Privacy Policy

Thank you for your interest in MOIA. Here we would like to inform you about how we handle your personal data. Protecting your privacy is very important to us. Your personal data is only processed in accordance with data protection regulations. 

This privacy policy applies to all websites and apps provided by MOIA that refer to this policy.

Overview:

Section A: General provisions

Section B: Use of MOIA Websites

Section C: Use of MOIA App and MOIA Mobility Services

Section A – GENERAL PROVISIONS

A.1. What is personal data?

Your personal data includes any information that can be associated with you as a natural person. Such details include your name, e-mail address, mobile number, location, and payment information.

A.2. Who is responsable for processing data?

The responsible party (“Data Controller”) for the processing of your personal data in connection with the use of our websites and apps, unless otherwise stated below, is MOIA GmbH, Alexanderufer 5, 10117 Berlin, Germany, registered with the commercial register of the Berlin Charlottenburg District Court, no. HRB 189716 B (“MOIA”, “we”, “us”).

If there are links to third-party websites, the respective provider is responsible for data processing in connection with use of the linked website.

A.3. Purposes and legal basis of data processing

We process personal data for the following purposes and on the legal basis explained below.

Providing services: First and foremost, we process your data in order to provide the services you use and, where applicable, to charge for this (e.g. creating a user account, booking of MOIA Mobility Services). The legal basis for processing data in this context is the necessity for the performance of a contract with MOIA (article 6 (1)(b) GDPR) and/or legitimate interests pursued by us (article 6(1)(f) GDPR).

Legal obligations: We process personal data if and to the extent necessary to fulfill our legal obligations (e.g. retention requirements under tax law) (article 6(1)(c) GDPR).

Compliance with the MOIA Code of Conduct and enforcement of legal claims: We also process personal data if this is necessary to assert financial or other legal claims, or to investigate violations of the MOIA Code of Conduct and to be in a position to take action based on this document (e.g. instances of vandalism). The legal basis for processing data in these cases is the necessity for the performance of a contract with MOIA (article 6(1)(b) GDPR) and/or legitimate interests pursued by us (article 6(1)(f) GDPR).

System security and crime prevention: Another purpose of data processing is to ensure the security of our systems and, for instance, to prevent and detect fraud and other crimes. For this purpose, we store information such as your IP address when you register or book fee-based services. The legal basis for data processing in this context is the protection of MOIA’s legitimate interests (article 6(1) GDPR).

Improving our services: We are constantly working to enhance our services. For this purpose, we use anonymized data if possible. The legal basis for data processing here is the protection of MOIA’s legitimate interests (article 6(1) GDPR).

Marketing: We pursue the purpose of successfully marketing our services. That is why we, for example, provide optional personalized e-mail marketing to our users and measure the success of our online campaigns. The legal basis for processing personal data for marketing purposes is the user’s consent (article 6(1)(a) GDPR) and/or the legitimate interests pursued by MOIA (article 6(1)(f) GDPR).

A.4. Data transfers and transmitting data to third countries

We use various services that process data on our behalf (e.g. website hosting, email delivery, customer service). Each service provider is checked by us and guarantees an adequate level of data protection. 

In some cases, data may be transferred to countries outside the European Union or the European Economic Area. In such cases, suitable safeguards are in place to ensure an adequate level of protection of personal data for the natural persons concerned. 

We share information with affiliated companies and third parties if this is necessary to provide our services or to protect legitimate interests (e.g. if a MOIA Mobility Service is provided by a Cooperation Partner or if you book a MOIA Mobility Service through a third-party platform).

A.5. Contact and feedback

If you contact us, for instance to submit a request or to provide feedback, we will store this information to process your request or respond to the feedback. We will contact you about your request or feedback if this is necessary to clarify matters.

If you submit feedback on a MOIA Mobility Service, no personal data will be passed on to the driver.

A.6. Application at MOIA

If you would like apply for a job at MOIA, you can find information about data protection with regard to your application on our application portal.

A.7. Data deletion

We either delete or anonymize personal data as soon as it is no longer necessary to store it for the purposes of providing our services, protecting our legitimate interests, or complying with statutory retention periods. In the case of anonymization, all information that would make it possible to identify a specific natural person are rendered unrecognizable.

