Platform privacy policy
Last updated: 10 October 2026
This policy is for the people who use the Traktion platform: the driver app, the management interface and the related services. It supplements the information notice your employer gives you. The traktion-das.com website has its own privacy policy.
1. Who are we?
The Traktion platform is published and operated by Traktion SAS, SIREN 994 394 682, 251 rue Joseph Louis Lagrange, 59300 Famars, France, represented by Romain Tissot‑Charlod, President.
Data protection officer: dpo@traktion-das.com.
2. On whose behalf do we process your data?
Traktion is used only by rail operators, for their employees and the people placed at their disposal, during working time and for the missions assigned to them. Our role depends on the data:
| Situation | Controller | Role of Traktion |
|---|---|---|
| You use Traktion for your work at a rail operator (driver, dispatcher, administrator) | Your employer, or the company employing you for the mission | Processor: we process your data on its behalf and on its instructions (GDPR, Art. 28) |
| Platform security, technical logs, management of our own accounts | Traktion | Controller |
| Traktion staff member taking part in a trial, with the management’s approval | Traktion | Controller |
For any question about how your employer uses your data, contact your employer first: its information notice tells you how.
3. What data, for what purpose, on what legal basis?
| Purpose | Data | Legal basis |
|---|---|---|
| Manage your account and access rights | Surname, first name, work e-mail address, staff number, role, company, optional photo | Legitimate interest of the employer and performance of the employment contract |
| Plan and carry out driving missions | Assigned missions, planned and actual times, reports and notes | Legitimate interest of the employer: organisation and safety of rail operations |
| Assist driving and follow trains in service | Position, speed, heading and time, only during the missions you are assigned to | Legitimate interest of the employer: rail safety, within the limits set by the French data protection authority (CNIL) for employee geolocation |
| Manage working time, absences and overnight stays, if your employer uses these features | Hours, absences, overnight location | Legal obligation and performance of the employment contract |
| Keep the platform secure | Technical logs: date and time, action performed, IP address | Legitimate interest of Traktion and security obligation (GDPR, Art. 32) |
Your data is never used for advertising, commercial profiling or resale. No decision with legal effects on you is taken by fully automated means (GDPR, Art. 22).
4. Geolocation
Your position is recorded only during the missions you are assigned to as driver, never outside your working time and never continuously. The app shows “Location shared” while your position is being sent, and our servers reject any position sent outside this scope.
5. How long?
| Data | Retention period |
|---|---|
| Positions recorded during missions | Linked to your identity for 60 days after the mission; your employer may extend this to 1 year at most, with a justification. The route is then detached from your identity. |
| Missions and working time | Set by your employer, 5 years by default |
| Account | While you are active, then anonymised |
| Technical logs | 3 years, so that events can be reconstructed after an incident or during a rail safety investigation |
When the contract with your employer ends, its data is returned to it and then deleted within 30 days.
6. Who receives your data?
- The authorised people at your employer, according to their role.
- Traktion, for hosting, maintenance and support, only as far as necessary.
- Our hosting providers: Infomaniak Network SA (Geneva, Switzerland) and Traktion SAS (France).
- The base map and weather forecast providers used by the app (OpenFreeMap, OpenRailwayMap, Open‑Meteo). They receive the device’s IP address and the area shown or the route concerned, never your name. We plan to serve this data from our own servers.
- No other rail operator: each client has an isolated space, with its own identity service, its own database and its own network.
7. Where is your data?
The platform is hosted in Switzerland, a country recognised by the European Commission as providing an adequate level of protection. It will be moved to the European Union when we switch to a high-availability infrastructure; your employer will be informed at least 30 days in advance. The providers listed in section 6 are established in the European Union or in Switzerland. No data is transferred to any other country.
8. Security
Each client has an isolated space. Communications are encrypted, secrets are managed centrally, deployed software is verified, the network is segmented and access is logged.
9. Your rights
You have the rights of access, rectification, erasure, restriction, objection and portability (GDPR, Art. 15 to 21), and the right to give instructions about what happens to your data after your death (French Data Protection Act, Art. 85).
To exercise them:
- in the app (“My data”) or in the management interface (“My personal data”): download your data and request its erasure;
- with your employer, at the address given in its information notice; it answers within one month;
- with Traktion, at dpo@traktion-das.com. If your request concerns data we process for your employer, we forward it to your employer without delay and let you know.
You may be asked for proof of identity if there is reasonable doubt about who you are.
10. Complaints
You can lodge a complaint with the French data protection authority, Commission nationale de l’informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France, www.cnil.fr, or with the authority of the country where you live or work.
11. Cookies and trackers
The platform only uses the trackers it needs to work: sign-in session and display preferences. Usage measurement, if your employer turns it on, is hosted by Traktion and produces statistics without cookies; it links your use to your identity only with your explicit consent.
12. Changes
Any significant change to this policy is announced in the app before it takes effect. Previous versions are available on request.
13. Installation at your employer
If your employer has installed Traktion on its own servers, it is the only operator and your data stays on its infrastructure. It then publishes its own privacy policy. Traktion, as software publisher, only receives technical operating information, without personal data or in pseudonymised form. Traktion accesses anything else only for maintenance or troubleshooting requested or authorised by your employer, for a limited time and with logging. Two data protection officers then coexist: your employer’s for your data, and Traktion’s (dpo@traktion-das.com) for the technical information and maintenance access.