Terms and Conditions of Use

1. Preamble

TrustMe Mobile Application is published by A3BC Group, a société par actions simplifiée, registered in the Trade and Companies Register of Rennes under the number 839 604 576, with registered office located at 1 Contour de la Motte, 35000 Rennes.

A3BC Group has developed the Application and associated services, accessible on cell phones via its mobile Application downloadable from the Play Store and Apple Store application stores.

Any use of the Application requires consultation and acceptance of the present terms and conditions of use on initial installation. The user of the Application acknowledges that his or her use of the Application requires compliance with all the provisions defined herein.

2. Definitions

Terms beginning with a capital letter in these Terms Of Use (“TOU”) of the Application, whether used in the singular or plural, shall have the following meaning:

• “Anomaly”: refers to any reproducible and documented malfunction, defect, error or bug in the Application and in particular (i) any non-compliance with the functional and technical specifications defined by A3BC Group (ii) any malfunction which, individually or cumulatively, prevents access to, or has repercussions on the use of all or part of the functionalities of the Application. Anomalies are qualified as :

  • “Blocking Anomaly”: refers to any Anomaly that makes it impossible to use the main functionalities of the Application;
  • “Non-blocking Anomaly”: means any Anomaly that does not prevent the full, continuous and uninterrupted operation of the Application in its main functionalities;

  An Anomaly does not include any defect caused by or resulting from any use of the Application that does not comply with the provisions of these TOU.

• “Application”: refers to the application offered under the name TrustMe edited and provided by A3BC Group, giving access to the services, and which is available free of charge in the “Google Play Store” or in the “Apple Store”, to be downloaded by the User on his Android or iOS terminal. The Application also includes the Content, software, programs, tools (programming, navigation, …), documentation and other elements and services that make it up, updates and new versions that may be made to the Application by A3BC Group.

• “Content”: means, but is not limited to, the structure of the Application, editorial content, drawings, illustrations, images, photographs, graphic charters, trademarks, logos, acronyms, company names, audiovisual works, multimedia works, visual content, audio and sound content, as well as any other content present within the Application and/or any other element making up the Application.

• “Personal data”: means all data relating to an identified or identifiable natural person, directly or indirectly within the meaning of the regulations in force applicable to the processing of personal data and, in particular, within the meaning of European Regulation 2016/979 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

• “Partner(s)” : refers to public or private companies contractually linked with A3BC Group, in connection with the use of the Application to authenticate/identify the User to access a service provided by said company.

• “Party” : means the User, A3BC Group or both.

• “User”: refers to an individual accessing the Application on his or her cell phone.

3. Purpose

The purpose of these terms of use is to define the conditions of access and use of the Application.

4. Acceptance and enforceability of the TOU

4.1 Acceptance

The User may use the Application subject to prior acceptance of these TOU.

The User declares that he/she has obtained all the necessary information from A3BC Group concerning the services offered via the Application and accepts the present TOU without reservation.

Acceptance of these TOU is formalized by a validation button activated by the User using the Application for the first time. This constitutes proof that the User has read and understood these terms and conditions and is deemed to have accepted them.

The User may not transfer any of the rights granted to him/her by these TOU to another person.

4.2 Modification

The TOU may be modified or amended unilaterally and at any time by A3BC Group to reflect changes made to the Application. In the event of modification of the TOU, A3BC Group will inform its Users in advance. Any modification will come into force as from the date of its publication, mentioned at the end of these TOU.

The User has the option of refusing modifications to the TOU. As a consequence of such refusal, the User’s account will be suspended/terminated, and the User will no longer be able to use the services of the Application.

5. Hardware compatibility

Before using the Application, the User is invited to check the compatibility of his hardware with the Application. To date, TrustMe is compatible with Android 11.0 and iOS 15.0, as well as any subsequent versions.

6. Accessing the Application

6.1 General access

Access to the Mobile Application is free of charge for any User with access to the Internet or a mobile network. All costs associated with access, whether hardware, software or Internet access, are the sole responsibility of the User. The User is solely responsible for the proper functioning of his/her mobile equipment and Internet access.

The service is available 24/7.

