Legal information
Privacy policy
Last updated : · Version 1.0
This is a translation of the French document, provided for information only. It has not yet been reviewed by a lawyer and may contain inaccuracies; the French version is available below.
Document in preparation: 6 item(s) of information are still to be completed by the publisher. They are highlighted as follows: …
This policy explains what personal data JO & GEN processes when you use Gaston, le voyageur, why, on what legal basis, for how long, with which providers, and how to exercise your rights. It is drawn up in accordance with Regulation (EU) 2016/679 (“GDPR”) and French Act No. 78-17 of 6 January 1978 (“Informatique et Libertés”).
Our commitments
- No advertising, no audience measurement tools, no resale of data.
- Your trips and your messages to the co-pilot are not used to train AI models.
- Without an account, your trips are saved in your browser; only the full version of a preview is kept on our servers, without your identity, so that it can be unlocked.
1. Data controller
JO & GEN, société par actions simplifiée (SAS), 64 impasse des Places, 69480 Lucenay, France, SIREN 948 988 985, represented by its President, Anthony Jasicki. Contact for any question relating to your data: contact@gaston.travel. Data protection officer: To be completed: state whether a data protection officer has been appointed and, if so, their contact details.
2. Data processed, purposes, legal bases and retention periods
- Processing
- Account
- Data
- Email address, password (stored only in hashed form by our authentication provider), first name or display name, surname and first name if you provide them, language, travel preferences (pace, nights per stop, interests), dates of creation and of last sign-in
- Purpose
- Creating and securing your account, authenticating you (password or sign-in link by email), synchronising your trips across your devices
- Legal basis (GDPR, Art. 6)
- Performance of the contract (b)
- Retention period
- Until the account is deleted; an inactive account (no sign-in and no subscription for 2 years) is deleted after a warning, or only deactivated if it gives access to purchased trips (only the data strictly necessary for that access is then kept, separately)
- Processing
- Trips
- Data
- Starting points, destinations and stops, dates, duration, pace, interests, budget, travelling with children or pets, language, vehicle, trip name, places added, itinerary produced
- Purpose
- Building, saving, editing and exporting your trips
- Legal basis (GDPR, Art. 6)
- Performance of the contract (b)
- Retention period
- Without an account: in your browser only, until you delete them. With an account: until they or the account are deleted
- Processing
- Nationality of travellers (optional)
- Data
- Nationality of the person preparing the trip and, if they provide them, those of their travelling companions (country of the passport used, chosen from a list), in the trip form, in a trip's “Formalities” tab or in “My account”
- Purpose
- Personalising the trip's “Formalities” tab (identity documents, visa, authorised length of stay); in “My account”, pre-filling your future trips. It is never sent to the AI provider nor shown via the public link
- Legal basis (GDPR, Art. 6)
- Consent (a): the question is optional; you withdraw it at any time by clearing the answer: in a trip, from its “Formalities” tab (“Who for?”, then “Clear nationalities”, or removal of a travelling companion); in the form or “My account”, by returning to the first option “Nationality” in the list
- Retention period
- With the trip: for as long as the trip (in your browser without an account, on your account otherwise); it is never kept in the full version of a preview stored on our servers. In the account preferences: until the answer is cleared or the account is deleted
- Processing
- Previews created without an account
- Data
- Full version of the preview kept on our servers with a secret token, without identity; the token is kept in your browser
- Purpose
- Allowing you to link the preview to an account created afterwards (“Save this itinerary”) and to unlock it
- Legal basis (GDPR, Art. 6)
- Pre-contractual measures taken at your request (b)
- Retention period
- Until it is linked to an account; previews not linked: To be completed: retention period for anonymous previews, to be set and applied
- Processing
- Vehicles
- Data
- Name, type, height, width, length, weight, 4x4, default vehicle
- Purpose
- Adapting itineraries to your vehicle's dimensions
- Legal basis (GDPR, Art. 6)
- Performance of the contract (b)
- Retention period
- Until they or the account are deleted
- Processing
