Privacy Policy

Personal Data Protection

CIXI (Last updated: June 16, 2026)

CIXI, a simplified joint-stock company (société par actions simplifiée), with its registered office located at 315 rue Novus Parc - 74330 Poisy - France, registered with the Annecy Trade and Companies Register (RCS) under number 821 036 514 ("CIXI"), specializes in daily mobility.

Within the framework of using the services offered by Cixi (PERS, downloading our Cixi Application, etc.) ("the Services") or when browsing our websites https://www.cixi.life and https://shop.cixi.life, you are likely to communicate personal data concerning yourself to us.

CIXI has implemented appropriate guarantees and security measures in order to protect your personal data.

You are invited to read this policy, which explains how your personal data is processed by CIXI:

either as a data controller when it ensures the operational management of its websites, the PERS, the Application, and the Services;
or as a data processor when it acts in the name and on behalf of its Partners.

If necessary, you can ask all your questions directly to CIXI by sending an email to privacy@cixi.life or by postal mail to the address: CIXI, 315 Novus Parc, 74330 Poisy, France.

1. Why does CIXI process your data?

All the data you enter when downloading the Application, generate during your use of the PERS, or when communicating with CIXI's customer service are collected for the purpose of providing you with the Services offered by CIXI.

Some of this data is mandatory, while others are optional to benefit from all the Services. The mandatory or optional nature of the personal data to be filled in is indicated during collection.

If you refuse to provide mandatory data, CIXI will not be able to provide you with the requested Services (such as creating your account on the Application), nor respond to your other eventual requests.

2. CIXI's role in processing your data

When does CIXI act as a data controller?

CIXI is the data controller for data related to the operational management of its website, the PERS, the Application, and the Services. Any processing of personal data necessary to allow the PERS and/or the Application to function or to establish User statistics is carried out by CIXI as a data controller.

When does CIXI act as a data processor?

When CIXI processes your personal data on behalf of a partner, the latter is the data controller and CIXI is the data processor. This is particularly the case when you authorize the sharing of your data with the manufacturer, seller, repairer of your vehicle, or the manager of a vehicle fleet.

What personal data processing is carried out by CIXI?

The tables below describe the data collected by CIXI as a data controller, the reason for this collection and its legal grounds, the recipients of the data, and the retention period. Longer archiving periods than those mentioned below may be implemented to allow CIXI to comply with its legal obligations.

The terms for sharing non-personal data with CIXI, resulting from the use of a connected device delivering information on the state of the PERS, are detailed in the General Terms of Use.

2.1. Processing related to websites

2.1.1. Newsletter subscription

Question	Answer
What data is processed?	Email address, Language
Data subjects	Newsletter subscribers
On what legal ground is the data processed?	Consent
Who is the recipient of the data?	Sales department, Marketing department
How long is the data kept?	Until consent is withdrawn; At the longest: 3 years after the last opening of a newsletter

2.1.2 Management of information requests (contact form, pre-reservation notifications, brochure)

Question	Answer
What data is processed?	Last name, first name, Email, Type of requester (company or individual), Company name (if company), Purpose of the request, Country
Data subjects	Persons making the contact request
On what legal ground is the data processed?	Consent
Who is the recipient of the data?	Sales department, Marketing department, Digital department
How long is the data kept?	For information requests: 3 years from sending the contact or information request. For requests for notification of pre-order availability: 3 years from the date of data collection.

2.1.3 Creation and management of the user account on shop.cixi.life

Question	Answer
What data is processed?	Last name, first name, Email
Data subjects	Creators of a user account
On what legal ground is the data processed?	Consent
Who is the recipient of the data?	Sales department, Marketing department, Digital department
How long is the data kept?	Until account closure, or in case of inactivity, after 3 years

2.1.4 Order management on shop.cixi.life

Question	Answer
What data is processed?	Last name and first name, Email address, Phone number, Delivery and billing addresses
Data subjects	Persons who have placed an order
On what legal ground is the data processed?	Contract
Who is the recipient of the data?	Sales department, Marketing department
How long is the data kept?	Period necessary for the execution of orders, then as long as the account is active if the buyer holds an account. In the absence of an account, archiving for five years from the order (statute of limitations period).

