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Personal Data Policy

PERSONAL DATA POLICY

Troc-Vélo offers you a service for posting and browsing classified listings online via its website www.troc-velo.com (hereinafter "the Site").

As part of this service, Troc-Vélo needs to collect and process personal data about you.

Keen to protect your privacy and therefore your personal data, Troc-Vélo is committed to ensuring the highest level of protection for your personal data in accordance with the applicable European and French regulations.

All the answers to your questions about how Troc-Vélo uses your personal data are here:

1- WHO COLLECTS AND USES MY DATA?

Primarily, the person who collects and processes data about you, referred to as the data controller, is the company AVANIS (publisher of the Troc-Vélo site), a Société par Actions Simplifiée (simplified joint-stock company) with share capital of €169,562, registered with the Chartres Trade and Companies Register under no. 484 395 629, whose registered office is at 7 Rue de la Fosse aux Canes - 28200 Châteaudun – France (hereinafter "Troc-Vélo").

In addition, other companies may collect personal data about you, as controller or joint controller.

Indeed, while you browse the site, partner companies may collect data via cookies. To find out more, please see the "Cookies" section.

Likewise, when you buy a product from a professional seller, the seller may process personal data about you, as data controller, in order to process your order.

Finally, when you use the solution offered by one of our payment providers, that provider collects and processes data about you in order to process your payment request.

In these cases, the personal data policies of these third parties apply.

2- WHAT DATA IS COLLECTED AND PROCESSED?

The data processed by Troc-Vélo comes from:

• your registration: data given on the sign-up form such as your surname, first name, date of birth, contact details and interests. For professionals, this also includes your SIRET number and your company name.

• your use of Troc-Vélo services: data used to identify and authenticate you (connection logs, IP address), data relating to the listings published, to products purchased via Troc-Vélo services, to your browsing path on the site, to your search history, to your account history (registration date, date of last login, number of logins, number of current listings, number of listings created and the reviews you have posted/received), to the paid options you have subscribed to (payment method, amount, etc.), exchanges with our customer service, exchanges via the Troc-Vélo messaging system, in particular for the purpose of detecting illegal content, and geolocation data when you use the "search near me" feature.

• sites and mobile applications published by third-party entities: information relating to browsing or to the advertisements sent to you

3- WHY IS MY PERSONAL DATA PROCESSED?

Troc-Vélo collects and processes data about you for the following purposes:

WHY DO WE USE YOUR PERSONAL DATA? Purpose of the processing WHAT JUSTIFIES THIS USE? Legal basis for the processing Customer account management: account creation, account management, consent management, etc. Legitimate interest Use of Troc-Vélo services: publishing your listings, access to the site's messaging system, posting content on the forum, creating a list of followed listings, creating a list of followed members, putting sellers and buyers in touch, searching for listings near you, creating a history of the listings you have recently viewed, sending emails about the use of our services (listing search, reply to a listing, etc.) Performance of a contract Sale and invoicing of credits and paid options Performance of a contract Sharing a listing on social media Consent Customer relationship management Performance of a contract Fraud prevention Legitimate interest Communication management: sending personalised or non-personalised promotional messages by electronic means Consent Content personalisation Legitimate interest Improving navigation on the site Legitimate interest Handling requests relating to the exercise of your rights (right of access, rectification, objection, erasure, etc.) Legal obligation Carrying out satisfaction surveys Legitimate interest Analysis and statistics Legitimate interest Handling disputes and litigation Legitimate interest Technical operations on the site: technical, organisational or cybersecurity operations relating to anomaly detection and to securing your data and the information systems from which your data is processed Legitimate interest Responding to official requests from public or judicial authorities empowered to make them Legal obligation Compliance with the regulations applicable to our business Legal obligation Cookie management Legitimate interest for necessary cookies Consent for other cookies

All data processing is based on one of the "legal bases" provided for by the regulations, namely:

• Consent: the person has consented to the processing of their data

• Contract: the processing is necessary for the performance or preparation of a contract with the data subject

• Legal obligation: the processing is required by law

• Legitimate interest: the processing is necessary for the pursuit of the legitimate interests of the organisation processing the data or of a third party, with strict respect for the rights and interests of the people whose data is processed

4- WHO CAN ACCESS MY DATA?

To achieve the purposes described above, your data may be passed on:

  • To authorised persons, depending on the purpose, within the company Troc-Vélo: departments in charge of marketing, studies and analysis, customer service, staff in charge of accounting, IT and information systems security, etc.

