Privacy Policy - North America

Privacy Policy

We at moovel Group GmbH, Hauptstätter Straße 149, 70178 Stuttgart, Germany ("moovel" or "we" or "us") take the protection of your personal data seriously. Data security and the protection of your privacy are very important to us when processing personal data with regard to the moovel app und the services obtained therefrom (together "moovel service") and we consider both in our business processes. We will process your personal data exclusively on the basis of the applicable data protection laws, in particular the German Federal Data Protection Act (Bundesdatenschutzgesetz; "BDSG").

Collection, processing and use of personal data to perform the contract

moovel will collect, process and use your personal data provided by you as well as the data obtained by using the moovel services as a data controller to the extent this is necessary to establish, structure or change the contractual relationship between you and moovel and to initiate, enter into, and perform a mobility contract between you and the respective mobility service provider with whom you enter into a contractual relationship via moovel and to discover, identify and remove any disruptions in the operations.

To the extent that moovel is involved into the communication for a mobility contract between you and the respective mobility service provider, moovel will transfer the data required for such mobility contract to the respective mobility service provider, which shall use the data on its own responsibility for the purpose of initiating, entering into, and performing the contract. This shall also include the settlement of any further claims (e.g., settlement of any damage incurred or processing of parking tickets if a car sharing offer is used). The identity of the respective mobility service provider is disclosed during the booking process. The data processing by the mobility service provider is subject to the privacy policy of such a mobility service provider.

If you enter additional personal data, such as photos or data relating to your social network profiles, into your moovel account on a voluntary basis, you do so to individualize your moovel account and for the purposes of communication with moovel or the mobility service provider. moovel will process such voluntarily provided personal data only for these purposes. You will be free to delete such data.

Furthermore, moovel will use the e-mail address or postal address specified by you to inform you in accordance with the applicable laws about any changes to products or services and to provide you with any other information as required by law.

1.1.) Use of personal data to settle payments

1.1.1) Payment via PayPal

If you use the available payment method via PayPal (credit card via PayPal, direct debit via PayPal or "purchase on account" via PayPal), the data necessary to settle the payment will be transferred to PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal"). Please note that PayPal reserves the right to obtain a credit report. Paypal will use the result of the credit check with regard to the probability of default to decide whether to offer the respective payment method or not. The credit report may include score values which have been determined in a scientifically acknowledged mathematical-statistical process, also taking into account address data. For details on the credit check by PayPal – in particular on the credit agencies used – please refer to PayPal's privacy policy: https://www.paypal.com/us/webapps/mpp/ua/privacy-full

1.2.1) Payment via credit card

Credit card payments will be settled by our service provider Braintree, a division of PayPal Inc., 22-24 Boulevard Royal, L-2449, Luxembourg. The data will also be processed in the United States. The Privacy Policy of Braintree can be found here: https://www.braintreepayments.com/legal

1.2.) Invoicing

For the time being, moovel shall send its own invoices and invoices issued by moovel on behalf of the individual mobility service providers exclusively by email. Please note that a communication by email can have security gaps. If you do not agree to the sending of invoices by email, please contact our customer service at hello@moovel.com.

1.3.) Online validation of the driving license

If you participate in the offered "online" validation of your driving license, the photos of your driving license taken by you and the portrait made by you will be collected, processed and used for checking your driving license. The data necessary to check the driving license will be extracted automatically, a face match will be performed and the photos and portraits received will be saved as permanent evidence of moovel's checking the driving license. In case that an automated processing is not possible (e.g., because of poor picture quality), the pictures will be reworked manually by our service provider Jumio India Pvt. in India. A participation in the online validation is only possible if you have given your respective express consent.

If a face match is not possible despite manually reworking the photos, we offer you to call in at one of our validation points or to make an appointment for contacting us via Skype or Facetime. Please note that moovel is not responsible for any data collection and/or use by Skype or Facetime; Skype is a service by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA, and Facetime is a service by Apple Inc., 1 Infinite Loop, Cupertino, California, USA, 95014. A statement on the data usage by Skype is available at http://privacy.microsoft.com/en-us/privacystatement/. A statement on the data usage by Facetime is available at http://www.apple.com/privacy/privacy-policy/.

2. Other use of personal data

Personal data shall only be used for purposes other than the performance of the contract to the extent that moovel is authorized by law to do so or if you have given your express consent to such use.

2.1.) Disclosure of personal data to public authorities

moovel is entitled to disclose your personal data to regulatory authorities and law enforcement authorities to the extent this is permitted by law.