A.8. Rights of the data subject

You have the right to receive information about the personal data we hold about you. In addition, you are entitled to request that your data be corrected or deleted and/or transferred, to object to data processing, to withdraw any consent previously granted, and/or to complain to a data protection supervisory authority. You can either initiate the deletion of your personal data in your "Account & Privacy" settings by clicking on the "Delete account" button or by sending an email to datarequest@moia.io. In both cases, your personal data will be deleted no later than one month after receipt of your deletion request.

You may contact our data protection officer at any time to assert your rights as a data subject or to inquire about data protection. The data protection officer can be contacted by e-mail:

datarequest@moia.io 

or by mail:
 
MOIA GmbH
-Data Protection Officer-
Alexanderufer 5
10117 Berlin, Germany

A.9. Security

We keep your data secure using appropriate technical and organizational measures. Information that is transferred via our websites and apps is always encrypted.

A.10. Privacy Policy updates

We reserve the right to update this Privacy Policy from time to time. If there are any fundamental changes, we shall inform the MOIA App users about the update.

Section B – USE OF MOIA WEBSITES

B.1. Visting our website

When you visit our website, the browser you use automatically sends a range of information to our servers. This includes your operating system, browser, and screen resolution settings as well as the date and time of your visit. Transferring this data is necessary in order to display the website content properly in your browser. This information is not associated with a specific natural person.

B.2. Cookies, tracking and map content from external providers

To make our websites more user-friendly and to evaluate the interest in our products, we use cookies and similar technology that helps us to track, for example, how long users spend looking at certain content. This information is not associated with a specific natural person.

We divide cookies into the categories "necessary", "statistics" and "personalization".
Cookies in the "necessary" category are essential to enable the website visit (article 6(1)(b) GDPR).

Cookies in the "statistics" and "personalization" categories are only set with the user's consent (article 6(1)(a) GDPR). The consent can be revoked at any time with future effect by deleting the cookies in the browser. Further information on the categories of cookies and the settings can be found here:

Cookie preferences


The following cookies are used:

 

We use the following third party services for support:

B.2.1 Google Analytics

We use Google Analytics on our website. This is a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). By using Google Analytics, we are able to understand usage behavior on our website. For this purpose, user profiles may be created with a pseudonym. These user profiles are not associated with a specific natural person.

As a rule, Google will anonymize your IP address when you use our website if you are inside a member state of the European Union or the European Economic Area. In exceptional cases, the IP address may be sent to a server in the United States, where it is then made anonymous.

Google Analytics will only be activated if you have accepted cookies of the category “statistics”.

In addition to the standard functions of Google Analytics, we use the extended feature Remarketing with Google Analytics. This extended feature will only be activated if you have accepted cookies in the "Personalization" category and enables target group-oriented advertising in the Google advertising network.

You can deactivate Google Analytics by deleting the cookies in your browser or by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

Alternatively, you can click here to save a cookie that will prevent your data from being collected when you access this website in the future.

More information about Google Analytics and data usage by Google can be found here:

https://www.google.com/analytics/terms/us.html and https://policies.google.com/privacy?hl=en.

B.2.2 Google Ads Remarketing

We use Google Ads. By using Google Ads, visitors of our websites can be targeted with advertising when they visit other websites in the Google Search Network or Google Display Network. For this purpose, pseudonymous usage profiles can be created.

Google Ads will only be activated if you have accepted cookies of the category “personalization”.

You can deactivate Google Ads by adjusting your cookie settings or by downloading and installing the browser plug-in available under the following link: https://support.google.com/ads/answer/7395996?hl=en

More information about Google Ads and data usage by Google can be found here: https://policies.google.com/technologies/ads?hl=en and https://policies.google.com/privacy?hl=en.

B.2.3 Facebook Pixel and Facebook Custom Audiences

On our website we use both the Facebook Pixel and Facebook Custom Audiences retargeting (also in the Pixel mode). These services are provided by Facebook Inc., 1 Hacker Way, Menlo Park, California, USA and Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”). A pixel is placed on our website that establishes a connection to Facebook servers when you visit the website. In this way, Facebook learns that you have visited our website and may associate this information to your personal Facebook profile. We use the Facebook Pixel to determine how effective our advertising on Facebook is. We use Facebook Custom Audiences in order to display advertising to our website visitors on Facebook that reflects their interests. For more information on how Facebook collects and processes data, please visit: https://www.facebook.com/about/privacy/.

Facebook Pixel and Facebook Custom Audiences will only be activated if you have accepted cookies of the category "personalization". You can deactivate both services by deleting the cookies in your browser.

