How is my personal data used and protected?

Preamble

What is personal data?

This is any information relating to a natural person who is identified or can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to that person.

How is personal data collected?

Personal data may be collected directly from the customer, particularly when subscribing to a service, making contact, or in response to a request, etc.

Personal data may also be collected indirectly during a trip on the ALIAE highway network, using technical devices related to information technology and video surveillance. ALIAE is one of the first highway operators in France to implement Flux Libre, a technology based primarily on video that will eventually enable toll collection without toll booths.


Who is responsable for processing ?

Each company—ALIAE as the concessionaire of the highway network and APRR as the operator, pursuant to an operating agreement—is individually responsible for its own data processing activities:

  • ALIAE SAS, with capital of €119,017,000, registered in the Cusset Commercial Register under number 844 440 370 RCS Cusset, whose registered office is located at LIEU DIT LE TERNAT - DIOU (03290)
  • APRR SA, with capital of €33,911,466, registered in the Dijon Commercial Register under number 016 250 029 RCS Dijon, whose registered office is located at 36 rue du Docteur Schmitt, SAINT APOLLINAIRE (21850).


Protection of personal data

ALIAE and APRR collect and process only the personal data strictly necessary to provide customers with personalized, high-quality services.


Data processed and associated purposes


I. Toll Calculation, Collection, and Billing Management:

APRR is responsible for the following processing activities:

a) Calculation of the toll amount based on the vehicle category:

Data processed:

  • To verify a vehicle’s category: Video footage from cameras installed at toll lanes, enabling the creation and management of a data list including the vehicle’s license plate number, country of registration, toll category, and the date of the vehicle’s last passage through a toll lane.
  • To verify a vehicle’s category when passing through a toll lane: Video footage from surveillance cameras installed in toll lanes in the event of a technical alert regarding one of the components used to determine the category, or in the event of a discrepancy between the category determined by the toll equipment and the one listed in the database.

b) Determining the route to ensure correct toll billing:

Data processed:

  • Upon entering the network: A photo of the license plate, the license plate number (anonymized), country of registration, and details related to the toll transaction. 
  • At network exit: A photo of the license plate, video footage of the vehicle passing through, the license plate number, country of registration, and details related to the toll transaction.

c) Toll collection

Data processed:

  • Journey-related data: Timestamp and network entry and exit points, vehicle category, transaction price.
  • Subscriber data: identity, subscriber number, information held on payment cards or badges issued by the issuers: number, expiration date, and for certain types of subscriptions: date and place of birth, vehicle registration number.
  • Data necessary for customer support (upon request or due to a technical alert): Videos from video surveillance.

d) Billing Management

Data processed:

  • Data processed regarding payment methods: Issuer identification, card number, expiration date.
  • Data processed regarding electronic toll subscribers: Video footage from surveillance cameras installed at toll lanes, used to enforce and monitor commercial terms and conditions.


II. Operation and maintenance of a free-flow toll collection system:

APRR, as the operator of ALIAE, informs you that the following processing activities are carried out on behalf of ALIAE and the free-flow system on the A79. APRR is responsible for this processing. 

The data collected and processed comes from the free-flow equipment gantries, which capture all the data necessary to determine and collect the toll for any vehicle passing under a gantry. 

a) Maintenance 

Data is collected by free-flow equipment known as “gantries,” without affecting toll collection, in order to measure the equipment’s performance and/or compare it with data from a toll barrier located near the gantry(ies). Such devices are installed on on-ramps, off-ramps, and on the main roadway on the A41 North, A43, A48, A49, and A311.

Data processed for every vehicle passing under a gantry: Context photo, license plate number and country (with associated photo), identifier and electronic toll tag data, vehicle characteristics and category, timestamp of passage, and gantry location.

Data processed at toll plazas: Location of the toll lane, context video of the toll lane showing the vehicle, and other data identical to that collected under the gantry.

b) Calculation of tolls on open-traffic sections

The data collected and processed relates to the calculations performed by APRR to determine tolls on open-traffic sections.

Vehicle identification data: License plate number and country (with associated photo), vehicle category and characteristics 

Trip data: Timestamp of passage under the gantry and gantry location;

Data relating to subscribers: identifier of the electronic tag(s) present in the vehicle; data contained in the detected electronic tags. 

c) Determination of the vehicle’s emission class to apply the appropriate toll rate

The data collected and processed relates to the processing carried out by APRR to ensure the correct toll rate is applied to customers based on the emission class of the vehicle they are using. A list is compiled containing license plate numbers with certified emissions.  

Data relating to vehicle identification:  License plate number, country, vehicle fuel type, or French Euro emission class (data provided by the Vehicle Registration System for French vehicles, and by the customer for foreign vehicles).

d) Payment of tolls for open-access travel on the payment website

The data collected and processed pertains to all processing carried out by APRR to ensure the collection of tolls for trips made on the open-access section. 

On the ALIAE payment site, payment for a trip requires, for trip identification, either entering the license plate number or using the customer account.