2.2.) Fraud prevention

moovel will transmit the login details provided by you (name, first name, street, house number, postal code, city and date of birth) to credit agencies. This is for the purpose of verifying that you are registered and/or available at the address specified by you. Your login details may be transferred when you enter them for the first time and whenever you change your name or address. moovel also reserves the right to re-verify your address if there is reasonable suspicion that the data relating to your person might not be correct. For the purpose of verifying your address, moovel will refer to data from the following address service providers:

• Schufa Holding AG (Kormoranweg 5, 65201 Wiesbaden, Germany)
• Bürgel Wirtschaftsinformationen GmbH & Co. KG (Gasstraße 18, 22761 Hamburg, Germany)
• Creditreform Boniversum GmbH (Hellersbergstraße 11, 41460 Neuss, Germany)
• Verband der Vereine Creditreform e.V. (Hellersbergstraße 12, 41460 Neuss, Germany)
• Deltavista GmbH (Dessauerstraße 9, 80992 München, Germany)
• Dun & Bradstreet Inc. (103 JFK Parkway, Short Hills, NJ 07078, USA)
• Hoppenstedt, Bisnode Deutschland GmbH, (Robert-Bosch-Straße 11, 64293 Darmstadt, Germany)
• Infoscore (arvato Financial Solutions, Bertelsmann SE & Co. KGaA, Carl-Bertelsmann-Straße 270, 33311 Gütersloh, Germany)
• Deutsche Post AG (Charles-de-Gaulle-Straße 20, 53113 Bonn, Germany)

If your address cannot be verified, moovel reserves the right to refrain from offering you any services that can only be booked if a valid address is available (e.g. carsharing services). If you have any questions in this respect, please contact our customer service at hello@moovel.com.

Furthermore, in order to protect you and us against cyber crimes, moovel will perform risk assessments whenever a non-gratuitous service is booked. The purpose of such risk assessments is to find out whether a transaction has, in fact, been authorized by the respective authorized person. For this purpose, data such as IP addresses for geolocalization (this prevents unauthorized use of your data from abroad) or the device IDs of your terminals are used in order to prevent abuse as far as possible. For this purpose, we refer to services by our service provider Kount Inc., 917 Lusk Street, Suite 300, Boise ID 83706, USA, which will be provided with the data required to perform the risk assessment. moovel reserves the right to reject transactions on the basis of the result of the risk assessment. If you have any questions, please contact our customer service at hello@moovel.com.

2.3.) Data usage to improve our customer service

moovel will also use your data to improve the customer service. For example, we retain any requests you raise with our customer service (e.g. by telephone, email, mail or via social media channels) and the related answers together with your other profile data. This enables moovel to better react to inquiries or proposals for change and, e.g., inform you, also by email, as soon as a function requested by you is available.

Furthermore, we also use the telephone number and email address you registered with moovel to identify you whenever you contact our customer service. This enables us to process your request more speedily.

2.4.) Use of data for advertising and market research purposes

We will only use your data for advertising or market research purposes to the extent this is permitted by law or if you have given your consent. You may revoke any consent given at any time in accordance with Section 7 of this Privacy Policy.

3. Use of external service providers

moovel will use the services of third parties (e.g. data centers) in connection with the use of data as specified in this Privacy Policy. These service providers are bound by data processing agreements with moovel pursuant to section 11 BDSG and will process personal data only and exclusively pursuant to the instructions and under the control of moovel as described herein. The non-European service providers named in the following table are to be pointed out specifically because it cannot be excluded that they will process data outside the European Economic Area. We guarantee an adequate level of data protection with all of our non-European service providers since there are data processing agreements in place in each case and they have agreed on the application of the EU standard contractual clauses for the transfer of personal data to data processors in non-EU countries.

Service providers

Amazon Webservices, Amazon.com, Inc., P.O. Box 81226 Seattle, WA 98108-1226 USA
Hosting and operation of our central IT system

Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Provision of the "Apps for Work" products (in particular email services)

Kount Inc., 917 Lusk Street, Suite 300 Boise ID 83706, USA
Protection against cyber crimes

Microsoft Dynamics, Microsoft Corporation, One Microsoft Way Redmond, WA 98052-6399, USA
Operation of our CRM system

Jumio India Private Ltd., 308-311, Geetanjali tower, Near civil line metro station, Ajmer road, Jaipur - 302006
Manual verification of driving licenses if automated verification failed

Sendgrid Inc., 1401 Walnut St #500 Boulder, CO 80302
Support in sending customer emails

4. Social login

We offer you the possibility to register with us by using your existing profile with a social network of selected providers.