- Purchases and subscription
- Data
- Stripe customer ID, plan, subscription status and end of period, packs purchased (Stripe payment reference, number of credits, date), use of credits (trip, number of days, date)
- Purpose
- Providing credits and Gaston Gold, managing billing, cancellation and complaints
- Legal basis (GDPR, Art. 6)
- Performance of the contract (b); legal obligation (c) for accounting
- Retention period
- For the duration of the contractual relationship; accounting records: 10 years (Article L123-22 of the French Commercial Code (Code de commerce))
- Processing
- Free plan limits
- Data
- Number and date of previews, Explore searches and exports
- Purpose
- Applying the limits of the free plan
- Legal basis (GDPR, Art. 6)
- Performance of the contract (b)
- Retention period
- For the lifetime of the account
- Processing
- Prevention of abuse without an account
- Data
- IP address and times of previews requested without an account
- Purpose
- Limiting the number of free previews per connection, as each preview has a computing cost
- Legal basis (GDPR, Art. 6)
- Legitimate interest (f): protecting the service against abuse
- Retention period
- Taken into account over a rolling 24 hours; kept in server memory only (never written to the database) and erased at the latest when the server restarts
- Processing
- Location on request
- Data
- Approximate position of the device, when you tap “locate me”
- Purpose
- Finding the name of the nearest town to fill in the starting point
- Legal basis (GDPR, Art. 6)
- Consent (a), given in the browser's permission window and withdrawable in its settings
- Retention period
- Not kept by JO & GEN, unless you keep this place as the starting point of a trip
- Processing
- On the road guidance (beta, Gaston Gold)
- Data
- Precise position of the device, speed and heading, continuously during guidance; track of the route travelled
- Purpose
- Guiding you to the day's stops, recalculating the itinerary if you leave it, suggesting stops along the way; keeping your track for you
- Legal basis (GDPR, Art. 6)
- Performance of the contract (b) for the guidance requested; consent (a), given in the browser's permission window and withdrawable in its settings
- Retention period
- Position: sent to the server only to calculate the itinerary or search for stops, never recorded by JO & GEN; transmitted for this calculation to routing and place services (Valhalla of the FOSSGIS association, OpenRouteService of HeiGIT, OpenStreetMap via Overpass and Photon). Track: kept on your device only, 30 days, erasable and exportable
- Processing
- Co-pilot and AI generation
- Data
- Trip parameters and content (never the nationality of travellers), messages you write to the co-pilot
- Purpose
- Producing the trip programme and responding to your requests
- Legal basis (GDPR, Art. 6)
- Performance of the contract (b)
- Retention period
- The conversation is not recorded by JO & GEN (it stays in the open tab); see the AI provider's retention periods in section 4
- Processing
- Shared trips
- Data
- Members and roles, colour, author and date of the invitation, invitation links (token fingerprint, role, any reserved email address, number of uses, expiry), change log (author, summary, date), day being viewed in real time
- Purpose
- Allowing a trip to be prepared by several people
- Legal basis (GDPR, Art. 6)
- Performance of the contract (b)
- Retention period
- As long as the trip exists; real-time presence is not recorded
- Processing
- Public links
- Data
- Link token, author and creation date
- Purpose
- Allowing a reduced, read-only version of a trip to be shared
- Legal basis (GDPR, Art. 6)
- Performance of the contract (b)
- Retention period
- Until the link is revoked or the trip is deleted
- Processing
- PDF road book
- Data
- Copy of the trip sent to the print engine with a short-lived token
- Purpose
- Generating the PDF file
- Legal basis (GDPR, Art. 6)
- Performance of the contract (b)
- Retention period
- 10 minutes at most, in server memory
- Processing
- “Road books” newsletter
- Data
- Email address, first name (and surname for members), date, version of the text accepted and sign-up page
- Purpose
- Sending you, no more than once a month, trip ideas and news
- Legal basis (GDPR, Art. 6)
- Consent (a); Article L34-5 of the French Post and Electronic Communications Code (Code des postes et des communications électroniques)
- Retention period
- Until you withdraw your consent; in the absence of any interaction on your part, 3 years after sign-up or the last contact from you
- Processing
- Customer service, complaints and exercise of rights
- Data
- Your messages, our replies, relevant documents
- Purpose
