Privacy policy (GDPR)

This English translation is provided for convenience. In the event of any discrepancy of interpretation, the French version prevails.

Codetrail, publisher of the PTI Connect service, attaches paramount importance to the protection of personal data. This policy describes, in accordance with the General Data Protection Regulation (GDPR, EU 2016/679) and the French "Informatique et Libertés" Act, the processing carried out.

1. Data controller

The controller of the data collected via the website and the subscription process is Codetrail, reachable at jt@codetrail.eu.

Regarding the data of agents processed within the platform (position, alerts, etc.), the Customer (the employer) is the data controller and Codetrail acts as a processor within the meaning of article 28 of the GDPR.

2. Data collected

• Subscriber: last name, first name, business email, phone, role.
• Company: company name, address, EU VAT number.
• Payment: card details processed directly by Stripe (they do not pass through our servers).
• Agents (within the platform): identity, geolocation during an alert, safety events, audit logs.
• Technical: connection logs, strictly necessary browsing data.

3. Purposes and legal bases

• Subscription and account management — performance of the contract (art. 6.1.b GDPR).
• Billing and payment — performance of the contract and legal obligation (art. 6.1.b and 6.1.c).
• Provision of the PTI service (alerts, geolocation, supervision) — performance of the contract on behalf of the Customer, in keeping with the workers' vital interests (art. 6.1.d).
• Security and legal obligations (audit logs, French Labour Code) — legal obligation and legitimate interest (art. 6.1.c and 6.1.f).

4. Recipients and processors

Your data is never sold. It is accessible to authorised staff of Codetrail and to its technical processors, strictly within the scope of their duties:

• Stripe — card payment processing.
• Hosting provider — sovereign hosting in France.

5. Retention periods

• Account and subscription data: for the duration of the contract, then archived in accordance with legal obligations.
• Accounting and billing documents: ten (10) years (legal obligation).
• Alert data and audit logs: period defined by the Customer, in compliance with regulations.
• Geolocation data: kept only as long as strictly necessary to handle the alert.

6. Transfers outside the European Union

Hosting takes place in France. Where certain processors may process data outside the European Union, such transfers are governed by appropriate safeguards (standard contractual clauses of the European Commission).

7. Your rights

In accordance with the GDPR, you have the rights of access, rectification, erasure, restriction, objection and portability, as well as the right to set directives regarding the fate of your data after your death. You may exercise these rights by writing to jt@codetrail.eu.

Regarding agents' data processed within the platform, such requests must be addressed to the Customer (employer), who is the data controller; Codetrail assists them for this purpose.

8. Cookies

The website only uses cookies strictly necessary for its operation (session, security). No advertising or third-party tracking cookie is set without your consent.

9. Security

Codetrail implements appropriate technical and organisational measures (encryption in transit, access control, logging) to ensure the security and confidentiality of the data.

10. Complaints

You may lodge a complaint with the French data protection authority, the Commission Nationale de l'Informatique et des Libertés (CNIL) — www.cnil.fr — or with your local supervisory authority, if you consider that your rights are not being respected.

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