Privacy Policy – WhatsApp Ally Experiment on the Île-de-France Mobilités Network
Version: 06/09/2026
Experimentation period: from June 10, 2026 to July 10, 2026
This privacy policy explains how BeTomorrow processes personal data as part of the experimentation of the Ally Mobility demonstrator accessible via WhatsApp for information requests relating to the Île-de-France Mobilités network, using open data.
This policy only concerns the WhatsApp experimentation. For the use of the Ally Mobility showcase website, please refer to the privacy policy applicable to the website.
1. Responsable du traitement
Le responsable du traitement est :
BeTomorrow
44 rue Barreyre, 33300 Bordeaux
France
Contact protection des données : rgpd@betomorrow.com
2. Purpose of the experiment
Ally Mobility is a conversational demonstrator allowing users to ask mobility-related questions, for example about routes, schedules, next departures, disruptions, stops, lines, or practical transport information.
The experiment is limited in time, from June 10, 2026, to July 10, 2026. It is offered for the purposes of testing, understanding usage, and improving the performance of the Ally product.
BeTomorrow reserves the right to introduce access limitations related to usage, or to suspend or decommission the demonstrator, particularly in the event of excessive usage, technical incidents, misuse, or operational constraints.
Personal data processed
When you use the demonstrator via WhatsApp, we may process the following categories of data:
Data from WhatsApp:
your phone number, necessary for sharing via WhatsApp;
the technical conversation or message identifiers transmitted by WhatsApp;
the dates and times of sending or receiving messages;
the technical information or metadata made available by WhatsApp as part of using the service.
The phone number is processed to enable communication with you. It is then pseudonymized: in our application databases, we store an internal identifier and not the plain phone number.
Data you voluntarily send us:
the content of your WhatsApp messages;
the mobility information you mention, for example an address, a station, a stop, a line, a route, a route preference, or a travel constraint;
your location or GPS coordinates if you choose to transmit them to us;
any other content you choose to send via WhatsApp.
Data generated when using the demonstrator:
the responses generated by Ally;
the technical traces related to the functioning of the service;
the logs for errors, performance, availability, and observability;
the information necessary for understanding usage, evaluating response quality, and improving the product.
4. Beware of sensitive data
The demonstrator does not intend to collect sensitive data within the meaning of the GDPR, such as health data, information relating to a disability, political opinions, religious or philosophical beliefs, or any other sensitive data.
We ask that you do not transmit such information in your messages.
However, certain mobility requests may lead a user to spontaneously mention a specific situation, such as an accessibility need. In this case, this information is processed only to the extent necessary to understand and respond to your request.
5. Filtering and pseudonymization
BeTomorrow implements measures designed to limit the collection and retention of directly identifying data.
In particular:
the phone number is pseudonymized and replaced by an internal identifier in the application database;
a personal data detection and filtering mechanism based on Azure AI Language / PII is used to reduce the presence of certain personal data within the processing operations;
certain proper nouns are not automatically filtered because they may correspond to names of stops, stations, public places or points of interest necessary for the operation of the service.
Microsoft indicates that its PII service can detect and mask personal data in unstructured text, with various categories such as people, addresses, emails, phone numbers, IP addresses, and location data.
Pseudonymization reduces risks but does not constitute anonymization. The data processed as part of the experiment therefore remains likely to be personal data.
6. Purposes of processing
Data is processed for the following purposes:
Provide the Ally demonstrator via WhatsApp This includes receiving your message, interpreting it, generating a response, and sending this response via WhatsApp.
Understand the usage of the demonstrator Messages and usage traces may be analyzed to understand the types of questions asked, difficulties encountered, common user journeys, and user needs.
Improve the performance and quality of the Ally product Data may be used to improve the relevance of responses, detect errors, evaluate performance, reduce hallucinations, and improve prompts, internal tools, and filtering mechanisms.
Ensure security, proper functioning, and technical supervision Technical logs may be used to prevent abuse, detect incidents, fix errors, measure service availability, and maintain the demonstrator.
Manage requests related to data subject rights Data may be used to respond to requests for access, rectification, objection, restriction, or erasure.
Data is not used for targeted advertising purposes nor sold to third parties.
7. Legal bases
The processing is based on the following legal bases:
BeTomorrow's legitimate interest in testing, operating, securing, and improving its Ally demonstrator;
your consent, when you voluntarily choose to transmit certain optional information, particularly your precise location or, where applicable, sensitive information necessary for understanding your request;
compliance with legal obligations, when BeTomorrow must retain or communicate certain information to comply with a legal obligation or a request from a competent authority.
You may object to processing based on legitimate interest for reasons relating to your particular situation, subject to compelling legitimate grounds that BeTomorrow may have to continue the processing.