- Responding to your requests and keeping proof thereof
- Legal basis (GDPR, Art. 6)
- Performance of the contract (b); legal obligation (c); legitimate interest (f) in securing evidence
- Retention period
- For the time needed to handle the request, then 5 years (ordinary limitation period, Article 2224 of the French Civil Code (Code civil))
- Processing
- Technical logs
- Data
- IP address, date and time, address requested, browser, response code, error messages
- Purpose
- Ensuring the operation, security and diagnosis of the service
- Legal basis (GDPR, Art. 6)
- Legitimate interest (f): security of the service
- Retention period
- According to the hosting providers' retention periods (section 4); the CNIL generally recommends between 6 months and 1 year for security logs
Nationality of your travelling companions. If you provide the nationality of the people travelling with you, do so only with their agreement and tell them what it is used for: personalising the trip's formalities. They may exercise their rights with us just as you can (see Your rights). Fellow travellers you invite to a trip see the nationalities saved with it; those who can edit it can also change or clear them, from its “Formalities” tab.
Data marked as required in forms (email address and password for an account, payment information for a purchase) is essential for the provision of the service; without it, the account or the purchase cannot be completed. Other data is optional.
Payment details are entered directly with Stripe: JO & GEN neither receives nor stores bank card numbers.
3. Who has access to your data
- authorised staff of JO & GEN, within the limits of their duties;
- members of the trips you share (they see your first name or display name, never your email address, and the content of the trip, including the nationality of travellers if it has been provided) and the people to whom you send a public link (reduced version, without the exact starting point, dates or nationalities);
- our providers (processors), solely for the needs of the service (section 4);
- administrative or judicial authorities, where required by law.
4. Providers and transfers outside the European Union
- Provider
- Vercel Inc. (United States)
- Role
- Hosting of the application, running of the servers, technical logs
- Data concerned
- All requests sent to the website (IP address, address requested, browser) and data passing through our servers
- Location and safeguards
- Processing mainly in the United States; project execution region: To be completed: Vercel region selected (by default Washington, iad1; Paris cdg1 recommended). Vercel participates in the EU-U.S. Data Privacy Framework (adequacy decision (EU) 2023/1795); its data processing agreement provides for the standard contractual clauses (Decision (EU) 2021/914). Runtime logs kept for 1 hour (Hobby plan), 1 day (Pro) or 30 days (with Observability Plus)
- Provider
- Supabase Pte. Ltd. (Singapore)
- Role
- Database, accounts and authentication, file storage (newsletter sign-ups), real-time features
- Data concerned
- Account, trips, vehicles, purchases, sharing, newsletter
- Location and safeguards
- Data hosted in the region: Irlande (AWS eu-west-1, Dublin). Supabase states that it governs its transfers to the United States and Singapore by the European Commission's standard contractual clauses; Singapore does not benefit from an adequacy decision. To be completed: check the data processing agreement (DPA) signed with Supabase
- Provider
- Stripe Payments Europe, Ltd. (Ireland)
- Role
- Payment, subscription, invoices, fraud prevention
- Data concerned
- Email address, customer ID, payment method, amounts
- Location and safeguards
- Stripe also acts as a separate controller for its own obligations (fraud prevention, legal obligations), in accordance with its privacy policy. Stripe, Inc. participates in the EU-U.S. Data Privacy Framework
- Provider
- Anthropic Ireland, Limited
- Role
- AI model that composes the trips and answers the co-pilot
- Data concerned
- Trip parameters and content, messages to the co-pilot (without your email address or the nationality of travellers)
- Location and safeguards
- Data processing agreement based on the standard contractual clauses (modules 2 and 3); the places of processing are not specified in it, and processing outside the European Union, in particular in the United States, is possible. According to Anthropic, API inputs and outputs are deleted within 30 days, subject to exceptions (enforcement of its usage policy, legal obligation), and are not used to train its models
- Provider
- Google (Google Maps Platform)
- Role
- Place search and place photos
- Data concerned