2.2. Processing requiring the Cixi application

2.2.1 Creation and management of User accounts (application)

Question	Answer
What data is processed?	Username, Email, Password, Mobile phone number, Hardware ID (Unique server channel or app identifier), Language, Notification and data sharing preference center, Sharer / guest (beneficiary) status, PERS (pedal system) number, Identifier of the vehicle on which the PERS is mounted, Vehicle status, History of vehicles on which the PERS has been mounted, History of borrowed and/or shared vehicles, History of vehicle logs, History of received notifications, History of communication logs
Data subjects	Application users
On what legal ground is the data processed?	Contract (acceptance of ToS)
Who is the recipient of the data?	Support, Sales department, Marketing department, Digital department
How long is the data kept?	As long as the account exists.

2.2.2. Vehicle usage statistics

Question	Answer
What data is processed?	User Account data; Data relating to journeys made (trips, durations, average speeds); History; Data relating to energy supplied and produced; Preferred power mode for each journey; Journey status
Data subjects	Account holder in the application (user)
On what legal ground is the data processed?	Contract (acceptance of the application ToS) and Consent for processing requiring geolocation
Who is the recipient of the data?	Support, Sales department, Marketing department, Digital department
How long is the data kept?	3 rolling years

2.2.3 "Vehicle loan" feature

Question	Answer
What data is processed?	User Account data, Sharing key, Data linked to the guest (data linked to the guest's Account if they downloaded the application, otherwise the guest's email address), Loan start and end dates (check in/check out), Status: completed / in progress / available (yes/no), Vehicle location at the start and end of availability
Data subjects	Owner user and guest users (authorized users in the context of vehicles made available for a vehicle fleet).
On what legal ground is the data processed?	Contract for the owner User and consent for the guest User.
Who is the recipient of the data?	Support, Sales department, Marketing department, Digital department
How long is the data kept?	3 rolling years

2.2.4 Geolocation Feature

Question	Answer
What data is processed?	PERS number, Geolocation of the PERS, Usage statistics, If applicable: Vehicle identifier, Vehicle logs
Data subjects	Account holder in the application (user)
On what legal ground is the data processed?	Consent
Who is the recipient of the data?	Support
How long is the data kept?	Data kept for 3 rolling years for Account Users who have expressed their consent.

2.3. Processing related to the PERS not necessarily requiring the Cixi application

2.3.1 Real-time monitoring of PERS usage

Question	Answer
What data is processed?	Vehicle status; history of vehicles on which the PERS has been mounted; history of borrowed and/or shared vehicles; history of vehicle logs; history of communication logs; Data relating to energy supplied and produced; Diagnostic data: PERS number, Unique server channel or app identifier, Base data: battery status and level, PERS connection mode, Warning data (PIN code error, lock/unlock status, hardware status (battery, PERS, braking, lighting, cockpit, cable, etc.)), Alert data regarding the nature of hardware failure (PERS, battery, braking, motor, connected box, etc.), History of maintenance alert notifications + Account data if PERS associated with a User Account
Data subjects	Owner of the PERS
On what legal ground is the data processed?	Contract (acceptance of ToS). The collected data is necessary for Cixi to enable it to provide the features provided in the Application. In the absence of an application: legitimate interest (but data not linked to an identifiable User).
Who is the recipient of the data?	Support
How long is the data kept?	3 rolling years when the data is associated with an Account. If there is no User Account, the data is not linked to an identifiable User.

2.3.2 "Vehicle tracking and anti-theft detection" feature

Question	Answer
What data is processed?	User Account data, Status: lock / Unlock, Vehicle logs, Geolocation of the PERS
Data subjects	Account holder in the application (user) or Vehicle owner
On what legal ground is the data processed?	Consent (at the user's request)
Who is the recipient of the data?	Support
How long is the data kept?	Time of the instruction of the file by the competent judicial authorities or until the issue of a doubt-clearing procedure not leading to the confirmation of the vehicle theft. (Point 167 guidelines edpb 01/2020). Otherwise, conservation for the duration of the processing (lost vehicle located and location transmitted to the owner).