8. Mandatory or optional nature of the data
Using WhatsApp technically involves the processing of your phone number by WhatsApp and by BeTomorrow to enable the exchange.
The content of your messages is necessary for the demonstrator to understand and respond to your request.
The transmission of your GPS location is optional. If you do not wish to transmit your location, you can make your request by manually indicating a stop, a station, an approximate address, or a public place.
9. Recipients and subcontractors
The data may be accessible, within the limits of their duties, to authorized personnel of BeTomorrow working on the Ally experiment.
They may also be processed by the following technical service providers:
WhatsApp / Meta, for routing messages and using the WhatsApp channel;
Microsoft Azure, for hosting, some application processing, and filtering of personal data;
Vercel, for certain application or hosting components;
Langfuse, for observability, technical analysis, and improving the demonstrator's behavior;
where applicable, any other service provider strictly necessary for the operation, security, or maintenance of the demonstrator.
10. Hosting and data localization
The main infrastructure of the experiment is hosted on Azure in Europe.
Langfuse is used in the European region, hosted on AWS Ireland.
Some service providers, specifically WhatsApp / Meta or Vercel, may involve processing or data transfers outside the European Economic Area. WhatsApp indicates that its Business services may involve transfers and processing to the United States and other countries, according to its global operation. Vercel provides a Data Processing Addendum applicable to certain clients and specifies that, in this context, the client acts as the data controller or processor, and Vercel as the sub-processor for Customer Data.
When transfers outside the European Economic Area are carried out, they are governed by the appropriate safeguards provided by the applicable regulations, including the Data Privacy Framework (EU-US data protection framework), standard contractual clauses, or data transfer addenda.
11. Retention period
The data collected as part of the experiment is stored for a maximum period of 24 months from the end of the experiment, i.e., at the latest until July 10, 2028, unless a valid request for deletion is made or there is a legal obligation to the contrary.
This period allows BeTomorrow to analyze usage, evaluate the quality of the demonstrator, correct errors, and improve the Ally product after the testing period.
The deletion of data will be carried out manually, at the latest at the end of this maximum period.
Data may be deleted before this deadline when it is no longer necessary for the purposes described above.
Data processed directly by WhatsApp remains subject to WhatsApp's own privacy policy and retention periods. In particular, WhatsApp states that delivered messages are generally deleted from its servers, while certain undelivered messages or media may be stored temporarily in encrypted form to facilitate their delivery.
12. Security
BeTomorrow implements technical and organizational measures designed to protect the personal data processed as part of the experiment, including:
pseudonymisation of the phone number;
limitation of stored data;
filtering of certain personal data;
control of access to technical environments;
hosting on professional infrastructure;
application and organizational security measures adapted to the experimental nature of the demonstrator.
However, no security measure can guarantee zero risk. Users are invited not to transmit confidential, sensitive, or unnecessary information with their mobility request.
13. Absence of automated decision-making producing legal effects
The Ally demonstrator automatically generates responses to your mobility requests.
These responses do not produce any legal effect regarding you and do not constitute an automated decision within the meaning of Article 22 of the GDPR. They are provided for experimental and informational purposes.
The demonstrator does not replace the official information, emergency, or assistance channels of the transport network.
14. No automated decision-making producing legal effects
In accordance with the applicable regulations, you have the following rights:
right of access to your data;
right of rectification;
right of erasure;
right to restriction of processing;
right to object to processing based on legitimate interest;
right to portability, where this right is applicable;
right to withdraw your consent at any time when processing is based on your consent.
To exercise your rights, you can contact BeTomorrow:
by email: rgpd@betomorrow.com
by mail: BeTomorrow – 44 rue Barreyre, 33300 Bordeaux, France
To enable us to identify your data within a pseudonymized environment, it may be necessary to provide us with a screenshot of your latest interactions, showing the exact hour and minute of a specific message. This will allow us to locate the corresponding internal ID in our databases without improperly re-identifying other users.
BeTomorrow will respond to your request within one month of receiving it. This period may be extended by two months in the event of a complex request or a large volume of requests, in accordance with the GDPR.
You also have the right to lodge a complaint with the CNIL.
15. Use of WhatsApp
Using the demonstrator requires you to use WhatsApp. WhatsApp processes certain data for its own purposes according to its own terms and privacy policies.
In particular, WhatsApp states that users must provide a mobile phone number to create an account, that certain usage, log, device, connection, and general location information may be collected, and that users can choose to share their precise location.
We invite you to consult WhatsApp's privacy policy to understand the processing carried out by WhatsApp independently of BeTomorrow.
16. Policy modification
This policy may be modified to reflect changes in the experiment, the processing carried out, the tools used, or the applicable legal framework.
The applicable version is the one available at the time of using the demonstrator.