Privacy Policy
This Privacy Policy explains what personal data Passeport Batterie processes, why, and what rights you have under the General Data Protection Regulation (EU) 2016/679 (GDPR), for the Company accounts, members, and passport data handled by the service.
1. Data controller
The data controller for personal data processed through the service is the publisher of Passeport Batterie. Full legal identification and contact details are to be confirmed — see "Points pending confirmation" below.
2. Data we process
We process: account data for each Company (name, billing details, subscription); data about each member of a Company account (name, email address, role, category scope); and battery passport data entered by a Company, some of which — the fields marked public under the tiered-access model — is made available without login to anyone holding the corresponding QR-code link.
3. Why we process it
We process this data to operate the Company account and its subscription, to let members collaborate on passport data according to their role, to make the passport data required by Regulation (EU) 2023/1542 available to the public and to approved economic operators, recyclers, and authorities, and to meet our own legal and billing obligations.
4. Legal basis
Company and member account data is processed to perform the contract between the Company and Passeport Batterie (Art. 6(1)(b) GDPR). Passport data made public is processed to comply with the legal obligations the Company has under Regulation (EU) 2023/1542 (Art. 6(1)(c) GDPR) and, where it is the Company's own data about its products rather than data about an identifiable individual, generally falls outside GDPR's personal-data scope.
5. Who receives this data
Data is accessible to the Company's own members according to their role, to the technical subprocessors that host and operate the service (hosting/infrastructure providers — to be listed, see "Points pending confirmation"), and, for passport fields marked public or legitimate-interest/authority-reserved, to the corresponding audiences described on the compliance page. We do not sell personal data.
6. How long we keep it
A published passport's public-facing data remains available for at least 10 years from publication, regardless of the Company's subscription status — a platform commitment described on the compliance page. Account and member data (name, email, role) is kept for the duration of the subscription; the exact retention period after an account closes is to be confirmed — see "Points pending confirmation" below.
7. Your GDPR rights
Subject to the conditions set by the GDPR, you have the right to access, rectify, erase, or restrict the processing of your personal data, the right to data portability, the right to object to processing, and the right to lodge a complaint with your national supervisory authority. Requests can be sent to the contact address in §11. Note that erasing a member's account data does not retroactively remove battery passport data already published under the long-term availability guarantee (§6), since that data describes the battery, not the member.
8. Security
Access to Company dashboard data is restricted by account authentication and the role/category-scope model described on the compliance page; public passport fields are, by design, intentionally accessible without authentication. Technical and organizational measures appropriate to this model are applied to protect data against unauthorized access, alteration, or loss.
9. International transfers
Whether any personal data is processed or stored outside the European Economic Area, and under what safeguard, is to be confirmed — see "Points pending confirmation" below.
10. Cookies and local storage
The public website stores your language preference (English/French) in your browser's local storage so it is remembered on your next visit. This is strictly functional and is not used for tracking or advertising; at the time of writing, the service does not use third-party analytics or advertising trackers on its public pages.
11. Contact
Questions about this policy or requests regarding your data can be sent to the contact address to be confirmed — see "Points pending confirmation" below.
12. Changes to this policy
This policy may be updated as the service evolves. Material changes will be notified to Company owners/admins before taking effect.
Points pending confirmation
This page is a structured draft, not a finished legal document. The following points still need to be decided, confirmed, or filled in by Nicolas (or outside counsel) before this page can be considered final:
- Full legal identification and contact details of the data controller (§1)
- List of technical subprocessors / hosting providers (§5)
- Exact retention period for account and member data after account closure (§6)
- Whether any data is transferred outside the EEA, and under what safeguard (§9)
- Whether a Data Protection Officer is appointed and, if so, their contact details
- Final contact address for data-protection requests (§11)