Personal Data Protection Policy

1. Data Controller

Oovoom acts as Data Controller within the meaning of the GDPR regulation, as it is the legal entity that determines the purposes and means of processing the personal data collected.

When it uses third parties in the context of data processing, they generally act as processors within the meaning of the GDPR regulation and Oovoom ensures that they undertake to comply with current regulations and a number of principles aimed at guaranteeing the security of the data collected.

2. Data Collected

Oovoom does not collect any sensitive data within the meaning of Article 9 of the GDPR.

During registration, Users are informed of the data that is essential for Oovoom to carry out processing, which is marked with an asterisk.

The categories of data likely to be collected include in particular:

• Identification data: surname, first name, title, postal address, email address, telephone number, customer ID, company name, R.C.S., etc.
• Payment data: bank account details (IBAN, BIC), credit card number (CVV is never kept), billing address.
• Contractual and transactional data: information related to payment operations, subscriptions, subscribed services, amounts, frequency, transaction history, payment incidents.
• Data relating to vehicles and drivers (if applicable): vehicle model and brand, registration number, driver's license number, insurance contract and accident reports, ANTAI violations, driver schedules, etc.
• Geolocation data: this data is collected in particular when the customer searches for the nearest garage to their current position;
• Navigation data: IP address, terminal type, session data, pages consulted, timestamp, cookies and trackers (see cookies).
• Data from interactions between Oovoom and Users, customers or not: Messages sent via forms, exchanges with support, customer feedback, comments, reviews, participation in games or promotions.

3. Use of Collected Data

The processing of said data is essential for Oovoom to execute the contract and in particular to allow Companies (i) to access and use the Platform, (ii) to access their Company Personal Space and (iii) to make an appointment with a Garage Owner. In addition, this data allows the Platform to be improved and developed, which constitutes a legitimate interest.

Users authorize Oovoom to provide certain information

• (i) to Oovoom Garage Owners in the context of the execution of these terms, namely in particular the connection of Customers with Oovoom Garage Owners and
• (ii) to its technical service providers in order to benefit from certain functions of the Platform (forum, reviews, comments, ...).

Oovoom undertakes not to transmit the personal data entrusted to it to third-party companies for commercial prospecting purposes.

Below is a table specifying the legal basis for data collection according to purposes:

4. Data Retention Period

User data is retained for the period necessary to provide the Services and in accordance with legal and regulatory obligations.

Thus, the retention period depends on the purpose of the processing:

• Contractual data: throughout the contractual relationship, then archived for 5 or 10 years according to legal obligations.
• Navigation data (cookies, logs): retained for up to 12 months.
• Commercial prospecting: 3 years from the last active contact.
• Applications: 2 years after the last contact with the candidate.

5. User Rights

In accordance with the GDPR, Users have the following rights:

• Right of access: obtain a copy of the data processed.
• Right of rectification: correct inaccurate data.
• Right to erasure (right to be forgotten): in cases provided by law.
• Right to object: including in particular the right to object to the use of their personal data for prospecting purposes.
• Right to restriction of processing: in certain cases (e.g.: contesting accuracy).
• Right to portability: receive data in a readable format and transmit it to another data controller.
• Right to organize the fate of data after death.
• Right to withdraw consent at any time (when processing is based on consent).
• Right to lodge a complaint with the CNIL (www.cnil.fr).

Users can exercise by sending a request to the following email address: contact@30mille.com or in paper format to Oovoom's registered office address.

They can also lodge a complaint with the competent supervisory authority (CNIL (www.cnil.fr)).

6. Processing of Publications

Oovoom reserves the right to delete or modify content published by "Company" Clients on the Platform, without notice, in particular notes and comments addressed to Garage Owners.

The Company acknowledges and accepts that Oovoom is not obliged to save published content or provide a copy, and we do not guarantee the confidentiality of said content in any way.

All content published by the Company on the Platform, whatever its nature, remains under the full responsibility of the Company.

The Company undertakes to grant free of charge and exclusively and irrevocably, the right to Oovoom to use said content without spatial-temporal restriction, to publicly distribute them on the Platform or on any other online and offline medium, to keep them in databases, to reproduce and make them available to the public, to translate them into other languages, and to exploit them for marketing purposes. The Company definitively renounces any claim relating to the content granted by it.

The Company acknowledges and guarantees that all content published on the Platform is free of rights that would restrict its use by Oovoom.

7. Data Recipients

The personal data collected is intended for Oovoom and will not be transferred or exchanged to third parties, except for the data exchange necessary for the execution of the contract. In this respect, Companies acknowledge and accept that their personal data and that of their employees, if applicable, may be transmitted to Oovoom's partners involved in the execution of the contract concluded between the User and Oovoom and in particular to Oovoom Garage Owners.

Oovoom asks each of its contractual partners to confirm compliance with applicable regulations regarding the protection of personal data. Oovoom Garage Owners undertake to comply with the provisions of these terms and the personal data protection policy available on the Oovoom website.

Furthermore, only authorized personnel from the group and Oovoom's service providers may have access to the personal data collected and be required to process it, without prejudice to their possible transmission to bodies responsible for a control or inspection mission in accordance with applicable legislation and/or regulations or for the purpose of responding to a judicial or administrative decision.

Subject to their complete anonymization, Oovoom is entitled, in compliance with applicable legal and regulatory provisions, to use the personal data of Users and their employees, in particular for statistical, measurement, transfer and/or exchange purposes with third parties.

8. Transfers Outside the European Union

Personal data collected by Oovoom is hosted in the European Union.

If it uses affiliates or service providers located outside the European Union, Oovoom undertakes to verify that appropriate measures have been implemented so that Users' personal data benefits from an adequate level of protection.

9. Data Security

Oovoom collects and processes Users' personal data in compliance with current regulations.

In addition, Oovoom implements appropriate technical and organizational measures to ensure the security, integrity, confidentiality and availability of personal data (access control, encryption, etc.).

That being said, Oovoom draws users' attention to the fact that no transmission or storage technology is completely infallible.

Also, in the event of a proven violation of Users' personal data, likely to generate a high risk for their rights and freedoms, Oovoom will inform the competent supervisory authority of this violation under the conditions provided by current regulations, provided that this violation has directly concerned Oovoom.

10. Warning

The Company expressly acknowledges and accepts that, as soon as it provides personal information on the internet, this information may be collected and used by third parties.

11. Collection and Use of Non-Personal Information

Like many commercial organizations, we monitor the use of this Platform by collecting global information. We may automatically collect non-personal information about you, such as the type of internet browser you use, the pages you visit or the website that directed you to our Platform. This information does not allow you to be identified and is only used to help us provide an effective service on this Platform.

12. Use of Cookies

Oovoom receives and records information from your browser when you use the Platform and uses "Cookies" to collect this information. "Cookies" are small removable data files, containing no personal information, that are stored by your internet browser. They allow you to carry information on our Platform without having to enter it again. They allow us to analyze web traffic and improve our online services. They cannot be used to identify you. You can configure your web browser to inform you of "Cookie" placement requests or to completely refuse "Cookies". You can also delete files containing cookies.

In case of refusal of "Cookies", Oovoom does not guarantee the optimal functioning of the Platform.

The Company acknowledges and accepts that Oovoom reserves the possibility of implanting a "Cookie" in its computer or mobile phone in order to record any information relating to navigation on the Platform.

13. Policy Update

Oovoom reserves the right to modify this Policy at any time, in order to comply with legislative and regulatory developments and/or improve its personal data processing and protection policy.

In case of modification, a new version will be updated and published online with the last update date.

In case of substantial modification, Users will be informed and will, if necessary, have to express their consent.