Privacy Policy

Last updated on March 14th, 2018

1. Recitals

This privacy policy (hereafter the “Privacy Policy”) describes the means of collection and processing of personal data relating to the users of the AYRUU service and the AYRUU website.

The data processing is implemented by the French company TRIGONE TECH SAS, a simplified joint stock company with a share capital of € 34,380, registered with the Paris Trade and Companies Registry under number 812 944 387, whose registered office is at 38 rue de Berri, 75008 Paris, France (hereafter, “TRIGONE TECH”).

TRIGONE TECH collects and processes certain personal data (i) as part of the AYRUU service which TRIGONE TECH provides to its users through the AYRUU mobile application (hereafter the “Mobile Application”), allowing them to organize the different stages of their journey (before, during and after the travelling) and to come into contact with other individuals travelling with them (hereafter the “Service”) and/or (ii) through the AYRUU website located at https://web.ayruu.com/ or any other URL that may be substituted thereto (hereafter, the “Website”).

As data controller, TRIGONE TECH is concerned about best protecting the privacy of users of the Website and the Mobile Application (hereafter, the “Users”) and implements all necessary measures in this respect. Specifically, TRIGONE TECH undertakes to ensure a level of protection of the Users’ personal data compliant with European and French legislation relating to personal data.

2. User information

This Privacy Policy enables the Users to know more about the sources and uses of their information processed as part of their use of the Website and/or the Service, and on their rights. This Privacy Policy is therefore important for the Users who value a rewarding experience of the Service and expect to be able to use the Service securely. This Privacy Policy is also important for TRIGONE TECH who wishes to be able to respond to the Users’ queries in the most precise and complete fashion, and take into account the Users’ expectations.

TRIGONE TECH therefore makes this Privacy Policy available on the Website and/or on the Mobile Application so it is readily visible by and accessible to the Users, and the Users are able to review it before subscribing to the Service.

The User is deemed to have read the Privacy Policy and to be informed of the means of collection and processing of his/her personal data upon registration to the Service or browsing of the Website.

3. What type of personal data does TRIGONE TECH collect?

TRIGONE TECH collects certain personal data which is directly entered by the User upon registration to the Service (in particular as part of the registration forms), such as notably:

* registration information e.g. pseudonym and email address;
* profile data e.g. surname, name, industry sector, country of residence, etc.

The User’s pseudonym and profile data may be visible to other Users.

Other data may be collected during the time of the User’s browsing on the Website or the Mobile Application, during the time of use of the Service or when the User communicates with TRIGONE TECH through the Website or Mobile Application, such as in particular:

* the User’s IP address;
* the User’s browsing data (pages visited, etc.), as further described below.

Some information, completed on an optional basis by the User (such as e.g. the comments inserted in the profile free text fields, the picture of the User, etc.), may reveal the racial or ethnic origins, political opinions, religious or philosophical beliefs, or sexual orientation of the User, which is considered sensitive data within the meaning of French and European data protection legislation. By freely communicating such data to TRIGONE TECH, the User is deemed to have expressly consented to their collection and processing by TRIGONE TECH.

The User may at any time revoke his/her consent, by removing such content from his/her User account. In such case, the data will be permanently deleted by TRIGONE TECH subject to any applicable legal or regulatory requirement.

Besides, upon accessing the Service, the User agrees that his or her position will be geolocated during his/her journey. The User is expressly informed that he/she will not be able to use the Service if he/she refuses to allow TRIGONE TECH access to his/her location data.

4. Why does TRIGONE TECH collect the Users’ personal data?

The User is informed that his/her personal data is collected for the sole purposes of providing the Service subscribed to the User.

In this respect, TRIGONE TECH collects the User data to:

* enable the User to access the features and functionalities of the subscribed Service (including paid-for options as the case may be);
* manage and administer the User’s account;
* enhance the User’s experience of the Service;
* improve the content of the Service provided to the User;
* follow the User’s browsing on the Mobile Application in order to understand the User’s browsing pattern and improve his/her user experience in the future;
* elaborate various stastistics regarding the Service.

TRIGONE TECH also collects the personal data of the Users through the Website to:

* send them newsletters with their prior express consent, together with any other communications;
* follow the User’s browsing on the Website in order to understand the User’s browsing pattern and improve his/her user experience in the future;

5. Who has access to the Users’ data?

The User who completes his/her profile through the Service expressly consents to have his/her personal data shared with other Users of the Service. The Users’ personal data is thus exclusively shared between the Users of the Service, as part of the use of the Service only in a connected mode.