6.2 Availability of the Application

However, A3BC Group reserves the right, without prior notice or compensation, to temporarily or permanently close access to all or part of the Application or access to one or more of its services, in particular to carry out updates, maintenance operations, modifications or changes to operating methods, servers and access times, without this list being limitative.

A3BC Group is not liable for damages of any kind that may result from these changes and/or from the temporary unavailability or permanent closure of all or part of the Application or of one or more of its services.

A3BC Group reserves the right to improve or modify the Application at any time in line with technological developments.

In the event of interruption or impossibility of using the Application, the User may contact A3BC Group’s support service to obtain information by using the contact form in the Application or by e-mail at the following address: support@a3bc.org. All communications between the User and A3BC Group’s support service must be in French or English.

6.3 Eligibility requirements

In order to create an account in the Application, the User must be over 18 years old with a cell phone compatible with the requirements described in Section 5, an internet connection, and a cell phone number bearing one of the following dialing codes: Andorra (+376), Belgium (+32), Finland (+358), France (+33), Germany (+49), Italy (+39), Libya (+218), Luxembourg (+352), Morocco (+212), Scotland (+44), Spain (+34), Mauritania (+222), Wales (+44), Portugal (+351), Romania (+40), United Kingdom (+44), Western Sahara (+212), Switzerland (+41), Sweden (+46), Ukraine (+380).

7. Application description

7.1 Application

TrustMe is a digital identity wallet that allows the User to securely store and verify their credentials and share them with third parties with their explicit consent.

TrustMe contributes to the dematerialization of online and face-to-face public and private procedures, while preventing identity theft and document fraud.

TrustMe is in the process of obtaining substantial-level eIDAS certification from the Agence Nationale de la Sécurité des Systèmes d’Information (ANSSI) for its electronic identification system.

7.2 License to use

A3BC Group or its assignees grants the User a simple right to use the Application, updates and developments. The user license is intended for personal use and for use in accordance with these TOU. The user licence granted by A3BC Group to the User is revocable, non-exclusive, non-transferable and worldwide. Consequently, the User acknowledges that the Application, updates and evolutions are not sold and that the User has no ownership rights.

The Application consists of a set of texts, interfaces, photographs, graphics, images, means of navigation, logos, drawings and models, computer codes, software, fonts or any other element marked by intellectual property rights which A3BC Group or its assigns hold, or which have been licensed to A3BC Group or its assigns for incorporation into the Application directly and/or indirectly.

7.3 Use of the account by the User

Access to and use of the User’s account are strictly personal and are exclusively reserved for the User who holds the account. Under no circumstances may the account be shared with other persons.

All use of the account is deemed, until proof to the contrary, to have been made by the User, who assumes all consequences, particularly legal and financial.

The account is used under the sole responsibility of the User.

When the User enters information about him or herself or uploads a document or proof of identity, he or she undertakes to ensure that these elements are complete, accurate, up-to-date and expressly concern him or her.

8. Using the Application

8.1 Creation of an account by the User

The creation of an account in the Application by the User consists of the following steps:

• step 1 : The User reads, scrolls to the end of the TOU and accepts them by clicking on the provided button;
• step 2 : the User is asked to enter a cell phone number and then confirm it with a validation code received by SMS ;
• step 3 : the User is asked to enter an e-mail address and then confirm it with a validation code received by e-mail ;
• step 4 : The User is invited to choose a password that meets security requirements imposed by A3BC Group. Once the account created, if the User gives his/her consent, he may later add a biometric fingerprint authentication method, in accordance with the rules laid down by A3BC Group.

The User undertakes to provide only complete, accurate and up-to-date information about him or herself.

8.2 Use of authentication means

The Application is intended for strictly personal use and its use is the sole responsibility of the User.

Access to the account is subject to entering the login and a means of authentication. The identifier is the cell phone number used to create the account. The means of authentication is the one defined by the User, as described in section 8.1.

The user can change his login within the application. This requires modification of the telephone number credential as described in section 8.3.1.

The User must logout at the end of each session.

8.2.1 Password

When the User has chosen a password authentication method, the passowrd is strictly personal and :

• must comply with the requirements imposed by A3BC Group;
• must not, under any circumstances, be communicated to a third party by the User.