4.1.) Registration via Facebook

If you want to register with moovel via Facebook, you have to consent to the subsequent data exchange between moovel and Facebook. If you give this consent, you will initially be redirected to Facebook. Facebook will then request you to log in with your user name and password. Of course, this data will not be transferred to us. If you are already registered with Facebook with your device, this log-in step will be skipped. Facebook will now inform you which data will be transferred to us and will ask you to confirm this. Facebook will transfer the data available in your public profile to us, but we will only use your first name and surname and your Facebook ID. Besides, Facebook will also transfer your date of birth and your address data to us. This data will initially be used by us to set up your moovel ID and, subsequently, as described in this Privacy Policy. We need your Facebook ID in order to be able to identify you if you submit a request via Facebook. There will be no further, in particular no permanent, connection between your moovel and Facebook accounts.

During the login process, Facebook will, of course, receive the information that you are registering with moovel. However, we will not transfer any further data to Facebook. For the purpose and type of the subsequent data processing by Facebook, please refer to Facebook's privacy policy. In the Facebook privacy policy, you can also obtain information about your existing rights and possible settings to protect your privacy. The privacy policy of Facebook is available at: https://www.facebook.com/privacy/explanation.

4.2.) Registration via Google

If you want to register with moovel via Google, you have to consent to the subsequent data exchange between moovel and Google. If you give this consent, you will initially be redirected to Google. Google will then request you to log in with your user name and password. Of course, this data will not be transferred to us. If you are already registered with Google with your device, this log-in step will be skipped. Google will now inform you which data will be transferred to us and will ask you to confirm this. The following data will be transferred to us: First name and surname, your verified email address, your address data, and Google profile id tokens. We need your Google profile id tokens to identify you.

This data will initially be used by us to set up your moovel account and, subsequently, as described in this Privacy Policy. There will be no further, in particular no permanent, connection between your moovel and Google accounts.

During the login process, Google will, of course, receive the information that you are registering with moovel. However, we will not transfer any further data to Google. For the purpose and type of the subsequent data processing by Google, please refer to Google's privacy policy. In the Google privacy policy, you can also obtain information about your existing rights and setting possibilities to protect your privacy. The privacy policy of Google is available at: https://www.google.com/intl/en-US/policies/privacy/.

4.3.) Registration via Twitter

If you want to register with moovel via Twitter, you have to consent to the subsequent data exchange between moovel and Twitter. If you give this consent, you will initially be redirected to Twitter. Twitter will then request you to log in with your user name and password. Of course, such data will not be transferred to us. If you are already registered with Twitter with your device, this log-in step will be skipped. Twitter will now inform you which data will be transferred to us and will ask you to confirm this. The only data transferred to us is your verified email address.

This data will initially be used by us to set up your moovel account and, subsequently, as described in this Privacy Policy. There will be no further, in particular no permanent, connection between your moovel and Twitter accounts.

During the login process, Twitter will, of course, receive the information that you are registering with moovel. However, we will not transfer any further data to Twitter. For the purpose and type of the subsequent data processing by Twitter, please refer to Twitter's privacy policy. In the Twitter privacy policy, you can also obtain information about your existing rights and possible settings to protect your privacy. The privacy policy of Twitter is available at: https://twitter.com/privacy?lang=en.

5. Other disclosure of data to third parties

Upon booking some of the mobility services, we will ask you whether you agree that we will transfer certain personal data to the respective mobility service provider, e.g., for setting up a user account or for sending you special offers. In such cases, we will only transfer your data if you have given your express consent during the booking process.

6. Use of anonymized data for the purposes ofstatistical analyses and improvements of products and services

moovel will also use your master and usage data (such as your age or the frequency of using our services) for the purposes and preparing statistical analyses and improving products and services. For such purposes, your data will be anonymized and will only be processed in anonymized form.

7. Revocation of consents, right to object, provision of information

Consents given may be revoked any time with effect for the future. Should you wish to revoke any consent given, please notify us accordingly by mail to moovel Group GmbH, Datenschutz, Hauptstätterstr. 149, 70178 Stuttgart, or by email to hello@moovel.com. You may object to the use of your personal data for advertising purposes and market and opinion research by notice to the above mentioned addresses at any time with effect for the future. You will not incur any costs in connection with the revocation or objection, except for the costs of transmission at the base rate. After your objection or revocation, we will no longer be able to inform you of any innovations, promotions or special discounts.

Registered users may access certain information online and delete or change such information themselves, if desired. If, despite our efforts to ensure that the data is accurate and up to date, we have stored any incorrect information, we will correct such information immediately upon your request.

8. Data security

moovel has technical and organizational security measures in place to protect your data managed by us against manipulation, loss, destruction and unauthorized access. Our security measures are continuously improved in accordance with the technological development.

9. Amendments
moovel reserves the right to change the present Privacy Policy from time to time. Any updates will be published at www.moovel.com/en/DE/privacy-policy. Please check before any booking process whether there is an update available.

