PERSONAL DATA PROTECTION & COOKIE POLICY CHARTER

1.    Purpose of processing, legal basis, and period of storage of data collected

Either you or the User designated by you to access the Customer Area may be likely to provide the Company with a certain amount of personal data such as your surname, forename, email address, and telephone number so as to be able to access functions and/or services available in the Customer Area. 
The information collected is necessary to process the Contract(s) signed with the Company, failing which the Contract cannot be performed.
The Company processes personal data you have provided for the following purposes and on the following legal basis:
 

Purpose of processing	Legal basis		Personal data collected	Retention period
Creation of a User profile and access to the Customer Area, Multi-Account management	Contract		Identification data.  (Surname, forename, email address), connection data (login, password)	Term of Contract + 6 months
Subscription to additional services (CARDalert, CARDControl, PASSalert, eBilling…)	Contract		Email address	Term of Contract + 6 months
Access to trip-related services (tolls, parking, road taxes or any duty levied in relation with use of a Vehicle within a toll network, technical, legal and bookings assistance)	Contract		Registration plate	Term of Contract + 6 months
Device management (AS 24 and AS 24 – EUROTRAFIC Cards and PASSango HGV Toll Badges)	Contract		Surname, forename, vehicle registration	Term of Contract + 6 months
Invoice management (view and download invoices, transactions not yet invoiced…)	Contract		Email address	Term of Contract + 6 months
Vehicle geolocation data, route simulator comparison, trip reporting, geolocation-based fuel transactions	Contract		Registration, vehicle GPS coordinates	Term of Contract + 6 months   Geolocation data: 1 year
Customer claims management to motorway concessions in France	Contract	Vehicle registration		Term of Contract + 6 mois

 

Your personal data will not be processed subsequently in any manner which does not comply with those purposes described above or within the data collection forms. Data are stored for as long as required for processing, namely for as long as the data subject, namely the Customer or authorised User, requires access to the Customer Area. Once data subject is no longer bound by a contract to its company, the account and related data are deleted.

2.    Data Recipients

Your personal data may be communicated to one or more of the data controller's departments or to Total Group companies and relevant service providers or subcontractors.  
The personal data indicated under Article 1 are hosted by SIGMA INFORMATIQUE.

3.    Data Transfers

Any transfer of data to a country outside the European Economic Area shall be carried out in accordance with the applicable regulations and in such a way as to protect your data appropriately. 
In order to ensure an adequate protection of personal data originating in the European Economic Area that may be transferred to Total Group entities located outside the European Union, the Total Group has adopted “Binding Corporate Rules” (BCR) – Company internal rules. 
For data transfers not covered by the BCR, to countries outside of the European Economic Area, other measures to ensure adequate protection are taken. 
If you would like more information about our BCRs please click here www.total.com/fr/donnees-personnelles#Binding%20Corporate%20Rules%20de%20Total. For more information about other measures taken to ensure adequate protection, please write to the contact address specified below.

4.    Data security and confidentiality

Each data controller takes the appropriate technical and organisational steps to protect the security and confidentiality of personal data incumbent upon them, including with regard to any subcontractors, in particular to prevent data from being distorted, damaged or disclosed to unauthorized third parties.

5.    Cookie management

5.1. Principle
A cookie is a file which stores information pertaining to web browsing by your computer on the Customer Area (e.g. number of visits, number of pages consulted, etc.) and notably makes visits to the Customer Area more fluid.
At any time whatsoever you can delete “cookies” installed on your computer, object to storage of new “cookies” and receive notification before installation of a new cookie by adjusting the settings of your web browser using the instructions below (“Types of cookies, cookies and statistics, and settings”). 
Please note that if you remove a “cookie” or object to the storage of cookies on your device, you may not be able to use some of the Website's services. 

5.2. Types of cookies, cookies and statistics, and settings.
Cookies which may be installed on your browser when visiting the Customer Area are cookies which either have the exclusive purpose of allowing or streamlining electronic communications or which are strictly necessary for provision of the service requested (language cookies, identification cookies, etc.), or are statistics cookies or others in line with the terms and conditions outlined below. 
When cookies require your agreement before installation, we prompt you to grant consent using the “find out more” link displayed on the first page of the Website, with it being indicated that by continuing to browse the Customer Area you accept these cookies. 

5.2.1. Which cookies are installed?
•    Cookies issued by the data controller

Cookie	Description	How to object?	Period
Website (cookie_agreed)	Register the choice of a user regarding cookies	See article 5.2.2	12 months

•    Statistics cookies

Publisher of the cookie	Description	How to object?	Period
AT INTERNET idrxvr tmst	Allow to see how many users are connected to the Customer Area, as well as the frequency of these connection	http://www.xiti.com/en/optout.aspx	13 months
Google Analytics	Allow to see how many users are connected to the Customer Area, as well as the frequency of these connection	https://tools.google.com/dlpage/gaoptout/.	14 months

 

Statistics cookies are used to measure the number of visits, the number of pages viewed, users’ activity on the Customer Area and how often they return. The statistics tools used each generate a cookie with a unique identifier, which is stored for no longer than the duration specified above. Your IP address is also collected in order to determine the town/city from which you are accessing the service. Your IP address is immediately anonymized after use so that you cannot be identified as a natural person. The statistical data on frequency of visits are collected by the concerned provider and subsequently transferred to the data controller in an aggregated and anonymized form in a web interface to which it alone has access. The data collected are not transferred to third parties or used for other purposes. You can block these cookies at any time by opting out as described above.

5.2.2. How do you delete cookies, be notified of installation or change your browser settings?
The “Help” section of each browser specifies how to refuse cookies or be notified of their installation or deactivate them. Below are the links to this section for the most commonly-used web browsers:
 

6.    Your rights/Contact

Pursuant to current regulations, you have the right to access, correct, delete and object to the use of your personal data. You also have the right to object or to consent to processing of your personal data. You can ask for your personal data to be sent to you and you have the right to give instructions for the use of your personal data after your death, where such a provision is applicable.  You can also request restriction of the data, portability of the data and/or make a claim to the competent supervisory authority. Please send your request to the email address: 
as24.ie.privacy@as24.com (Ireland) / as24.gb.privacy@as24.com (UK) or by post to the following address: AS 24 FUEL CARD LTD - 11-19 station Road, WD17 1AP Watford