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Hera13 Transport

Privacy Policy

Last updated: May 2025

Preamble.Preamble

This privacy policy is intended to inform Riders and Drivers using the Application developed by HERA 13 TRANSPORT of the ways in which their personal data is collected, processed and used, and of their rights regarding the protection of personal data under applicable provisions, in particular Law No. 78-17 of January 6, 1978 on data processing, files and freedoms (known as the "Data Protection Act") and European Regulation 2016/679 on the protection of personal data, known as the "GDPR".

This privacy policy governs all processing carried out by HERA 13 TRANSPORT, a French limited liability company (SARL) with capital of €1,000.00, registered with the Marseille Trade and Companies Register under number 938 563 475, whose registered office is located at 55 rue Grignan – 13006 MARSEILLE (hereinafter "HERA 13"), as data controller within the meaning of the GDPR.

HERA 13's personal data processing policy can be viewed directly within the Application or on HERA 13's website. Validation of the Account by the Rider or Driver constitutes acknowledgment by the Rider or Driver that she has been informed of the conditions under which her personal data is processed, as set out herein, and that she accepts them without reservation.

1.Definitions

Application
means the application developed by HERA 13, available on the Apple App Store.
Client
means the individual or legal entity who has created an Account on the Application developed by HERA 13.
Account
means the Rider's or Driver's profile created upon first access to the Application.
Driver or Rider
means the individual or legal entity who has created an account on the Application developed by HERA 13.
Terms
means the document establishing the rights and obligations of each Party in connection with the use of the Application.
Rider Data or Driver Data
means all information and data of Riders or Drivers, including all personal data, provided by them in connection with their use of the Application.
Credentials
means the usernames and passwords enabling Riders or Drivers to access the application.
Party
means either HERA 13 or the Client, as applicable.

2.Data Processed by HERA 13

As part of the use of the Application, HERA 13 collects and processes personal data relating to Riders and Drivers.

HERA 13 acts as data controller within the meaning of the GDPR for the personal data covered by this privacy policy, relating to Account creation and use of the Application by both Riders and Drivers.

2.1 Categories of Data Processed

Riders' and Drivers' contact details as listed in the Terms when the Account is created, namely: last name, first name, date of birth, phone number and email address.

Drivers' professional information: valid driving licence; proof of vehicle insurance; copy of the registration certificate; copy of the professional VTC (private hire) card; proof of registration in the VTC register; proof of professional liability insurance; proof of business insurance (operational liability); valid identity document (verified by our provider Didit); medical examination certificate for the VTC card; driving record extract (RIR); where applicable, a company registration extract (Kbis) less than six (6) months old; the vehicle sticker (macaron).

Profile information: profile photo, saved addresses, language of use and communication preferences.

Geolocation data: pickup location, drop-off location, route, nearby vehicles, ride times and, more generally, all data relating to how the ride is carried out.

Payment data: amount charged, payment history and invoices. This data is processed by our secure payment provider Stripe (Stripe Payments Europe, Limited), which acts as a data processor within the meaning of the GDPR. HERA 13 does not directly retain bank data, which is hosted by Stripe in compliance with PCI-DSS standards.

Data relating to recordings of communications and correspondence exchanged through the HERA 13 application's messaging tool, or in the event of contact with any member of support, including via [email protected].

Data relating to sensors and the technical condition of the vehicle.

Identification data for the device used, in particular the IP address on which the Application was installed.

2.2 Basis for Data Processing

HERA 13's legitimate interest, in particular its commercial interests and the provision of a service consistent with its commercial and security policy, in order to combat fraud and malicious or dangerous activities and to maintain the safety of Riders and Drivers.

Legal obligations incumbent on HERA 13, in particular in connection with monitoring and providing documents required by regulations applicable to intermediary transport-matching services, or in connection with financial obligations regarding the retention of invoices or accounting data.

Performance of the contract, with regard to the collection of data relating to the creation of the various accounts and to matching Riders with Drivers, including location data as well as financial data.

The explicit consent of Riders or Drivers for the processing of data relating to their identity, status and professional data, as well as for sending notifications, newsletters and promotional and marketing communications.

If a Rider or Driver refuses to provide personal data governed by this privacy policy, this could prevent HERA 13 from providing the services it intends to provide or from complying with legal requirements. Such refusal may also affect the functioning of the account and prevent the provision of the services HERA 13 intends to provide through the Application.

2.3 Data Collection

Data relating to Users is collected by HERA 13 directly from the Rider or Driver when they log into their account on the Application.

2.4 Purpose of Processing User Data

Rider and Driver Data is processed to enable use of the Application, including in particular the identification and location of a Rider in order to connect her with a Driver as part of the use of the matching Application for the purpose of offering a transport service.

This data is also processed for archiving purposes for evidentiary purposes, for producing audience and traffic statistics, for distributing commercial and marketing content, and for carrying out commercial prospecting operations.

In summary, personal data is processed for one of the following purposes: managing the Rider's or Driver's Account; optimizing the Application to best adapt it to the needs of Drivers and Riders; providing support in finding a Driver and during the course of a ride; collecting the Rider's payment for the purpose of settling the service provided by the Driver; promoting good practices and preserving the safety of both Riders and Drivers; and regularly informing Riders and Drivers about transport services and any developments to the features of the HERA 13 Application.

2.5 Retention Period for Rider and Driver Data

Rider and Driver Data, such as their contact details, Drivers' professional information and profile information, will be kept in active storage for the entire period during which the Account remains valid, and then for a period of three (3) years thereafter, for evidentiary purposes, unless a different statutory retention period applies.

