Privacy

Working draft dated 9 September 2026. Reconciled with application corrections. Unpublished, not yet in force. Legal and operational validation required: admission of 16- and 17-year-olds, map provider terms, identity and complete operational information remain to be resolved before publication.

1. Controller and scope

The data controller is Tristan MURAT, a sole trader (entrepreneur individuel, EI), trading as Tristanovate Solutions, SIREN 925 380 586, SIRET 925 380 586 00014, Plan Villard, 73600 Moûtiers, France. He publishes Foulevo and provides the contact for data protection matters: contact@foulevo.com.

This policy describes the personal data used to provide the Foulevo application, manage accounts and outings, enable communications, secure the service and respond to requests. It describes the optional choices actually prepared in the application; a future website registration or feature does not constitute processing that has already started.

Foulevo does not sell personal data. Data is nevertheless processed by technical service providers needed for the features described. The absence of sales therefore does not mean an absence of transmission.

2. Data collected and its source

Data comes from your entries and actions, people who communicate with you within the service, technical operations necessary for its functioning and, if you choose that login method, the authentication provider concerned.

| Category | Information concerned | | --- | --- | | Account and authentication | Email address, account identifier, secure authentication elements, login sessions, choices and versions of accepted texts. For Google or Apple login: identifiers and account information actually transmitted for that login. | | Profile and preferences | Display name, profile identifier, private date of birth, self-reported gender, optional photo and cover, biography, city or reference area, language, country, time zone, sports, level and entered preferences. | | Sports activity | Self-reported pace, distance, elevation gain, goals and progress indicators; optional indicators such as VO₂ max and VMA when offered; summaries and feelings you choose to enter. | | Outings and relationships | Outings created or joined, dates, places, meeting points, admission requests, invitations, groups, follows, availability and activities associated with the account. | | Content and communications | Posts, comments, photos, reactions, conversations and sending metadata; voice recordings when this feature is actually activated; shared summaries, thank-yous and memories. | | Support and security | Requests, replies, reports, items necessary for their examination, moderation measures and technical information relating to incidents. | | Technical data | Session and notification identifiers, application version, technical device and error information, operational and usage events; IP address during network communications, depending on the services concerned. | | Optional choices | Consents and withdrawals regarding emails, optional statistics and sensitive sports indicators, presented separately. |

Required fields are identified during collection. Their absence may prevent account creation or performance of the requested feature. A photo, biography, physiological indicator or newsletter subscription is not necessary to access essential features.

Free-text fields may contain sensitive personal information. Do not enter a medical record, identity document or sensitive information about another person. Foulevo does not offer identity verification by sending an identity document or verification selfie.

3. Purposes and legal bases

| Purpose | Basis for processing | | --- | --- | | Create and administer the account, provide profiles, outings, groups, communications and requested features | Performance of the contract constituted by the Terms of Use, only for data necessary for these features. | | Find outings and present suggestions suited to chosen criteria | Performance of the requested service; optional features or unnecessary data rely on separate consent where required. | | Prevent abuse, protect accounts, diagnose strictly necessary errors, provide human moderation and respond to requests | Foulevo's legitimate interest in providing a safe and reliable service, after examining necessity and individuals' rights; legal obligation where a provision requires a particular operation. | | Optionally measure usage with Amplitude and internal Supabase analytics events | Optional account-specific consent, withdrawable at any time. Traces necessary for an account or security operation remain separate from this analysis. | | Send Foulevo updates or the newsletter | Prior consent, separate from acceptance of the Terms of Use and emails necessary for the account. | | Process indicators that constitute health data, including certain physiological indicators | Explicit and specific consent under Articles 6 and 9 of the GDPR, for a precisely explained optional use. | | Respond to data rights, carry out legally grounded authority requests and comply with an applicable retention obligation | Legal obligation. | | Retain evidence strictly necessary for a dispute | Legitimate interest in establishing, exercising or defending a right, within applicable limits; appropriate additional basis where sensitive data is concerned. |

A legitimate interest does not permit circumventing a consent requirement applicable to trackers or sensitive data. Technical access granted by the phone does not automatically replace that consent.

4. Visibility and recipients within Foulevo

Other members receive only information accessible under the features used and visibility rules. The profile and each post have separate choices. A 'public' audience within the community means distribution to authorised Foulevo members; it does not, on its own, authorise indexing of the content on the open web.

Date of birth is not displayed as public data. The general discovery area must be distinguished from the exact meeting point, which is restricted to the organiser and admitted participants under the applicable access controls.