The customer account provides access to trip details and registration for trip alerts. This requires linking the account to a vehicle through verification of the license plate number based on supporting documents (VIN, vehicle registration, lease agreement, etc.)

Data related to vehicle identification: License plate number, vehicle class

Data related to trips: Timestamp of passage under the gantry, data on unpaid trips (entry, exit, amount due, class).

Data processed regarding payment methods: credit card or store card numbers. 

Data related to creating a customer account and signing up for passage alerts: Email address associated with the license plate.

Data related to verifying the link between the license plate and the customer account: VIN number or any other supporting document.


III. Ticketless entry at the Montmarault on-ramp:

This system replaces a traditional toll gate at the network entrance. Exit data is collected at the Deux Chaises toll gate.

APRR is responsible for this processing.

Data processed for all vehicles passing under the gantry: Context photo, license plate number and country (with associated photo), identifier and electronic toll tag data, vehicle characteristics and category, timestamp of passage, and gantry location.

Data processed at the toll plaza: Location of the toll lane, context video of the toll lane showing the vehicle, and data identical to that collected under the gantry.


IV. Customer Relationship Management:

ALIAE and APRR collect and process personal data whenever they come into contact with a customer. ALIAE and APRR are each responsible for this processing depending on the contact channels used by the customer.

The data collected is necessary to provide the customer with an appropriate response to any request, complaint, or inquiry.

The data processed includes the following: Customer’s identity, phone number, mailing address, email address, and the subject of the request.


V. Detection of Toll Non-Payment:

Categories of data processed:

  • Photo of the license plate and context video from cameras installed on toll roads 
  • Vehicle registration number and make
  • Mobile phone number 
  • Transaction data (timestamp, entry and exit stations, lane number, toll amount) 
  • CNP number


VI. Combating Toll Violations:

APRR is responsible for the following data processing activities:

a) Combating toll fraud:

Categories of data processed:

  • Videos and images from video surveillance cameras installed at toll lanes
  • Data relating to subscribers and non-subscribers: Identity, license plate number, and payment method information
  • Data relating to trips and route anomalies
  • Data relating to vehicle specifications

b) Toll non-payment violations:

Categories of data processed:

  • Videos and images from video surveillance cameras installed on toll lanes
  • Data related to the violation: Timestamp of lane passage and violation, location, toll station, lane, toll amount
  • Vehicle data: Vehicle characteristics, toll class, license plate number, country
  • Data relating to the driver and owner: Identity, address
  • Data used to query the Vehicle Registration System (SIV): vehicle characteristics and registration number, toll station, lane, timestamp of the violation, badge number of the issuing officer
  • Data from the SIV: Identity or business name, common name or married name, SIREN number, address, status as owner on the registration certificate, vehicle characteristics.
  • In the event of a dispute, loan, or rental of the vehicle: last name, first name, gender, date and place of birth, address, and driver’s license number of the person who was driving or likely to drive the vehicle, electronic toll collection customer number.


VII. Settlement of toll non-payment notices and payment notices on the website https://paiement.aliae.com:

APRR is the data controller for this processing.

Data processed: date and number of the non-payment notice or payment notice, case number, license plate number, vehicle make, route and amount, payment method 


VIII. Video surveillance on the highway network: 

For the purposes of traffic management, network operations, and public safety, our highway network is equipped with a video surveillance system. 


Legal Basis for the Processing of Personal Data

APRR and ALIAE are authorized to process personal data in connection with, among other things:

•    Their legal obligations, including toll collection (traditional, free-flow, or ticketless entry), fraud prevention, the identification of non-payment of tolls and issuance of payment notices, and billing management,

•    Their legitimate interests regarding payments on the website https://paiement.aliae.com, customer relations, management of exception lists for electronic toll subscribers, and maintaining the operational condition of a free-flow toll collection system and ticketless entry

•    The performance of a public interest mission regarding the determination of the toll amount and its operation, as well as video surveillance,  

•    Consent to subscribe to the services offered: sending newsletters and commercial offers, passage alerts.



Mandatory or Optional Data

Certain data fields listed on the forms are mandatory. If the subscriber chooses not to provide this information, APRR and ALIAE will be unable to provide access to the services offered.

 

Retention Periods for Processed Data

In accordance with the principles set forth in applicable regulations, APRR and ALIAE retain personal data only for as long as is necessary to fulfill the purpose for which it was collected.

Accordingly, the following retention periods are observed:


I.Toll determination, collection, and billing management:

a) Determination of vehicle class for the application of the correct toll rate:

  • Data required to confirm a vehicle’s category: Video: up to 28 days; other data: 13 months from the vehicle’s last passage.
  • Verification of the vehicle category upon passage through the toll lane: Videos: maximum 28 days.

b) Determination of the route for applying the correct toll rate: 

If the network entry data provided by the customer matches the system data, the processed data is deleted a few minutes after the vehicle passes through the network exit. 