- Our servers query Google with place names and coordinates, without your identity; your browser loads the photos from Google's servers, which receive your IP address
- Location and safeguards
- Google LLC participates in the EU-U.S. Data Privacy Framework
- Provider
- MapTiler AG (Switzerland)
- Role
- Address search while typing, satellite and terrain maps, name of the nearest town
- Data concerned
- Text typed in the place fields and IP address (from your browser); coordinates (from our servers)
- Location and safeguards
- Switzerland: country recognised by the European Commission as providing an adequate level of protection
- Provider
- OpenFreeMap
- Role
- Base maps (tiles)
- Data concerned
- IP address and map areas viewed (from your browser)
- Location and safeguards
- To be completed: operator, server location and safeguards of OpenFreeMap
- Provider
- Wikimedia Foundation (United States)
- Role
- Photos from Wikimedia Commons
- Data concerned
- IP address and browser, when your browser loads a photo; cookies placed by Wikimedia (see the cookie policy)
- Location and safeguards
- To be completed: applicable safeguards, or loading of the photos via our servers (recommended fix)
To find places and calculate routes, our servers also query data sources (OpenStreetMap and its Overpass and Nominatim services, Photon, OpenRouteService and other routing engines, TripAdvisor, OpenTripMap, Wikipedia, Eurostat, European Commission). These requests contain coordinates and place names, but neither your identity nor your IP address.
You can obtain a copy of the safeguards governing transfers by writing to contact@gaston.travel.
5. Your rights
You have the rights of access, rectification, erasure, restriction of processing, data portability and objection to processing based on legitimate interest (Articles 15 to 21 of the GDPR). You may withdraw your consent at any time, without affecting the processing already carried out: unsubscribe link in each newsletter, location settings of your browser, clearing the nationality of travellers in the “Formalities” tab of each trip, or returning to the first option “Nationality” in the list in “My account”. You may also set out instructions regarding what happens to your data after your death (Article 85 of the French Data Protection Act (loi Informatique et Libertés)).
- from the “My account” area: edit your information, your vehicles and your preferences (including the nationality of travellers), export your trips (PDF, GPX), delete your account;
- from the “Formalities” tab of each trip (“Who for?”): edit or clear the nationality of travellers saved with it;
- by email to contact@gaston.travel, or by post to JO & GEN, 64 impasse des Places, 69480 Lucenay, France.
We respond within one month, which may be extended by two months for a complex request (Article 12 of the GDPR). Proof of identity is requested only where there is reasonable doubt as to your identity.
If, after contacting us, you consider that your rights are not being respected, you may lodge a complaint with the Commission nationale de l'informatique et des libertés (CNIL), online at cnil.fr/fr/plaintes or by post: CNIL, Service des plaintes, 3 place de Fontenoy, 75007 Paris.
6. Automated decisions
Itineraries are produced automatically, with the help of an AI model, from the parameters you choose. No decision producing legal effects concerning you or similarly significantly affecting you is taken solely on the basis of automated processing, within the meaning of Article 22 of the GDPR.
7. Minors
The service is reserved for adults. We do not knowingly collect data concerning minors. Trips may indicate that they include children, without any information about them.
8. Security
Exchanges with the service are encrypted (HTTPS). Access to data in the database is partitioned by row-level security rules: each person accesses only their own data and the trips shared with them. Invitation tokens are stored only as fingerprints. Administration keys never leave our servers. In the event of a data breach presenting a risk, we notify the CNIL and, if the risk is high, the data subjects (Articles 33 and 34 of the GDPR).
9. Cookies and local storage
JO & GEN places only cookies and local storage necessary for the service to function, with no advertising or audience measurement. Third-party cookies may, however, be placed by Wikimedia when certain photos are displayed. The full list is given in the cookie policy.
10. Changes to this policy
This policy may change, in particular when the service offers new features. The date of the update is shown at the top of the page; any significant change is notified to members by email or within the service.