Conversations are intended for their participants. Invitations, admissions and blocks govern communications. This access confidentiality does not mean that Foulevo provides end-to-end encryption; strictly necessary technical or moderation access remains possible within the framework described here.

Post-outing summaries have their own audience. A private thank-you is not automatically added to the recipient's profile: a proposal to publish it requires their agreement. Sharing a memory is a separate action.

A person authorised to view content may keep a copy. Foulevo cannot guarantee erasure of all screenshots or copies made outside the service, without prejudice to its obligations towards recipients and your rights in relation to them.

5. Location and phone permissions

Location. The location feature uses a one-off foreground position to locate you on the map or help you choose a point. It is not intended to track your movements continuously. You can refuse this permission and use an area entered manually. The city or coordinates of a reference area saved in the profile, and the places saved for an outing, are separate from this one-off request.

Contacts. The contact search flow lets you select a person and use their name to search for a profile. It does not carry out a general address book import or transfer all phone numbers or email addresses. A preference setting does not constitute a phone access permission.

Photos and camera. Media is selected or captured at your initiative, then sent when you save or share it. A memory card exported to your device is a separate copy on that device.

Microphone. When the voice message feature is available, microphone access is requested to record the message you choose to create. It is not continuous listening. Sending is a separate action after recording. This feature must be added to the published version of the policy only if it is actually activated at launch.

Notifications. Notifications use a technical device identifier and the corresponding preferences. You can manage them in Foulevo and in the phone settings. Refusing them does not prevent access to the service.

Calendar. The internal calendar is based on Foulevo outings. This version announces no general reading or automatic synchronisation of your Google or Apple calendars. Any future connection will be accompanied by specific information and the necessary permissions.

6. Diagnostics and usage measurement

Sentry receives technical error and performance diagnostics when the integration is configured. Before transmission, the corrected version removes direct account identifiers, typed messages, request bodies, link parameters, signed media paths and precise coordinates present in the filtered fields. Session video recordings are disabled. The minimisation control and provider settings must be verified on the version actually distributed; these mechanisms are not a general guarantee that network requests are anonymous.

Amplitude and the internal Supabase events used for optional usage analytics are subject to the same explicit choice per account. Without consent, these events are not sent through their application pathway. Refusing consent preserves access to the service's features. Permitted properties are limited to technical categories such as sport, action type, duration, number, platform and source; private messages, profile content and precise meeting points are not added.

The choice can be withdrawn in settings. Switching accounts does not carry over another account's consent. Withdrawal prevents future optional events; previous data is subject to erasure procedures and applicable retention periods. The contracts, regions and retention periods actually configured remain to be documented before publication.

7. No advertising integrated in this version

No AdMob, Unity LevelPlay or AppLovin MAX advertising SDK is integrated in the version examined. This policy therefore describes no active advertising recipient for the application.

Any future advertising will require an inventory of processing and partners, appropriate information and the required choices before activation. Agreement to the Terms of Use, statistics or emails does not constitute consent to that future use.

8. Emails and newsletter

Emails essential for security, authentication and handling a request are separate from promotional messages.

Subscribing to Foulevo updates or the newsletter is optional and requires a separate affirmative choice. Each promotional email identifies Foulevo and offers simple, free unsubscription. You can also write to contact@foulevo.com. Creating an account, accepting the Terms of Use or not objecting do not, on their own, constitute a newsletter subscription.

Contact details are not sold or provided to partners for their own campaigns solely on the basis of this subscription. Adding a partner or new purpose later will require appropriate information and authorisations. The future website's sending provider will be identified before the subscription form opens. Any tracking pixels for opens and clicks are not activated solely on the basis of consent to receive the newsletter.

9. Sensitive sports data and minors

The current flow sets a minimum age of 16; the conditions and safeguards applicable to 16- and 17-year-olds remain to be validated before access is opened. Date of birth is used in particular to apply this rule and the appropriate protections; it is not intended for public disclosure.

Sports activities do not automatically turn all data into health data. However, VO₂ max, certain physiological measurements or certain reported feelings may reveal health information. Processing them calls for specific safeguards: necessity of the data, optional entry, dedicated information, explicit consent when that basis is used, the option to withdraw and a separate visibility choice.

VO₂ max and VMA (maximal aerobic speed) are self-reported and optional. Saving them requires an explicit action separate from the 'display on my profile' choice. The corrected version keeps proof of consent with the version of the information presented. In the editor, withdrawing this consent and saving deletes the values; you can also delete an indicator individually. Refusal does not limit access to essential features. Older values without this proof do not automatically become public. The relevance and proportionality of the profile purpose must nevertheless be confirmed in the legal validation, particularly for minors.

