PRIVACY POLICY AND PERSONAL DATA

Last updated: February 27, 2026

Data Controller:
SARL VIRATRIP
5 rue Pierre Ronsard, 13111 COUDOUX, France
Email: contact@viratrip.com
Telephone: +33662225579

In the course of providing its services, Viratrip may collect personal data relating to Users.

This Privacy Policy informs Users of the manner in which Viratrip collects and processes Users' personal data.

1. Nature of the data collected

When registering and using the Application, Viratrip only collects and retains certain information, namely: name, surname, postal address, photo, email, telephone number, location data.

Viratrip may also have access to the User's contact database in order to identify and possibly contact contacts already using the Application. This access will be subject to the prior express consent of the User, who is free to refuse.

Each User is therefore informed that when they create an account on the Application they may be put in contact with another User through their contact database, which they accept.

2. Purposes of the collection and processing of personal data

Viratrip collects the User's personal data that is strictly necessary to fulfil its contractual obligations.

The legal bases for processing are as follows, in accordance with Article 6 of Regulation (EU) 2016/679 (GDPR):

• Performance of a contract (Art. 6.1.b GDPR): processing of data necessary for the provision of the Services (user account, routes, geolocation during navigation);
• Consent (Art. 6.1.a GDPR): access to the User's contact database, geolocation outside of navigation, cookies and trackers;
• Legitimate interest (Art. 6.1.f GDPR): improvement of the Services, fraud detection and Application security;
• Legal obligation (Art. 6.1.c GDPR): retention of billing data in accordance with accounting and tax obligations.

Viratrip's Services cannot be provided without Viratrip processing personal data about Users and other users, including location data. The processing of the data that the User shares with Viratrip, including his or her geographical data, is essential to the Services provided on the Application.

Failure to provide personal data will prevent access to the Application Services.

3. Persons with access to personal data

Viratrip does not share the personal data collected with any third party. Only Viratrip and its staff have access to the User's personal data.

The Viratrip team may include Viratrip staff, contractors, subcontractors or external consultants, who are responsible for participating in the implementation, execution and operation of the Application.

Such staff, consultants, subcontractors or service providers are subject to the same processing and confidentiality obligations as set out in this Privacy Policy.

The main categories of subcontractors are as follows:

• Google (Firebase): hosting, database, authentication, analytics, push notifications, file storage;
• Mapbox: mapping, route calculation, navigation;
• Apple / Google: subscription management and in-app payments via the App Store and Google Play Store.

4. Security measures

In processing personal data, Viratrip is committed to ensuring the security of personal data and to complying with applicable law by implementing appropriate technical and organisational measures.

These measures are intended to protect data against accidental or unlawful destruction, accidental loss, alteration, disclosure or unauthorised access.

5. Data retention time

Viratrip retains Users' personal data for the following periods:

• User account data (name, surname, email, photo, telephone): retained for the duration of the account, then deleted within 30 days after the account is deleted by the User;
• Location and route data: retained for the duration of the account, then deleted within 30 days after the account is deleted;
• Billing data: retained for a period of 10 years in accordance with accounting and tax obligations;
• Connection data (logs): retained for a maximum period of 12 months in accordance with applicable regulations.

The personal data of Users is stored in the European Union in accordance with the requirements of the Data Protection Regulation.

Certain subcontractors (in particular Google/Firebase and Mapbox) may process data outside the European Union. In such cases, these transfers are governed by appropriate safeguards, in particular the Standard Contractual Clauses (SCCs) adopted by the European Commission, in accordance with Article 46 of the GDPR.

6. Users' rights to their personal data

Each User has the following rights:

- The right to obtain confirmation as to whether or not their personal data are being processed and, if so, the right of access to such data,

- Right to limit personal data,

- Right to portability of personal data,

- Right to object to the processing of personal data for reasons related to his/her particular situation. In any case, the User has the right to object to the processing of his/her personal data for commercial prospecting purposes.

- Right to rectify any personal data collected;

- Right to request deletion or restriction of access to their collected personal data.

The User may exercise these rights by sending an e-mail to the contact address contact@viratrip.com.

Viratrip undertakes to respond as soon as possible and at the latest within one month of receiving the request.

If the User considers that the processing of his/her personal data constitutes a violation of the legislation in force, he/she has the right to lodge a complaint with the French data protection authority (CNIL - Commission Nationale de l'Informatique et des Libertés - www.cnil.fr).

7. Cookies and trackers

The Application and the associated website may use cookies and trackers for operational purposes, audience analysis and improvement of the Services.

Cookies that are strictly necessary for the operation of the Application do not require the User's consent. However, analytics and audience measurement cookies (in particular Firebase Analytics) are only placed after obtaining the User's consent, in accordance with CNIL recommendations.

The User may at any time configure or refuse cookies from the settings of their browser or the Application.

8. Protection of minors' data

The Application is reserved for natural persons of at least 18 years of age, holding a driving licence, in accordance with the General Terms and Conditions of Use. Viratrip does not knowingly collect personal data concerning minors.

If Viratrip discovers that personal data of a minor has been collected without the consent of a person with parental authority, such data will be deleted as soon as possible.