2.3.3 Vehicle diagnosis / Support

Question	Answer
What data is processed?	Same data as the "monitoring PERS usage" processing + Nature of the Bug and eventual exchanges with the support service + Real-time diagnostics + geolocation.
Data subjects	Geolocation is necessary to guide, if applicable, the User to the nearest repairer and to identify the applicable law (consumer guarantee) according to their geographical situation. Owner of the PERS.
On what legal ground is the data processed?	Contract (when the Owner has an Account) + consent for geolocation. Consent when the Owner does not have an Account.
Who is the recipient of the data?	Support
How long is the data kept?	3 rolling years when data is associated with an Account. If there is no User Account, the data is not linked to an identifiable User.

2.3.4 PERS Improvement (connected box)

Question	Answer
What data is processed?	Non-identifying and aggregated data from PERS usage data
Data subjects	Owners of the PERS
On what legal ground is the data processed?	Legitimate interest
Who is the recipient of the data?	Support, R&D Team
How long is the data kept?	N/A: Anonymized data

When Cixi acts as a data processor, it is up to the users who have subscribed to services from its partners to validate their privacy policies to identify any data processing entrusted to Cixi.

3. With whom is CIXI likely to share your personal data?

CIXI may eventually be required to use tools published by third parties in order to provide the PERS, the Application, and/or the Services.

In all cases, CIXI remains the Data Controller or first-tier processor depending on the processing concerned and remains responsible for compliance with the provisions of the General Data Protection Regulation.

It also agrees to work only with processors who strictly comply with the applicable regulations and present a level of security in line with applicable standards.

4. Is your personal data transferred outside the European Union?

Your data is hosted in the European Economic Area (EEA).

For the needs of providing the Services, CIXI may use processors located outside the EEA or likely to perform all or part of the outsourced processing outside the EEA.

For these processors, CIXI agrees to implement appropriate safeguards to allow these transfers. It agrees in particular to use only processors located in countries benefiting from an adequacy decision from the European Commission or with which it has concluded standard contractual clauses.

5. How does CIXI protect your personal data?

CIXI has implemented technical and organizational measures to protect your personal data, particularly against eventual violations likely to cause, accidentally or unlawfully, the destruction, loss, alteration, unauthorized access, or disclosure of your personal data.

These measures ensure an appropriate level of data security and take into account the state of knowledge, the costs of implementation compared to the risks, and the nature of the data to be protected.

CIXI also guarantees that members of its staff and any person required to process personal data concerning you comply with internal rules and procedures relating to the processing of personal data, and in particular the technical and organizational security measures implemented to protect your personal data.

6. What are your rights over your personal data?

In accordance with the applicable regulations on the protection of personal data, you have the following rights over your personal data:

You can request to have access to the personal data that CIXI has about you and to obtain a copy, including in electronic format;
You can request the rectification, update, and erasure of your personal data, as well as the limitation of their processing;
You can object to the use of your personal data within the framework of processing based on the legitimate interest of CIXI;
You can request the portability of your data when the processing is based on the contract or your consent;
You can withdraw your consent when it has been collected, without this withdrawal affecting the lawfulness of the processing previously carried out;
You can communicate to CIXI your post-mortem directives regarding your personal data in the event of your death (for example, their deletion or transmission to any person of your choice).

For any question and to exercise your rights, you can contact CIXI directly by sending an email to privacy@cixi.life.

In case of difficulty, you can contact the CNIL via its website or by mail: 3, place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.

7. Minors

CIXI does not process personal data of minors, the creation of an account on the Application and the purchase of a PERS being reserved for adults.

8. Updating this policy

This policy is subject to change, notably in the event of changes to the Services offered by CIXI. Therefore, we recommend that you consult this policy each time you access the Platform.