Data relating to identity documents will only be kept for as long as necessary for identity verification, which is carried out by our provider Didit, who acts as a data processor within the meaning of the GDPR. As soon as identity verification has been carried out, the document in question will be deleted in accordance with Didit's retention policy.

Geolocation data will be kept for a period of one year after the relevant service, for the purpose of handling any potential claims, and will then be anonymized.

Financial and accounting data will be kept for a period of ten years in accordance with applicable French regulations on this matter.

3.Cookies

HERA 13 may collect and process data relating to the device on which the Rider or Driver accesses the Application. This data is not attributable to a named individual.

In this context, HERA 13 may use cookies, or similar technologies, for the following purposes:

• Authenticating Riders and Drivers;
• Remembering the Rider's or Driver's preferences and settings;
• Designing advertising campaigns and evaluating the effectiveness of those advertising campaigns;
• Analyzing traffic and trends on the application, and understanding the behavior and interests of Riders and Drivers in connection with their interactions relating to the use of HERA 13's services.

Statistical cookies, provided they comply with the guidelines and recommendations issued by the CNIL on September 17, 2020, may be used without requiring the user's consent to be obtained.

Cookies and trackers installed while browsing the Platform expire after a period of twelve (12) months from the last visit to the Platform.

4.Data Sharing

HERA 13 only uses the aforementioned data for the purposes set out in this privacy policy.

The data is not used for any other purpose, is not transmitted to third parties, and is kept confidential.

HERA 13 may nevertheless use technical service providers, in particular: for hosting its website and/or the application on shared server infrastructure and for routing emails or content; Stripe (Stripe Payments Europe, Limited), for the secure processing of payments; and Didit, for identity verification of Drivers and Riders.

Where applicable, data may potentially be accessible to the provider, strictly within the scope of the service provided.

In this regard, HERA 13 undertakes to implement all measures necessary to protect the personal data of Riders and Drivers in connection with the provider's access to the personal data covered by these terms.

If HERA 13 transfers personal data to a third country, in particular if its servers hosting the data or the operators handling calls are located outside the European Union, HERA 13 undertakes to ensure that contracts entered into with the providers concerned include the standard contractual clauses established by the European Commission to guarantee the security and confidentiality of the data transferred.

5.Security

HERA 13 only processes the data it collects in strict compliance with applicable legislation, and in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, known as the GDPR.

In this regard, HERA 13 undertakes in particular to:

• Not use the data for purposes other than those specified herein or in the general terms and conditions appearing on the Application or on HERA 13's website;
• Not disclose the data to third parties, whether private or public, individuals or legal entities, other than the technical service providers referred to above;
• Inform Riders or Drivers of any breach or security failure that has direct or indirect consequences on the data and/or that may accidentally result in the disclosure of or unauthorized access to data;
• Ensure that members of its staff who may access Rider or Driver Data are bound by a confidentiality obligation;
• Ensure that the servers hosting Rider and Driver Data are located within the territory of the European Union;
• Ensure that any subcontractors that HERA 13 uses or may use in connection with its business comply fully with the provisions of the GDPR and are subject to obligations identical to those imposed on HERA 13 under these terms regarding the confidentiality and security of data;
• Assist Drivers and Riders, upon request, with handling requests to exercise the rights of data subjects concerning data processing;
• Delete or return to the Client, at her choice, all Data detailed in this privacy policy at the end of the contractual relationship, without retaining a copy.

6.Rights of Data Subjects

In accordance with the French Data Protection Act of January 6, 1978 and Regulation (EU) 2016/679 of April 27, 2016, known as the "GDPR", data subjects concerned by the processing of personal data referred to in this privacy policy have an individual right of access, rectification, erasure, restriction, objection and portability regarding the data concerning them.

The rights to object to or restrict processing may only be exercised subject to the reservations set out in applicable regulations, in particular Articles 17 and 21 of the GDPR, with regard to data processing justified by a legitimate interest or by the necessity of performing a contract.

For the data referred to in Article 2 herein, requests to exercise the aforementioned rights must be sent to HERA 13, in its capacity as data controller. The person making the request must provide their last name, first name, address and email address, under the following conditions:

• Either by post to the following address: 55 rue Grignan – 13006 MARSEILLE, HERA 13 TRANSPORT.
• Or by email to the following address: [email protected].

Data subjects concerned by the processing described herein also have the right to lodge complaints with the competent supervisory authority regarding the exercise of the aforementioned rights. For persons residing in France, the competent supervisory authority is the CNIL.

7.Marketing and Promotional Communications

As stated in its Terms, HERA 13 reserves the right to send marketing and promotional communications, such as promotional codes, to the email address and/or phone number provided by Riders and Drivers, where they have authorized HERA 13 to do so directly or on the basis of explicit consent. Marketing or promotional communications may be personalized based on information collected in connection with the Rider's or Driver's use of the Application.

If Riders or Drivers no longer wish to receive such communications, they may unsubscribe via the link at the bottom of any such communication, in their profile settings on the Application, or directly at the following email address: [email protected].

8.Changes to the Privacy Policy

HERA 13 reserves the right to amend this privacy policy, either to strengthen the protection of privacy and transparency it wishes to provide to Drivers and Riders, or in the event of a new or reinforced legal or regulatory obligation.

9.Dispute Resolution

Disputes relating to the processing of personal data are resolved through support at the following email address: [email protected].

If, after contacting HERA 13, the Rider or Driver believes that her rights are not being respected, the Rider or Driver may submit a complaint to the Commission Nationale de l'Informatique et des Libertés (CNIL): www.cnil.fr.

For any questions regarding this Privacy Policy, please contact us at:

[email protected]