TRIGONE TECH does not share the Users’ personal data with any third party, except in the following cases:

* hosting of TRIGONE TECH’s data, including the Users’ personal data, by a third party hosting service provider that is legally bound to safeguard the confidentiality of the Users’ data;
* sharing of the Users’ personal data in case of merger or take-over, partial or total contribution of assets or any form of restructuring implemented by TRIGONE TECH;
* communication of the Users’ personal data to TRIGONE TECH’s external counsels (lawyers, accountants, auditors, etc.) who are bound by a confidentiality obligation;
* communication of the Users’ personal data to relevant authorities pursuant to applicable law and/or a court order or decision.

6. What are the Users’ rights as regards the personal data collected by TRIGONE TECH?

The User has a right of access, rectification, objection, restriction, erasure and portability of his/her personal data as provided for by applicable law.

The User may send his/her request to TRIGONE TECH:

* by regular mail at the following postal address: TRIGONE TECH SAS, 38 rue de Berri, 75008 Paris, France;
* by email at: contact@ayruu.com.

If the User considers that his/her rights have not been respected, he/she may lodge a complaint with the French Data Protection Authority (CNIL, “Commission nationale informatique et libertés (CNIL)”) or any other relevant supervisory authority.

7. What are the means of storage and hosting of the Users’ personal data?

The Users’ data is stored for a duration that does not exceed the duration of the User’s subscription to the Service, subject to any applicable retention obligation required by law.

The Users’ data is hosted in the European Union with security and confidentiality measures as required by applicable laws and regulations.

8. What are the means of transfer of the Users’ personal data outside the European Union?

There is no transfer of the Users’ personal data outside of the European Union as part of the Service. Specifically, the Users’ personal data is hosted in the European Union.

9. Cookies

(i) What is a cookie?

A cookie is a small file that the browser stores locally on the User’s hard drive or mobile terminal equipment and that enables TRIGONE TECH to record information on the User and on his/her browsing pattern on the Website and/or Mobile Application.

Before implementing such technologies, TRIGONE TECH requires the User’s prior consent as provided for by applicable law.

(ii) Why does TRIGONE TECH use cookies?

TRIGONE TECH implements cookies through the Website and/or Mobile Application in order to allow:

* the User to identify himself/herself and to subscribe to the Service;
* TRIGONE TECH to manage and administer the User’s account, to improve the content of the Website and/or Mobile Application, to follow the User’s browsing, to elaborate statistics in order to measure the audience of the Website and/or Mobile Application, and to make available to the User, at his request, the different options of the Service.

As part of the Service, TRIGONE TECH does not allow third parties to deposit cookies on the Users’ terminal equipment.

(iii) Which cookies does TRIGONE TECH use?

* Purely technical cookies

Some of the features and functionalities of the Service cannot operate if TRIGONE TECH does not use certain cookies (the purely technical or functional cookies). In such case, the law does not require TRIGONE TECH to obtain the prior consent of the User before implementing such cookies.

This includes notably “session cookies”, whose purpose is to maintain the identification data regarding the User during his browsing experience, and which disappear as soon as the User leaves the Website or Mobile Application.

This also includes “shopping cart cookies” which are necessary to provide the paid-for options of the Service which are requested by the User.

* Audience measurement cookies

Apart from purely technical cookies, which are required to optimize the User’s browsing on the Website and/or Mobile Application,TRIGONE TECH implements audience measurement cookies on the User’s terminal equipment after having obtained the User’s prior consent. The sole purpose of such cookies is to measure the audience of the Website and Mobile Application and evaluate the Service on the basis of anonymized browsing statistics. The data thus collected is not used by TRIGONE TECH in order to cross-check it with other data processing. The cookies usd by TRIGONE TECH do not enable to trace the User’s browsing on other websites.

To this effect, the User is informed, through the display of a banner on top of the Website and/or Mobile Application homepage, that by continuing his/her browsing experience, he/she accepts the use by TRIGONE TECH of cookies for such purpose.

* What can the User do about the cookies?

Where the User has allowed all or part of the cookies to be deposited, the Internet browser of the User automatically discloses some information to TRIGONE TECH, such as the IP (Internet Protocol) address, the version of the browser used on the User’s terminal equipment and his/her browsing experience on the Website and/or the Mobile Application (pages visited).

The User may at any time configure his/her browser in order to receive a notification whenever a cookie is sent, or oppose to the use of cookies.

If most of the browsers are configured by default to accept the installation of all cookies, the User has the possibility, if he/she wishes, to choose to accept the deposit of all cookies, or to reject them systematically, or alternatively to choose which cookies to accept depending on their issuers. This can be done by customizing certain settings. TRIGONE TECH is drawing the User’s attention to the fact that, by opposing the deposit of purely technical cookies, the User’s experience may be deteriorated.

TRIGONE TECH informs the User that he/she may at any time withdraw his/her consent by modifying the settings.

10. Modification of the Privacy Policy

TRIGONE TECH reserves the right to modify and/or update this Privacy Policy, in which case the User shall be duly informed thereof. The updated version of the Privacy Policy will be posted on the Website and/or the Mobile Application with an indication of the last revision date.