Personal data protection

 

When using the Trela Solution, the Beneficiary may be required to transmit Personal Data concerning him. 

Intersec attaches the greatest importance to the confidentiality of the information and Personal Data of the Beneficiary. Its privacy policy was founded in compliance with the Personal Data Regulation.

The Intersec company guarantees the Beneficiary :

• increased transparency on how Intersec handles Personal Data;
• a better accessibility of the information concerning the rights of the Beneficiaries as well as the obligations of Intersec in terms of protection of the Personal Data;
• that it does not sell Personal Data to third parties;
• that it ensures that the Personal Data is always secure;
• that a Beneficiary of the Application has the following possibilities at any time:
  
  • complete review of Personal Data stored on Intersec's servers
  • review and deletion of subscriptions to Content Publishers and Third-Party Content Publishers to which he/she has subscribed in connection with the Trela Solution;
  • and complete deletion of the Account and any database entries relating to it.

 

1. Anonymization

When the Application is used for the first time, as an unconnected Beneficiary, a unique technical identifier is automatically generated to formally distinguish this cell phone and this Beneficiary. This results in the creation of an anonymous contact profile, which is kept on Intersec Trela servers, without forcing the User to declare personal information. Example of internal contact identifier: id:contact162954380

The automatic reuse of this unique technical identifier from one session of use to another ensures the consistency of the Beneficiary's experience.

 

2. Personal data collected 

This section describes all the Personal Data collected and stored online, according to different use cases, from the simplest to the most complete.

• Non-connected use (anonymous)

Minimal use of the Application by a new Beneficiary who has simple usage, no need to save/synchronize their settings for continuity across multiple devices, nor a desire to subscribe to local alert feeds from Content Publishers via additional channels. Collection is then limited to:

• the internal contact ID ;
• the date of creation of the contact profile;
• the last approximate position (precision of the order of the department) of the cell phone.
  
  
  
• Connected Beneficiary (non-anonymous Beneficiary with an Account)

If the Beneficiary creates his Account to the Trela Solution, then Intersec collects (in addition to the Personal Data collected as an anonymous Beneficiary):

• his name ;
• first name (optional) ;
• His/her email address (email);
• his cell phone numbers for sending SMS (up to 5);
• his phone numbers for voice calls (up to 5) (optional) ;
• his postal address (optional);
• his preferred language (default: FR);
• His mobile device ID;
• His last known approximate position (coordinates of the points of the approximation square). Once a Beneficiary has defined one or more points of interest in the Application and/or the Website, they are sent and saved in his Trela contact profile.
  
  

For each area of interest are collected:

• the precise geographic coordinates (latitude, longitude) of the point of interest ;
• the name given to the Point of Interest (e.g. Hugo's school) (optional) ;
• the postal address associated with the Point of Interest (optional)

 

3. Subscription to alerts issued by Content Publishers and Third Party Content Publishers 

In case the Beneficiary subscribes to one or more Content Publishers or Third Party Content Publishers, the following Personal Data are collected and stored, for each association between a contact and a Content Publisher or Third Party Content Publisher:

• the date of subscription to the Content Editor or Third Party Content Editor;
• The authorized communication channels to the contact (SMS, voice, email);
• The types of authorized events (e.g. "Early Childhood", "Culture & Sports", "Older People")

 

4. Approximate geographic tracking 

The geographical tracking operated by the Trela Solution only needs to know the approximate positions of the Beneficiaries, with a limited temporal and spatial precision:

• squares of about 150km on each side in which the last position of the cell phone is written; and
• a position from one or more hours ago.

The last known approximate positions are necessary for the alert system to target the notifications (PUSH) to the cell phones to reasonable size geographical areas, rather than notifying all potential recipients on the whole territory, for each alert. This ensures a good balance between the amount of data pushed to cell phones versus the time to reception (target: less than 5 minutes). This operation by " blurry " location feedback only requires a few geolocation updates per day.

 

5. Purposes and legal basis of the processing of Personal Data 

The purpose of the Personal Data collected from the Beneficiaries is to allow the Trela Solution and the authorized Content Editors and Third Party Content Editors, when necessary, to alert and inform the Beneficiary according to his choice of categories and channel on the selected area.

 

 

6. Sharing of Personal Data with third parties 

The Beneficiary's Personal Data may be shared with third parties in the following cases:

• When Intersec has recourse to the services of third party service providers to provide hosting services or to use technical solutions for the dissemination of indicators on Intersec's premises. These service providers have limited access to the Personal Data of the Beneficiary, only within the framework of the execution of their services and have a contractual obligation to use them in accordance with the provisions of the Personal Data Regulation;
• If required by law, Intersec may transmit the Personal Data at the request of the authorities and comply with administrative and judicial procedures;
• If Intersec is involved in a merger, acquisition, sale of assets or receivership, it may be required to sell or share all or part of its assets, including Personal Data. In this case, the Beneficiaries will be informed, before the Personal Data is transferred to a third party.
• In the event that the Beneficiary subscribes to a specific Content Editor, he/she consents to the sharing of his/her Personal Data to this one for the purpose of allowing, when necessary, to alert and inform him/her according to his/her defined choices.    

7. Duration of storage 

Personal Data is kept exclusively for the purpose of reporting and only for as long as necessary to fulfill the purposes mentioned above. 

 

8. Transfer of Personal Data outside the EU

Intersec informs the Beneficiary that no transfer of his Personal Data outside the territory of the EU takes place to date. The processed data are hosted in France. In any case, Intersec undertakes to respect the legal provisions concerning the transfer of Personal Data abroad and undertakes to inform the Beneficiary.

 

9. Security

• All Personal Data that transit through our services are exchanged and stored encrypted on highly secure servers in France under the responsibility of Intersec.
• All the fields in the database are optional for a better management of the governance of Personal Data by the Accounts. They are set up in such a way that Personal Data is limited to what is necessary to send alerts. In other words, the platform aims to collect and use only the Personal Data that is necessary to send messages through the communication channels set up, namely:
• Minimized personal contact information - the columns strictly required to uniquely identify a contact;
• personal information of the Beneficiaries.

In addition to database encryption, Intersec implements column encryption for sensitive data fields (personal contact information). This measure ensures that the "plain text" display of these fields is only made possible to authorized and activated Users of the Content Editor or Third Party Content Editor, in the exclusive context of a secure session on the Website.

 

10. Implementation of Beneficiaries' rights 

In accordance with the Personal Data Regulations, the Beneficiaries may contact Intersec at the following address info@trela.fr to exercise the following rights

• they can exercise their right of access to know the Personal Data collected about them, in this case, before the implementation of this right Intersec can ask for a proof of the identity of the Beneficiary in order to verify its accuracy;
• If the Personal Data held by Intersec are inaccurate, they may request the update of the information;
• they may request the deletion of their Personal Data.
  

11. Evolution of the data protection policy

Intersec reserves the right to make changes to this Privacy Policy at any time. If a modification is made to the present policy, Intersec undertakes to publish the new version on its Application and the Website. If the Beneficiary does not agree with the terms of the new drafting of the policy, he/she has the possibility to uninstall the Application and to unsubscribe from the Trela Solution. 

 

12. More information 

To learn more about the policy of protection of Personal Data, the Beneficiary can contact the Data Protection Officer at the following address: dpo@trela.fr. This address can only be used to exercise his rights.

Finally, the Beneficiary can consult the policy at any time here.