Facebook page via our website – the provider of that website will be the controller of the personal data you provide on that site. For information about how they will handle your personal data, you should refer to the privacy notice on that website.

We share your data with the following categories of recipients.

• With our FREE NOW group companies who process personal information for purposes that are described in this Privacy Notice. You may exercise your data subject rights under the GDPR in respect of and against each of the parties. However, to speed up the response, we would kindly ask you to exercise your rights at support.free-now.com/hc/fr/requests/new. Our group companies, to which we transfer each of the personal data types described in this Privacy Notice, operate in the same sector as us and are based inside the UK/EEA.

• Our parent company, Lyft, Inc., and its affiliates, third party services providers and partners who provide data processing services to us or who otherwise process personal information for purposes that are described in this Privacy Notice. These parties are based inside and outside of the EEA/UK, including in the United States.

We work with the following categories of third party service providers: 

• Transportation companies and drivers provide journeys that you request through the App. To be able to provide these services, these providers receive your:
  • Identity data: name; profile picture (if you have chosen to upload this to the App). Drivers will only be shown your profile picture temporarily around the time of your booking;
  • Journey data: Journey booking information including the start/end location; live location;
    • Whilst your driver will be able to phone you about your journey (e.g., to warn you of traffic jams), we use a phone number masking service that means the driver will not be able to see your phone number;
    • Aggregated driver rating.

• Third parties that help enhance the security and functionality of our App so that we can better tailor it to our customers' needs. To be able to provide these services, these providers receive the personal data set out under section 3.9 above. We also use a provider of multi-factor authentication when you register on the App.

• Payment service providers and travel expense tool providers (where you choose to connect your account with a travel expense tool). To be able to provide these services, these providers receive the personal data set out under section 3.6 above.

• Mapping software providers (such as Google Maps) so that we can allow you to interact with maps on the App. To be able to provide these services, these providers receive your:
  • GPS location data (in an anonymised form so they cannot identify you).

• Anti-fraud and non-payment service providers. To be able to provide these services, these providers receive the personal data set out under section 3.8.

• Our advertising services and analysis partners.To be able to provide these services, these providers receive the personal data set out under sections 3.10 and 3.11.

• Customer communications services providers. To be able to provide these services, these providers receive the personal data set out under section 3.5.

• Our loyalty programme partners. To be able to provide these services, these providers receive the personal data set out under section 3.15.

• E-scooter, e-moped, e-bike or car rental companies, where you choose to hire these vehicles. These third parties receive the personal data that is listed under section 3.2. When you rent a vehicle provided by these companies, FREE NOW will act as a joint controller of your personal data alongside the vehicle provider. This means that FREE NOW and these providers will each process personal data. You can find out more about how these parties handle your personal data under their privacy notices available at:
  • TIER: link 
  • VOI: link 
  • Dott: link
  • Cooltra: link
  • SHARE NOW: link 
  • ZITY: link
  • Bird: link

You may exercise your rights under the GDPR in respect of and against each of the parties (either FREE NOW or our third-party service mobility provider). However, to speed up the response, we would kindly ask you to exercise your rights via support.free-now.com/hc/fr/requests/new.

• Identity verification provider, where you are asked to verify your driver's licence information to hire an e-scooter, e-moped or rent a car. To be able to provide these services, these providers receive the photo of your face and your driving licence.
• FREE NOW partners with third party providers (e.g. car rental companies) to offer their services within our App. For certain services you may be redirected to the provider’s website to order the service there. However, in order to process the reservation and payment, these third parties may receive the personal data that is listed under section 3.2. Your data will not be shared unless you decide to use that service and you will be always informed which company receives your personal data.

• If your FREE NOW account is connected to your employer (e.g., you pay for your tour via a business account and/or mobility budget provided by your employer), we will share personal data with your employer or other owner of the business account. To process this payment we will share your invoicing data, including your name, email address, fleet type, tour price and start/end location of your journey, but only to the extent that the relevant journey is paid by the business account or in scope of the mobility budget granted by your employer.

• Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary:
  • as a matter of applicable law or regulation,
  • to exercise, establish or defend our legal rights (or where it is necessary for our legitimate interests in enabling our drivers or partners to exercise their legal rights), or
  • to protect your vital interests or those of any other person.

• An actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice.

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you, including to serve interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.

In some cases, your personal information is transferred to, and processed in, countries other than the country in which you are resident.  These countries may have data protection laws that are different to the laws of your country. 

Specifically, our group companies are located inside the EEA/UK and we store all our data with a cloud service provider within the EU or in IT infrastructures and systems (employee computers) at our sites within the EEA/UK. Our parent company and its affiliates, third-party service providers and partners operate around the world. We have selected our service providers carefully to check that they will protect the personal data we share with them and we have engaged them in writing. 

Where we transfer your personal data outside the UK or EEA to these parties, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.

We have concluded data processing agreements with these parties in accordance with Art. 28 3 GDPR, in as much as this is required for the contractual purpose. The transfer to these parties outside of the European Economic Area takes place correspondingly on the basis of decisions by the EU Commission pursuant to Art. 45 GDPR or on the basis of standard contractual clauses. Transfers of personal data to our United Kingdom location, take place on the basis of the EU-UK adequacy decision. This ensures the consistent legality of data transfers.

For more information on the appropriate safeguards that we have implemented, you can contact us using the details provided in section 1. 

You have the following data protection rights. You can exercise these rights by sending us a message to support.free-now.com/hc/fr/requests/new or a letter to the address mentioned under section 1 above. 

• You have the right to access, correct, update or request deletion of your personal data; 
• you can ask us to restrict processing of your personal information or object to processing;
• you can request portability of your data;
• you have the right to opt-out of marketing communications we send you at any time (you can also exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you or through the Privacy menu on the "App"). We will implement your opt-out as soon as possible (due to technical reasons, this will be within 48 hours);
• if we have collected and process your personal data with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent; 
• You also have the right to give instructions concerning the use of your personal data after your death. During your lifetime, you can designate a person to carry out the general or specific instructions you have given to them on how to store, delete or disclose your personal data after your death.
• you may at any time lodge a complaint with the French data protection authority (the Commission Nationale de l'Informatique et des Libertés (CNIL)) if you are unhappy with how we have used your data. 

The CNIL’s address is:            

CNIL

3 Place de Fontenoy

TSA 80715

75334 PARIS CEDEX 07.

Helpline number: +33 (0)1 53 73 22 22

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

We have taken appropriate technical and organisational measures to keep your personal data secure (in particular to protect your personal data against unauthorised access by third parties, as well as accidental or intentional modification, loss or destruction). We review these measures periodically and change them in line with state of the art security processes.

The transfer of your personal data from your device (e.g. smartphone) to us is always encrypted. FREENOW is PCI DSS (Payment Card Industry Data Security Standard) certified.

We are committed to ensuring the confidentiality, integrity, and availability of our IT resources, software, and hardware. To achieve this, we process certain data for the protection and security of these assets. This includes monitoring our systems for threats, vulnerabilities, and unauthorized access, as well as implementing and maintaining security measures like firewalls, intrusion detection systems, and access controls. We also process data for backups and disaster recovery to prevent data loss and ensure business continuity. This processing is essential to safeguard your data and our services from cyberattacks, system failures, and other potential disruptions.

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or it to comply with applicable legal, tax or accounting requirements). In particular:

• Call recordings are deleted after 30 days;
• Inactive accounts are deleted after 3 years of inactivity.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.