Personal Data Protection Policy

Personal data means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to that person. Examples include: your surname and first name, date of birth, email address, telephone number, photograph, etc.
Ulys processes personal data relating to you in the context of its relationship with you and your use of its products and services. Ulys only processes data that is relevant and strictly necessary for the intended purposes.

We require all recipients of your personal data to implement appropriate technical and organisational measures to ensure its security and confidentiality.

For e-toll or electric mobility subscriptions issued by one of the VINCI Autoroutes Group companies (ASF, Escota, Cofiroute, Arcos or Ulys Mobilité Services), the management of personal data has been entrusted to Ulys.
The information below explains how Ulys collects and processes your personal data for the management of subscriptions (e-toll badges and/or electric charging cards).

           2.1.1 – At the time of subscription

When you take out a subscription, the company issuing the subscription (depending on the chosen offer) collects the following personal data:
•    Identification data: surname and first name
•    Personal characteristics: date of birth
•    Contact data: postal address, email address, telephone number
•    Bank account details
•    Products and services held or used: subscribed offers and options (e-toll badge and/or electric charging pass)
-    Where applicable, vehicle registration number and preferred journeys.
Ulys processes this personal data in order to provide the services to which you have subscribed or wish to subscribe. Such processing is necessary for the implementation of pre-contractual measures or for the performance of the subscription contract.
Certain fields are mandatory at the time of subscription. These correspond to the data required to provide the service. If you choose not to provide this information, your subscription may not be completed, and you may not be able to benefit from the service.
This data is retained for the duration of the contractual relationship and until the end of the statutory limitation period provided for under French commercial law, i.e. five (5) years from the date of termination of the contract.
Prior to subscription, a prospective customer may complete a contact form to request a call back and provide personal data and contact details (surname, first name, email address and telephone number). By submitting this information, the prospect consents to being contacted by a Ulys sales representative. This data is retained for two (2) months by Ulys sales teams and deleted if no subscription is concluded. 

        2.1.2 – During the performance of the subscription contract

During the performance of the subscription contract, Ulys uses your personal data to manage all aspects of your subscription, in particular to:
•    Invoice and collect payments (provide consumption tracking, calculate and invoice charges, collect payments)
•    Provide customer support and after-sales services
•    Manage personal data, contract characteristics and associated rights
•    Manage unpaid invoices (amicable recovery, litigation management, consultation of unpaid debt databases during new subscriptions, collection of security deposits where applicable)
This data is collected indirectly from motorway operators, car park operators and electric charging service providers. The following categories of data are processed, in particular to provide invoices and consumption statements:
•    Motorway journey data: date and time, entry and exit toll stations, vehicle category, transaction amount
•    Parking data: date and time, car park (name and address), transaction amount
•    Electric charging data: start and end time of charging, charging station (identifier and address), transaction amount and energy consumed
Data collected as part of a subscription is retained for the duration of the contractual relationship and for five (5) years following termination.
Your personal data (including bank details) may be shared with service providers acting on our behalf, banking and financial institutions, and payment issuers (e-toll badge issuers, payment card issuers), strictly for the purposes of providing the services.
Your personal data (in particular bank account details) may be disclosed to subcontractors engaged solely for the performance of services on our behalf, as well as to banking and financial institutions and payment issuers (toll badge issuers, payment card issuers).

Ulys also produces anonymised statistical analyses on the use of its services for service improvement purposes.

       2.1.3 – Fraud prevention and detection

At the time of subscription and during the performance of the contract, Ulys has a legitimate interest in implementing measures to prevent and combat fraud affecting you or the VINCI Autoroutes Group companies, or to prevent unpaid debts.
Your personal data (such as contact details or identity documents) may be shared with fraud detection and prevention service providers or debt recovery agencies. Such data is retained for eighteen (18) months.
In the event of confirmed fraud, the data is retained for a maximum of five (5) years from the closure of the fraud case, which occurs once the outstanding amounts have been settled.

     2.2.1 - Offers and news related to our services

Sending information to customers by email or SMS, particularly marketing communications relating to offers and news associated with subscribed services, is based on Ulys’ legitimate interest.
You may object at any time, free of charge, to receiving such communications by using the unsubscribe link included in each email or SMS.
Your personal data is retained for the duration of your subscription to our communication services.