If there is a discrepancy between the network entry data provided by the customer and the system data, the processed data is retained for a maximum of 3 months (the license plate number (anonymized), collected at network entry, is retained for no longer than the validity period of the toll ticket; the video footage, collected at network exit, is retained for a maximum of 1 month).

c) Toll collection:

Trip data: 5 years, or 10 years if a tax receipt is issued.

d) Billing management: 

10 years, in accordance with regulations.

Videos related to the commercial terms of electronic toll subscribers are retained for a maximum of 28 days.


II.Operation and maintenance of a free-flow toll collection system:

a) Maintenance

Context videos of the toll lane are retained for a maximum of 28 days; other collected data is retained for a maximum of 3 months.

b) Determination of the free-flow toll amount

Data is retained for a maximum of 12 months.

c) Determination of the vehicle’s emission class in order to apply the appropriate toll rate.

Data regarding the emission class is retained for a maximum of 12 months after the last passage for French vehicles (data provided by the Vehicle Registration System) and 36 months for foreign vehicles (data provided by the customer).

d) Payment of the toll fee via the online payment portal

Payment-related data is retained for up to 3 months after payment is made.

Data related to the creation of a customer account will be deleted after 3 years if there is no login activity.   

In the event of transmission, the VIN number or the document required to verify the vehicle’s registration number from the customer account is not retained. It is destroyed immediately upon completion of the verification.


III.Ticketless entry at the Montmarault entrance ramp:

Data collected when passing through the gantry is retained for a maximum of 4 days. 

Data collected when passing through the exit toll booth is retained in accordance with the “Toll Determination, Collection, and Billing Management” processing procedure.


IV.Customer Relationship Management:

Data on non-subscribers is retained for 2 years from the date of the last contact.


V.Recording of Toll Non-Payment:

Data related to records of toll non-payment are retained for 3 months after the record is created.


VI. Combating Toll Violations:

Data related to toll fraud are retained for a maximum of 6 years.

Data related to toll non-payment citations are retained for a maximum of 1 year; however, the data are retained until the end of any litigation proceedings.


VII. Settlement of toll non-payment citations and payment notices on the website https://paiement.aliae.com

See the retention periods specified in the respective processing procedures for non-payment findings and payment notices. 


VIII. Video surveillance on the highway network: 

Images, when recorded, are retained for a maximum of 30 days.


Recipients of the processed data

I.Toll Calculation, Collection, and Billing Management:

a) Calculation of the toll price based on vehicle category: The data is accessible exclusively to authorized internal departments of APRR.

b) Determination of the route for the application of the correct toll rate: The data is accessible exclusively to authorized internal departments of APRR.

c) Toll collection: Subcontractors receive the data under contracts that comply with regulations regarding the protection of personal data.

d) Billing management: Depending on the data categories, the data is accessible to banks, accreditation bodies, electronic toll subscription issuers, and other highway concession companies.


II. Development, qualification, and maintenance of a free-flow toll collection system

The data is accessible to authorized internal departments of APRR as well as to those of the subcontractor(s) under contracts that comply with personal data protection regulations.


III. Ticketless entry at the Montmarault on-ramp:

The data is accessible to authorized internal departments of APRR as well as to those of the subcontractor(s) under contracts that comply with regulations regarding the protection of personal data.


IV. Customer Relationship Management:

Personal data is processed by authorized internal departments of APRR or ALIAE.


V. Detection of Toll Non-Payment:

Personal data is accessible exclusively to authorized internal departments of APRR.


VI. Toll Fraud Prevention:

Personal data is accessible exclusively to authorized internal departments, with the exception of data relating to toll non-payment citations, which is shared with duly authorized SIV managers as well as with the public prosecutor in the event of non-payment of the payment notice.


VII. Settlement of toll non-payment notices and payment notices on the website https://paiement.aliae.com

The data is accessible exclusively to authorized internal departments of APRR. 


VIII. Video surveillance on the highway network: 

The data is accessible to authorized internal departments of APRR and AREA.

Law enforcement agencies may receive it if they issue a court order


Security measures applied to personal data

Personal data is subject to all necessary technical and organizational measures to ensure its confidentiality and security against any data breach, destruction, loss, alteration, disclosure, reproduction, or unauthorized access.

Subcontractors of APRR and ALIAE are subject to the same confidentiality and security obligations.


Location of personal data

Data is not transferred outside the European Union.


Automated decision making

Data processing is not subject to automated decision-making.


Rights of persons whose personal data are processed

In accordance with regulations, all individuals concerned have the following rights: Right of access, rectification, erasure, objection on legitimate grounds, restriction, and portability of personal data. All of these rights may be exercised by contacting the data protection officer at:

  • Electronically via this form
  • By post to the following address: APRR / AREA, Data Protection Officer, 36 rue Dr Schmitt 21850 St Apollinaire

Any person concerned by the processing of their personal data may, after contacting the data controller and if they consider that their rights have not been respected, lodge a complaint with the CNIL.