It is expressly reminded that A3BC Group will never, for any reason whatsoever, ask the User to communicate his/her password and any such request will be considered as a fraudulent request.

The User is entirely responsible for the safekeeping and use of his password. He/She must take all necessary measures to prevent unauthorized or fraudulent use of his/her account. To this end, the User is advised to :

• change their password regularly;
• not to set a password that has already been used for a service other than the one provided by A3BC Group.

8.2.2 Digital fingerprints

When the User add a fingerprint authentication method, biometric acquisition is performed through the cell phone’s camera to capture the four fingerprints of one of the User’s hands. Fingerprint acquisition is subject to the User’s consent to the processing of his/her biometric data.

Consent is validated by a button activated by the User who wishes to create a means of authentication based on fingerprints. This consent constitutes proof that the User is aware of the aforementioned provisions and agrees to the processing of his/her biometric data.

8.2.3 Managing authentication methods

The User may change his or her password at any time within the Application. However, the password cannot be deleted.

The User may delete his biometric authentication method at any time, as long as a password has been set.

If the User forgets his/her password or fails to authenticate several times, he/she can create a new password by following this link: https://app.trustmeid.io/recover?lang=en.

8.3Credential creation

The User can create several credentials:

• Cell phone number credential ;
• E-mail address credential;
• identity credential ;
• postal address credential;
• bank account credential;
• social security number credential;
• ID photo credential.

8.3.1 Cell phone number credential

The cell phone number credential is created automatically when the account is created within the Application by confirmation via a validation code that the User has received by SMS when creating his TrustMe account. Only one cell phone number credential is allowed. The User may delete and recreate a new cell phone number credential.

8.3.2 E-mail address credential

To create an e-mail address credential, the User is asked to enter an e-mail address and then to confirm it by means of a validation code sent to the e-mail corresponding to the e-mail address previously entered. Only one e-mail address credential is permitted. The User may delete and recreate a new e-mail address credential.

The e-mail address credential is used by A3BC Group to contact the User. A3BC Group does not use the e-mail credentials for advertising purposes.

8.3.3 Identity credential

The creation of the identity credential involves the following steps:

• step 1: The User enters the country of issue of his or her ID document, as well as the type of ID document and its expiry date. If the identity document has expired, the User will not be able to continue with the creation of his/her identity credential;
• step 2: The User enters his/her gender, first names, surname, given name and date of birth;
• step 3: the User confirms if he/she has a definitive French social security number. If the User does not have a definitive French social security number, the created identity credential will not allow him/her to connect with FranceConnect via his/her TrustMe account.

There are two types of identity credentials:

• identity credential compatible with FranceConnect: Validation of this identity credential is subject to the confirmation by the User of the possession of a definitive French social security number, remote verification of identity document and manual validation by the User of his/her place of birth. Accepted identity documents are passports, national identity cards or residence permits issued by a member state of the European Union, a member state of the European Economic Area or Switzerland, or a passport issued by a third country exempt from the short-stay visa requirement for entry into the territory of the European Union, a member state of the European Economic Area or Switzerland. The identity document must be valid;
• universal identity credential: This identity credential only requires remote verification of the User’s identity document. This identity credential does not allow the User to connect to FranceConnect via his/her TrustMe account.

Remote ID verification is carried out by a remote ID verification service provider, as defined by ANSSI certification. This requires video capture of the ID and facial recognition using the cell phone’s camera. The captured videos are then processed automatically, and a human operator verifies the information provided by the User. In addition, the User must accept the general conditions of use of our remote identity verification service provider UBBLE by Checkout.com (https://www.checkout.com/products/identity-verification)

Only one identity credential is allowed. If the User deletes his/her validated credential, he/she will not be able to create a new one. The User must contact A3BC Group support service to create a new credential by e-mail at support@a3bc.org. If the User notices the existence of erroneous information or wishes to modify attributes in his/her identity credential, he/she must immediately delete his/her identity credential and informs A3BC Group in order to create a new one.