Furthermore, you can opt-out of interest-based advertising on Facebook by adjusting your settings here: https://www.facebook.com/settings/?tab=ads#_=_.

Additionally, you can store an opt-out cookie by clicking here. This prevents data from being sent to Facebook when you access this website.

B.2.4 Google Maps

On our website, we use Google Maps so that you can access interactive maps. We use this feature to present our service area on a map, for example. Location data that is sent to Google is always made anonymous.

For more information about how Google processes data, see: https://www.google.com/policies/privacy/. You can find Google’s privacy policy on this page: https://policies.google.com/terms?hl=en.

B.2.5. Pinterest Tag

We use a “Pinterest tag” on our website. This is a pixel for Pinterest Inc., 635 High Street, Palo Alto, CA, USA (“Pinterest”). When you visit our website a connection to Pinterest servers is established. Through this connection, Pinterest is informed that you have visited our website and may assign this information to your personal Pinterest profile. We use the Pinterest tag to be able to track the effectiveness of our marketing on Pinterest and to be able to present visitors to our website with personalized ads on Pinterest.

The data collected in this way is anonymous and does not give us any references to the identity of the user in question. The data is stored in accordance with statutory data retention periods and then automatically deleted. Further information can be found in Pinterest's privacy policy: https://policy.pinterest.com/en-gb/privacy-policy.

The Pinterest tag is only enabled if you have accepted “Personalization” cookies. You can deactivate the tag by deleting the cookies in your browser.

You can also block personalized ads on Pinterest by deactivating the related settings under “Personalization” at https://help.pinterest.com/en/article/personalization-and-data.

B.2.6. LinkedIn Insight Tag

This website uses the conversion tool "LinkedIn Insight Tag" provided by LinkedIn Ireland Unlimited Company. The Insight Tag creates a cookie in your web browser that allows us to collect information such as: IP address, device and browser settings, and website events (such as page views). The IP addresses are shortened or - if they are to be used for cross-device recognition - hashed. The users' unique identifiers are removed within seven days to pseudonymize the data. This remaining pseudonymized data is then deleted within 180 days.

LinkedIn does not share any personally identifiable information with MOIA, but provides aggregated anonymized reports about the website audience and ad performance. In addition, LinkedIn offers retargeting via the Insight Tag. MOIA may use this data to display targeted advertising outside of its website. For more information about LinkedIn's privacy policy, please refer to the LinkedIn Privacy Policy.

LinkedIn members can control the use of their personal information for marketing purposes in their account settings. To disable ("opt-out") the Insight tag on our website, click here.

B.3. Downloading the MOIA App from a download link

You have the option of requesting to download the MOIA App on our website. To do so, you need to enter your mobile number. We can then send the download link directly to your mobile device. Your mobile number will be deleted immediately as soon as the download link has been sent and will not be used for any other purpose.

B.4. MOIA NEWS

If you subscribe to our marketing e-mails on one of our websites, we will send you information about vouchers, offers, products, and surveys by e-mail from time to time. You may revoke your consent to this at any time. To do so, select the unsubscribe link contained in each e-mail we send out or send an e-mail to datarequest@moia.io. In order to measure success of our marketing e-mails, we automatically save information about openings and clicks as well as the type of device used to access e-mails.

Section C – USE OF MOIA APP AND MOIA MOBILITY SERVICES

C.1. Registration

When registering to use our MOIA App, you enter your login details. We use this information to set up your user account. Fields are marked as optional if the respective information is not required for registration.
If you have added a photo to your user account, you can delete it or replace it with another photo at any time. Select your profile to see the various options that are available to you.

C.2. Requesting MOIA Mobility Services and integration of map content

C.2.1. Requesting a MOIA Mobility Services within the MOIA App

When you request a MOIA Mobility Service, we use the location details in the request (starting point and destination) to present booking options and to calculate the best routes for our vehicles.

We also use this information – with no reference to individual persons – to better tailor our services in line with demand and to improve our route calculation algorithm. 

We do not use location data to create a movement profile of you.

C.2.2. Integration of map content

Location data is shared with the map provider in order to display maps in the MOIA App and to navigate you to the point where you can start using the MOIA Mobility Service.

The map content is integrated using Google Maps, a service provided Google. Location data that is sent to Google is always made anonymous. For more information about how Google processes data, see: https://www.google.com/policies/privacy/. You can find Google’s privacy policy on this page: https://policies.google.com/terms?hl=en.