    2.2.2 - Offers and news from VINCI Autoroutes, its subsidiaries and/or commercial partners

Independently of any service subscription, you may subscribe to receive offers and news from VINCI Autoroutes, its subsidiaries and/or commercial partners.
You may withdraw your consent at any time, free of charge, using the unsubscribe link included in each email or SMS.
By subscribing, you consent to the collection of interaction data (consent status, email opens and clicks). Changes to consent history are retained for twelve (12) months. Interaction data is retained for three (3) years.

     2.3.1 - Functional and analytics cookies

When browsing our website, cookies may collect information about your device or network, based on our legitimate interest. You are informed upon first visit and may manage cookie preferences. Third-party cookies are placed only with your consent.
Further information is available in our Cookie Policy.
These cookies help improve navigation, generate visitor statistics and offer services tailored to your interests.

    2.3.2 - Consent-based cookies

By accepting advertising or social media cookies, you consent to data collection by third-party providers to build interest profiles and display relevant advertising.
Details are provided in our Cookie Policy.

Ulys provides a mobile application allowing users to access personalised services, including:
•    Customer account access
•    Mobility services map
•    Route calculation tools
•    User reviews for charging services
Users are informed of data collection when downloading and using the app.

    2.4.1 - App use with a subscription

For a toll subscription, the user’s data is collected by Ulys and will be transmitted to the company issuing the toll subscription. For more information on how personal data is processed in relation to toll subscriptions, the user may consult the Terms and Conditions (Article 15: Data Protection).
For an electric mobility subscription, the user’s data is collected by Ulys and will be shared with Ulys Mobilité Services. For more information on how personal data is processed in relation to the electric mobility subscription, the user may consult the Terms and Conditions (Article 12: Personal Data).

    2.4.2 - User reviews

If the user has given consent, they may submit a rating and review of their electric charging experience for publication. These reviews will be visible directly within the app.
In this case, the personal data collected will be used for informational purposes and to improve future user experiences.
This data is collected by Ulys and may be shared with its service providers and subcontractors. It is retained for three years.

    2.4.3 - Geolocation services

If the user has given consent, the app may collect their geolocation. The geolocation service enables several features:
•    Navigation guidance throughout the journey
•    SOS feature to send the user’s exact location in case of emergency
•    Current location determination, if the user wishes, to set the starting point for navigation
•    “Copilot” feature, which displays service areas and rest areas ahead of the user while geolocated on the motorway. The user may filter the displayed areas based on desired services. This Ulys feature operates across all motorways in France.

This data is collected by Ulys and may be shared with its service providers and subcontractors.
It is retained only for the duration of the user’s navigation, except where the SOS feature is activated. In that case, geolocation data is retained for up to three months.
Users are informed that geolocation may be disabled at any time by configuring their mobile device to deny the app access to location data.

    2.4.4 - Journey planning

       2.4.4.1 Conventional vehicles 

            A) Route planning
If the user wishes to plan journeys, the information collected is used by Ulys to provide estimated journey duration, toll costs and available services and offers along the route.
Information collected is deleted immediately after the end of the journey, unless the user saves the journey for later use. In that case, the information is retained until the user deletes the saved journey.

           B) Traffic alerts
If the user wishes to set up traffic alerts, the information collected is used by Ulys to inform the user of traffic events affecting their route.
Information collected is retained until the user deletes the alert and may be shared with service providers and subcontractors.

       2.4.4.2 Electric vehicles

If the user wishes to use the electric vehicle route planner, the information collected is used by Ulys to propose optimised routes for the user’s electric vehicle, incorporating charging stations available on the French and European motorway networks.
Information collected includes:
•    Departure and arrival locations
•    Information about the user’s electric vehicle (make, model, version)
This data is used to calculate journey duration and plan charging stops.
Information collected is retained until the user deletes the journey and may be shared with service providers and subcontractors to enable the electric route planning service. 

    2.4.5 Push notifications

If you have installed the Ulys mobile application, we may send information via push notifications, provided that we have obtained your prior consent and the notification service is enabled on your mobile device. Push notifications are subject to your prior consent. You may withdraw your consent at any time by disabling notifications in your mobile device settings.