8.3.4 Postal address credential

To create postal address credential, the User is invited to upload or take a photo of a document showing his/her postal address less than 3 months old. The accepted documents are those provided by energy and water suppliers and telephone operators, rent receipts, income tax notice, property tax, housing tax, housing certificate, housing insurance certificate. The User’s first and last name must appear on the document.

The document is processed automatically and manually to check its authenticity and extract the User’s postal address.

Only one proof of postal address is allowed. If the User notices any erroneous information in his or her proof of address, he or she must immediately delete it and create a new one.

8.3.5 Bank account credential

To create a bank account receipt, the User is invited to upload or take a photo of a French Relevé d’Identité Bancaire (RIB). The User’s first and last name must appear on the RIB.

The RIB is automatically and manually processed to check its authenticity and extract the User’s bank details.

Only one bank account credential is authorized. If the User notices any erroneous information in his/her bank account statement, he/she must immediately delete it and create a new one.

8.3.6 Social security number credential

To create a social security number credential, the User is invited to upload or take a photo of his/her carte vitale or his/her social security certificate. The User’s first and last name must appear on the submitted file.

Automatic and manual processing is performed on the submitted file to verify its authenticity and extract the User’s social security number.

Only one social security number credential is allowed. If the User notices any erroneous information in his/her social security number voucher, he/she must immediately delete it and create a new one.

8.3.7 ID photo credential

To create an ID photo credential, the User is invited to take a selfie of his/her face.

Automatic and manual processing is performed on the photo to check that it matches the User’s face.

Automatic processing consists of a biometric comparison between the facial photo supplied by the User and the facial photo on his/her ID document. The facial templates created for the biometric comparison are not stored.

Only one photo ID is authorized. The User has the option, at any time, of deleting his or her photo ID and creating a new one.

8.4 Using the document safebox

The User has a document safebox, accessible from the Application, where he/she can deposit documents.

No processing is carried out on the documents, and A3BC Group is in no way responsible for the documents deposited and their contents, apart from their availability, integrity and security.

The User may add and delete documents at will. The document safebox also contains the documents used to create credentials described in section 8.3.

8.5 Use of the Application with Partners

The User can share his information with a Partner via his account in the Application. To do so, the User is invited to :

• log in to his/her account in the Application ;
• scan the QR Code displayed on the Partner’s site, or enter his/her User ID;
• give his/her explicit consent in the Application to share their information.

The conditions applicable to access to the service provided by the Partner and to the processing of information shared by the User via its Application are those set by the Partner. A3BC Group is not involved in any relationship, contractual or otherwise, between the User and the Partner and does not intervene in any way in the said relationship between the User and the Partner.

The User remains solely responsible for his relationship with the Partner, including any damaging acts he may commit against the Partner.

8.6 Use of the Application between Users

The User can use two functions available in the Application to share his or her information with another User:

• Peer-to-peer Trust: This function enables two Users with validated identity credentials to exchange securely their first and last names directly in the Application. This exchange can only take place with the explicit consent of both Users;
• TrustId-On-Site: This function enables a User, who does not necessarily have an identity credential, to verify the identity of another User face-to-face. This verification can only be carried out with the explicit consent of the User, who will provide his or her first and last name.

9. Intellectual property

9.1 A3BC Group’s elements

Nothing in these terms of use is intended to transfer any intellectual property rights whatsoever in the elements owned by A3BC Group.

The Application, trademarks, designs, models, images, texts, photos, logos, graphic charters, software and programs, databases, sounds, videos, domain names, design or any other element composing the Application, with the exception of third party elements such as defined below, are the exclusive property of A3BC Group and are protected by any intellectual or industrial property right recognized by the laws in force.

Any total or partial reproduction and/or representation of any of these rights without A3BC Group’s express authorization is forbidden and will constitute an infringement.

Accordingly, you agree that you must not act or conduct in any manner that may directly or indirectly infringe the intellectual property rights of A3BC Group.

9.2 Third party elements

Elements belonging to third parties, including, but not limited to, trademarks, logos, images, texts, and sounds, are the exclusive property of their author and are protected as such by copyright, trademark or any other rights recognized by applicable laws.

You must not directly or indirectly infringe the property rights of third parties, whose elements are on the application and must not use these elements in any way whatsoever.