Foulevo does not infer a medical diagnosis or guaranteed fitness to participate in an outing from these indicators. A minor's rights and the involvement of their legal representative are assessed under the applicable provisions; accepting the Terms of Use does not waive them.

10. Service providers and authorised access

Administrative access is limited to Tristan MURAT and authorised technical personnel to the extent necessary for their duties. Group administrators and other members do not, by virtue of their role, have access to Foulevo's administrative tools.

| Service | Role and data categories | Verification status for this draft | | --- | --- | --- | | Supabase | Authentication, database, media storage and server functions; account and service data | Foulevo project verified in region eu-west-3, Paris. This concerns the project's main region, not a guarantee that all access and subprocessors are exclusively French. | | Sentry | Error reports and filtered technical context, with no direct account identifier added by the current filter | Integrated in code; organisation, region, contract and actual retention remain to be confirmed. | | Amplitude | Usage events and identifiers, according to consent and settings | Integrated in code; region, contract, retention and deletion with the provider remain to be confirmed. | | OneSignal and platform notification services | Notification identifiers, account association and elements necessary to deliver notifications | Integration identified; contractual recipients, settings and retention remain to be confirmed. | | Google or Apple for login, if the method is offered | Authentication information and profile data strictly received for the chosen login | To be reconciled with methods actually opened in the launch version. | | OpenFreeMap | Provision of base maps; network requests, IP address and requested map portions | Provider used by MapLibre; absence of an availability guarantee and terms concerning minor users remain to be resolved before access is opened to 16- and 17-year-olds. Map requests are not continuous tracking by Foulevo. | | Resend | Sending transactional account emails through the configured SMTP service | Domain, sender, delivery, contractual identity, region and retention period remain to be reconciled with operational evidence before publication. | | OVHcloud and any newsletter provider | Hosting and email according to the services actually used | Exact hosting service, contractual entity and contact details remain to be confirmed for the website; no newsletter tool is presented as already open. |

This draft list must be supplemented with the relevant contractual identities and service providers' information links before publication. Authorised authorities may receive required data where a request or legal obligation justifies it. Providers acting on our behalf are governed by the contractual obligations applicable to their role.

11. Data location and international transfers

Foulevo's main Supabase project is located in the Paris region. This location alone is not sufficient to conclude that all operations, support and service providers remain within the European Economic Area.

For each access or transfer outside the EEA, Foulevo must identify the country, recipient and applicable mechanism: an adequacy decision in force where its conditions are met, or safeguards such as standard contractual clauses accompanied by the necessary supplementary measures. Using a US provider does not allow it to be assumed, without verification, that an adequacy decision covers the service concerned.

The inventory of transfers and safeguards actually applicable remains to be completed before publication. A copy of the relevant safeguards or details of how to consult them may be requested at contact@foulevo.com, subject to redactions necessary to protect confidential information.

12. Retention

Data must be retained for the period necessary for its purpose. Deletion, withdrawal of consent or a legal obligation may change this period. Items necessary for a dispute are isolated from ordinary use and limited to what is justified.

None of the numerical retention periods proposed on 7 September is presented here as a purge already implemented. The inventory of periods, their justification and their implementation remain conditions for publishing the complete policy.

| Category | Retention criterion and status to finalise | | --- | --- | | Account, profile, relationships, outings and content | As long as necessary for the requested features, then erasure or justified processing when they are deleted or the account is closed. Rules specific to collective items remain to be documented. | | Inactive accounts | No automatic closure for inactivity alone. A necessity review procedure remains to be defined; absence of closure does not mean unlimited retention. | | VO₂ max and VMA | Until consent is withdrawn or the value or account is deleted, subject to applicable exceptions and residual copies that remain to be documented. | | Diagnostics, optional statistics and security logs | Periods per purpose and provider remain to be confirmed in the configuration and purge tasks. | | Support, reports, decisions and proof of consent | Retention limited to handling and to obligations or evidential needs actually applicable; deadlines and access remain to be documented. | | Optional emails and objection | Until withdrawal for promotional uses; minimal evidence of objection and its retention period remain to be defined before a campaign. | | Deletion receipt and service provider verification | Tracking limited to information necessary for execution and proof of it. Waiting for a provider is not completed processing overall. The receipt purge policy remains to be validated in the deployed version. | | Backups and residual copies | Cycle and maximum period remain to be confirmed with each service. Erasures must be reapplied before data is brought back into use following restoration. |

Truly anonymous statistics may remain. Replacing a name with an identifier is not sufficient to make data anonymous.