C.3. Payment function

C.3.1. Payment service provider

Your payment details are transmitted to our payment service provider in order to complete the payment process. Our payment service provider is Adyen N.V., Simon Carmiggelstraat 6–50, 1011 DJ Amsterdam (“Adyen”). The transmission of your data takes place for the purpose of payment settlement with the payment service provider Adyen according to Art. 6 (1) lit. f DSGVO.

To prevent and detect instances of fraud, your IP address, e-mail address as well as a device and payment service provider specific ID can be transmitted. All data transfers are encrypted. The legal basis for this processing is our legitimate interest under Art. 6 (1) lit. f GDPR.

Detailed privacy information about Adyen can be found online at:

https://www.adyen.com/policies-and-disclaimer/privacy-policy.

For more information about data processing when using PayPal, see:

https://www.paypal.com/webapps/mpp/ua/privacy-full.

C.3.2. Real Time Account Updater

To make your payment experience as convenient as possible, we use the Mastercard Automatic Billing Updater (ABU), which keeps your credit card information up to date. This automatic update of your credit card information provides a seamless process for updating the account without any action on your part as the cardholder. In addition, the feature simplifies uninterrupted service.

You may object to your credit card provider to the processing and forwarding of updated credit card information.

The legal basis for the collection of updated credit cards is the fulfillment of the contract according to Art. 6 (1) b DSGVO.

C.4. use of MOIA Mobility Services

When you book a MOIA Mobility Service, we will associate the booking details and information about performance of the MOIA Mobility Service to your user account, showing your previous trips in the MOIA App.

In addition, your information will be shared with the provider performing the MOIA Mobility Service. Data processing by the MOIA Mobility Service provider occurs in accordance with this Privacy Policy.

The driver of the MOIA vehicle is given your first name for identification purposes. Your initials will be displayed next to your stop on the vehicle’s information screen (e.g. “JB” for “Josephine Bloggs”). This allows you to track your position on the screen and see when you have reached your destination.

If there are any disruptions to the provision of our MOIA Mobility Services (e.g. your MOIA vehicle is delayed), we will use your contact details to notify you by phone, e-mail, text message, in-app alert, or push notification.

C.5. Optimization of the MOIA app and MOIA mobility services

When you use the MOIA app and the MOIA mobility services we provide, your data will also be processed by MOIA for other purposes. Such processing of customer data serves the purposes of continuously developing our offers, advertising campaigns, and mobility concepts while making them more attractive for you. To this end we use transaction data from MOIA mobility services (e.g. booked trips) and information about how the MOIA app is used so that we can respond better to customer inquiries and reviews and offer discounts or vouchers in a more targeted manner. Furthermore, reference to data allows us to control our spending on advertising more effectively and to offer our customers the best possible mobility services. By processing your data, we can also continuously improve our customer service and customer satisfaction by being in a position to respond to customer inquiries more individually.

The legal basis for the additional processing of your data is Article 6.4 of the GDPR in conjunction with the legal basis for the original processing in line with the fulfillment of contractual purposes (Article 6.1.1(b), GDPR) or the protection of our legitimate interests (Article 6.1.1(f), GDPR). Insofar as additional data processing is based on Article 6.4 of the GDPR in conjunction with Article 6.1.1(f) of the GDPR, our legitimate interests lie in increasing our service quality, improving customer communication, optimizing our offers, and ensuring that our advertising measures can be fully evaluated and improved.

We will store your data for additional processing as long as you use the MOIA app or our MOIA mobility services, and we will delete your data after the statutory retention periods have elapsed. Further information on exercising your rights as a data subject can be found in the section headed “General Conditions” of this data protection notice (A.8).
Data Protection Notice “CRM 2.0”

C.6. Use of vouchers

If you book a MOIA Mobility Service using a voucher that is billed to a third party (e.g. your employer or an event organizer purchased the voucher), information about the use of the voucher may be shared with the respective third party for accounting reasons (e.g. date and time of booking, booking number, coupon code, price). Your account information will not be forwarded to the third party. A personal reference can only be made by the third party, if the third party issues the voucher personalized.

The legal basis for transferring the data is Article 6 (1) sentence 1 lit. f DSGVO.