You must respect all the rights of third parties, whose content is on the Application.

10. A3BC Group’s liability

A3BC Group declines all responsibility for the use made of the Application by the User.

A3BC Group may be held liable for any direct and foreseeable damage caused by the proper use of the Application. Liability for indirect damage shall be excluded. Indirect damage includes, but are not limited to, loss of data, loss of time, lost profits, loss of turnover, loss of margins, loss of orders, loss of customers, operating loss, loss of revenues, loss of business actions, as well as harm to brand image, loss of expected results, damage suffered by Users and third party action, even if A3BC Group has been advised of the possibility of such damage.

A3BC Group shall not be liable for:

• the quality of the service, as the service is offered “as is”;
• any disruption to the use of the Application;
• any impossibility of using the Application;
• any disruption to the use of the Application due to maintenance operations, incidents or problems related to its ability to support the systems required to use the service, as A3BC Group’s obligation is a best effort obligation to perform its services within the meaning of French law;
• any computer security breaches, which may cause damage to Users’ hardware;
• any impossibility of accessing the Application arising out of or in connection with the destruction of hardware, computer attacks or hacking, the temporary or permanent restriction, removal of or ban on access to the internet network for any reason whatsoever, including breakdowns or unavailability inherent in the hosting servers;
• the impossibility for the User to access their account, due to the deletion or suspension of their account by the company, for any reason whatsoever;
• any malfunction, access unavailability, misuse, improper configuration of the User’s mobile phone, or use of by the User of a browser or operating system that is not widely used;
• the consequences of any access not authorized by the User to documents on the mobile phone, for example following the theft or loss of the said phone;
• the infringement of User rights in general.

11. User liability

The User undertakes to use the Application only under the conditions defined herein and furthermore :

• not to use the Application for personal advertising or product sales purposes;
• not to commit any act of counterfeiting, not to reproduce, download, represent or modify all or part of the Application;
• not to hinder or alter the operation of the Application;
• not to interfere with the proper functioning of the Application, and in particular not to introduce viruses or any other technology harmful to the Application or the services offered therein;
• not to communicate his or her means of authentication to a third party;
• not to access the A3BC Group Application by any means other than downloading the Application distributed by A3BC Group from the legal platforms;
• to inform A3BC Group, without delay, of any error, irregularity or suspicious behavior that he/she observes in the use of the Application, as soon as he/she becomes aware of it.

The User is entirely responsible for his/her use of the Application and associated services. He/she undertakes to use the Application in a fair manner, in compliance with these general terms and conditions of use, and with applicable laws and regulations, in particular those relating to intellectual and industrial property.

In this respect, A3BC Group reserves the right:

• to keep, for purposes of proof, all logs, connection traces and data of a personal nature or otherwise proving the imputability to the User of the behavior or actions in question, in accordance with the TOU;
• to suspend the use of the Application by any User who fails to comply with these TOU, and to communicate all necessary information to the competent services responsible for the repression of infringements;
• take legal action in the event of fraud.

12. Personal data

In accordance with the regulations concerning the protection of personal data, you are informed that A3BC Group processes personal data as a controller.

To learn more about processing of personal data and the extent of your rights, please read the Privacy Policy.

As part of the management of Users’ personal data, A3BC Group records the User’s actions performed exclusively in the Application for the purposes of maintenance and incident management of the Application, such as the handling and correction of Errors.

Regarding the collection of the fingerprint template of four fingers of the User’s hands, as this data is considered as biometric data within the meaning of Article 4(14) of the General Data Protection Regulation (“GDPR”), a specific consent is required from the User when collecting and using this data for authentication purposes.

To learn more about this data processing and how to withdraw consent at any time, please read the Privacy Policy.

13. Data storage period

The data storage period is detailed in the personal Privacy Policy

14. Security

A3BC Group makes its best efforts, in accordance with the rules of the art, to secure the service considering the complexity of the Internet. However, it cannot guarantee absolute security.

The User acknowledges that he/she is aware of the nature of the Internet network, and in particular its technical performance and response times for consulting, querying or transferring information data.

