Legal Notices

    1. LEGAL NOTICES

    The website accessible under the address https://www.free2move.services/ (hereinafter referred to as the “Site”) and the application Free2move Services, available from the Stores (Apple Store and Google Play), (hereinafter referred to as the “Application”) are published by PSA Automobiles SA, a Société Anonyme (public limited company), the registered office of which is located at 2-10 Boulevard de l’Europe, 78300 Poissy, France, registered on the Versailles Trade and Companies’ Register under number 542 065 479.

    Email: support@smartservices.zendesk.com

    The director is Myriam Vergès.

    The platform was designed by Capgemini.

    The Site and Application are hosted by Amazon Web Services on servers located in Europe.

    1. PRIVACY POLICY

    This privacy policy is intended to inform you how your personal data (hereinafter referred to as “Personal Data”) is processed by PSA Automobiles SA as controller.

    PSA Automobiles SA takes the respecting of your privacy and the confidentiality of your Personal Data very seriously, and is committed to processing your Personal Data in compliance with applicable laws and regulations, and in particular Law No. 78-17 of 6 January 1978 on information technology, files and freedoms (hereinafter referred to as the “Data Protection Act”), and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “Regulation”).

    Data Collected

    When you register on the Application or when you benefit from Free2move Services, PSA Automobiles SA collects a certain amount of Personal Data concerning you as detailed below:

    • Information which identifies you: your first and last names, your phone number, your email address and your postal address;
    • Information about your vehicle: model, colour, number plate, geolocation;

    This data is identified as mandatory. Failure to reply will prevent PSA Automobiles SA from responding to your request and/or performing the service ordered.

    PSA Automobiles SA informs you that, in order to manage and respond to your requests, your data may be shared with Opel Automobile GmbH, Bahnhofsplatz, 65423 Rüsselsheim am Main, Germany.

    We share your personal data with the recipients indicated in order to meet the following objectives:

    • Last name, first name and e-mail address to conduct a customer satisfaction survey if you provide your consent – INTERSOFT CEE SRL, MOLNAR JANOS 13 bl 4 sc A app 7, Brasov, Romania.
    • Name, first name and postal address to send the Recharge Card – Futurlog SASU, 25 avenue Rapp, 75007 Paris, France

    In addition, when you register, you are asked for bank details: credit card number, expiry date, email address. PSA Automobiles SA informs you that these data are collected by its partner Banque PSA Finance, a public limited company whose registered office is located at 68 avenue Gabriel Péri, 922230 Gennevilliers. Banque PSA Finance guarantees you a secure payment by integrating the SSL security standard. For any questions about payment methods, please contact Banque PSA Finance at the following address: solutionspaiements@mpsa.com.

    Finally, in order to counter computer attacks, your IP address is recorded (the IP address is a unique identifier assigned to any connected machine that allows you to communicate within a network, like a postal address). This information may also be used by law enforcement agencies in legal proceedings to identify a dishonest person.

    Use of the data

    PSA Automobiles SA processes your Personal Data for the following purposes:

    • Creating your account and providing Free2move Services ;
    • Managing and optimising customer relations;
    • Sending supplies related to the services subscribed (badge/card);
    • Ensuring the proper functioning of the Website and the Application;
    • Managing your requests for access, rectification and card stop rights;
    • The management of complaints and disputes.

    These processing operations have as their legal basis the necessity for the execution of the contracts to which you are a party (General Terms and Conditions of Use and General Terms and Conditions of Sale).

    PSA Automobiles SA, in the context of the fulfilment of its legitimate interests, consisting in particular in improving its services by improving its knowledge of the User, and in carrying out commercial operations for the purpose of acquiring and retaining customers, may also process your Personal Data for the following purposes:

    • Operations relating to customer management and business development (e.g. sending newsletters and other information relating to the products and offerings of PSA Automobiles SA or any other company in the PSA Group);
    • Develop statistics, trade surveys;
    • The improvement of Free2move Services services to meet your needs;
    • Offer an additional service;
    • The management of people’s opinions on Free2move Services.

    The recipients of this Personal Data are, strictly within the framework of the purposes set out above: the authorised personnel of PSA Automobiles SA, any company of the PSA Group and their service provider partners.

    Your rights

    In accordance with the “Data Protection Act” and the Regulation, you have the right to access, rectify, erasure, restrict processing, to data portability and to object to processing of personal data concerning you which is based on Art. 6 (1) 1 e) or f) GDPR or where the personal data are processed for direct marketing purposes in accordance with the applicable law. Finally, you have the right to define general and specific directives defining how you intend to exercise these rights after your death.

    Please note that your above-mentioned rights are restricted by law and must be fulfilled by us possibly only under certain conditions.

    You can exercise your rights of access and rectification directly from the personal space of your Account in the Application.

    You can claim your above-mentioned rights by sending a request by e-mail to support@smartservices.zendesk.com or by phone at the following number 09 72 72 72 05 11 (price of a local call from a landline).

    You can also exercise your right to lodge a complaint with the Autorité Nationale de Protection des Données (National Data Protection Authority) by sending your request to the Commission Nationale de l’Informatique et des Libertés (National Data Protection Commission), by mail to the following address: 3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07, or on the CNIL website available at the following address: https://www.cnil.fr or by phoning  the following number: 01 53 73 22 22.

