Privacy Policy — 法驾通
Last updated :
1. Data controller
The data controller for personal data collected via the Code de la route app is Delphin JEANNET EI, sole trader operating under the trade name "Djavrok" (SIRET: [[À COMPLÉTER : numéro SIRET — immatriculation en cours]]), based at: 6 rue Charles Infroit, 78570 Andrésy, France. Contact: contact@djavrok.com.
2. Data collected and purposes
Progress and revision data
Your answers to question sets, your progress, your success statistics by topic and your settings are stored locally on your device, so you can track your progress and resume training where you left off. This data is not sent to the publisher, unless you enable a backup or sync feature, where applicable.
Technical data
In the event of a technical issue, and if the app includes a diagnostic tool (see the third-party SDK section below), limited technical data (device type, OS version, installation identifier, crash logs) may be collected solely to fix app issues.
[[TO COMPLETE: if the app offers account creation, cloud sync across devices, or any processing that sends data to the publisher, describe precisely the data involved, its purpose and legal basis here]]
3. Legal bases
- Performance of pre-contractual or contractual measures: providing the requested training service (Art. 6.1.b GDPR).
- Legitimate interest: improving app stability and security, crash prevention (Art. 6.1.f GDPR).
- Consent: where applicable, for any processing not strictly necessary for the app to function (Art. 6.1.a GDPR), collected before any related data collection.
4. Third-party SDKs and services
As of the last update of this document, Code de la route does not integrate any third-party advertising, analytics or tracking SDK. This section will be updated if that changes.
5. Data retention
- Progress data stored locally on the device: kept until the app is uninstalled or manually cleared by the user.
- Technical and diagnostic logs (where applicable): kept for a maximum of 12 months from collection.
- Data processed by enabled third-party SDKs: kept per each provider's own retention periods, detailed in their respective policies.
6. Transfers outside the European Union
When third-party SDKs are enabled (Google AdMob, Firebase), some data may be processed by Google on servers located outside the European Union, including in the United States. These transfers rely on the European Commission's standard contractual clauses and/or any other applicable adequacy mechanism, as implemented by Google as a processor.
7. Your rights
Under the General Data Protection Regulation (GDPR) and French data protection law, you have the following rights over your personal data:
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to object
- Right to data portability
- Right to set directives about the fate of your data after your death
These rights can be exercised by writing to contact@djavrok.com. You will receive a response within one month at most.
8. Complaint to the CNIL
If, after contacting us, you believe your rights are not being respected, you may lodge a complaint with the CNIL (3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France, https://www.cnil.fr).
9. Protection of minors
As the French driving theory test can be taken from age 15 (accompanied driving), the app may be used by minors. The app does not knowingly collect personal data beyond what is strictly necessary for its local operation described in section 2. [[TO COMPLETE: describe compliance measures applicable to minors, including the absence of personalized ads for under-13s where applicable, and any platform self-certification required (e.g. Google Play Families)]]
10. Data security
Reasonable technical and organizational measures are implemented to protect processed data against unauthorized access, loss or alteration.
11. Changes to this policy
This privacy policy may be updated, in particular to reflect changes to the app or to applicable law. The last update date is shown at the top of this page. We encourage you to review it periodically.
12. Contact
For any question about this policy: contact@djavrok.com.