  • To third parties who will process it on their own behalf:

    • Professional sellers
    • Payment providers
    • Administrative and judicial authorities.

  • To service providers acting on behalf of Troc-Vélo (processors) for the following services:

    • IT and technical services
    • Payment
    • Management and personalisation of site content
    • Sending commercial prospecting emails
    • Carrying out analyses, studies and statistics

No data is sold or rented to third parties for commercial purposes.

5- HOW LONG IS MY DATA KEPT?

Troc-vélo keeps the personal data it collects only for as long as necessary for the purposes of the processing and in accordance with applicable law.

Primarily, your data is kept for as long as your account is "active" and for 3 years after your last contact, counted from your last activity (logging in to your account, posting a listing, etc.) or until your account is deleted. After this period, the data is deleted.

More specifically:

• Geolocation data is kept only for the duration of your search and is then erased.

• Data relating to your searches is kept until the listing or the account is deleted.

• Your listing history is kept until your account is deleted.

• Reviews are kept until your account is deleted. They may also be deleted by a moderator if a review is not relevant.

• Selections are kept until the selected product is withdrawn or when it is sold/removed from the site.

• Messages are kept until your account is deleted. They may also be deleted by you.

• Saved searches and search alerts are kept until your account is deleted. They may also be deleted whenever you wish.

• Followed members are kept until your account or the followed member's account is deleted, or the member is manually removed.

In addition, data about you may be kept for longer under specific legal obligations or in view of the applicable statutory limitation periods. In particular, data may be kept for:

• 6 years for tax documents,

• 10 years for accounting records,

• The entire duration of any litigation and until all avenues of appeal have been exhausted.

6- HOW IS MY DATA SECURED?

At Troc-Vélo, we take all appropriate precautions to preserve the security of your data and, in particular, to prevent it from being distorted, damaged or accessed by unauthorised third parties.

To do so, we take into account the nature of the personal data and the risks presented by the processing, in order to put in place appropriate technical, physical and organisational measures to preserve the security and confidentiality of your data: access authorisation controls on information and use of the https (Hypertext Transfer Protocol Secure) protocol to protect your data, access to your account through authentication using confidential usernames and passwords, encryption of certain data, etc.

All our selected providers must offer guarantees in terms of quality, security, reliability and resources to ensure the implementation of technical and organisational measures, including for the security of processing. Processors and providers undertake to respect confidentiality levels at least identical to our own.

7- IS MY DATA PROCESSED OUTSIDE THE EUROPEAN UNION?

No data is transmitted to providers located outside the European Union.

8- WHAT ARE MY RIGHTS OVER MY DATA?

In accordance with the regulations on the protection of personal data, you have the following rights over your data:

  • Right of access: the right to ask whether or not your data is being processed. And if so, your right to consult it.
  • Right of rectification: the right to ask for inaccurate data to be corrected and for incomplete data to be completed and updated.
  • Right of erasure: the right to obtain the deletion of your data, subject to our legal retention obligations.
  • Right to object: the right to object to the processing of your data.
  • Right to data portability: the right to recover the data you have provided to us, and to transmit it to another data controller.
  • Directives in the event of death: the right to give us directives on the handling of your personal data after your death. For example, if you want it to be kept, erased or passed on to a designated third party.

To exercise your rights, you can:

  • If you already have an account on our site, directly change some of your data yourself. Once in your account, click the "edit" button, where you can change your email address, surname, first name, postal address, telephone number, interests and password. You can also choose whether or not to receive our newsletter. Professionals can also add/edit their company name and SIRET number directly in their account.

  • Otherwise, simply write to Troc-Vélo, DPO - 5 avenue de Newton – 78180 Montigny le Bretonneux, stating your surname, first name and email address. In accordance with the regulations in force, we may need to ask you for additional information/supporting documents in order to verify your identity. Troc-Vélo will reply within a maximum of 1 month after you exercise your right. In some cases, owing to the complexity of the request, this period may be extended.

9- WHO SHOULD I CONTACT IF I HAVE PROBLEMS?

If you have problems, you can contact:

  • Customer Service via the link:
  • The Data Protection Officer: Troc-Vélo– Data Protection Officer (DPO) – 5 avenue Newton – 78180 Montigny le Bretonneux.

If you are not satisfied with the reply, you can still refer the matter to the CNIL: https://www.cnil.fr/

10- COOKIES

To improve its services and personalise your experience, Troc Vélo uses cookies every time you use our site/application.

For more information on the use of cookies, visit our dedicated page.


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