13. Your rights and choices

Under the conditions laid down by the GDPR, you can request access to your data, rectification, erasure, restriction of processing and, where the conditions are met, portability. You can object to processing based on legitimate interests for reasons relating to your situation and object to direct marketing at any time.

You can withdraw consent without affecting the lawfulness of operations carried out before withdrawal. Choices regarding optional statistics, emails and sensitive indicators are separate. Your device settings also let you change technical permissions.

Send your request to contact@foulevo.com, identifying the account or data concerned. The process is free, subject to the limited cases provided by law for manifestly unfounded or excessive requests. Proportionate identity verification is requested only where there is reasonable doubt; do not send an identity document or password without being asked.

This version publishes no commitment to support within 48 hours. Information on the action taken on a rights request is provided without undue delay and no later than one month after receipt. An extension of two months is possible if justified by its complexity or the number of requests; reasons are provided and the extension is notified during the first month. An initial response does not necessarily mean the request has been fully carried out.

You can set instructions on what happens to your data after your death under French law. You can also contact the CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, or use any other remedy provided by law.

14. Account deletion

Deletion can be requested in the application or without the application by email to contact@foulevo.com. The account and data deletion page describes the steps, data concerned, timeframes and exceptions. Closure is not replaced by simple deactivation.

Tracking distinguishes the account and files already processed from verification still ongoing with service providers. A status awaiting these checks is not presented as completed deletion overall. Erasure requests must also cover data processed on our behalf by the relevant providers. Data processed by a third party under its own responsibility is subject to its procedures for exercising rights, without prejudice to the steps incumbent on Foulevo.

15. Security, recommendations and artificial intelligence

Foulevo uses authentication, access control and network communication protection mechanisms. Administrative access and content visibility must be limited to the service's needs. No service can guarantee absolute security; in the event of a data breach, the applicable assessment, notification and information obligations are followed.

Outing suggestions rely on criteria such as sport, area, availability, preferences and self-reported level information. They assist discovery and do not constitute a decision that, on its own, produces a legal effect or a guarantee of compatibility. Admission remains subject to the outing's rules and its organiser's choices.

Artificial intelligence tools used for Vive's voice, jingles or brand creations do not, by virtue of that use, receive general access to Users' content. Any future use of AI on their data must be defined, explained and given a legal basis before implementation. A general service use clause does not constitute permission to freely reuse their data.

The website's Vive assistant

Technical information added on 30 September 2026. Vive is an optional automated assistant intended to guide visitors through Foulevo's information. It accesses neither your account nor the application's private conversations and meeting points, and performs no action in your account.

The Cloudflare service is contacted to check its availability when you open the panel. When you send a question, its text and up to eight recent messages from the exchange are sent to Foulevo's Cloudflare Worker. When an answer is generated, the service uses Workers AI with documented Foulevo information. Technical connection data, including the IP address, is also processed to route requests and limit abuse.

Displayed messages are held in the memory of the open page. The website does not save them in persistent browser storage and they disappear when the page is reloaded or left. The assistant's code creates no transcript database. This does not mean that Cloudflare processes no technical logs; the provider's processing arrangements remain to be documented in the retention inventory.

Avoid sending a password, payment method, health information or private information about another person. Answers may be incomplete or incorrect. For a request concerning your account, your rights or a personal difficulty, you can contact directly contact@foulevo.com. No email is sent automatically by Vive.

Website audience measurement

The website may use Google Analytics 4 (Google Ireland Limited) to learn which pages are viewed and understand traffic to foulevo.com. This optional measurement is activated only after you choose 'Accept' in the panel displayed on the website. If you refuse, the Google Analytics tag is not loaded. Visit information and measurement identifiers may be sent to Google after acceptance. We disable Google signals and advertising personalisation in this tag's configuration.

You can accept, refuse or change this choice at any time using 'Manage cookies' at the bottom of the page. The choice is stored locally in your browser. When you withdraw consent, the website stops loading the tag on the next navigation and attempts to delete the Google Analytics cookies set on foulevo.com. The retention and transfer arrangements for data processed by Google remain described in the Google's privacy policy.

16. Changes to the website and policy

The foulevo.com website evolves over time. Adding a form, newsletter, measurement tool, embedded video or community space must be accompanied by information appropriate to the processing actually introduced. This policy requests no consent for unspecified future uses.

Updates state their date. A significant change is brought to your attention by appropriate means before it applies, subject to situations requiring immediate action. A new purpose requiring consent leads to a new choice; simply publishing a new policy does not constitute consent.