PRIVACY POLICY
MODUM

MODUM is a free application dedicated to the digital part of the Mobility Surveys. These mobility surveys answer a need of general interest of the public authorities organizing mobility on a territory. Indeed, these communities wish to propose a transport offer (metro lines, road development, etc...) adapted to the uses of the citizens moving on their territory. This is where MODUM intervenes, to measure these mobility uses, by carrying out surveys with a sample of citizens.

The objective of MODUM is to help these communities to adjust the mobility offer to the real needs of the users. To achieve this, MODUM collects, with their consent, the trips, activities and location of its users. These data are then aggregated to measure mobility flows on a territory. Public decision-makers (cities, regions, public transport operators,...) can then use this data to guide their decision making such as deciding the route of a future public transport line, sizing parking lots or evaluating a bicycle path project.

For these purposes, the application collects, with the user's prior authorization, the location data from his or her smartphone, only during his or her travels and for the duration of the mobility survey. The location data collected makes it possible to determine for a user :

• the transport modes of the user

• the reason for their trips

• the duration of their trips

• their geolocated positions

2. Processing of personal data

The personal data are processed by the company Autoroutes Trafic, which develops the MODUM application (hereafter called "we", "our" or "us"):

AUTOROUTES TRAFIC SAS, a simplified joint stock company registered in the PARIS Trade and Companies Register under the number 445 091 754 00033, whose registered office is located at 59 Boulevard Exelmans, 75016 PARIS.

No data is stored or transferred outside the European Union, MODUM's services are integrated on Microsoft Azure servers hosted in France.

All user data is pseudonymized, meaning that no name, email or phone number is used to link the data to a user. Instead, a unique identifier is used, generated from the survey code. This survey code is provided to the user in advance in order to log in and use the MODUM application.

3. Collecting personal data

When using the MODUM application, the user is led to transmit information to us, some of which are of an identifiable nature ("personal data"). This is notably the case when the user fills in the contact form in the MODUM application or when he/she informs us of a problem by email, chat or telephone.

The personal data we process includes the following personal information:

• The user's ID:

This randomly generated ID is used to uniquely identify the user.

• The user's location data:

This data is used to allow the user to view their routes and activities chronologically and on a map in the app.

• The user's Firebase ID:

This identifier is used to send notifications to the user.

To automatically detect and analyze a user's trips, the app uses background location to collect the user's location data, even when the app is closed or not in use.

For some "100% digital" mobility surveys, the user may be asked to fill in an additional form where the following personal data are also processed:

• The user's first and last name

• The user's age

• The user's telephone number

• The user's home and work address

• The user's profession

• The user's email address

We do not collect any sensitive data about users such as racial or ethnic origin, political, philosophical or religious opinions, as well as any data relating to trade union membership, health or sex life.

4. Sharing of collected personal data

The user's personal data collected by the application is shared within the strict usage of the mobility survey only with the following entities:

• The organizing authority: in charge of managing the mobility survey

• The field service provider: in charge of carrying out, monitoring and supervising the mobility survey

The personal data of the user that can be shared with the entities previously named are :

• • • The user's ID

• The user's first and last name

• The user's age

• The user's telephone number

• The user's home and work address

• The user's profession

• The user's email address

5. Purpose of collecting and sharing personal data

By agreeing to the collection of personal data listed in 3., the user can access the basic features of the MODUM mobile application, namely:

• View their trips and geotagged activities chronologically

• View their geotagged trips and activities on a map

By agreeing to the sharing of the personal data listed in 4., the user agrees to :

• Participate in the digital component of the mobility survey in question

• Allow the entity in charge of the mobility survey to measure his/her travel flows

6. Retention of personal data

In the absence of an express request to the contrary, the user's personal data is kept for up to 90 days after the end of the mobility survey.

7. Legal security compliance

We may be required by law, legal process, litigation and/or a request from local government or public authorities to disclose the user's personal data. We may also be required to disclose personal information if we are required to do so for national security, law enforcement or other public policy purposes, where such disclosure is necessary and appropriate. If permitted by law, the user will be notified in advance of the transfer of their data.

We may also disclose personal information if we believe, in good faith, that such disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.

8. User rights

Within the framework of the above-mentioned processing operations, the user has the right to request access to his personal data in a standard structured format, to modify his data and to have them deleted. Furthermore, the user has the right to object to the processing of his/her personal data or to request the restriction of such processing.

In any case, the user also has the right to file a complaint with the competent data protection authority.

9. Changes to the Privacy Policy

We may change our Privacy Policy from time to time in accordance with our legal obligations. You should check this page regularly for any changes or updates to this document.

10. Contact

We can be contacted for any questions regarding our Privacy Policy or the user's personal data:

• By mail at the following address Autoroutes Trafic, 59 boulevard Exelmans, 75016 Paris

• By e-mail at the following address: app@autoroutes-trafic.fr