    Right to withdraw your consent

    You have the right to withdraw your consent at any time (to do so, write to xx). The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

    Contacting us

    PSA Automobiles SA, 2-10 Boulevard de l’Europe, 78300 Poissy, France, the names of the members of the management can be found here: https://www.groupe-psa.com/en/automotive-group/governance

    Contacting the Data Protection Officer: PSA Automobiles SA, Protection des Données Personnelles, Case courier YT238, 2-10 Boulevard de l’Europe, 78307 Poissy CEDEX, France

    Guarantees

    In accordance with its legal obligations, PSA Automobiles SA undertakes to take all reasonable technical and organisational measures, and requires its subcontractors and partners to ensure the security and confidentiality of your Personal Data in accordance with the “Data Protection Act” and the Regulations.

    Data retention 

    PSA Automobiles SA shall keep your Personal Data for the following periods:

    • If you interrupt the subscription process before signing your contract, your User Account will be deleted within three (3) years of data collection and the corresponding data will be deleted;
    • If you complete the subscription process, your Personal Data will be retained for the duration of the Contract plus five (5) years.
    • Geolocation data is stored for two months after the completion of the service order (remote payment of on-street parking fees, guidance service to underground car parks) requiring information on your geolocation to be executed. You have the option of deactivating the geolocation device at any time and free of charge by proceeding as follows:
    • You are using the Application from the on-board computer of your Group vehicle: press the SOS button and the Assistance button simultaneously for less than one second. The Vehicle then proposes to switch to “non-geolocated” mode and asks to confirm this action by pressing the Assistance button. A voice message confirms the status change. It is specified that the geolocation of the Vehicle is automatically reactivated each time the Vehicle is started;
    • You are using the application from your smartphone: go to your smartphone’s settings to disable geolocation.

    In the event geolocation is disabled, PSA Automobiles SA informs you that the services requiring the collection of your geolocation to be provided cannot be performed.

    1. COOKIES

    What is a cookie? 

    A cookie is a small text file sent to your browser by the website you are visiting, and stored on your terminal equipment. Cookies allow the website visited to collect information about your visit, such as your visit to the site or your preferred language, in order to improve your browsing experience and the content and functionality of the website.

    What cookies are present on the Site? 

    • Functional cookies: you are informed that during your visits to the Site, PSA Automobiles SA may install technical cookies on your device, allowing you to track your navigation without having to request authentication on each page. These cookies are automatically deleted by the browser when it closes.
    • Cookies for audience measurement: PSA Automobiles SA uses Google Analytics, a statistical tool that can place cookies on your device, to compile statistics such as the number of visits, the number of pages viewed, the activity of users of the Site and their frequency of return. We inform you that all data collected through the use of these cookies is used anonymously by PSA Automobiles SA to improve the quality of the Site.

    PSA Automobiles SA informs you that no cookies are present in the Application.

    How can the recording of cookies be disabled?

    You have the option to refuse to accept cookies on your device via your browser.

    Depending on the browser used, you have the option of:

    • Listing the cookies used for each site;
    • Deleting the cookies saved;
    • Refusing to accept new cookies;

    PSA Automobiles SA informs you that functional cookies are necessary for the proper functioning of the site.

    Note that Google publishes a tool to specifically refuse the audience measurement cookies used by its Google Analytics and Adjust solutions. This is available at the following address: https://support.google.com/chrome/answer/95647?hl=fr.

    1. INTELLECTUAL PROPERTY

    PSA Automobiles SA grants Users a limited access licence to its Website and Application solely for their personal use. This licence does not include any resale or commercial use of the FREE2MOVE Services services, any collection or use of information, description or prices, any use of the Application, its content, any downloading or copying of account information for the benefit of third parties, any use of data mining, robots or other data mining collection tools.

    No hardware and information related to PSA Automobiles SA may be reproduced, duplicated, copied, copied, sold, resold, visited, or otherwise exploited for any commercial purpose without the express written consent of PSA Automobiles SA.

    All elements of the Application and Website, whether visual or audio, including graphics, logos, page headers, icons, scripts, service names and underlying technology, are the EXCLUSIVE property of PSA Automobiles SA and are protected. As such, and in accordance with the provisions of the Intellectual Property Code, only the use defined herein is permitted. Any other use, not expressly authorised in advance, is prohibited and constitutes counterfeiting. By connecting to the Application, the User agrees not to copy or download all or part of their content.

    1. MODIFICATION

    We reserve the right to make improvements or modifications to or discontinue the information, services, products and other elements of the Site and Application at any time without prior notice.

    1. HYPERLINKS

    The Website and the Application may include links to other sites. As PSA Automobiles SA has no control over these sites, we are not responsible for the content, information, documents, products or services they contain or to which they provide access.

    Consequently, access to and use of these websites is at your sole risk.

    Similarly, the existence of a hypertext link from a third-party site to the Site does not imply any cooperation between PSA Automobiles SA and this third-party site. As PSA Automobiles SA has no control over third party sites, we do not assume any responsibility for the content, information, documents, products or services.