Data Privacy: Heropolis Application

Your personal data protection is a priority for Heropolis.

When you use the Heropolis mobile application (hereinafter the “Application”), we collect personal data about you.

The purpose of this policy is to inform you about how we process this data in accordance with Regulation (EU) 2016/679 of 27 April 2016 concerning the protection of individuals with regard to the processing of personal data and the usage of this data (hereafter “GDPR”).

1. Who is the data controller ?

The data controller is HEROPOLIS SAS, registered SIRET 840 822 993 (DUNS 271285816) and  located 10 Allée de la paix, 95320 Saint-Leu-la-Forêt, France (hereafter “Us”).

2. What data do we collect ? 

The Solution consists on a platform for authorities in charge of the security of a territory or personals. It allows representatives of these authorities (e.g. municipal police, isolated workers, authorized personnel) to manage enriched geolocated alerts (position, classification, chat messaging, ambient sound, movement of the device, images, video) , through a mobile application.

The alert management platform is based on three distinct processes:

  • top-down and bottom-up alerts management, using a mobile application
  • users management (participants and issuers) when alerts are received via the Heropolis application in order to allow emergency response and/or the traceability of information on these alerts, via the web supervision interface;
  • information management in order to accelerate emergency services intervention and/or the traceability on these alerts, using chat or VOIP.

The platform distinguishes the access permissions to the application according to 4 roles:

  • administrator (web application access) ;
  • supervisor (web application access) ;
  • first-responder (mobile application) ;
  • emitter (mobile application).

e3. What is the collected data used for ?

The Data Controller determines the purpose(s) for which the data is processed. Unless otherwise stated in the Data Controller’s Information Document, these purposes are in principle the following:

Processing Purpose Legitimacy
Mobile application (managing emissions and receiving alerts) Managing the alerts within Heropolis (transmission et reception)  Allow the intervention of emergency services, a first level of doubt removal and/or the recording of information on these alerts
Web supervision Interface Management of users and alerts received within the Heropolis application Allow actions following alerts (e.g. rescue intervention) and/or recording information on alerts

Chat

Exchange of information allowing the management of emergency alerts Allow implementation of actions following alerts (eg emergency response) and/or the recording of information on these alerts.

4. What is the legal basis for the processing ?

The legal basis for processing is determined by the Data Controller, depending on the purpose for which he is using the Solution. Unless otherwise stated in the Controller Information Document, this legal basis is in principle one and/or the other of the following:

 

  • Processing is necessary for compliance with a legal obligation to which the Controller is subject
  • Processing is necessary to protect the vital interests of the person emitting the alert or another person
  • Processing is necessary for the performance of a task aiming to the public interest or in the exercise of official authority vested in the Data Controller.

Data
Recipients Storage period
Alert location Administrator 30 days after alert is closed
Alert location Supervisor Alert duration (< 1 day)
Alert location First responders if committed Alert duration (< 1 day)
Emitter Location Supervisor and fist responders Alert duration (< 1 day)
First responder location Supervisor/Administrator 30 days after the alert is closed
First responder location First responders if committed Alert duration (< 1 day)
First responder location Supervisor/Administrator Alert duration (< 1 day)
Mobile Supervisor location First responders if committed Alert duration (< 1 day)
Chat related to the current alert (text+pictures+timestamp) Supervisor 30 days after the alert is closed
Chat related to the current alert (text+pictures+timestamp) All Alert duration (< 1 day)
Pictures related to on alert, audio discrete record (20s after an alert)

Administrator

30 days after the alert is closed
Identification data: user email, last name, first name, password, last connection date, statistical audience measurements, issuer/intervener status

Administrator

Active account duration

Environmental data (discrete photos, discrete sound recording)

Supervisor/Administrator Alert duration (< 1 day)
First responder profile picture (if set)

Administrator

Active account duration
First responder profile picture (if set) Supervisor Active account duration
Audio/Video Live Streaming Supervisor (on action logged) No registration
Identity: surname / first name (if provided, excluding alias or generic identity) Administrator / Supervisor Active account duration

5. Other data recipients

Without prejudice to the other recipients to whom the Data Controller may transmit your data, we transmit them on our side to our own subcontractors for the purpose of implementing the Solution:

  • Our hosting providers,
  • Service providers allowing the sending of notifications on smartphones, SMS and emails,
  • The service provider allowing video streaming (public IP in some cases).

6.  Are your data likely to be transferred outside the European Union? ?

 

Your data is kept and stored for the duration of the processing on the servers of the Scalingo company, located in France.

As part of the tools we use (see article concerning our subcontractors), your data may be transferred outside the European Union. The transfer of your data in this context is secured using the following tools:

  • either the data is transferred to a country that has been the subject of an adequacy decision by the European Commission, in accordance with Article 45 of the GDPR: in this case, this country ensures a level of protection sufficient and adequate considering  the GDPR;
  • either the data is transferred to a country whose level of data protection has not been recognized as adequate for the GDPR: in this case these transfers are based on appropriate guarantees indicated in Article 46 of the GDPR, adapted to each service provider , including but not limited to the conclusion of standard contractual clauses approved by the European Commission, the application of binding corporate rules or under an approved certification mechanism;
  • either the data is transferred on the basis of one of the appropriate safeguards described in Chapter V of the GDPR.

7. What are your rights over your data ?

You have the following rights regarding your personal data :

  • Right to Information: This is precisely why we have written this policy. This right is provided for in Articles 13 and 14 of the GDPR.
  • Right of access: You have the right to access all of your personal data at any time, under Article 15 of the GDPR.
  • Right of rectification: you have the right to rectify your inaccurate, incomplete or outdated personal data at any time in accordance with Article 16 of the GDPR
  • Right to limitation: you have the right to obtain the limitation of the processing of your personal data in certain cases defined in Article 18 of the GDPR.
  • Right to erasure: you have the right to request that your personal data be erased, and to prohibit any future collection of it for the reasons set out in Article 17 of the GDPR
  • Right to lodge a complaint with a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a violation of the applicable texts. (Article 77 GDPR)
  • Right to define directives relating to the storage, erasure and communication of your personal data after your death, in accordance with Article 40-1 of the Data Protection Act.
  • Right to withdraw consent at any time: For consent-based purposes, GDPR Article 7 provides that you may withdraw your consent at any time. This withdrawal will not call into question the legality of the processing carried out before the withdrawal.
  • Right to portability: under certain conditions specified in Article 20 of the GDPR, you have the right to receive the personal data that you have provided to us in a standard machine-readable format and to require its transfer to the recipient of your choice.
  • Right to object: Under Article 21 of the GDPR, you have the right to object to the processing of your personal data. Note, however, that we may continue to process them despite this opposition, for legitimate reasons or the defense of legal claims.

You can exercise these rights by writing to us at the contact details below. We may ask you on this occasion to provide us with additional information or documents to prove your identity.

8. Which cookies do we use?

To find out more about the management of cookies, we invite you to consult our Cookies Policy.

9. Point of contact for personal data topic

Contact email : dataprivacy@heropolis.fr 

Contact address : 10 Allée de la paix, 95320 Saint-Leu-la-Forêt

10. Amendments

We may modify this policy at any time, in particular to comply with any regulatory, jurisprudential, editorial or technical developments. These modifications will apply on the effective date of the modified version. You are therefore invited to regularly consult the latest version of this policy. Nevertheless, we will keep you informed of any significant changes to this privacy policy.

Effective date : November 1, 2021

Heropolis SAS

18 bis rue de Villiers

92300 Levallois-Perret

FRANCE