    2.5.1 - Contact form

Ulys has set up a service for handling enquiries and/or complaints relating to toll subscriptions, electric mobility subscriptions and/or the use of our digital services (customer account and Ulys application).
Your personal data is collected on the basis of our legitimate interest in processing your request and responding to your enquiry. This service allows you to send us a comment, question, request or feedback.
If you wish, you may contact us via the contact form by providing your surname, first name and email address, and, where applicable, your subscriber reference number. You may also submit a complaint or make a suggestion online by providing your surname, first name, postal address, telephone number and email address.
Personal data collected in connection with an enquiry or a complaint is intended for the teams responsible for handling requests (Ulys and its service providers) and is used to manage your request and improve our services (quality improvement process).
This data is retained for six months for an enquiry and three years for a complaint.

    2.5.2 - Customer service calls

You may contact our customer information service at any time if you experience difficulties with our services or network. In doing so, you may be required to provide personal data (for example, your surname, first name, email address or subscriber number).
Calls may be recorded for service improvement purposes. Call recording is not systematic.
Personal data collected during a telephone call is intended for the teams responsible for handling requests (Ulys and its service providers) and is used to manage your request and improve our services (quality improvement process). This data is retained for one month. 

    2.5.3 - Online chat (iAdvize)

On our website, you may use the live chat tool (iAdvize) to obtain information and/or assistance. During a chat conversation, certain personal data may be requested in order to respond to your enquiry and access your customer account (email address, subscriber number, surname, first name, etc.).
Personal data collected during a chat conversation is intended for the teams responsible for handling requests (Ulys and its service providers) and is used to manage your request and improve our services (quality improvement process). This data is retained for one year.

    2.5.4 - Contacting the Data Protection Officer

The companies of the VINCI Autoroutes Group are required, under French Data Protection Act No. 78-17 of 6 January 1978 (as amended), to implement a system for handling requests and/or complaints relating to the protection of personal data.
You may therefore contact our Data Protection Officer, at any time and under the conditions set out in section 4, by writing to the following address: dpd@ulys.com
As part of your request, you will be required to provide identification details.

    2.5.5 - Customer satisfaction surveys

When you use our services and where you have given your consent, we may use your personal data to carry out customer satisfaction and quality surveys. These surveys are intended to measure satisfaction levels and identify areas where we can improve our performance.
Customer satisfaction surveys form part of our ongoing customer relationship management.
You may opt out at any time, free of charge, by using the unsubscribe link included in each electronic message (email or SMS).
Personal data collected as part of these surveys is intended for our research and insights teams and is retained for three years.

As part of the Club Ulys programme, we share personal data with our service provider Obiz, which operates a benefits programme for eligible Ulys subscribers. Obiz receives certain items of your personal data in order to authenticate you and enable access to the dedicated website.
The personal data shared with our service provider Obiz as part of the Club Ulys programme consists of your surname, first name, email address and customer number.
This data is retained by Obiz for two years from your last login to the platform.

You may contact us to submit an unsolicited application, which will be reviewed by our recruitment teams.
You may also sign in using your LinkedIn account or your Welcome to the Jungle account to view job opportunities matching your profile, in which case you agree that information from your profile is shared with us by these third parties.
Your personal data is processed by our authorised teams for the purpose of managing your job application and is retained for the duration of the recruitment process.
If your application is not successful, your personal data is deleted at the end of the recruitment process.

As part of the management of your toll subscription, the issuing companies of the VINCI Autoroutes Group (ASF, Cofiroute, Escota, Arcos and Ulys Mobilité Services) have appointed ULYS, a VINCI Autoroutes Group company, to develop and market the toll subscriptions they offer.
In this context, your personal data is processed by ULYS for the purposes of managing your subscription.
All recipients of your personal data, including our service providers and commercial partners, are located in countries that offer an adequate level of personal data protection, primarily within mainland France.
We strictly require all recipients of your personal data to use it solely for the purposes described above, only to the extent necessary to carry out the tasks entrusted to them, and to implement appropriate technical and organisational measures to ensure the security and confidentiality of your personal data.

You have the right to access, rectify, erase, restrict or object to processing, and to data portability, as provided by the GDPR.
Where processing is based on consent, you may withdraw your consent at any time via your customer account or by using the unsubscribe link in our emails.
You may contact our Data Protection Officer at: dpd@ulys.com or via the dedicated form.
The Data Protection Officer has one (1) month to respond, extendable by two (2) months depending on complexity and volume of requests. In the event of an extension, you will be informed within one (1) month of receipt of the request.
To update your personal data (contact details, bank account details, email address), you may access your Customer Account or contact Customer Services.
If you consider that your rights have not been respected, you may lodge a complaint with the French Data Protection Authority (CNIL).