Effective as of: April 4, 2016

moovel Group GmbH
Hauptstätter Straße 149, 70178 Stuttgart, Germany
Registry court: Local Court (Amtsgericht) of Stuttgart HRB-Nr. 753820 , VAT ID: DE 301445428
Managing directors (Geschäftsführer): Jörg Lamparter, Dr. Sebastian Dehnen

Data protection
moovel appreciates your interest in its products and your visit to this website. Your privacy is important to us and we want you to feel comfortable visiting our site. The protection of your privacy in the processing of your personal data is an important concern to which we pay special attention during our business processes. Personal data collected during visits to our websites are processed by us according to the legal provisions valid for the countries in which the websites are maintained. Our data protection policy is also based on the data protection policy applicable to Daimler Group.

Daimler Data Protection Policy

moovel websites may include links to other websites which are not covered by this privacy statement.

Collection and processing of personal data
When you visit our website, our web servers store as standard details of your browser and operating system, the website from which you visit our website, the pages that you visit on our website, the date of your visit, and, for security reasons, e.g. to identify attacks on our website, the IP address assigned to you by your internet service provider; this IP address is stored for seven days. With the exception of the IP address, personal data is only stored if you choose to submit it to us, e.g. during registration, in a survey, in a competition or in order to enable performance of an agreement.

Use and passing on of personal data and limitation of use to specific circumstances
moovel uses your personal data only to the extent necessary for the purpose of technical administration of the website, for customer management, for product surveys, and for marketing.
Personal data is transferred to state organizations and authorities only within the scope of mandatory national provisions of law. We have placed our employees, agencies and dealers under a duty of confidentiality.

Choice
We would like to use your data to inform you about our products and services and, if applicable, to ask you about them. Of course, participation in such activities is voluntary. If you do not wish to take part, you can notify us at any time so that we can exclude your data accordingly. You can find further information on the relevant page of the website.

Newsletters
Our website can be used to subscribe to newsletters. The data provided during the newsletter registration will be used only for the purposes of sending out the newsletter, provided you have not consented to other use. You can cancel the subscription at any time by using the unsubscribe option provided in the newsletter.

Social plugins
moovel uses so-called social plugins ('buttons') of social networks such as Facebook, Google+ and Twitter.
When you visit our websites these buttons are deactivated by default, i.e. without your intervention they will not send any data to the respective social networks. Before you are able to use these buttons, you must activate them by clicking on them. They then remain active until you deactivate them again or delete your cookies (please refer to 'Cookies').
After their activation, a direct link to the server of the respective social network is established. The contents of the button are then transmitted from the social network directly to your browser and incorporated in the website by it.
After activation of a button, the social network can retrieve data, independently of whether you interact with the button or not. If you are logged on to a social network, the network can assign your visit to the website to your user account. A social network cannot assign a visit to other moovel websites unless and until you activate the respective button there as well.
If you are a member of a social network and do not wish it to combine data retrieved from your visit to our websites with your membership data, you must log out from the social network concerned before activating the buttons.
We have no influence on the scope of data that is collected by the social networks through their buttons. The data use policies of the social networks provide information on the purpose and extent of the data that they collect, how this data is processed and used, the rights available to you and the settings that you can use to protect your privacy.

Cookies
Information on the cookies that we use and their features can be found in 'Cookies'.

Analysis of usage data
We use Adobe Omniture to track the preferences of visitors and to identify especially popular sections of our websites. In this way, we can adapt the content of our website more specifically to your needs and thereby improve what we offer you.
If you do not wish moovel to collect and analyze statistical data related to your visit you may object to the future use of your date at any time (opt-out).
For the technical implementation of your objection it is necessary to install an opt-out cookie on your browser. This cookie will only indicate that you have opted out. Please note that for technical reasons the opt-out cookie will only affect the browser you object from. If you delete the cookies in your browser or use a different end device or browser, you will need to opt out again.
Click here to install the opt-out cookie.

Security
moovel uses technical and organizational security measures to protect the data supplied by you and managed by us against manipulation, loss, destruction, and access by third parties. Our security measures are continually improved in line with technological developments.

Right to Information
On request, moovel or the representative responsible for you will inform you in writing as soon as possible and in accordance with applicable law whether and what personal data relating to you has been stored by us. If you are registered as a user, we also enable you to view the data yourself and, if applicable, to delete or amend it. If incorrect information is stored despite our efforts to ensure that data is accurate and up to date, we will correct it at your request.
If you have any questions about the processing of your personal data, you can contact our Group Data Protection Officer, who, along with his team, is available should you have any requests for information, suggestions or complaints.

Group Data Protection Officer
Dr. Joachim Riess
Daimler AG
HPC 0518
70546 Stuttgart
Germany