GeoWallet Mobile Application
Update date: October 8, 2021
The GeoWallet Application is edited by the company Blocs et Compagnie, a simplified joint stock company registered in the Montpellier Trade Register under the number 828 399 915, whose registered office is located at 418 Rue du Mas de Verchant
Bp 12, 34935 Montpellier Cedex 9, France.
User: the user of the GeoWallet mobile application
Company: The User’s employer, or the User himself for one-person compagnies
Processing of your Personal Data
The GeoWallet application collects personal data from its Users. This data is encrypted, anonymized, stored on the User’s phone and online on servers, then analyzed in a secure environment on behalf of the Company. The analyses of the User’s personal data in a protected environment, for which Blocs et Compagnie is responsible on behalf of the User and the Company, are based on the User’s prior acceptance in the mobile application of an explicit analysis contract proposed by the Company.
Object and purpose of the processing
The GeoWallet solution proposed by Blocs et Compagnie is based on a Mobile Application allowing the User to build a history of trips in a vehicle equipped with a Bluetooth beacon. The User’s trips in this vehicle are automatically detected and the geolocation data related to these trips are encrypted, stored on his cell phone, and hosted online by a digital trust solution implemented by Blocs et Compagnie and integrated in the GeoWallet Application. The User can accept a contract in the mobile application authorizing the Company to perform analyses on his geolocation data to retrieve relevant results on the User’s business trips and a mileage summary of the User’s personal trips, without ever directly accessing the details of the User’s personal trips. Only the result of the analysis, which can be consulted by the User, is transmitted to the Company.
The following data are collected by the GeoWallet mobile application on the User’s phone:
Data provided by the User in the mobile application to create his/her GeoWallet account, necessary to establish a contract with the Company:
Passphrase allowing the User to sign the contracts established with the Company
Company ID, previously communicated by the Company to the User
Data provided by the User to build up a data history and perform the analyses provided for in the analysis contract established with the Company in the mobile application:
Analysis contract including the Company identifier, the validity period, the analyses to be performed and their frequency
Odometer values of the User’s car requested at regular intervals by the mobile application to the User in order to take into account during the analyses the trips not listed by the mobile application as unlogged distances
User’s vacation periods to automatically categorize trips as personal trips during the User’s vacations
Data automatically collected by the mobile application to build up a data history and perform the analyses as per the analysis contract established between the Company and the User in the mobile application:
Type of activity – stationary, walking, biking, driving
GPS position and time stamp
In addition, the GeoWallet application must have the following permissions to always operate, including when the application is closed, in order to detect that a trip in the vehicle that is associated with the User is starting and to record the location data for that trip. This permanent access ensures that all the User’s trips in the relevant vehicle are recorded, including when the application is turned off, and avoids any interaction with the User’s phone while driving for security reasons.
Activity detection to detect when a vehicle trip is starting or ending
Bluetooth access to confirm that a trip is starting or ending in the vehicle equipped with the Bluetooth beacon
Access to the Geolocation Data allowing to record only the geolocation data related to the trips of the vehicle equipped with the Bluetooth beacon when the User drives it
To allow the User to reconfigure his account in case of change of phone or after reinstallation of the application, a screenshot of the User’s passphrase is made and saved in his photos on his phone, after temporary authorization by the User to access his Photos. This screenshot should be printed and saved in a safe place, and then deleted by the User from his phone.
The cartography integrated to the application is provided by the company Mapbox. In order to improve its services, Mapbox proposes to the User to collect anonymized usage information including information on his/her phone (model, manufacturer), operating system, map display requests and geolocation information: https://www.mapbox.com/telemetry/
The application may also transmit technical information to Blocs et Compagnie, especially in case of malfunction. These data are not nominative, do not contain confidential information and have for only goal to improve the reliability of the application.
Duration of data retention
The encrypted and anonymized User data will be kept for a period of six years, after which it will be completely deleted, unless the User requests its deletion beforehand.
Legal basis for processing personal data under the General Data Protection Regulation (GDPR)
Because we need to perform a contract between the User and the Company
Because the User has authorized us to do so
Because we have a legitimate interest in carrying out this processing and the rights of the User do not override this legitimate interest
Transfer of Data
In certain circumstances, Blocs et Compagnie may be required to disclose the User’s Personal Data if required to do so by law or in response to valid requests from public authorities (e.g., a court or government agency). As the User’s data is encrypted and anonymized, any transmission to external third parties, in the User’s country of residence or outside it, by Blocs et Compagnie is impossible. Only the User, or the Company based on the analysis results it holds, can make this transmission. No data is transferred outside of the European Union, the services of Blocs et Compagnie are hosted in France on the servers of: OVH SAS – 2 rue Kellermann 59100 Roubaix.
Rights of the concerned persons
In accordance with the amended law n°78-17 of January 6, 1978, and the EU Regulation 2016/679, the User has the possibility at any time to exercise his/her rights of access, rectification, opposition and deletion, limitation or portability of personal data. The User can access his data through the History and Analysis tabs in the GeoWallet Application and can request from the application in the “Manage my data” section to retrieve his personal data in a standard structured format. The User has the right to erase his data. Uninstalling the application does not result in the deletion of the User’s data. The deletion of data is done in the “Manage my data” section of the Application. This action will delete all the User’s data. The deletion is final.
For any question about the processing of his data or to exercise his rights, the User can contact the Data Protection Officer of Blocs et Compagnie, by email (firstname.lastname@example.org) or by mail addressed to Blocs et Compagnie, Data Protection Officer, Paris&Co – Le Swave, Grande Arche de La Défense, 1, Parvis de la Défense, 92800 Puteaux.
The User may also address a complaint to the CNIL, 3 place de Fontenoy, 75007 Paris.