Data protection

Date of last update: 11/05/2021

CarryMe SAS places great importance on the protection of your personal data. This Privacy Notice provides you with clear and detailed information about how your personal data is protected by CarryMe ("we").

As the data controller, we are responsible for collecting and processing your personal data in the course of our business activities. This Privacy Notice aims to inform you about the personal data we collect about you, the reasons why we use and share it, how long we retain it, what your rights are, and how you can exercise them.
1. What personal data do we use about you?

We collect and use your personal data, namely any information that identifies you or allows you to be identified, to the extent necessary for the implementation of our activities, and to offer you personalized and quality services.

Depending in particular on the service we provide you, we collect different types of personal data about you, including:

  • Identification information (e.g., gender, full name, gender, photo, email);
  • Private or professional contact information (e.g., postal address and email address, telephone number);
  • Data collected in the context of our interactions with you on our website, our application, connection and tracking data such as cookies, connection to online services, IP address, calls, discussions via instant messaging, emails, interviews, telephone conversations.

We may collect the following special categories of personal data (or "sensitive data") only after obtaining your explicit prior consent: Health data: for example, if you request to transport medication, its classification (name of the medication) will be stored in CarryMe. However, the medical prescription will be sent to the traveler, along with the medication, without being stored in CarryMe; this data is processed only if strictly necessary.

We never ask you to provide us with other sensitive data such as data relating to your racial or ethnic origin, your political opinions, or relating to your trade union membership, genetic data or data relating to your life or sexual orientation, unless we are legally obligated to do so.
2. Who is this notice addressed to and from whom do we collect personal data?

We collect data directly from you (when you contact us, visit our website, use our services, participate in a survey or event we organize), but also data about other people indirectly. Indeed, we collect information about people even if they have no direct connection with us because they have a connection with you, for example: members of your family; close friends without a family relationship;

When you provide us with the personal data of third parties such as those listed above, please ensure that you inform the individual to whom this data relates that we are processing their personal data and direct them to this Privacy Notice. We will also provide them with this information where possible (for example, if we do not have their contact details, we will not be able to contact them).
3. Why and on what legal basis do we use your personal data?

In this section, we explain how and why we use your personal data and draw your attention to certain processing activities that we consider likely to have more significant consequences for you and which, in some cases, require your consent.

**A.**To comply with our various legal and regulatory obligations, we use your personal data to comply with applicable regulations in order to:

  • Monitor operations and identify those that are abnormal/unusual; manage, prevent and detect fraud;
  • Monitor and report the risks (financial, credit, legal, compliance or reputational, default, etc.) that we and/or your company may face;
  • Record, if necessary, telephone conversations, instant messaging discussions, emails, etc.

**B.**To perform any contract to which you are a party or to perform pre-contractual measures taken at your request

We use your personal data to enter into and perform our contracts and to manage our relationship with you, in particular to:

  • Define your insurance risk score and determine an associated pricing
  • To assess whether we can offer you a service and under what conditions; to assist you, in particular by responding to your requests; to provide you with services;

**C.**To serve our legitimate interests

We use your personal data for the following purposes:

  • Risk management: managing, preventing and detecting fraud; asserting rights in court and defending ourselves in litigation;
  • Personalization of our offer, as well as that of other entities within your company, to: improve the quality of our services;*
  • Security and performance management objectives for IT systems, which includes: managing information technology, including infrastructure (e.g., shared platforms), business continuity and security (e.g., user authentication);
  • More generally: to inform you about our services; to conduct customer opinion and satisfaction surveys; to improve the efficiency of processes (training our staff by recording telephone conversations in our call centers and improving our call scripts); to improve the automation of our processes, in particular by testing our applications, processing complaints automatically, etc.

In all cases, our legitimate interest remains proportionate, and we ensure, through a balancing test, that your interests or fundamental rights are protected. If you would like more information about the balancing test, please contact us using the contact details provided in section 9, "How to contact us," below.

**D.**To respect your choice when we asked for your consent for specific processing

As part of certain personal data processing activities, we will provide you with specific information and ask for your consent to this processing. Please note that you can withdraw this consent at any time.

  • If we carry out further processing for purposes other than those set out in Section 3, we will inform you and, if necessary, obtain your consent;
  • If we process special categories of personal data (or "sensitive data") such as health data.

4. With whom do we share your personal data?

Data sharing: No personal data will be transmitted to a third party through CarryMe.
5. International transfers of personal data

In the case of international transfers from the European Economic Area (EEA) to a country not belonging to the EEA, the transfer of your personal data may take place on the basis of a decision made by the European Commission, when the latter has recognized that the country to which your data will be transferred ensures an adequate level of protection.

In the event of a transfer of your data to a country whose level of data protection has not been recognized as adequate by the European Commission, we will either rely on a derogation applicable to the specific situation (for example, if the transfer is necessary to perform a contract concluded with you, such as in particular when making an international payment) or we will take one of the following measures to ensure the protection of your personal data: standard contractual clauses approved by the European Commission; binding corporate rules.

To obtain a copy of these measures to ensure the protection of your data or to receive details relating to where it is accessible, you can send us a written request according to the terms indicated in Section 9 below.
6. How long do we keep your personal data?

We retain your personal data for the period necessary to comply with applicable laws and regulations, for the period required for the purposes for which it was collected or for a period defined in view of our operational constraints, such as to assert legal rights or respond to requests from regulatory bodies.

Regardless of your status: Telephone recordings made for the purposes of improving service quality and training our staff are kept for 6 months. Analytical documents resulting from these recordings are kept for 1 year. Information relating to your identity and provided when you request to exercise your rights as described in Section 7 is kept for a period of one to three years, depending on the type of right, from the date you exercised that right.
7. What are your rights and how can you exercise them?

In accordance with the legislation applicable to your situation, you may exercise the following rights, where applicable:

  • Right of access: you can obtain information concerning the processing of your personal data as well as a copy of it;
  • Right to rectification: if you believe that your personal data is inaccurate or incomplete, you can request that it be amended accordingly;
  • Right to erasure: you can request the deletion of your personal data, within the limits authorized by law;
  • Right to restriction of processing: you can request the restriction of the processing of your personal data;
  • Right to object: You can object to the processing of your personal data for reasons relating to your particular situation. You have the absolute right to object at any time to your data being used for direct marketing purposes, or for profiling purposes if such profiling is related to direct marketing.
  • Right to withdraw your consent: if you have consented to the processing of your personal data, you can withdraw this consent at any time.
  • Right to data portability: where permitted by law, you can request the return of the personal data you have provided to us, or, where technically possible, the transfer of this data to a third party.
  • Right to define guidelines regarding the retention, erasure or communication of your personal data, applicable after your death.

If you wish to exercise the rights mentioned above, please send us a request by email to the following address: Contact@CarryMe.fr

Please include a scan/copy of your proof of identity, when required, so that we can identify you.

In accordance with applicable legislation, in addition to the rights mentioned above, you may lodge a complaint with a competent supervisory authority.
8. How can I be informed of changes to this personal data protection notice?

In a world where technologies are constantly evolving, we may need to update this Notice regularly.

We invite you to review the latest version of this document online, and we will inform you of any significant changes through our website or via our usual communication channels.
9 How to contact us?

If you have any questions regarding our use of your personal data under this Privacy Notice, you can contact our Data Protection Officer who will process your request: Contact@CarryMe.fr

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