SPALLIAN undertakes to respect the confidentiality and more generally to protect your personal data, which is collected and processed when you use the accessible sites (hereinafter the "Site" https://thelma.app/ and https://tell-my-city.com/) or via thelma Smartphone application (hereinafter the "Application"). In this respect, SPALLIAN complies with European and French legislation on the protection of personal data, principally EU regulation n°2016/679 known as "RGPD" and law n°78-17 known as "Informatique et Libertés".

In this context, the SPALLIAN Company (whose registered office is located at 44 rue Chanzy - 75011 PARIS, registered with the Paris RCS under number 528 688 419 - dpo[a]spallian.com) is the data controller within the meaning of the RGPD, for the collection and processing of personal data carried out on this Site or via the Application.

The Personal Data collected

The personal data that SPALLIAN is likely to process are:

• Personal data provided by you when registering

• The user's email address

• The "hashed" login password

• Your name

• Your first name

• Your year of birth (optional)

• Your telephone number (optional)

• Your gender (optional)

• Information that may be collected when you use the Site/Application services. This information may include:

  • Photographs and comments submitted by you in connection with a report, suggestion or congratulation. You will be asked for authorization to collect photographs submitted in connection with reports, suggestions or congratulations.

  • Data relating to your position (geolocation) in connection with the alert. You will be asked for authorization to collect and process your geolocation data to enable SPALLIAN to transmit the location of the alert.

Purposes of processing

Your personal data may be collected and processed via the Site/Application for the following purposes:

• The creation of your user account for registration and access to the Site/Application

• The management and follow-up of alerts, suggestions and congratulations by SPALLIAN and by local authorities and other authorities receiving alerts, who may need to communicate with you in this context.

• The management of internal operations necessary to provide the Site/Application services by SPALLIAN, including resolving software bugs and operational problems, performing data analysis, testing and research, and monitoring and analyzing activity and usage trends.

• News, alerts or public consultations sent by SPALLIAN or its partners.

The data you provide is necessary for the performance of the contract concluded between you and SPALLIAN and for the management of commercial relations, and also corresponds to SPALLIAN's legitimate interest in presenting and improving its services.

Data recipients

The purpose of the Site/Application is to forward your reports, suggestions or congratulations to the relevant authorities. In this context, SPALLIAN transmits some of your information to cities and competent national authorities, so that they can process your reports/suggestions/congratulations and exchange information with you.

As a result, they are the recipients of the following data:

• Content of reports, suggestions or congratulations sent by you, with or without comments and/or photos attached by you,

• The location of reports, suggestions or congratulations sent by you,

• Your contact information, i.e. your e-mail address, to enable the receiver to communicate with you via the application. Your surname, first name, year of birth, telephone number and gender are optional and can only be provided if you provide them.

The data transmitted when registering for or using the Application may also be transmitted to partners, Public Service Delegates and/or City Service Providers either for the processing of reports, suggestions and congratulations or for legal reasons or in connection with a claim or dispute.

Shelf life

The data of visitors to the Site/Application, who are SPALLIAN customers or prospects, is kept for the time necessary to manage the commercial relationship and to process their request(s). User account data is kept for three years from the time the account is considered inactive. This data may also be destroyed at the request of the interested party addressed to SPALLIAN.

All data used to establish proof of a right or contract, or stored to comply with a legal and/or regulatory obligation, may be subject to an archiving policy, and stored for these purposes in accordance with the legal and/or regulatory provisions in force.

Reports, suggestions and congratulations sent via the Application may be anonymized (i.e. it may not be possible to re-identify the user, either directly or indirectly) for statistical processing.

Your rights

In accordance with law no. 78-17 of January 6, 1978 and the RGPD, you have the right to access, rectify or delete your personal data, and, where applicable, the right to portability of your data. You may request the restriction of or object to the processing of your data, or, where applicable, withdraw your consent. You may also define directives concerning the fate of your data after your death, in application of article 32 6° of the amended law n°78-17 of January 6, 1978.

To exercise these rights, please contact SPALLIAN by e-mail at support@spallian.com or by post at 44 rue Chanzy - 75011 PARIS, giving your full name, e-mail address. In accordance with current regulations, this request must be signed and accompanied by a photocopy of an identity document bearing your signature, as well as the address to which the reply should be sent. A reply will be sent within one month of receipt of the request.

In accordance with the law, you have the legal right to lodge any complaint with the competent supervisory authority, in France the CNIL: https://www.cnil.fr