C.7. Improving our services

C.7.1 Google Firebase

We use Google Firebase to improve our app and to provide various features. Google Firebase makes it possible to use a variety of products. In particular, we use Crashlytics, Google Analytics for Firebase, Dynamic Links, Cloud Messaging, In-App Messaging, A/B Testing and Remote Config. You can find more information about these services here.

When Google Firebase is used, data is sent to Google using a pseudonym. We are unable to associate this data with a specific natural person. You can find more information about data privacy in connection with Google Firebase here.

You can opt-out Google Firebase (with the exception of Remote Config and A/B Testing) at any time by moving the “Analytics” slider inside the MOIA App accordingly. You can find the slider in the MOIA App's privacy settings when you visit your profile.

C.7.2 adjust

We use a service called “adjust” in our MOIA App. Provided by adjust GmbH, Saarbrücker Strasse 37a, 10405, Berlin (“Adjust”), adjust helps us to establish links between advertising campaigns and the subsequent installation and use of the MOIA App so that we are able to measure the success of advertising campaigns.

For this purpose, we use pseudonymized data such as your IDFA or Google Play Services ID as well as truncated IP and MAC addresses. The information collected is not associated with a specific natural person without explicit consent.

The data privacy policy of Adjust can be found under the following link:

https://www.adjust.com/privacy-policy/

You can opt-out adjust at any time by moving the “Analytics” slider inside the MOIA App accordingly. You can find the slider in the MOIA App's privacy settings when you visit your profile.

C.8. Push notifications

Our MOIA App offers push notifications, which are messages created by the MOIA App that can be displayed on your device. You can decide at any time whether you want to allow push notifications or not by adjusting on your device.

C.9. Personalized marketing

We aim to send you messages that are of interest to you. For this reason, we ask for your consent to the following during the registration for our MOIA App:

"I am at least 16 years of age and would like to receive personalized information about vouchers, offers, products, and surveys from MOIA by e-mail, text message, push notification, or through advertisements (e.g. via social media). Data about location, usage, and content will be combined for this purpose. I have read the privacy policy. You have the right to withdraw your consent at any time.”

Your consent is optional. With your permission, we will use the information below to determine whether certain content is of interest to you:

Registration data (e.g. email address, first name, last name), Booking data (e.g. spending, journeys made, preferred starting points and destinations), Usage data (e.g. opening rates and click behavior in the MOIA Apps, websites, and newsletters), Location data (When processing locations, MOIA may use location-based services such as WLAN, GPS, or Bluetooth, which are used for data transmission. Localization only takes place in close proximity to our virtual MOIA stops and inside our MOIA vehicles. The storage of location information is temporary; this data is not used to create movement profiles. Additionally, MOIA may request a “blurred” location when the MOIA App is launched in order to decide which service area is of interest to you. This blurring takes place on your device, so no exact location is transmitted to MOIA. A log of blurred locations is not created.).

Consent is granted for the following marketing channels:

Email, SMS, Push notifications (if enabled on your device), In-app notifications, Advertising on third-party websites (retargeting), Advertisements within the Google and Facebook advertising networks (MOIA may use a campaign management tool provided by emarsys eMarketing Systems AG, Hans-Fischer-Straße 10, 80339 Munich (“emarsys”) to upload a hash of your e-mail address (a combination of letters and numbers) to the Google and Facebook advertising networks. Each advertising network can compare this hash value to other hash values that are already known to the network and determine whether you are a network user or not. If this is the case, advertisements may be displayed within the network. For more information about the Facebook data policy, please visit: https://www.facebook.com/policy.php. Google’s privacy policy can be found online at: https://policies.google.com/privacy?hl=en).

You may withdraw your consent to receiving personalized marketing information at any time with effect to the future. To do so, select the unsubscribe link contained in each e-mail we send out, adjust the privacy settings in the MOIA App, or send an e-mail to datarequest@moia.io.

Please note that it can take up to 48 hours to process your withdrawal of consent for technical reasons.

The legal basis for processing your personal information for personalized marketing is your consent (article 6(1)(a) GDPR).

C. 10. More time to walk

In your profile, you can adjust your preferred walking speed. If you activate this setting in your profile, this information will be stored in your account.  The processing of this information is used for the fulfillment of the contract according to Art. 6 (1) lit. b GDPR.

C.11. Visual impairment

You can provide information about your visual impairment in your profile so that the drivers are aware of you when you arrive and actively look out for you. In this case, we process this data on the basis of your consent pursuant to Art. 6 (1) a GDPR.

Berlin, 03.09.2020