The User must inform A3BC Group of any service failure either via the contact form in the Application, if still accessible, or via A3BC Group’s customer service: contact.trustme@a3bc.io

The User is aware that data circulating on the Internet is not necessarily protected, in particular against possible misappropriation.

The User declares that he/she accepts the characteristics and limits of the Internet and agrees to take all appropriate measures to protect his/her own content, data and/or software from contamination by any viruses on the Internet network.

15. Miscellaneous

15.1 Good faith

The Parties agree to perform their obligations in good faith.

15.2 Waiver

The Parties mutually agree that the fact that one of the Parties tolerates a situation does not have the effect of granting acquired rights to the other Party. Furthermore, such tolerance shall not be interpreted as a waiver of the the rights in question.

15.3 Headings

In the event of difficulties of interpretation resulting from a contradiction between any of the headings appearing at the top of the clauses and any of the clauses, the headings will be declared non-existent.

15.4 Severability

If one or several provisions of these terms of use were to be held invalid or so declared by a law, a regulation or a final decision having res judicata effect delivered by a court having proper jurisdiction, the other provisions shall remain in full force and effect.

15.5 Entire agreement

These terms of use constitute the entire agreement between the Parties.

15.6 Notices

All notices or communications between you and A3BC Group may be made by any electronic means. As a result, you acknowledge that you are fully aware that A3BC Group may communicate to you information by any electronic and paperless means that may be directly or indirectly linked to your account.

The terms of use are archived on a reliable and durable medium that may be used as evidence.

15.7 Force majeure

A3BC Group shall not be liable for any breach of these TOU in the event of Force Majeure.

Cases of force majeure or fortuitous events are expressly considered to be those defined by the provisions of article 1218 of the French Civil Code and generally accepted by the jurisprudence of French courts and tribunals.

15.8 Language

The terms of use are written in French language.

15.9 Subcontracting

A3BC Group reserves the right to call upon subcontractors of its choice for the execution of all or part of the services described in these TOU. A3BC Group remains solely responsible to the User.

15.10 Costs

All equipment, connection, communication and other costs required to access and use the Application are at the User’s expense.

15.11 Evidence agreement

A3BC Group and the User agree that in the event of a dispute, the following evidence shall be admissible in court:

• Means of authentication (telephone number, password, biometrics, e-mail address, etc.) used in the Application;
• Event logs, personal and non-personal data, and connection data to the Application;
• The User’s activity history relating to the sharing of information with Partners.

15.12 Mediation

The User is hereby informed of the possibility of resorting to a conventional mediation procedure or any other alternative dispute resolution method in the event of a dispute relating to the present terms of use.

To this end, the User is hereby informed that, after first attempting to resolve the dispute amicably and directly with A3BC Group, he/she may refer the matter to the Consumer Mediator via the form available on the CMAP website at www.cmap.fr/consommateurs, or by post to CMAP - Service Médiation de la consommation, 39 avenue Franklin D. Roosevelt, 75008 Paris.

For further information on the mediation process, the User is invited to consult the consumer ombudsman’s website: www.cmap.fr.

The User is hereby informed that disputes may not be submitted to the mediator if the claim is manifestly unfounded or abusive, or has been previously examined or is in the process of being examined by another mediator or by a court.

The same applies if the User has submitted his request to the mediator more than one year after his written complaint to A3BC Group, or if the dispute does not fall within the mediator’s field of competence, or if the consumer does not justify having previously attempted to resolve his dispute directly with A3BC Group by means of a written complaint.

16. Governing law

Unless otherwise provided by mandatory law, these terms of use shall be governed by the laws of France.

French law shall apply to both form and substance, notwithstanding the place of performance of the essential or ancillary obligations.

UNLESS OTHERWISE PROVIDED BY MANDATORY LAW, ANY DISPUTE NOT RESOLVED BY AN AMICABLE PROCEDURE ARISING BETWEEN THE USER AND A3BC GROUP SHALL BE SUBJECT TO THE COMPETENT COURTS WITHIN THE JURISDICTION OF THE COURT OF APPEAL OF PARIS (FRANCE).

A3BC Group’s Terms of Use, updated version: 14 01 2025.